Response to public engagement exercise on land supply 27 March 2012

Response to CEDD’s  Stage 1 Public Engagement Exercise on:
Enhancing Land Supply Strategy – Reclamation outside Victoria Harbour and Rock Cavern Development

Living Lamma promotes environmental improvement and sustainable development on Lamma Island. Our group currently has more than 300 members and many more supporters in the community.

We would like to respond to the proposals outlined on www.landsupply.hk by giving our objections to the assumptions, scope, and methodology of the study, as well as our objections to proposed reclamations off north Lamma, next to the quarry site on Lamma, and at other areas where the visual impact would adversely affect the quality of living environment for neighbouring residents.

Assumptions of the Study

The assumptions on which the study is based are controversial. While it is true that land is in short supply in Hong Kong, it does not necessarily hold true that reclamation will fulfill aspirations for “quality living environment” or that it is a suitable and sustainable method to sustain economic growth.

Unfettered reclamation along Victoria Harbour has decimated any natural features and has often restricted or removed the ability of the public from enjoying the waterfront. Measures such as the setting up of the Harbourfront Commission have come too late to “protect and preserve Victoria Harbour as a special public asset.”

The areas of shoreline in Hong Kong that still have landscape and ecological value are outside the scope of the work of the Harbourfront Commission. These areas are under the greatest threat from insensitive development. Though protection should be granted under the Foreshore and Seabed Ordinance, in practice loopholes exist that allow concrete to be poured over areas of natural shoreline.

In rural island districts, straight-line reclamations undertaken by CEDD are out of keeping with the natural environment and the rural character. They have also impacted traditional ways of life, cutting off access to the water for local people whose lives and traditions are based around the sea. They have also prevented alternative designs, which have could have developed the potential of these areas from developing into attractive locations for junk trips, which would have greatly enhanced the local economies.

The population assumptions cannot be taken seriously. As yet, Hong Kong has no population policy on which to base these figures.

The Scope of the Study

The scope of the study is limited only to reclamation or rock cavern development. Other methods of enhancing land supply are not included. There are reportedly almost 250,000 empty flats in Hong Kong.1 There are also an unknown number of warehouse and factory spaces that are used for residential use, and the potential (like in other cities) to redevelop these areas for housing. In rural areas, properties that have been abandoned are just left to fall into disrepair.

If the purpose of the study is really to create a “quality living environment” and meet housing demand, then an examination of existing housing stock and opportunities for upgrading, reassigning or redeveloping should be included.

If the purpose is to create a land bank to guard against short falls in government income, then other measures to ensure the long-term health of public finances, such as broadening the tax base, should be explored.

Though rezoning, land resumption and redevelopment are dismissed as options for providing sufficient land to meet demand, the challenges involved in these options come down to government’s poor relationship with the public. These options should certainly be included and efforts made to overcome challenges such as improving public relations and the development of clear, fair and enforceable policy.

Interesting, problems of land banking by a small circle major developers and speculation are not highlighted as challenges in the consultation document. These issues should be explained to the public in any discussion on Hong Kong’s land supply.

The potential for rock cavern development to locate facilities that might not be attractive within the community should be explored, as should other ideas to minimize the visual and environmental impact of such facilities. In the case of Lamma Island, though residents put forward alternatives to the straight-line reclamation of Yung Shue Wan harbour in 1995, these ideas were ignored. As a result, waste treatment facilities, which could have been more sensitively located, are now a dominant feature of the harbourfront.

Methodology

The methodology used in the consultation raises concerns about bias. The project seems to present a fait accompli. The question of whether reclamation is desirable does not seem to be in question. Indeed, the process results in “long- listed sites”, followed by “short-listed sites. As with similar consultations, the department tasked with the design and execution of the study, CEDD, also stands to benefit from massive resource allocation necessary to further reclamation.

As noted by the consultation paper, the public has expressed strong aspirations for the protection of Victoria Harbour. Are we to see history repeated as

1 Analysis of housing stock in Hong Kong concludes, “ Supply-­‐Shortage Hypothesis is really nonsense.” See: http://www.alsosprachanalyst.com/real-­‐estate/hong-­‐kong-­‐ property-­‐the-­‐real-­‐supply-­‐situation.html

government now targets other areas outside Victoria Harbour for reclamation in a study driven by CEDD for the benefit of CEDD?

Objection to Reclamation

We strongly object to the proposed reclamations planned to the north of Lamma island, and at the site of the former Lamma quarry. In the last 20 years, there has been a succession of government projects that have eroded the natural landscape and have contributed to the environmental degradation of the island. This negatively impacts the quality of the living environment, one of the issues that this consultation seeks to address. Instead, we would like to see commitment to appropriate design and the enhancement of public facilities in our community in line with the planning intention for Lamma, which states:

“The general planning intention is to conserve the natural landscape, the rural character and car-free environment of Lamma Island; to retain Luk Chau in its natural state; and to enhance the role of Lamma Island as a leisure destination. The ecologically and environmentally sensitive areas including the Sham Wan SSSI, the South Lamma Island SSSI, mountain uplands, woodland and the undisturbed natural coastlines should be protected.

Future growth of the settlement is limited to the existing villages and development nodes. The existing low-rise, low-density character of the traditional villages and other residential areas should be retained. Supporting Government, institution and community and open space facilities have been allowed for. Opportunities have also been provided for the enhancement of the waterfront of Yung Shue Wan and integrating recreational and visitor attractions. It is also the planning intention to preserve the cultural heritage of Lamma Island, which is one of the most ancient settlements in the territory. The heritage sites could also serve as visitor attractions to enhance the role of the island for conservation and as a leisure destination.”

Sadly, there has been little action by government to support and fulfill the aspirations of this plan. Lamma Island should be considered an ecological asset for all of Hong Kong, a model of sensitive, rural design that does not follow the model of “destroy first, build later” that is increasingly prevalent in rural areas.

The consultation states that government wants to form land through reclamation using construction waste, without necessarily having demand for specific usage. The sites, once formed, may remain unfinished for years, assuming that demand will arise land in the location of the site formation. This approach is not acceptable. The impact on the surrounding areas could be devastating. It is hoped that this consultation will conclude that Hong Kong’s future land supply strategy should be based on sound planning that fulfills aspirations to enhance the quality of the living environment, not on the ambitions of CEDD to reclaim Hong Kong’s future.

Author: Jo Wilson