Heritage Conservation Policy in Hong Kong (March 2007)

It is most unfortunate that a complete consultation exercise has to be repeated three years after the previous public consultation on the same subject was launched in early 2004. In the absence of any information regarding the results of the round of consultation of 2004 nor any relevant actions/progress the HAB has since taken to respond to the comments received, the main views expressed in the HKIP’s position paper submitted to the Bureau in 2004 still hold.

The HKIP in its 2004 position paper supported the Government’s initiative to review the policy and urged the Government to formulate an effective and holistic heritage conservation policy due to the current inadequacy and the gradual loss of HK’s heritage to the pressure of economic development. 

Having wasted three years without any progress, the urgency of this policy is even more pressing now as more heritage buildings or sites have disappeared one by one over time. More of these buildings or sites are facing similar threat now. Without a comprehensive policy formulated with public consensus, any further demolition of these sites would likely provoke public outcry and meet strong objection.

Integrated Planning and Heritage Conservation Approach

Heritage conservation cannot be considered and implemented in vacuum. Assessment of what to preserve and how to preserve require a comprehensive planning approach with sensitive urban design consideration. Central District, an area rich in heritage assets and cultural diversity due to its early settlement of both the European and Chinese, would be a good example to illustrate this. 

Being the central business center, Central District is the main source of supply of quality office space. Traditionally and even up till now, the eastern part of Central commands a fair bit higher land value than that of the western end. Although both the eastern and western ends are dominated by high-rises, the setting and the quality of space do make a
difference. The eastern end of Central District has a high concentration of declared monuments and heritage sites including the Government Hill which consists of the St John’s Cathedral, St Joseph Church, the Helena May Institute, CE’s official residence, the Government headquarters and the Court of Final Appeal building and the LegCo building. With these low-rise heritage buildings and public open spaces such as the Chater Garden and the Statue Square in between, breathing spaces and comfortable visual relief have been naturally provided within the very dense urban area. Because of the setting this area is also home to high quality and award-winning buildings. The value of the office space here is thus higher than that to the west. It is apparent here that conservation of our heritage assets adds value to land. 

Within the same commercial area, high-rises pile on yet more high-rises are found in the western part of Central between Pedder Street and Sheung Wan. There are hardly any open spaces, nor buildings of architectural interests apart from the tiny Pedder Building and the Central Market. Despite developers’ full effort to squeeze all the possible inches and floors into their development the quality of the built environment here is reflected through the lower land value.  

From this example, it is not hard to prove the views that “heritage conservation often hinders economic prosperity” and “if the society wants economic prosperity, we have to demolish and build new thing” to be wrong. Instead, this is a very good illustration of heritage conservation adding substantial value to land prices by enhancing the built environment. 

Nevertheless the opportunity to enhance the western part of Central is still available. With foresight, the Government can pro-actively preserve the graded Central Market building for adaptive re-use instead of turning the site into yet another curtain-walled high-rise through a land sale exercise. This last remaining heritage site is more valuable to act as a breathing space for the congested built-up area being a high quality conservation project which would increase the land value in this area by enhancing the environment. The higher land value would also make new or redevelopment projects financially viable even without maximizing the development intensity. This is Central’s last chance to revive and we certainly hope the concerned authorities would listen and reconsider.


Considerations for Heritage Conservation

The HKIP urges the Government to make genuine commitment to preserve our city’s heritage and considers that for all future cases it should learn from the Star Ferry mistake. 

We acknowledge that we have to balance economic, social and environmental aspects in any development proposal, but present indications are that short term economic return has always been given an unduly significant bias over other factors. 

We strongly recommend the Government to take the following considerations into account in the formulation of heritage policies:

  1. To  undertake and speed up the compilation of a comprehensive inventory of all  heritage assets in the Territory, including buildings, streets,  places, and architectural objects, for preservation
    - The present list of heritage buildings/sites is far from complete and lacks a comprehensive background.

    - Expeditious actions are needed since the heritage and potential items are under increasing threat.

  2. To involve the public in the process, especially the District Councils, and to allocate funding to each DC to carry out a detailed study/survey of its heritage assets 

    - It would minimize the chances of neglecting valuable but hidden assets, and the local communities know their respective areas and local customs much better.

    - It would correspond with Government’s intention to involve the DCs more in management of local facilities.

  3. To set out clear and transparent criteria for the grading of the  heritage assets after taking into consideration the public’s view. 

    - The current grading system is confusing as not all grades are accorded a preservation status. Non-preservation status is not effective at all as it implies no commitment.
    - The gradings should also be subject to continuous review.


  4. To set up an independent heritage trust fund for the continuous sustainability of heritage conservation.

    - The Heritage Trust fund is necessary for the maintenance of specific projects and the continuous promotion of the conservation initiatives as a whole.

    - It should also be used to support and match private sector / self-initiated heritage funds or foundations in the acquisition of worthwhile sites /buildings.

  5. To introduce compensation mechanism either in cash or in kind such as possible tax break and non in-situ exchange of development potential as incentive to encourage property owners to preserve worthwhile heritage buildings/sites.

    - Green building initiatives have been accorded bonus / incentives in the building development mechanisms and development incentives have also been suggested in association with nature conservation. It is only logical that conservation of heritage buildings and features duly deserves equal and genuine support from the Government.


  6. To adopt a holistic approach including integrated district-wide planning context, flexibility in adaptive re-use of preserved buildings, creation of sense of place in urban design. 

    - As mentioned above using Central district as an example, the overall environment, attraction and property values of a whole district could be enhanced under a comprehensive conservation conscious approach.

  7. To seriously review the present institutional mechanism and relevant organizational structure with a view to achieving an integrated and holistic approach to heritage conservation. 

    - Due to the intricate inter-relationships between heritage conservation and urban development / redevelopment, the work demands heavy involvement of the multi-faceted skills in land and planning and also the decisions under the land and planning policy domain - in particular if the above-mentioned integrated and district-wide approach is to be pursued.  The resources of and service provided by the AMO
    - which is under the purview of LCSD, would patently be inadequate. One would logically expect that the alternative would be to locate the AMO directly under the Housing, Planning and Lands Bureau in view of the land and planning policy implications, or for operational reasons, to subsume the AMO under the Planning Department for more efficient co-ordination.

Heritage Conservation zone

It is also suggested that whilst a comprehensive assets list is to be compiled, that action should also be taken with priority to identify the broader areas of high heritage value, if we are serious about adding value to our city as a whole. Let all stakeholders be aware and consensus be built to embrace a long term vision where the old and the new co-existent in harmony. 

To preserve such places in a comprehensive manner, it is timely to consider the introduction of a “heritage conservation zone” in the statutory town plans, besides any administrative conservation plans. Good urban design principles, associated streetscapes and integration of the new and the preserved elements can be usefully implemented through such process as the requirement for submission of comprehensive master layout plans and conditions of planning approval. 

The Government Hill, the Central Police Station/Victoria Prison, the Central Market, the street market on Graham Street, the Hollywood Road ex-police quarters site are well-positioned in this context for conservation on their individual merits. The missing piece of the mechanism is perhaps a holistic framework to join the separate efforts together to ensure that we would not lose sight of the forest even if we succeed to maintain our focus on the tree. There are certainly other areas in other districts such as Yau Ma Tei where heritage conservation zones can be introduced. It is however only possible while they are still in existence. The Sun Yat Sen Trail is a reminder that it is already too late.
While Hong Kong prides ourselves of being efficient we must not lose sight of the need to maintain a quality setting for its investors and more so for its people. Quality settings invariably attract quality building design and result in higher land value. The setting and attention to details are what distinguishes a gourmet restaurant from a fast food shop and couture from mass-produced garment. Heritage conservation is often viewed as obstruction to development and a costly undertaking. It is however these very assets which we all owe our identity that add value to our city. To be or not to be Asia’s world city, it is our choice after all. 


Public Affairs Committee
Hong Kong Institute of Planners
March 2007