NENT NDA Planning and Engineering Study - Stage 3 Public Engagement (Sep 2012)

HKIP-PAC- Comment on NENT NDA Sep 2012.pdf

NENT NDA (Kwu Tung North, Fanling North, and Ping Che/Ta Kwu Ling) 

Planning and Engineering Study -Stage 3 Public Engagement

Position Paper of the Public Affairs Committee of the Hong Kong Institute of Planners

We have the following views with respect to the Stage 3 Public Engagement for the North East New Territories New Development Areas (NDAs) Planning and Engineering Study. 


At present there is no coherent housing strategy that reflects and balances the needs and priorities of different stakeholders and looks at the situation in holistic terms as a basis for producing a strategic development plan. Hence, in the NENT NDA public engagement, there emerged significant divisions polarising the community and various stakeholders. These include landlords and tenants hoping to maximise compensation; ‘green’ environmental activists; and developers who have accumulated large land reserves. 

While Government proposals for New Development Areas are broadly supported in principle, we consider that there is no clear overall direction over priorities, in relation to short, medium and long-term goals. 

We consider that the issue of housing in Hong Kong and therefore the pertinent aspects of development strategy, should be supported by a sustainable "Long Term Housing Strategy on Housing Need" that needs to examine a number of related issues holistically, including, inter alia, the following issues and concerns :- 

Housing Need : 
w A clear definition of housing need over a 30-year period in relation to realistic population growth levels, given that after the 2011 Census the current projected Resident Population will increase to 1.47 million by year 2041; 
w The most realistic and desirable breakdown of public and private housing needs/demand; 

Quality of Housing : 
w The issues of ‘quantity’ and ‘quality’ - given that the average space standard in public housing is 11 sq metres per person, and that a very high percentage of private housing is below 47 sq metres GFA. If living conditions in general are to be improved, the NENT NDA housing development needs a balance between quality and quantity since the flat sizes in this location would likely be relatively small; 
w Priority should not be neglected to improve the extremely poor housing conditions of sub-divided and ‘cage’ units currently affecting some 100,000 persons in the urban area;

Land Policy
w Innovative solutions and policies may be required to stimulate developers to build on their land banks; 
w The open ended commitment under the Small House Policy to reserve large tracts of land to meet the need for small houses development should also require to be reviewed with due priority although this also contribute to an extent to meet part of housing needs; and
w The impact on housing demand and housing prices due to Mainland purchasers should be closely monitored. 

We suggest that the Administration should also pay due regard to these relevant and policy issues apart from having to respond to the more local /district based aspirations and grievances. 

Housing Demand 
w In view of the projected 1.47 million population increase in 30 years, given that the Government would invest hugely to develop the 533 ha of developable land within the NENT to provide 54,000 housing units and to accommodate only 150,000 population, the development intensity and the population target for the NENT could be suitably reviewed, subject to sustainable development principles, to increase the cost effectiveness of the NDA particularly for housing provisions. 

Industrial Demand 
w Kwu Tung North appears to be located in an advantageous location, with a railway station/ interchange between the East Rail and the West Rail (the Northern link) and is only about 2.5 km away from Sheung Shui station. It is however not clear what precisely the 14 ha. of “Commerce, Research and Development” zoned sites at the Kwu Tung North town centre, or Special Industry Zones would be developed into or how demand has been calculated, although the intended ‘job opportunities’ creation is said to be 35,400. We would appreciate clarification of these projections. 

Regional Integration: 
w The strategic location of the NENT NDA presents an opportunity for a long term closer integration with Shenzhen but this must be handled carefully to address the public’s concern about the NENT becoming a the “backyard of Shenzhen”, as there is now a very different political, economic and social situation in the NT than when new towns in the NT were built some 35 years ago. The consultation document should clarify in what way the NENT will promote “social and economic development in Shenzhen and Hong Kong” and what benefit this would bring to the HK community. 

w If regional integration with the Greater Pearl River Delta (GPRD) and Shenzhen in particular, is a long term development strategy of the HKSAR, it would be useful to know at what strategic level and how these NDAs fit into such a strategy, taking into account such factors as the Qianhai development and the Lok Ma Chau Loop development as well as the role of Hung Shui Kiu in the NT.. 

Creation of Green Living Environment 
w The proposed Carbon Reduction Strategies, such as compact city design, environmental-friendly transport network, energy efficient buildings, District Cooling System, Effluent Reuse System, green urban design are supported. Government should set out innovative incentives to entice participation from both the private sector and the community at large to help achieve this objective. 

w Innovative proposals and policies in terms of financial and other assistance are called for if there are genuine farming communities affected. Consideration should also be given to the possible creation of a ‘green’ urban fringe, combining opportunities for market gardening, experimental agricultural endeavours, leisure and recreational facilities. 

Social Dissonance 
w Government has proposed to adopt a “Conventional New Town Approach” i.e. resumption to implement the NDA. Approximately 3,500 households or about 10,000 people would need to be vacated. The social disturbance of this magnitude requires careful consideration. 

Recently, the clearance of about 200 households in Choi Yuen Tsuen aroused a major public outcry and took 24 months before clearance could proceed. In resuming the 26 ha. of Choi Yuen Tsuen, the Government spent over HK$250 million on land compensation and ex-gratia allowances. For the development of NENT NDAs, Government will need to resume 200-300 hectares of land. An estimated HK$40 billion is to be allocated to resettle and compensate the affected villagers. Enhancing such ‘rewards’ for one group of stakeholders in order to balance the needs of another is controversial and needs to be considered in detail since it might act to polarise society.

Implementation Approaches 

The single implementation approach (i.e. resumption) for the three NDAs without partnership with the existing land owners contradicts the development approach currently adopted by Government in the urban area. The Development Bureau is advocating “more diverse forms” of redevelopment under the new Urban Renewal Strategy (URS) promulgated in February 2011. The Strategy stresses a “bottom-up” redevelopment approach rather than solely relying on the traditional “top-down” resumption approach or CNTA approach. 

w Financial Burden on Government and Taxpayers in CNTA approach - The resumption expenditure is in addition to the huge capital works expenditure (HK$46 billion) required for site formation and infrastructures prior to making the land available for sales and developments. Besides, the NENT NDA development is in addition to the committed capital works projects such as the XRL($70b), Kai Tak ($100 b), SCL ($72b), and other future projects such as the 3rd runway, WEL, NWNT NDA, Tung Chung New Town Extension, cavern developments, etc. which may be simultaneously undertaken within a similar time horizon. 

w Under the CNTA approach, Government and taxpayers have to bear the financial risks associated with the initial capital expenditure vis-à-vis risks arising from property market fluctuations, whilst the land revenue from land sales would only be available some years downstream. It also needs to be clarified how the development might impact on the resources for provision of community facilities such as education, health, social services, and elderly services. 

CNTA approach compared with PPP approach - In relation to the CNTA approach, it is noted that Government has explained that this as to avoid possible allegations about collusion in using a PPP approach. It is considered that the U- turn (from PPP to CNTA) from Stage I to Stage 3 in respect of land production / resumption policies in the carrying out of new developments is causing some confusion to the market and the general public. Without prejudice to either the CNTA or the PPP approach, each option could have its advantages. It has been proven in the 1970s that the CNTA approach could ensure that the programming of the overall development is well coordinated, whereas through a PPP approach sometimes innovative concepts of comprehensive development could be achieved if suitable conditions are imposed. Thus, it is suggested that options should perhaps be open to the possibility of a “mixed approach” with a combination of strategies to deal with different packages of the developments within this vast development area as appropriate. 

w These mechanisms and policies are equally, if not more important than the Outline Development Planning layouts themselves, since they have wider implications on all other future developments throughout Hong Kong, and the NT in particular. 

Public Engagement Process Needs to be Over-hauled 

w The outcome of the Public Engagement process for the NENT NDA’s has not resulted in a consensus of public opinion on the way forward, and instead appear to have had the reverse effect by bringing public differences to the fore. Many issues of strategic and policy implications are mixed up with local concerns in the feedback. 

w A detailed analysis of the public engagement should be made to make it more effective so that a positive outcome can be achieved. 

w According to Sherry R. Arnstein, there are 8 rungs in the ladder of citizen participation. Here, public participation in Hong Kong in the past and the present “public engagement” appear to be pitched more at a “consultation” level whereas Public Engagement experience in other countries suggests that the process could be more participatory involving the stakeholders in active and creative dialogue or partnership in order to build up public consensus and commitment to a project. 

w While we have not carried out a detailed analysis, from our professional experience the following points may be worth further investigation :- 
i. The timeframe for the engagement is too long. In the case of the NENT NDA the process started in 2008, with a series of briefings. The Stage 1 Community Workshop was on the 20 December 2008, and the Stage 2 Community Workshop one year later on 12 December 2009. Stage 3 Engagement started four years later in June 2012 with the Public Forum in September 2012. Four years has been too long in that the previous information and views exchanged may no longer be valid as things change quickly within that time. With the lapse of time, the contents should be changed to fit. 
ii. Transparency -- There is no apparent response to submissions. Partly because of the time lag in the past 4 years between the public providing input and the response, there is a feeling that the input is not respected. Also the process does not clearly indicate how a particular comment has been dealt with. 
iii. Sincerity and Creativity - The Briefing Process in the past few years was time consuming and ineffective. The ‘briefing’ system is often one of telling a group what Government is going to do. Instead, in future consideration could be given to engaging various target groups more effectively like partners in the form of focus group discussions which might even bring out creative solutions apart from building up more mutual trust.

Public Affairs Committee
of the Hong Kong Institute of Planners
September 2012