"Planning & Engineering Study on Development of the Lok Ma Chau Loop" Stage 2 Public Engagement (July 2012)
Comments of the Public Affairs Committee (PAC) of the Hong Kong Institute of Planners (HKIP) on the Planning and Engineering Study on Development of Lok Ma Chau Loop Stage 2 Public Engagement
A continued criticism of this type of comprehensive study that evidently takes several years to complete, with several rounds of public consultation, is that the Scope of Work is too extensive and “all encompassing” for one study. The process tends in practice to swamp the actual product. What ultimately suffers is the quality of the plan itself. Ideally an exercise of this nature should be divided into two separate parts and properly funded : the first being a strategic study backed up by investigations to ascertain what is both feasible and desirable from all perspectives, and to ascertain precisely what best meets the set objectives within the identified opportunities and constraints; the second a planning, landscape and urban design study with engineering, transport, traffic, environmental and economic input, with the end product not merely a Recommended ODP but planning and design proposals and parameters to ensure quality.
Our comments are as follows:
1. Although the various objectives of developing the LMC Loop area for higher education use, complemented by high-tech Research and Development (R&D) and Cultural and Creative (C&C) industries are supported, it is considered that the present Planning and Engineering Study is not just a matter of designing an Outline Development Plan on paper. At a policy level, there should be clear support of relevant policies and the establishment of appropriate institutional mechanisms to ensure that the project would indeed be value adding and successful. This aspect has however not been addressed. It is quite surprising that implementation aspects of this highly recommended proposed “Education Use”have not even been discussed in the study..
2. The assessments as given appear to be directed mainly to engineering designs and packaging. It is considered that the Study is lacking generally in four aspects – viz. (a) quantified values when it comes to the achievable economic benefits; (b) the strategic context vis-à-vis possible competition from other cities /places in the Pearl River Delta region (e.g. tourism; university towns, etc.) ; (c) the various social impact assessments appear to be rather arbitrary and (d) the expected support from and impacts on the immediately adjacent areas (those on HK side and Area C on Shenzhen side) are not well defined. Apart from the Loop, the surrounding areas are also crucial. However, no detailed information on Area B has been provided.
3. As far as design and layout are concerned, the current Recommended Outline Development Plan (RODP) has only made a few changes to the Preliminary Outline Development Plan (PODP), such as by the lowering of building heights by 3 storeys, and the introduction of the “flexible” interpretation (“interchangeability”) of the future High-tech Research and Development (R&D) and Creative and Cultural (C&C) Industries. We include comment on these and on the rest of the changes below. We make reference to the technical papers available on the web-site, including the PPT, and Technical Papers TR3, 4, 5 and 7 (no TR 6) which are just Summaries of Technical Reports. Reference is also made to the “Executive Summary of TR2B – Formulation of Conceptual Land Use Options, Preliminary Outline Development Plan, Preliminary Master Urban Design and Landscape Plan” which was completed in Nov 2010. More specific comments on these TRs are as follows.
4. TR 4 of Jan 2012
(a) Regarding the “Interchangeability” of “High-tech Research and Development (R&D) and “Cultural Creative (C&C) Industries”, the terms are not sufficiently defined. The generic terms such as “high-tech”, “cultural” and “creative” are also quite nebulous. Without any reference to statutory or established administrative bodies vested with due authority, these terms and their implications need to be set out in detail in order to control development and design. The practice and definitions in HKSAR and Shenzhen might also be different. There is also a need to assess the difference in site value under different possible scenarios now that there is a wide range of flexible combinations of land uses.
(b) From past experience in Hong Kong such as interpreting buildings regulations and related definitions, it is noted that different departments have different interpretations under their respective ordinances and purview, necessitating the issue of Joint Practice Notes. There thus appears to be a lot of potential loopholes under the recommendations of the subject Study.
(c) Whilst the guiding principle of the Study is: “Joint Study, Joint Development and Joint Benefit” (re. Chapter 1 of the Stage 1 public engagement report), it is not clear what the mechanisms are for taking forward this RODP (which is in effect a simple land use zoning layout plan). There is mention of “joint development”, “jointbenefit” (joint profit sharing ?), but organizational and management mechanisms need to be addressed prior to implementation.
(d) It is not clear how the introduction of “interchangeability” tallies with the respective economic and employment policies of HK SAR and Shenzhen.
5. TR 4 – Page 5
District Cooling System (DCS) - Page 5 says : “… … The choice of location for the DCS plants was made after careful consideration on factors such as plant efficiency based on its proximity to the cooling load centre, the overall planning and design of the site, as well as planning of Area C in SZ. Detailed technical assessment of the DCS was discussed in the Green Initiative Assessment of Technical Report No.5.” It is however noted that TR5 mainly discussed the proposed Membrane Bioreactor (MBR) method and reuse of Treated Sewerage Effluent (TSE) which has yet “to be discussed with EPD”. No mention is made about Area C – which has always been unclear since the PODP stage. In January 2011, in commenting on Stage 1 of this study, the Public Affairs Committee of the Hong Kong Institute of Planners (HKIP PAC) raised similar questions about Area C -- whether Area C would be developed concurrently to generate synergy with Area A. It is still not clear what Area C will be developed into, when and how.
6. TR 4 – page 6 re. Transport
The only concrete proposal for an external connection is the Western Connection Road (WCR) – an access from the MTR LMC Station side. It is questionable to have only one vehicular access due to emergency considerations, whilst there will be an estimated 29,000 workers and 24,000 students in the Loop area and possibly also outside visitors. It is acknowledged in the report that an additional road linkage at the eastern part of the Loop is likely to be necessary. Although an indicative alignment has been suggested, in the Study there is no programme or commitment for its implementation. TR4 has also mentioned that external pedestrian (footbridge-cum-traveller)/traffic connections with Lok Ma Chau Station and San Tin Highway/Fanling Highway would be detailed in TR5. However, there is no such information in TR5.
7. TR4 – page 21 re. Urban Design
The HKIP PAC, in January 2011, suggested that the western access location be given due priority in urban design, as it would be a “gateway” to the whole Loop area. This aspect has not been taken into account in the RODP.
8. TR 4 - page 8 : “Land Use Review alongside Proposed Infrastructure in Area B”
P.8 states that “A separate land use review to identify development potential for the areas adjacent to the connection roads leading to the Loop is being undertaken”. Since these areas may depend and may have impact on the same access roads. Why is the review separate and when will be review be released? Have the possible impacts been built into the current assessments ?
9. TR 5 - page 13
(a) Within TR5, the various references to Socio-Economic Impact Assessment are very ambiguous. In some references “development” appears to mean the whole Lok Ma Chau Loop development, while in others “development” appears to include only the part(s) of the engineering works being mentioned in that paragraph. This needs to be made clear.
(b) The proposed use of the CASET model to test the proposed works (pages 15-17) and its relationship with the rest of the Socio-Economic Impact Assessment, (in paras. 8 and 9 and their sub-paragraphs) is somewhat confusing since one seemingly covers the impacts due to the future landuse and development of the whole Loop area together with the short term impacts, while the other paragraphs may be limited only to impacts of parts of the engineering works, and are regarded as short term impacts. Para. 9.3 is somewhat ambiguous as it essentially gives the impression that there are no adverse social impacts whatsoever.
(c) Para.8.1 states : “ … … The high value-added higher education, high-tech R&D and C&C industries within the LMC Loop provide synergies with tourism and commercial proposals in the neighbouring developments of the Closed Area and the NENT NDAs. …” The terms “synergies”, “tourism” etc. are very attractive, but there are no substantiations anywhere else in the report about these aspects. HKIP PAC in January 2011 raised the matter of accessibility to the site and feasibility of bringing in visitors /tourists in view of potential support to the C & C industries. This should have been assessed and taking into account in the related EIA and TIA at this RODP stage.
10. TR 5 - page 14, para. 8.3, re. Social Impact Assessment
(a) It states : “ … It is anticipated that the villages and economic activities within Area B and the adjoining areas will mostly be unaffected by the LMC Loop development…” Whilst this might be technically correct in spatial terms, there is likely to be an inevitable secondary impact on local villages in economic and social terms on the entire physical and economic emphasis in this area will change.
(b) TR5 also states : “ .. The proposed ECR and WCR, connecting LMC Loop with the external areas, would have some impacts on the population and the economic activities associated with them, …. The impact would likely to be short term in nature which could be minimized through careful design of the road alignments …” ; “Except for the land required for the proposed ECR and WCR, the existing villages and economic activities in Area B would not be affected … …” While land might not be resumed, it cannot be said there is minimal or no social impact, and that (social) impact will only be limited to areas immediately adjoining the roads. It should be noted that the villages are only 500 metres away and there is no visual barrier between them and the road.
11. TR 5 page 14, para. 8.5 re. Economic Benefits
The report states that “ … any social implications would be handled under the established procedures/practice” without attempting to address the special situation of this site – where the users could be from HKSAR or from Shenzhen.
12. TR 5 page 19, para.9.3 re. Assessment of Social Impacts under the subject of “Sustainability Assessment”
(a) In Sub-para. 7 - “Private housing rent in outside areas”. Only “students” are mentioned and not the “staff” who could perhaps afford to pay higher rents
(b) No mention has been made as to what type of accommodation that people in the high-tech industries and those in the C&C sector prefer and how such accommodations might be necessary compared with the conventional type of houses and village type housing commonly found. Perhaps developments in the new NDAs would provide alternatives for them.
(c) The study should integrate recommendations of related studies of the surrounding areas (such as the NDA study) so that its own conclusions/recommendations would complement those of the surrounding environs. For example, it is worthwhile to explore using parts of the NDAs to provide alternative housing accommodation for the work force from the Loop area . As such, connections between the Eastern Connection Road and the NDAs would need to be examined.
13. Item 10.2 The urban design framework should address precisely how the design principles and objectives will be met. At present this is vague and Figure 2 mainly shows the landscape framework. Urban design involves more than building height profiles – this needs to address how the grouping of buildings will address place making criteria, connectivity, continuity of frontages, means of climatic protection for pedestrians etc so that individual buildings are not simply experienced in isolation but add up to more than the sum of the parts in terms of coherent massing and urban design.
While the layout introduces areas of parkland through the area and a natural landscape edge, the overall impression is one of a European-style business park rather than an urban entity in its own right. As such the perspectives shown in Figures 5, 6 and 7 give no indication whatsoever of spatial or street quality, let alone meaningful urban landscape. This needs to represent the unified pattern of roads, paths, and spaces that connect to form the framework for development and from which the underlying organisational framework and morphology are derived.
14. Page 21, para.10.2 : Key Green Initiative Proposals – Green Infrastructure
Has any attempt been made to make use of the proposed extensive stretch (12.8 ha) of reed beds in conjunction with the sewage treatment system?
15. TR 7 –“Stage 1 Implementation Strategy, Cost and Revenue Estimate and Development Programme”
The report appears to cover mainly civil engineering and E & M works contracts, packaging and implementation whereas land transaction matters and their implications are not covered at all throughout the current presentation. If there is such information, it has not been provided on the web-site. There is also no allowance for a “what if” programme changes of the Kwu Tung North NDA and how it might affect the ECR and the Loop development. (Phase 2 includes the ECR and a Flushing Water service reservoir.)
16. There is a lack of detailed environmental assessment on the surrounding areas in TR4 and TR5. For example, no environmental assessments have been carried out on the external linkage of the surrounding sensitive areas while Stage 1 of the Study’s Community Engagement indeed recommended that all infrastructural provision should not impose adverse impact to the villages, such as Ha Wan Tsuen.
17. In January 2011, the Public Affairs Committee (PAC) of the Hong Kong Institute of Planners (HKIP) has already submitted its comments to the Government on the Stage-1 Public Engagement of the subject Study (ref. . http://www.hkip.org.hk/En/Content.asp?Bid=7&Sid=76&Id=595 ). It is however noted that many of the queries raised therein have not been addressed. We have reiterated some of these above as part of our comments.