The South-East Kowloon Planning Review (2005-6)

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2 The Hong Kong Institute of Architects Position Paper on The South-East Kowloon Planning Review (2005-6) A) Background The Hong Kong Institute of Architects (HKIA) has been invited by the Planning Department and its Consultants (The Project Team) for the South-East Kowloon Planning Review (2005-6) to offer profession views on the Government s proposals as part of the public consultation. The HKIA holds an open and supportive attitude towards the Planning Review. Where possible, HKIA members have been encouraged to participate in public consultations as individuals to provide constructive professional advice. The HKIA acknowledges the cooperative and open attitude taken by the Project Team. B) Chronology of Events A series of HKIA in-house events as open forums for the HKIA members to express and exchange their views on the Government s proposed concept plans took place chronologically as follows:- 29 November 2005 The HKIA invited the Project Team for an internal discussion. Three interim design options proposed by the Project Team were put forward for review. The HKIA President, Vice-president, various Council members, HKIA representatives for the Harbour Enhancement Committee (HEC) and Members of the Planning and Lands Committee (under Board of Local Affairs) attended the meeting and exchanged their views with the Project Team. April - June 2006 Hong Kong Urban Design Alliance (HKUDA) - a Joint Task Force of the HKIA and the Hong Kong Institute of Planners (HKIP), organized a Kai Tak Urban Design Competition open to all members of the two institutes. There were over 30 submission entries. 26 August 2006 HKUDA organized a discussion session on the second stage Kai Tak Planning Review. During the session, the Project Team presented the latest draft of the concept plan addressing to specific urban design issues. Winning designs of the Kai Tak Urban Design Competition as well as an alternative proposal by HKIA member Mr. Philip Liao (proposal commissioned by the political party DAB) were all presented and discussed. The session was open to all members of the two Institutes only. The Hong Kong Institute of Architects Page 1 of 16

3 C) Executive Summary of HKIA Positions on the Proposed South-East Kowloon (SEK) Plan The following sets out the principal positions of the HKIA with regards to the proposed SEK Concept Plan:- Hong Kong needs an overall strategy for the Waterfront developments and the HKIA urges the Government to embark on a holistic independent study immediately. The SEK site should aspire to be a showcase for innovative waterfront habitat planning showcase to the world. HKIA generally supports lower plot ratio and a gradation of height controls but objects to the banal literal height cut-off policy. Occasional orchestrated height punctuation should be allowed to create a more interesting skyline. Smaller parcel of residential lots should be allowed in lieu of large scale CDA developments Most of the so-called constraints to the Study are in fact administrative constraints and no so much so technical constraints. The HKIA urges the Government to take a more liberal and open-minded approach to plan for a better SEK. The new SEK must be fully integrated into the existing neighbourhoods and helps to rejuvenate these older districts. Bridge linkage between the Runway tip and Kwun Tong area is of paramount importance. HKIA supports any environmentally-friendly mass transportation modes subject to practical operational considerations. The HKIA welcomes more green spaces but would caution for inactivity or overtly over-sized and under-activated urban empty vacuums. Peripheral activities are equally important. HKIA urges the Government to avoid the repeat of some undesirable planning aspects as seen in Ma O Shan and Cheung Kwan O. SEK must be planned with more distinctive local character. Conventional land use planning and land disposal methodologies must give way to more innovative approach. Conventional traffic-led design must be stopped. More user-oriented urban space planning design should be adopted instead. Car parking provisions under current HKPSG will severely hamper the urban quality of SEK and should be a subject of further review. At-grade street life should be promoted as much as possible in lieu of separate-grade designs. The conflicts of exclusivity vs. public accessibility should be carefully handled and envisaged at planning stage. More design competitions should be promoted to engender a more interested space as well as to groom our own local design talents. Land reclamation debates should not dwell on legal technicalities but should address the correct engineering needs and the respect the choice of the people. Since the SEK site is full of histories, the new SEK plan should respect and make references to historical and cultural heritages as much as possible. HKIA promotes and supports the Government for any genuine green architecture and planning concepts and sees SEK as the showcase for the world. HKIA also sees SEK as not only confined by the study boundaries and would urge the Government to take a much wider territorial perspective of how it can be integrated into the rest of Hong Kong strategically. HKIA holds an open attitude towards Government facilities in SEK site but would caution the negative effect it may bring to the urban vibrancy of the environment, especially after normal working hours. HKIA also suggests the Government to seriously consider making land bank reserves for swapping sites with future Urban Renewal Authority projects in the inner city areas. The Hong Kong Institute of Architects Page 2 of 16

4 D) HKIA Comments on Specific Areas of the Proposed SEK Concept Plan The following sets out the detail and elaborated comments of the HKIA members expressed during the above listed events, which have been collated as HKIA s consolidated comments on specific areas and/or issues. A. GENERAL PRINCIPLES 1. The Need for an Overall Strategy for Waterfront Developments of Hong Kong Should a strategy be available, it would be easier to determine if reclamation is indeed required in the Overriding Public Interest. It is recommended that the Government immediately embarks on an independent holistic Harbour Waterfront Review, of which the public consultations could be the mandate for resolving the current reclamation uncertainties. 2. Pioneering Good Waterfront Habitat Planning Design Kai Tak is the last piece of precious large scale urban land in the inner city Hong Kong occupying prominent waterfront location. This is an astounding opportunity to explore good urban planning concepts to promote a unique waterfront/ waterborne habitat. To achieve this, conventional building/ planning control methodologies and mechanisms shall be allowed to give way to new innovative approaches. SEK planning must go beyond pure land use planning. The conventional traffic-led approach must be abandoned for a more user-oriented urban space planning approach. 3. Height Control In general, HKIA supports a lower plot ratio for the SEK plan and a gradation of height controls in order to preserve the ridgeline and to avoid excessive building wall effects. However, HKIA does not see a literal height cut-off policy, such as those implemented in Tsim Sha Tsui East and thus created the banality of urban form there, as the correct solution. Occasional punctuation and orchestration of building heights should be allowed to foster an interesting skyline. Height proliferation by certain permissible percentage of volumetric mass could be an alternative for consideration. 4. Residential Developments HKIA supports the residential developments lots being divided into varying sizes so that large and small scale developers could have the opportunity to participate in the development of SEK making the urban spaces of SEK richer and more diversified. It could also result in better urban designs by competitions. If possible, land lot divisions should be made in such a way that the geometry would deter wall effect building masses, e.g., avoid long strips of land in parallel with the runway. HKIA also sees the SEK plan as catalyst to rejuvenate the surrounding older districts. The residential zoning control review should take a much wider perspective beyond SEK study boundaries. The Hong Kong Institute of Architects Page 3 of 16

5 5. Technical Constraints in the SEK Planning are Self-inflicted by Bureaucratic Circumstances or Real Technical Limitations? It was too early to label many of the issues as technical constraints inherent to the SEK plan prior to the public consultation, leaving not much room for the public to select among the options. The Government should start with resolving these issues now regarded as constraints of the Planning Review with the Technical Departments at technical level first in order to single out the real engineering issues so as to achieve a better planning for SEK. 6. Integration with the Adjacent Existing Areas and Into The City Itself For Citizens Enjoyment and to Help Rejuvenate the Existing Neighbourhoods Better integration can come in the forms of good pedestrian/vehicular accessibility, alignment of urban grid and fabric, preservation of major view corridors, building scale transition, creation of vistas and focal points as local landmarks, etc. Integration should look into not only the sufficiency of connection points but the quality of such conduits of activities because such would significantly influence the success of the SEK plan. Conventional approach should give way to more innovative ideas both in terms of design at technical level, and open-mindedness in land administrative level. 7. The Public Desires More Green Open Space in the New SEK Plan The HKIA recognizes that the public desires more green open space. HKIA however cautions that the scale and shape of the proposed Metro Park should be carefully considered in order that the planned park can be positively engaged with the neighbourhoods and be activated by the perimeter developments. A vast empty park will do no more than an urban barricade. Although Central Park of New York has often been cited as parallel comparison the downside of having an overtly large space demanding people to travel long distances should be carefully addressed. 8. Avoid the Repeat of Some Undesirable Urban Planning Aspects as Observed in the Earlier Designs of Ma On Shan and Cheung Kwan O SEK must be planned with strong character(s) of its own distinguishable from the rest of Hong Kong, least to say Ma On Shan and Cheung Kwan O. This is the last opportunity for a major inner city revitalization planning which will also have a long term shockwave effect on Kowloon City, San Po Kong, Ngao Tau Kok, Kowloon Bay and Kwun Tong. 9. Car Parking Provisions Must be Reviewed at Planning Stage Car parking provisions for large flat units are much higher than for smaller flat units under the current Hong Kong Planning Standards and Guidelines (HKPSG). Yet, given the intrinsic panoramic sea-view and the low density quality of the waterside developments, residential units here are likely to be large in size. Substantial car park provision pressure along the waterfront should not be overlooked. If 100% full coverage multi-storey podium car parks are to be avoided, then a more holistic technical review of car parking provisions within the SEK plan should be undertaken and special planning control guidelines should be devised. Notwithstanding the fact that deep basement might not be a viable option within the runway, Planning Department must address the issue of whether to encourage direct traffic access to the waterfront at all. Such is a technical consideration that must be addressed at planning stage level. The Hong Kong Institute of Architects Page 4 of 16

6 10. At Grade Activities Should be Re-Established as a Healthy Way of Urban Living Many previous examples in our new town planning have shown an inclination towards separate grade design approach. This has resulted in deserted and sterilized ground plane, internalized shopping mall spaces, retail and commercial homogenization and people s general antipathy towards the city they live in. Since SEK is bordered by beautiful waterfronts, HKIA strongly urges that its planning must avoid the same separate grade design formula pattern used in the past and the Government must re-visit how to re-invent our ground floor street scenes and re-create our street lives. 11. The Conflicts Between Exclusivity and Public Accessibility And Urban Spatial Vibrancy Must be Addressed In general, HKIA supports lower plot ratio for the water front developments but would caution that the intrinsic panoramic sea-view and low plot ratio will definitely result in developments here being very large, luxurious and exclusive, which might be in conflict with the public s right to access to the waterfront and the urban spatial vibrancy. HKIA is of the view that public s right to enjoy the waterfront space must not be forfeited nor compromised. Yet, if a public waterfront promenade is to be created, usually, according to conventional approach, it would be allocated to LCSD for future design and management in the post-planning stage. There have been grave concerns that such kind of land parcel disposal would be appropriate anymore as private sector participation was often denied the opportunity due to policy issues. The conflict between development exclusivity, public accessibility, and land management must be fully addressed in the concept planning stage. This must be established as major waterfront planning principle to be respected by all Departments but allow enough freedom for private sector participation. 12. More Design Competitions for Public Works and/or Urban Design Studies As the intrinsic geographical quality of the SEK site is astoundingly unique even by world s standard, SEK planning is an important platform for the Government to display its aspiration for good quality urban living. Competitions can attract talents, local and overseas alike, and to allow the building industry to prosper. The HKIA strongly urges the Government to adopt a competition-based designer appointment system to allow talented architects/ planners from local or abroad to contribute positively to the SEK developments. 13. The Discussions on Planning and Urban Design Issues of SEK Planning Review has Ultimately Turned the Subject into a Legal Debate of Whether to Have Reclamation or Not HKIA fully supports and upholds the spirit of the Protection of Harbour Ordinance. However, the institute is of the view that there needs to be clarification on certain technical definitions which are in spirit not in contravention with the Ordinance but under the current framework is legally up for challenge. The fear for legal proceedings has caused many good urban design concepts to be abandoned prematurely. HKIA urges the Government to take a bold move to clarify the situation as early as possible, whether through an Amendment Bill in Legco or through other publicly endorsed means. The Hong Kong Institute of Architects Page 5 of 16

7 14. Respect For History And Heritage Through Good Urban Planning Design. Kai Tak is full of histories recent and afar. Careful planning is required to reflect the historic heritage of the site exemplifying its own character beyond the superficial rich/ poor, public/ private realms distinction. The public deserves a more cultured and value-adding urban space planning design. 15. Green Architecture HKIA supports and promotes genuine green architecture and environmentally-friendly designs. Kai Tak could be a showcase district for the Government to demonstrate its determination in improving our living environment. 16. Strategic Planning Owing to the sheer size and scale of the planning exercise, the Government is urged to take a more macroscopic planning view towards SEK as the site will significantly change the way East Kowloon is integrated into the rest of Hong Kong. Strategic planning may affect other areas of Hong Kong not necessarily bound by the immediate adjacent neighbourhoods. For example, the linkbridge between Kwun Tong and the Runway tip could provide not only a more direct and easier accessibility between Kai Tak and Kwun Tong, but to Hong Kong Island via the Eastern Harbour Crossing as well. 17. Sufficient Government Land Bank Reserve Our urban environments within the existing built up areas are aging fast. The past three decades have seen unprecedented developments to shaping our economic tour-de-force but at a huge price. The past short-sighted property-led development model will no longer be sufficient to meet the demands of the Hong Kong people as our city grows older and environmental problems surface. To tally with the 2030 Planning visions for Hong Kong, conventional land use planning and land disposal methodologies must also be reviewed now. HKIA suggests the Government to form a strategic planning unit with Urban Renewal Authority to consider any need for reserving government land bank within the SEK site at planning stage to pave the way for future urban renewal schemes and to allow the possibility for swapping sites. The HKIA see the greater benefit the planning of SEK can bring to the rest of Hong Kong in this regard. B. NORTH APRON AREA 1. Public Housing Site Even though part of the North Apron site has been earmarked for Housing Authority and foundations are already partially completed, issues regarding the development scale, tower alignment, tower heights, wall effect and ventilation and repeating standard block design should still be further studied. HKIA urges Planning Department to re-visit the scale of development and not to allow the Cheung Kwan O scenario to be repeated here. 2. Local Open Square The HKIA acknowledges the proposed central open space as an important local landmark feature of the The Hong Kong Institute of Architects Page 6 of 16

8 North Apron Site and would appreciate it being further enhanced in the urban design studies. 3. Linkages with Adjacent Sites While vehicular traffic linkage from this site to San Po Kong and Kowloon Bay is appreciated, more at grade pedestrian linkages are needed. In general, footbridges are preferred over tunnels for security reasons. Commercial uses along such connecting conduits should be positively considered and encouraged. The need for possible re-zoning should also be addressed. 4. Road T2 and Local Distributors It is acknowledged that the Road T2 have been partially sunken. HKIA urges Planning Department to eliminate as much as possible the "spaghetti" of roads planned near the current Hongkong International Trade and Exhibition Centre (HITEC). 5. Schools as Noise Mitigation Measures The Project Team appears to have accepted the Prince Edward Road East as a physical study boundary and limitation. While the HKIA acknowledges the environmental issues in particular with the traffic noise problem, as well as the planning constraints imposed by the existing motorways on SEK s northern edge, the current study has not addressed the possibility of re-routing some of the existing roads into the site, thereby reducing and improving the traffic volume, noise and air quality impact to the existing systems. It is suggested that the Project Team should pro-actively consider making use of the SEK study area circumscribed by the existing Prince Edward Road East to divert some traffic into the Depot and North Apron sites so as to create an "island" situation, which could be utilised to house retail activities (possible with retail bridges) to help smoothen the experience of crossing a ten-lane urban canyon. The lining of school sites along the edge of the North Apron Site is not a satisfactory way to integrate SEK with existing context. More innovative approach in sinking or re-routing the existing and anticipated additional traffic should be considered. C. DEPOT AREA 1. Continuing the Existing Grid of Kowloon City The existing grid of Kowloon City should be respected and extended into the new SEK Depot site to foster a better urban planning integration. 2. Terminating the Existing Major Streets The SEK plan should address the termination of many major artery roads. For example, Boundary Street terminates at the Olympic Garden junction just outside the Depot site. It would be a lost opportunity to see conventional design with topside residential development here above the future MTR depot. A landmark building should be located here to address the end of Boundary Street vista. 3. Landscape Deck as Pedestrian Crossing The HKIA acknowledges the merits and the positive amenity values in the proposed deck crossing over Prince Edward Road East. However, the HKIA cautions that although the intended deck is to be wide, spacious and welcoming to facilitate a smooth transition from the old district to the SEK site, when it The Hong Kong Institute of Architects Page 7 of 16

9 comes to Lands Department in the post-planning stage the deck could probably be viewed as GFA accountable with no deductible premium. It would therefore be very likely to shrink back to an ordinary 6m-wide footbridge under commercial pressures. Therefore, Planning Department should consider a mechanism to secure such kind of wide open deck be controlled and implemented without loss of originality. 4. Existing Underground Tunnels The existing underground pedestrian tunnels at Olympic Garden and Nga Tsin Wai Road should be upgraded to make them more amicable. Commercial activities within these underground passages should also be considered to help smoothen the experience of crossing the busy road. 5. View Corridors The view corridors to the Lion Rock through the depot site topside development should be preserved. But occasional orchestrated punctuation should also be positively considered for a more interesting skyline. D. MA TAU WAI AREA 1. Existing Parks The HKIA supports and welcomes the preservation of the existing Hoi Sham Park and the relocation of the Emperor s Rock from the existing Sun Wong Toi Garden to its original location. 2. Waterfront Promenade Accessibility HKIA in general supports lower plot ratio for the water front development but would caution that the intrinsic panoramic sea-view and low plot ratio will definitely result in developments here being very luxurious and exclusive, which might be in conflict with the public access to the water front and the urban spatial vibrancy. The conflict between development exclusivity, public accessibility, and land management must be fully addressed in the concept planning stage. E. RUNWAY AREA 1. Protection of the Ridgeline HKIA considers the low density building scale in the runway site as an attempt to respect the ridge line is in the right direction. However, it should be pointed out that respect for ridgeline should not be taken as a rigid mechanical system as in building height control (example: Tsim Sha Tsui East) as such would create banality. From an urban design point of view, occasional punctuation could produce a more interesting and orchestrated skyline. A better system than a simplistic building height control should be developed and adopted. The Hong Kong Institute of Architects Page 8 of 16

10 2. Scale of Development Sites HKIA considers small scale development land parcels on the runway site is in the right direction. It is further suggested that the transverse streets within the runway site should be made wider to allow for seaviews from the site interior and to minimise the likelihood of future wall effect due to competition for maximum sea views. 3. Car Parking Provisions The HKIA cautions that car parking provisions should take into consideration of the effect of the potentially large flat sizes due to the outstanding quality of the SEK site. Preferably public car parks could be provided at a few locations to free up the site planning constraints under HKPSG Chapter 8 so that the future developments will not end up in the conventional "15m-podium" design just to contain the car parks. 4. Vibrancy of the Central Boulevard and Street Lives HKIA welcomes the provision of a Boulevard along the runway site as a reference to the runway history. HKIA urges for more consideration to be given to the anticipated vibrancy of the boulevard as the site parceling calls for super luxurious apartment developments on the runway site in which the high security requirement and exclusivity will be in conflict to the public engagement. Traffic within the narrow and elongated runway area should be planned as efficient and controlled as possible and the majority should be diverted to run along the Kowloon Bay hinterland instead. HKIA also queries if the scale of the Metro Park would be too overwhelming to such an extent that it diminishes the critical mass of the development portion towards the end of the runway, thus making it a secluded rich people s enclave with insufficient activities to feed back onto the Park. 5. Recognizable District Characters As the Runway site is rich is historic references and context, some kind of planning control mechanisms, e.g. verandah space, building alignments, etc., could be incorporated to engender a genuine local district character instantly perceivable without the need to rely on architectural features. 6. Interaction with Kowloon Bay and Kwun Tong Connections to the Kowloon Bay are sparingly few and far apart. The lack of direct footbridge / vehicular bridge linkage to Kwun Tong makes the tip of the runway extremely difficult to reach especially in case of emergency. At a distance of only approximately 200m away, ferry service commuting between Kwun Tong and the runway tip is more of an hassle than a joyful ride. This is simply impractical. HKIA strongly urges the Government to reconsider the provision of a direct bridge connection between Kwun Tong and the tip of the runway. This will definitely facilitate the successful development of the future cruise terminal and tourism node at the end of runway, the redevelopment of Kwun Tong town centre, as well as the on-going transformation of Kwun Tong Business Area. The bridge, as a strategic connection between Kai Tak and its hinterland, would be a long-term infrastructural project, which could tie in with proposal to de-commission the public cargo working areas in Kwun Tong in the long run. The Hong Kong Institute of Architects Page 9 of 16

11 Also, the local distributor road along the northern edge of the runway site may cause the buildings to be single aspect. Such could be an unsightly view for the inhabitants in Kowloon Bay. HKIA suggests that half-sunken roads or roads with sloping berm on either side should be considered at the planning stage rather than to rely on the future architecture design to suit an at grade road and to meet the EIAO requirements with features. The SEK plan should also allow more efficient vehicular circulation along the narrow and elongated runway by diverting more traffic to the hinterland F. METRO PARK 1. Shape and Park Framework HKIA welcomes the Project Team s proposed framework and trail of green areas and parks ranging from the proposed new Sung Wong Toi Park, the Depot Green, the Stadium Park to the Metro Park. The differing scales of greens are appreciated. However, HKIA also cautions that the shape and orientation of the Metro Park should not obstruct continuation of urban vibrancy. Accessibility to the Park must be positively addressed and cannot rely on natural filtration of people from the two ends. 2. Activation of the Park The Metro Park should be provided in a location with high accessibility not only to the local residents but also to all people of Hong Kong. The open space must be activated by filtering various functions in the perimeter urban setting or it risk being an urban barricade / urban void. 3. Theme Park The theme park in the previous plan disappeared in the draft PODP. HKIA queries the necessity for theming at all. 4. Consistency of Planning Concept until Implementation If a planning concept to the Metro Park is to allow activities to filter through, then Planning Department must devise a mechanism to ensure this being carried out in the post-planning stage. In the conventional approach, the Metro Park will be allocated to LCSD for management, who will in turn initiate their own design and construction processes. The end product may not be what the SEK planning has wanted. 5. Metro Park on the Deck If the 600m break on the runway is a technically necessity for the DSD storm water discharge, then HKIA would caution if putting landscaping on the artificial deck is indeed technically viable. The Project Team is advised to take a more detail investigation to make sure that the future soft landscaping and usage of this Metro Park on a Deck is not constrained in any way and there should always be opportunity for extensive grass/ green covered land in this area. A barren hard-paved deck is hard to be unacceptable. The Hong Kong Institute of Architects Page 10 of 16

12 G. STADIUM 1. Site Selection HKIA recognizes the relocation of the stadium to the south depot area as shown in the current draft PODP brings forth improvement in planning terms by:- i) Resolving the clash with the DSD drainage reserve zone, ii) Resolving the clash with the Central Kowloon Link exit portal and other local distributors (the Spaghetti ). iii) Less land constraints for the required 24ha site area iv) It being closer to the water front v) It being closer to the Ma Tau Wai region and can help revitalize this area. However, it also creates other potential problems that require the Project Team to look into detail:- i) The stadium complex is now also closer to residential developments. Noise could be an issue. ii) iii) The Park will be under the shallow of the Stadium bulk Is the main entrance of the Stadium on the north or on the south? How would the Project Team envisage people s main approach to the Stadium? There are also other proposals as outcomes from the Kai Tak Urban Design Competition that the Stadium could be sited on the Kowloon Bay side water front and engages with the Nullah, or at the tip of the runway and be a natural iconic landmark. Alternatively, as sports stadium is a building structure with inward looking design, the Multi-purpose Stadium could be moved to the north-eastern part of Kai Tak and reserve the waterfront location for other green spaces and theme park uses. The Project Team should pro-actively review the pro s and con s of these options and allow a choice for the public. 2. Retail and Commercial Functions HKIA concurs with the idea that retail activities to integrate with the sports function is in the right direction. 3. Options for People There is no option for not having a stadium in all the proposed plans. People have not been given enough choices as to whether a Stadium is what the SEK really wants. 4. Self-sustainability The Stadium site was enlarged from the original 16ha to 24ha. The planning design should clearly show the "associated property development" to the Stadium to give the public a full picture rather than just a rosy sports theme. The Hong Kong Institute of Architects Page 11 of 16

13 5. Crowd Control and Mass Transit It was felt that there was no absolute need that the Stadium must be sited directly above the MTR lines even though the merit of speedy crowd dispersement and evacuation was acknowledged. It was even considered that the departing crowd could bring retail opportunities to the nearby shops if they were to funnelled to walk through a short distance before reaching the MTR stations. 6. Stacking Over It was suggested that the Stadium could even sit on top of the "spaghetti" of roads near the Central Kowloon Link exit portal just like the way Roponggi Hills was conceived. More green land could therefore be released for other use and the unsightly roads and noise issues could be contained. H. CRUISE TERMINAL 1. Berth Alignment The parallel berthing as shown in the current plan is illogical as the cruise ships block the precious waterfront area and are spreading the servicing too far apart for efficient immigration and security control. The current proposed alignment is only a haphazard solution to avoid the reclamation debate. The berth direction should be inclined and projects into the harbour with finger piers. The SEK project Team should not be afraid to propose what is engineeringly correct. 2. Connectivity to Kwun Tong HKIA considers a direct linkage from Kwun Tong to the end of runway should be seriously considered otherwise the Cruise Terminal is at a dead end. The Cruise Terminal must be made more accessible to the public in order to survive. 3. Landmark Building The end of the runway offers the opportunity to have a significant landmark building. Whether this landmark building should be of private or public sector is open for further discussion. It is suggested that other than a cruise terminal, other innovative ideas and attractions at the tourism and entertainment node could possibly include an observation tower, entertainment and shopping centres, as well as hotel developments, etc. The views of Hong Kong Tourism Board should also be consulted. 4. Stand-Alone Tourist Spot If the Cruise Terminal were ever to be anticipated as a tourist spot then it must not be a stand-alone building at the tip of the runway as the location is way out of reach from the other conventional tourism centres in Hong Kong. Also, the function of a Cruise Terminal is not itself attractive and conducive to tourism activities. It must be a destination for a series of tourism nodes along the length of the SEK site. In other words, more tourism and/or culture related activities must be planned within the SEK. The Hong Kong Institute of Architects Page 12 of 16

14 I. HELIPAD 1. Convenience vs. Nuisance HKIA acknowledges the operational functions are compatible with those of the Cruise Terminal. However, the environmental impact of the helipad is very significant. HKIA would like to point out that while the location of the helipad is technically speaking not geographically bound to any particular spot in Hong Kong, the runway tip panorama view of the Hong Kong Island is. This panoramic view is worth a lot more than a convenient helicopter launch pad in Hong Kong. That means the helipad should in no way be allowed to diminish the special scenic quality of this site which should be the first priority in the SEK plan. If the helipad function should prove to be in conflict with the proposed landmark building or infringes onto the public s enjoyment of the site, HKIA will strongly object. Planning Department is therefore urged to look into the scale, bulk and operation of the helipad in this sensitive area and at the same time to prove that they have exhausted all alternative locations in Hong Kong before locating it at the current proposed spot. J. NULLAH WATERWAY 1. Rehabilitation The scale of the waterway is in good humane proportion. Subject to it being successfully purified, the water surrounding Kai Tak Approach Channel can be rehabilitated to improve the environment significantly. It can also provide a serene water body in the inner city area for recreational purpose. HKIA s position on this issue is that since reclamation is a irreversible process, we should allow the environmental technical experts to attempt to improve the water quality first, before it could be concluded whether total reclamation of the nullah is the only practicable solution. K. CARGO HANDLING AREA 1. Relocation Planning Department is urged to re-consider if the cargo handling area near Kwun Tong should be treated as a constraint to the planning of Kai Tak or they can simply be decommissioned and relocated. The need to foster good waterfront planning should be given priority over the cargo handling operations as the traditional industrial centres for Kwun Tong area have been relocated anyway. L. ENVIRONMENTALLY FRIENDLY DESIGNS 1. Natural Ventilations and Green Buildings HKIA has always devoted to the promotion of environmentally friendly buildings and fully supports this being instigated as a planning requirement in the SEK plan. However, recently the public has growing concerns on if the environmental features are being exploited for bonus GFA s or additional plot ratios, resulting in massive wall effects and destroying the very purpose of the green features. The Hong Kong Institute of Architects Page 13 of 16

15 While bonus plot ratios and GFA are legally permitted, the HKIA holds an open attitude towards a clearer guideline for the industry. 2. Monorail and Mass Transport System HKIA supports the idea of environmentally friendly mass transport system but would caution if the mono-rail could be an effective and efficient operation considering its relatively short distance, citing the early Jubilee Line extension in London or Sydney s monorail as examples. Other means of environmentally friendly transportation, such as trams, Automated People Mover (APM) system or trolley-bus should also be explored. 3. Centralised Utilities Service Tunnel HKIA supports the concept of centralised utility service tunnel subjects to detail design and implementation. 4. Waste Treatment HKIA urges the Project Team to look into a more centralised waste treatment and sorting mechanism, rather than to rely on individual developer s own initiatives, to promote a greener living environment. 5. District Cooling / Seawater Cooling HKIA urges Planning Department to look into provisions to allow for district cooling and/or seawater cooling, which would involve land provisions. HKIA also cautions that the proposed seawater pump houses should be so designed as not to hamper the water front quality. M. GOVERNMENT SERVICES CENTRES 1. G/IC Facilities within the SEK Plan HKIA holds no strong view on what type of Government accommodations should be located within the SEK plan but acknowledges that from urban design point of view strategic planning of G/IC facilities can help limit building masses, providing open view and maintaining air ventilation corridor to the existing built-up areas. However, if planned incorrectly, Government accommodations are prone to easy degeneration into barren urban blockage dead spaces especially after normal office hours. They are not particularly conducive to vibrant urban living culture. Over-concentrated Government facilities can easily produce uninviting urban vacuums (e.g. Capital Hill in Canberra, Australia) and cut-off urban spaces. The HKIA urges the Government to plan carefully for any Centralised Government facilities in SEK and to ensure that it is well-integrated with the community. 2. Hospital The location of the hospital should be well-located for speedy service to the Kowloon East district, where a shortage of hospital beds is dire. The Hong Kong Institute of Architects Page 14 of 16

16 3. Existing Airport Police Station and Car Parks The existing Airport Police Station and car parks should be relocated because it has lost its purpose or function to be there. Also, the site is a good opportunity for linking back to San Po Kong area in anticipation for the future re-zoning of the factory sites across the road. N. LAND RECLAMATION 1. Respect for the Locals HKIA opines that the need for reclaiming the nullah should be an issue subject to rational consideration and not a sensational discussion. HKIA understands from the SEK Project Team that the locals were in fact in favour of reclaiming it but before the environmental issue was proven irresolvable, the Team assumes it would stay put. 2. Choice for the People HKIA observes remarked that all proposed plans have been showing a non-reclaimed concept. As a matter of putting forward a viable option for the public's healthy discussion, there should at least be one option showing the nullah being reclaimed. 3. Creating Vistas HKIA suggests that the SEK Project Team should actively look into ways of sinking or hiding the "spaghetti" of roads as these would seriously hamper the vistas of the future purified nullah. The end of the nullah is in fact an ideal location for an imposing public building facing the nullah waterway. 4. Ordinance Amendment The planning for Kai Tak would be a good chance for the public and the SAR Administration to reconsider the appropriateness of some of the technical definitions for reclamation laid down in the Harbour Protection Ordinance. O. IMPLEMENTATION 1. Post-Planning Stage There have been countless examples that good planning intentions turned out to be bad urban spaces because of bureaucratic considerations at the post-planning stage. The planning for SEK should not be halted at the completion of the respective Outline Zoning Plan(s). The implementation of planning for SEK should be an integrated approach which relies on a concerted effort of various government departments with high level coordination. HKIA urges Planning Department to take a lead in ensuring the good planning designs are successfully implemented beyond bureaucratic boundaries. The Hong Kong Institute of Architects Page 15 of 16

17 P. OTHERS MISCELLANEOUS ISSUES 1. Public Consultations HKIA suggests that scaled physical model(s) should be a must in the public consultations to help the public to visualize the proposed urban spaces. 2. Fine-tuning Designs HKIA suggests that prior to OZP or ODP, there should be a further stage to fine-tune the 3-D design consideration in order to come to a spatially more enriched space planning, rather than to complete the "land use plan" and let the future developers to build according to their own agendas. The Hong Kong Institute of Architects Page 16 of 16