Press Release 新聞發佈

香港鄉郊基金 – 新聞稿及土地規劃政策立場 (2017-8-22) HKCF Press Release and Position Paper on the use of country park land for building development

香港鄉郊基金

新聞發佈

2017822

[English version further down]

  1. 近來多了向郊野公園(包括船灣淡水湖)要地用作房屋用途的言論,香港鄉郊基金強調郊野公園是供香港廣大市民享用的公共資源,有極為重要的康樂、旅遊、自然保育及歷史文化保育功能,不可隨意侵蝕
  2. 就香港政府有關找尋土地供廉租公營房屋及非牟利老人院等用途的政策目標,香港鄉郊基金已向香港政府遞交了一份立場書。
  3. 香港鄉郊基金認為在達致此目標的過程中,政府必須遵循現有政策、最優做法及以原則為本的施政方式,找尋土地的過程應該基於一個土地等級制度,郊野公園及根據郊野公園條例指定的特殊地區應為最後和逼於無奈的選擇
  4. 政府有幾個不需要製造新土地的選項:
    a. 檢視香港現有房屋的使用

             b.檢視現有政府土地儲備及填海土地的計劃用途

                 計劃用途應與廉租公營房屋及非牟利老人院比較,擴建廸土尼樂園顯然不能視                   為比廉租公營房屋更應在已填海得到的相關土地上建設。

            c. 工業區及工業樓宇重訂用途

  1. 在香港找尋土地興建廉租公營房屋及非牟利老人院,優先次序應該基於一個土地等級制度,郊野公園及根據郊野公園條例指定的特殊地區應為最後和逼於無奈的選擇。以下段落列出相關的土地等級,排在前面的等級應優先考慮:

            a.新發展地區、新市鎮擴展項目、統合發展區

            b. 棕地

                  棕地面積有估計超過1,000公頃,雖然沒有官方定義,不過視乎破壞程度,棕                       地包含以下幾類:

                  i. 類近工業土地、露天貨倉、未獲授權用途

                ii. 政府及私人土地,例如空置學校、潛在可以建築平台的基建項目、道路、鐵                        路及路邊空地

                iii.     已破壞或閒置的政府土地,如工地、舊學校、臨時停車場等

           c. 只有在以上各個等級都考慮淨盡後才應依次考慮以下等級:

                 i. 已受破壞、低生態價值、極低可能恢復生產的農地

                    約850公頃這樣的農地位於道路和鐵路附近,或在現有城鎮周邊,有以較低成                      本和較短時間內進行房屋開發的潛質。

                ii. 沒有受到法律保護的鄉郊地區

                iii. 正在耕作或高質素的農地

               iv. 各種受到保育規劃保護的土地,包括綠化帶、自然保育地區、具特殊科學價                      值地點、2004年新自然保育政策指定的優先保育地點、郊野公園不包括土                             地、水塘及引水區、郊野公園及特殊地區

  1. 香港鄉郊基金向政府遞交的文件全文(暫時只有英文本)附加於後。
  2. 如有查詢,請電郵chairman@hkcountryside.org 或致電林超英先生9109-1202。

 


Hong Kong Countryside Foundation

Press Release

22 August 2017

  1. Recently there are noises about using country park land (including the Plover Cove Reservoir) for housing purpose. The Hong Kong Countryside Foundation (HKCF) strongly stated that country parks are a public resource for public enjoyment by the Hong Kong  It has important functions in recreation, tourism, nature conservation and the conservation of cultural and historical heritage.  Haphazard attempts to take country park land away are not permissible.
  2. HKCF has submitted a position paper to the Government regarding its stated policy objective of searching for suitable land for public low-cost housing and elderly accommodation.
  3. HKCF advocates that the Government’s approach to achieving this objective must follow existing policies, best practice and principled governance. The approach to selecting land for such purposes in Hong Kong should be based on a hierarchy of land categories in which Country Parks (“CP”) and Special Areas designated under the Country Parks Ordinance should be the option of last resort.
  4. A number of options exist for Government without creating new land, including:
  • Review the current utilization of Hong Kong’s existing housing stock. Review of planned uses of existing Government land banks and reclamations.
  • Planned uses should be re-assessed vis-a-vis low-cost housing and elderly accommodation. Notably, the expansion of Disneyland cannot reasonably claim higher priority than low-cost housing on the existing designated reclamation land.
  • Re-purposed industrial areas and buildings.
  1. The priority for selecting land for public low cost housing and elderly accommodation in Hong Kong should be based on a hierarchy of categories of land in which Country Parks and Special Areas designated under the Country Parks Ordinance should only be the option of last resort. The following paragraphs set out the hierarchy in descending order of priority.
  • New Development Areas, New Town Extension Projects and Comprehensive Development Areas
  • Brownfield Sites.  The area of brownfield sites has been estimated to be more than 1,000 hectares.  While there is no official definition of brownfield site, however, in order of degradation we suggest it includes the following categories:

            i. Quasi-industrial land, open storage, and unauthorised existing uses

          ii. Govt Land and Private Land such as empty schools and potential podiums above                      infrastructure, highways, railways, and roadside area.

        iii. Degraded or idle Government Land, such as worksites, old schools, temporary                     carparks and others.

  1. Only when the above categories have been considered and exhausted should the following categories be considered, in descending order of priority.
  • Degraded farmland of low ecological value and with poor potential for restoration to productive agriculture. Some 850 hectares of such farmland is located in the proximity of roads or railways and/or on the periphery of existing towns and so have potential for housing development at relatively lower costs and in shorter time-scale.
  • Unprotected Countryside
  • Active or good quality Farmland
  • Conservation zonings of various types including GB, CA, SSSI; Priority Sites under the 2004 New Nature Conservation Policy and CP Enclaves; Reservoirs and catchments and Country Parks and Special Areas.
  1. The full text of HKCF’s submission to the Government (English only) is available appended below.
  2. For further enquiries, please contact Mr Roger Nissim by email rabnissim@gmail.com or telephone on 9385-5820.

 


 

The Hong Kong Countryside Foundation

On land for public low cost housing and elderly accommodation

For Policy Address

SUMMARY

The Hong Kong Countryside Foundation (HKCF) recognizes the Policy Objective to find suitable land for public low-cost housing and elderly accommodation.  The Government’s approach to achieving this objective must follow existing policies, best practice and principled governance.  The approach to selecting land for such purposes in Hong Kong should be based on a hierarchy of land categories in which Country Parks (“CP”) and Special Areas designated under the Country Parks Ordinance should be the option of last resort.

INTRODUCTION

  • Sensible and established process. The Government should conduct its search for land for housing development in a holistic manner, keeping in view the full range of society needs, using established procedures and professionals in the Planning Department and with the participation of the NGO community (Area 4 of the Biodiversity Strategy and Action Plan 2016) and Government’s Multi-Pronged approach to finding land resources (paras 117 and 121of the 2017 Policy Address).

PRINCIPLES

  • The processes to be followed should be transparent, professional, consultative, statutory and fair. To use Hong Kong Housing Society, a quasi-Government property agency, to develop housing projects on a pre-determined site circumvents established processes, deviates from principled governance and thus is wrong in principle.  It would be seen by the public as collusion driven by vested interests for a land grab by a body conflicted by its own interest in a pro-development outcome because of having interests and objectives for building development.
  • The Government has committed to “Maintain and enhance Protected Areas” (Action 1 of the BSAP). CP is Protected Area (PA).  Logical and normal planning principles and existing policies require Protected Areas of various sorts to be considered for building development only after all other alternatives have been assessed and exhausted.  The Government, or indeed any developer, should be required to demonstrate an overriding public need before CP and PA types of land is to be excised.
  • Sensible and principled governance requires prior examination of better land options or other alternative solutions for low cost housing and elderly accommodation. All those land categories of less value to the public should be examined first before any CP land is stripped of protection for building   It is neither good planning nor principled governance to only look at using CP land when objectively this is the worst option.
  • Good planning is best achieved by following existing Government Policies for planning, conservation and land use including inter alia: –
    1. HK’s Nature Conservation Policy, the Biodiversity Strategy and Action Plan (which implements the Convention on Biological Diversity and other international standards and principles, and which contributes to China’s National BSAP; see BSAP 2016 4.2).
    2. the Sustainable Development Policy, which in this application means the Sustainable use of Natural Resources again based on international best practice, and
    3. Planning Department’s own principles and criteria as set out in the HK Planning Standards and Guidelines and Town Planning Ordinance.

PRACTICAL CONSIDERATIONS

  • Land suitable for public housing requires convenient access to mass transport such as MTR, facilities to manage high volumes of sewage and waste disposal, and other infrastructure support for urban life. CP landscapes are typically hilly. Site formation and stabilization in hilly areas increases the site footprint, development costs, time and environmental impacts.  Road access to areas hitherto protected by their remoteness would lead to degradation and trashing.  When such abuses arise, resources will be needed to ensure effective enforcement actions by relevant departments.  This will add to the costs of unsuitable places being selected.  Pursuing the CP option is no quick fix.
  • Sites suitable for the elderly require nearby medical facilities, hospitals, social services and an enhanced need for emergency vehicular access, which are not typical characteristics of CP land. Improperly selecting sites in CP land would add to the isolation and the risk to a particularly vulnerable sector of the community.

PROCESSES

  • The EIA process must be used to ensure a professional, transparent, independent, and unbiased assessment is made in the public interest. The assessment must include the impacts of the project, the cumulative impacts, and consider alternative development options other than the developer’s preferred option to avoid and reduce impacts.  This assessment must also consider other sites (e.g. brownfield sites) as alternatives to avoid the impacts.  ACE must participate in evaluating development proposals against objective criteria.  ACE and AFCD have important roles in implementing BSAP which is Hong Kong’s duty to the Nation.
  • The Country and Marine Parks Board must assess and rigorously perform its duties to protect the CP according to the objectives of the Country Parks Ordinance. It should assess and require corresponding compensation via extensions of CP to offset the losses of area and ecological and recreational functions caused by individual developments impacting CPs and their periphery.
  • The assessment must, in all cases, go through the Town Planning Board with the Board following principles, policies, and factual and expert evidence. The Board should be neutral and unbiased in its decision making process.

HIERARCHY FOR SELECTING LAND

  • A number of options exist for Government without creating new land, including:
    1. Review the current utilization of Hong Kong’s existing housing stock.
    2. Review of planned uses of existing Government land banks and reclamations. Planned uses should be re-assessed vis-a-vis low-cost housing and elderly accommodation.  Notably, land sold to developers for private luxury housing does not yield low-cost housing while the expansion of Disneyland cannot reasonably claim higher priority than low-cost housing on the existing designated reclamation land.
    3. Re-purposed industrial areas and buildings. Experience has shown that old factory buildings can be repurposed for a variety of uses reflecting the city’s changing needs.  Alternatively, clusters of such buildings could be re-developed through holistic planning to serve the specific needs of our ageing population, with retirement villages, hospitals, day care centres and recreational facilities.
  • The priority for selecting land for public low cost housing and elderly accommodation in Hong Kong should be based on a hierarchy of categories of land in which Country Parks and Special Areas designated under the Country Parks Ordinance should only be the option of last resort. The following paragraphs set out the hierarchy in descending order of priority.
    1. New Development Areas, New Town Extension Projects and Comprehensive Development Areas The 2017 Policy Address paras 117 and 121 state that the priority is to develop areas concentrated with brownfield sites. The developments in Hung Shui Kiu, Yuen Long South and Kwu Tung North/Fanling NDA’s currently underway cover 380 hectares of brownfield sites.  We support this as a part of the strategy.
    2. Brownfield The area of brownfield sites has been estimated to be more than 1,000 hectares by a civil society team.  The results of Planning Department’s 2017 Brownfield Site Survey should be made available to the public and assist in the release of brownfield land for low-cost housing and elderly accommodation as a priority. While there is no official definition of brownfield site, however, in order of degradation/ownership we suggest it includes the following categories, which could overlap: –
      • Quasi-industrial land, open storage, and unauthorised existing uses, also on urban fringes. Most of the land is highly degraded, and mostly private land.
      • Govt Land and Private Land such as empty schools and potential podiums above infrastructure, utilities, highways, railways, and roadside areas.
      • Degraded or idle Government Land, such as worksites, old schools, temporary carparks and others.
    3. Only when the above categories have been considered and exhausted should the following categories be considered, in descending order of priority.
      • Degraded farmland of low ecological value and with poor potential for restoration to productive agriculture. About 850 hectares exist for assessment. Some 850 hectares of such farmland is located in the proximity of roads or railways and/or on the periphery of existing towns and so have potential for housing development at relatively lower costs and in shorter time-scale.
      • Unprotected Countryside, mostly Govt Land, a high percentage of Hong Kong.
      • Active or good quality Farmland.
      • Conservation zonings of various types including GB, CA, SSSI; Priority Sites under the 2004 New Nature Conservation Policy and CP Enclaves; Reservoirs and catchments and Country Parks and Special Areas.
  • Whenever land with recreation, ecological or heritage values are considered for housing development due process should be followed in assessing the impacts and corresponding compensation measures. Recognizing the public’s growing concern and effectiveness in blocking or delaying development projects in areas of high recreation, ecological and heritage values, all assessments should follow global best practice and principles including the following:
    1. Ratcliffe Criteria, 1977, originally for SSSI and partly used in EIAO TM, as refined for Hong Kong by Barretto and Kendrick 2007. (summary extract below)
    2. EIAO TM Criteria at Annex 8 Criteria for Evaluating Ecological Impact, Annex 16 Guidelines for Ecological Assessment, which requires Avoidance, Minimizing and Compensation for impacts.
    3. Principles applicable to Hong Kong, as confirmed in relevant court cases, include inter alia “holistic conservation” which requires protecting a watershed or landscape as a whole and cumulative impact assessment. Such criteria assist in replacing vague terms like “relatively low ecological and public enjoyment value” in Policy Address para 117.
    4. Compensation, with No net loss of Country Park or ecological function. For every piecemeal loss caused by each specific development project, especially at the periphery of CP and other ecologically significant areas, there must be immediate and correspondingly compensation, enhancement and restoration.  Compensation for loss at the periphery of CP is part of the Government Policy Address 2017 para 117.  Compensation should be made for losses of ecologically and recreationally valuable countryside outside CP also because loss of buffer (especially Green Belt) can cause major ecological damage in the long term.
    5. Public Enjoyment of Country Parks is the paramount reason against CP delivers Quality of Life through the provision of essential recreation for Hong Kong’s hard-working population, such as relaxation, hiking, picnic, physical exercise, enjoying the natural scenery and fresh air, nature photography, observations of trees, birds and wildlife, , see BSAP 2016 generally.  These benefits and values are enjoyed by at least 11.4 million visitors a year (AFCD figures for Country Parks 2014), and innumerable morning exercise practitioners all over Hong Kong.  Studies show our aging population increasingly rely on good environment for maintaining their quality of life.
    6. Other ecosystem services from the Countryside to be valued include inter alia:
      1. Water Resources (particularly water catchment areas),
      2. Reducing urban heat island effects,
  • Health protection and Traditional Chinese Medicine sources,

(See BSAP 2016 pages 4-7 and BSAP Action 17 Identify Ecosystem services.)

  • The Countryside now at risk is about half of the Hong Kong 80% of Hong Kong used to be green or Countryside.  Half of this is protected as CP (40% of HK land area), but the other half of the Countryside is NOT.  The Unprotected Countryside which is now being lost every day by piecemeal developments and abusive uses.  Thus the 80% green is declining to between 75-80%.  The actual losses of Countryside, being planned or on-going, must be assessed and the public informed.
  • Taking a National perspective Hong Kong’s protected areas network (PAN) is a de facto National Park in southern China. It represents a significant contribution to the fulfilment of the Central Government’s Plan for the Development of the Bay Area of the Pearl River Estuary (Plan) as a “green and healthy living environment”.  Having building developments in such areas would undermine the capacity of our PAN to fulfil this function.  Hong Kong must not appear to be reaping the benefits of the Plan, while at the same time undermining its intentions.

CONCLUSIONS

  • HKCF proposes that Government can achieve the Policy Objective to find land for public low-cost housing and elderly accommodation by following existing policies, best practice and principled governance and adhering to processes which are transparent, professional, statutory, fair and therefore welcomed by the public, so as to achieve sustainable use of natural resources, in particular our precious Countryside.
  • The approach to selecting land for such purposes in Hong Kong should be based on a hierarchy of categories in which Country Parks and Special Areas designated under the Country Parks Ordinance should be the option of last resort. HKCF proposes this approach to be adopted in Hong Kong for selecting land for development in future.  This would mainstream sustainability and conservation principles into planning and land use (which is a key part of the BSAP policy, Action 9).  Good governance based on these policy solutions helps value and protect our countryside, with sensible choices for the future based on sound principles.

The Hong Kong Countryside Foundation

1 August 2017

 


Abbreviations

BSAP               Biodiversity Strategy and Action Plan, December 2016

CA                   Conservation Area

CP                    Country Park and Special Area

EIAO TM         ,Environmental Impact Assessment Ordinance Technical Memorandum

GB                   Green Belt

SSSI                 Site of Special Scientific Interest.

Notes

The parts of the Ratcliffe Criteria (1977) essential to considering encroachments into Country Parks include the loss of buffer functions, the green corridor or ecological function and connectivity values of any periphery being considered for housing.  Fragmentation impact will be accelerated. Landscapes are easily lost.  All the criteria are relevant and were updated for use in Hong Kong, and extracted from Barretto and Kendrick 2007, Proceedings of the First South East Asian Lepidoptera Symposium 2006, page 93, as follows:

  1. Size
  2. Diversity, including wildlife Abundance/richness, species Assemblages, regional Comparison
  3. Rarity, including Uniqueness and endemicity
  4. Recorded history, including Age and Recreatability
  5. Fragility, including Recreatability, Nursery/Breeding ground
  6. Typicalness
  7. Naturalness
  8. Position in Ecological Unit, including Fragmentation and Ecological Linkage, (See BSAP Action 4 Maintain habitat connectivity for wildlife).
  9. Intrinsic Appeal, including Natural Landscape Beauty
  10. Potential value

 

香港鄉郊基金對施政報告的回應 (2017-1-18)

香港鄉郊基金歡迎施政報告113段提及,政府考慮透過非原址換地方式換取沙羅洞內具高生態價值的私人土地,作長遠保育沙羅洞,同時繼續物色合適地方納入郊野公園範圍。沙螺洞是僅次於米埔及內后海灣拉姆薩爾濕地的重要生態地區,號稱「山中米埔」,香港鄉郊基金敦促相關持份者積極配合,盡快落實這件好事。

香港鄉郊基金又歡迎施政報告115段提及,為了推動復育偏遠鄉郊環境而設立保育基金成立籌備委員會。香港鄉郊基金已有數年相關經驗,樂意提供予政府參考,協助使蘊藏於香港鄉郊的寶貴人文和自然資源,得以為香港社會發揮積極作用。

香港鄉郊基金注意到施政報告158段提及改善偏遠的公共碼頭,認為過去數年進行了復耕復村的荔枝窩村出入人人流增加,建議政府應該給予該村優先考慮。

香港鄉郊基金於2011年成立,五年來多次向政府建議以非原址換地方式取得沙羅洞私人土地,並採取有效措施保育當地人文及生態資源,高興見到建議終獲採納。

2013年開始,香港鄉郊基金蒙荔枝窩村村民信任,承租了四萬多平方米棄耕多年的農地,得到香港上海匯豐銀行支持,與香港大學、綠田園基金及長春社合作,重新開耕,同時進行研究和公眾教育,確保復耕、復村工作,既尊重和存護客家傳統,也符合科學精神,至今已經收成稻米六造及不少其他作物,重建荔枝窩的農耕精神面貎,提高市民對本村的認識,又開始促成小規模的在地經濟活動,令一度沈寂的鄉村生機勃發,逐步邁向可持續發展。

目前香港鄉郊基金正開展由香港賽馬會資助的項目,透過復修村屋和拓展體驗式教育,在荔枝窩建立「客家生活體驗村」,讓香港市民在荔枝窩接觸和認識客家傳統文化,以及理解內裏包含的可持續發展概念。

香港鄉郊基金成立的目的是通過聯繫持份者、倡議相關政策及策略、促成及執行個別在地項目等,與熱心保育香港鄉郊文化和自然資產的人士合作,共同為香港的美好未來努力。