Citizens Task Force on Land Resources Position Paper on Land Consultation

“Hong Kong is not short of land” — Position Paper: Citizens Task Force on Land Resources responding to the Task Force on Land Supply and the HKSAR Government Land Consultation


Although the public consultation by the Task Force on Land Supply (TFLS) is almost done, the discussion has yet to focus on sustainable development, optimal use of land, conservation of resources and housing policy.

Formed in September 2017, The Citizens Task Force on Land Resources (CTF) brought together members with a wide range of experience and skills including professionals, businessmen and community groups to broaden the debate over land resources.

Hong Kong is not short of land as our table at 5.4 demonstrates. At the beginning of this century, government discontinued the regular pipeline of land supply and sold sites earmarked for public housing to the private sector. Together with persistent low interest rates, quantitative easing, money flows from the Mainland, this caused property prices to rise rapidly leading to an affordability crisis. At the same time, sites earmarked for public housing were used for private residential development, impacting the supply of public housing.

Hong Kong’s land supply pipeline has only recently been restored and, together with rising interest rates and increased monetary controls exerted by the Mainland, has started to make an impact on property prices. At the same time, the allocation of land for public housing has picked up. This is masked by the increase in young people who join the waiting list for low cost public rental housing. Moreover, housing which comes newly available is not prioritized for the 115,100 households living in substandard conditions.

There is more positive news. The average living space per capita — although still below that of Singapore and Shenzhen — has steadily improved over the last three decades. The number of living quarters well exceeds the number of households. The population of Hong Kong will peak in 2043, and that of China as a whole in 2025.

The push for massive land supply is based on inflated assumptions regarding population growth and space requirements. Hong Kong does not need a land bank. We need to strengthen the regular pipeline of land supply for housing and economic development. This can be achieved through better planning of underutilised land resources and improvement of infrastructure in the New Territories.

Below we will respond to the questions raised and land supply options proposed in the consultation document of the Task Force on Land Supply. We will also highlight the missing land supply options. But first a more comprehensive framework for consideration.

1. There is no land shortage — we need better strategic land use planning.

The government needs to practise strategic planning for a long-term and regular pipeline of land supply. This can be achieved through well-planned NDAs and compliance with the Hong Kong Biodiversity Strategy and Action Plan.

2. The elephants in the room: Financialization of property and housing

The public consultation so far has been confined to land supply options. This fails to acknowledge the elephants in the room. Root causes of high housing prices are the financialization of property and housing, speculation and a high land price policy practiced by a government dependent on land revenues. Affordability, not land shortage, is the core housing issue faced by Hong Kong people. It is shocking to see how land supply continues to be moderated by government to maintain high land premium revenues.

3. Reconsider growth by numbers

Inflated population figures are used. Some are overstating Hong Kong’s future by almost 1 million. Hong Kong’s population will peak in 2043 leading to reduced need for land. Tighter controls over immigration will further reduce demand for housing. Our national population will peak in 2025. Rather than push Hong Kong’s population, we can focus on using more land for improving quality of life, recreation, open space and enjoyment of the countryside.

4. Misaligned housing policies

Housing should not be treated as a commodity. Therefore, the ratio between the private and public housing should be adjusted according to the need of the people, not the market. The possibilities of other forms of social housing, besides home ownership and public housing, should be explored to fulfil the need.

The lack of public housing is a result of allocation of land to private residential development. It is the Hong Kong government’s responsibility to ensure affordable housing for all. Such housing policy should prioritize the need of the 115,100 households who are inadequately housed. (Transport and Housing Bureau, 2017, p.6) New housing provisions should prioritize those who are in need first. Alternative — non-market — housing schemes should be offered which exclude premiums to government, or alternatively, government should fund those in need with rental vouchers.

5. Holistic planning based on solid principles

Guiding principles should be applied when Hong Kong government decides its strategies for land and infrastructure development:

a. Good planning with the community

b. Building on our strength as a compact city with efficient accessibility of jobs and amenities

c. Recognizing our green and blue assets as formidable competitive strengths

d. Pursuit of the Sustainable Development Goals (SDG) set by the United Nations (UN), the Hong Kong Biodiversity Strategy and Action Plan (BSAP), and the Paris Climate Agreement.

6. Comprehensive criteria for evaluation of land supply and development strategies

Criteria for evaluation of land supply and development options should not just be based on development benefits, costs and time required, but also on social justice, technical feasibility and life cycle analysis, environmental Justice, and quality of life.

7. Social justice in planning and development

Social justice can be realised through land-use planning serving the needs of the people. Our city should recognise that a resilient and ecologically diverse environment is the foundation of a healthy economy and a harmonious society. A fair and bottom-up planning process should be adopted involving people from all walks of life. The urban planning system should be democratized including reform of the Town Planning Board. Land ownership and development details including costs should be transparent for timely public discussion.

Social and environmental impacts should be evaluated prior to any development to minimise impacts on different stakeholders. The government should respect and make an effort to enhance existing communities and landscapes, instead of removing local character and gentrifying old urban areas.

8. Life cycle analysis beyond technical feasibility

Technical feasibility should cover development potential; development time and costs; political, legal and administrative expediency; jobs opportunity; connectivity to existing infrastructure; and life cycle analysis. Efficiency, such as the size of land parcels, is just one but not the only factor in planning for land supply. New development areas should ensure universal access to basic services such as water, sanitation, waste management, energy, food and mobility including road and railways, without negatively impacting the life of others. Any decision should improve people’s living standards and enhance productivity, mobility, and connectivity throughout the territory. Importantly, government must avoid breaching existing legal protections such as for natural habitats (country parks, water gathering grounds, land zoned for conservation uses) or others such as Victoria Harbour. The burden is on government to prove there is no other alternative.

9. Environmental justice is vital to the quality of life

Government should prioritize implementation of BSAP, and ensure the survival and healthy development of Hong Kong’s excellent ecosystems (including the natural benefits of peace and quiet, fresh air, clean water, beautiful scenery, thriving vegetation and wild things) which are fundamental to people’s physical, emotional and mental well-being, and hence everyone’s quality of life. Hong Kong needs to best use its unique natural capital of the beautiful countryside, clean streams, sea and landscapes, and high biodiversity to become the green lung of the Bay Area where there are places for natural regeneration, recreation, and healthy living. Respecting the existing natural landscape is laid out in the UN SDGs. Therefore, the government should improve its protection of habitats, preserve the country parks and areas of recreation and landscape value, and prioritize the redevelopment of sites such as brownfields. Environmental impacts should be minimized to keep a holistic, continuous habitat including building ecological corridors and strengthen the natural environmental resilience.

10. The goal of land planning is an improvement of the quality of life for the general public

The government should recognize Hong Kong as a compact city, and any future development should be planned and designed with reference to the natural landscape, providing high accessibility to employment and minimizing traffic impacts. In other words, the government should build urban settlements that not only respect the existing ecological features but should develop complete neighbourhoods where people can have ready access to employment opportunities, social amenities, social infrastructure and public spaces where people can meet to build communities and accumulate social capital. Land supply options should be evaluated for their impacts on overall traffic demand. Building a new CBD away from existing land resources is likely to induce much new traffic as against building out our existing development corridors.

11. We have a land reserve: Ample existing land can be optimized through better planning

Before reclaiming land and destroying country parks, Hong Kong should develop a long-term strategic spatial plan that tackles, among others, the issue of land supply in the city using its existing land resources. There are many areas of land which can be used better. These resources can be unlocked through good planning, after which land resumption can be applied. PPP is not acceptable as a prerequisite to the development of private “land bank”.

Underutilised land resources in the New Territories:

Brownfields: At least 723 ha[1]

Additional NDAs in New Territories: 720 ha

Land banks held by large private developers: 1,000 ha

Military Sites: At least 270 ha

Other sites:

Short-Term Tenancies, Unallocated Government land&Temporary Government Land Allocation: 270 ha

Underused land near to Disneyland: 60 ha

Nam Tong and other near shore reclamation: 688 ha

Total: 3,731 ha

12. Priority should be better use of land resources in the New Territories

Restoring and developing areas dominated by brownfields should be Hong Kong’s priority. These are ecologically damaged land. Brownfields suitable for housing in reasonable plots of 2 hectares or more amount to 723 hectares well beyond the TFLS suggestion that development potential of brownfields only covers 330 hectares. That some brownfield sites are “scattered” is not a valid reason for not using more of the remaining 970 hectares. We need overall planning for the areas dominated by brownfields, not just the brownfields themselves. Plans need to be implemented using the Land Resumption Ordinance. Land exchange can be used for smaller projects.

13. Stop the spread of brownfields

It is important that as we develop areas dominated by brownfields, and as we open up areas with new infrastructure that we ensure that these brownfield uses do not spread to green fields. Government need to legislate¸ amend guidelines and practice notes, and strengthen enforcement to halt eco-vandalism and incompatible uses to protect habitats and agricultural lands. It is essential that before unlocking brownfields for development, protections with effective statutory zoning, administrative measures, and conditions must be put in place to maintain the status quo and prevent trashing and Melhado uses of other sites.

To counter the impacts of the losses of greenfields, planning and land administration must consider regenerating and restoring farmland, streams and conservation areas and safeguarding and enhancing ecological corridors between Country Parks.

We need preventative measures to safeguard natural habitats in proposed NDAs, establish protocols for “no-go” zones and protect areas with high ecological values. There are around 4,400 hectares of agricultural land. The government should proactively preserve good and active agricultural land, establish a balancing mechanism and proper assessment when planning NDAs. The government should explore ideas on how to integrate farmland into urban design. Hong Kong needs a new form of urbanism that is ecological and humane.

14. Resolve infrastructure capacity for existing and future residents and business in NT

Government needs to allocate more resources to expand the transportation capacity in the New Territories. Existing plans for NDAs can be improved for more efficient use of land and the allocation of residential land for public housing can be increased to 70%. However, critical is that transportation is improved for existing residents and business based on our railway- based transport strategies, and that private car use is discouraged.

15. Turning Fanling Golf Course into a public good

When the private recreational land lease expires in 2020, government should consider greater public use. The high ecological and landscape qualities should be acknowledged and protected as Conservation Area. With our lack of public sports facilities, serious consideration should be given to continued use of the area for sports and recreation and conservation. There are divergent views among members on whether part of the golf course can be considered for housing.

16. Near-shore reclamation can be source for land under the right circumstances

Proposals such as for reclamation of Nam Tong near Tsueng Kwan O was not included. This would provide a total 688 hectares of land (reclamation of 212 hectares, 109 hectares of an existing island, the remainder better use of existing land) suitable for 350,000 residents. This would extend existing developed areas at less cost and result in better transport connectivity. Sunny Bay (100 hectares), Tsing Yi (no figure but estimate 50 hectares) and other suitable areas near existing infrastructure can be considered, provided there is low ecological value.

17. The military land is not taboo.

The military sites have great potential for development, for some of them are located in the heart of the urban area, such as Renfrew Road Barracks and Gun Club Hill Barracks. For barracks located in the New Territories, some of them are highly accessible to existing roads and infrastructures. There are altogether 19 military sites, cover 2,700 hectares of land.

Using military sites should not be treated as a taboo. There should be a transparent evaluation of military use versus public use of these sites. Article13 and 15 of the Garrison Law provide a legal foundation and mechanism for the Hong Kong Government and the military to do so, and to make proposals to the Central Government.

18. Village environs are not taboo.

The Government should review the small house policy, and reconsider the land now set aside as village environs and village development zones.

19. Land options that should be ruled out — East Lantau Metropolis

The proposal for an East Lantau Metropolis development is based on an inflated estimation of population growth and demand for land. Development of an ELM would direct resources away from resolving the many land, planning and transport issues in the New Territories.

Moreover, cost-effective, less risky alternatives exist which also have lower ecological impacts:

a) Damage and ongoing cost to Hong Kong and the regional and global climate

b) Major addition to Hong Kong’s carbon emissions

c) Low-lying area such as artificial island is highly vulnerable to extreme weather and tides and storm surges, more frequent flooding with more extreme weather events, like the Kansai Airport flooding and the recent no.10 Typhoon Mangkhut

d) Irreversible impacts on marine and wetland ecosystems.

e) Unrealistic time frame expectations: it would take 11 years to 14 years for 5 undersea tunnels, 2 land tunnels, 37 km of railways, 20km of roads

f) Recent Government mega projects indicate the estimate of $470 billion ELM project could become $600–700 billion, out of the public purse.

g) The cost could drain funding from social welfare, health insurance scheme, pensions scheme, public housing and degrades the quality of life.

h) The investment would divert resources from proper development of the NT.

20. Country Parks are a special asset, not a land bank.

The Government’s proposal of developing the Country Parks ignores the original intention of the Country Park Ordinance, the function of Country and Marine Park Board, and undermines the well-established and effective system of protected areas. Development of country parks without first establishing the public overriding need for a specific site, while there are many alternatives, and without clear demonstration of making all efforts to minimize the land taken, would change the basic principle of conservation in Hong Kong, which was to protect lands of high ecological values and water gathering grounds. Any change of the boundaries of country parks without recognition of their special status would set a bad precedent.

The government misleads the public by using the ambiguous term “periphery” suggesting that these areas are of relatively low ecological value. However, the areas the Hong Kong Housing Society is conducting pilot studies are clearly within the Country Park boundary. Country Parks are delineated under the Country Park Ordinance without distinguishing as core or periphery. There is in fact no difference developing Country Parks or developing the periphery of Country Parks. All such development causes irreversible impacts on their ecological, landscape, recreational and educational values.

Without considering the availability of ample and alternative suitable sites for development, the government unnecessarily puts conservation and housing development in a confrontational position. The Government continues to emphasize the urgency of the development of Country Parks, and create unnecessary social conflicts. Development of country parks is irreversible, and should be regarded as a last resort. Yet, the government failed to demonstrate the necessity to develop country parks when many alternatives, such as brownfields and idle sites are available.

21. Hong Kong needs an independent land resource committee

To reiterate, Hong Kong is NOT short of land. The government should develop a long-term strategy to mobilise the various types of land resources in Hong Kong to meet the future needs of people and place. The government should establish an independent, multi-sector and multi-stakeholder land resource committee responsible for planning a long-term strategic spatial plan with the community, not only to allow for a continuous supply of land for various uses, but more importantly for the flourishing of the people and a sustainable environment in Hong Kong.


Citizens Task Force on Land Resources

Ian Brownlee, Town Planner

John Batten, The Central and Western Concern Group

George Cautherley, Pro Commons

Billy Hau, HKU

Albert Lai, Pro Commons

Camille Lam, Town Planner

Lam Chiu Ying, Geography and Resource Management Department, CUHK

Kai Chi Leung, Independent Researcher

Mee Kam Ng, Institute of Future Cities, CUHK,

Merrin Pearse, Sustainability Strategist

Wing Shing Tang, HKBU

Tom Yam, East Lantau Metropolis Concern Group

Paul Zimmerman, Designing Hong Kong

[1] Liber research shows the likely figure for Brownfield suitable for housing in reasonable plots of 2 hectares or more which are in clusters of plots is 723 hectares.


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