Historic CLP Building
3 New Walled Buildings Destroy Its Beauty

CLP Power Hong Kong Administration Building (Head Office Building)(CLP Building) is a proposed Grade 1 Historic Building. The coming construction of 3 walled buildings will destroy its beauty.
Grade 1 Ho Tung Gardens however enjoy full conservation. There is Unclear conservation policy in HK.
Inadequate and deceiving picture under “Artists’ Impression” given by CLP
Green Sense urges TPB: require developers to release full application documents online, not only a summary

Haw Par Mansion, a Grade 1 Historic Building in Wan Chai, has merged with a walled building – The Legend, having a 9-storey carpark. Even calculating only the carpark, its height is already enough to exceed the height of the historic building. Also in Wan Chai, there is a Grade 3 Historic Building – Wan Chai Market. Two years ago, what was once declared “core elements preservation” by Urban Renewal Authority is now a luxurious residential development project by Chinese Estates Group.A 40-storeys building was constructed right above the market. It’s now time to think, whether the so-called “balance between conservation and development” in fact path the way for elimination of our scarce historic buildings?

The construction of CLP Building in Kowloon Argyle Street was finished in 1940s. It is over 70 years old and was proposed to be a Grade 1 Historic Building by Antiquities and Monuments Office. We, Green Sense, think that CLP Building should enjoy full conservation, especially as the clock tower in Star Ferry Pier, Central, constructed in a similar style, has already been demolished. The whole CLP Building should now be better preserved.

You can see there are many trees surrounding the CLP Building. The Building is over 70 years old.

CLP proposed to construct three 20-storey walled buildings and 5-storey carpark above the CLP Buildings. CLP claimed that it demonstrates a balance between conservation and development. Mrs. Carrie Lam, Secretary for Development later publicly supported the project. We, Green Sense, are really disappointed – there is nowhere you can find walled buildings above historic buildings except in Hong Kong. Haw Par Mansion and Wan Chai Market are examples how walled buildings destroy the spirit of a historic building.

On Friday (4 DEC 2011), Town Planning Board (TPB) will discuss the application from CLP. We are really disturbed by the possible weird combination of walled buildings and historic building. The clock tower in CLP Building (constructed earlier than the one in Star Ferry Pier) may become one of the components of a carpark. Roy Tam, President of Green Sense, said, “nowadays, striking a balance between conservation and development become an acceptable justification. In fact, it is nothing but an excuse to damage historic buildings.”

Apart from conservation reasons, we also raise objections for its lack of spacing between blocks and its excessive provision of parking spaces, which makes the carpark podium too large.

Also, we have found that the picture under artists’ impression released by CLP to the media a month ago was deceiving because of its photo-taking angle. And it is the one put on the TPB website. The public can hardly receive adequate and comprehensive information. The whole application document should be put online, instead of few chosen pages of summary. Currently, the public can only find the full documents in the secretariats of TPB in Shatin and North Point, and not the official website. It is inconvenient for environmental groups, the public and reporters. We sincerely hope TPB require full application documents to be put on web.

Deceiving Pictures from CLP

This is the picture from application summary in the TPB website, intended to give a false impression that CLP Building could be conserved harmoniously with 3 new buildings.

Picture provided by CLP

We have searched the full application document (which is kept in Shatin and North Point only), and found a very different picture. The following picture shows that the 3 new high-rise buildings are enormous and the clock tower is too small to be located at the first sight.

The proposed buildings are enormous and the clock tower is hard to be seen.

If there is no requirement from the TPB that full documents have to be released online, developers may simply produce pictures that are favourable to them.
Moreover, the consultancy team of Green Sense has vigorously studied the provided picture, which is under artists’ impression, and concluded that the depicted buildings may be smaller than the actual size of the proposed buildings. According to the CLP application, the proposed 3 buildings with a carpark podium should have reached 100m above Principle Datum (PD). We actually went there to observe and compare the CLP Building and the surrounding buildings, which are 100m PD. And we also concluded that the depicted buildings in the released picture under artists’ impression could well be too small. Based on the concerned picture, we have drawn a more realistic picture (in right). We now put the two pictures together for comparison and for your judgement.

(Left) Picture from CLP for TPB (Right) the one, we think, more adequately described the actual size of the proposed buildings.


About Redevelopment Project in Argyle Street by CLP
Objections – Town Planning Reason and Design of the Building

The application from CLP concerning the CLP Building in Argyle Street proposed to have part of its building re-developed as three 25-storey residential buildings (including 5-storey podium). We, Green Sense, object to the proposal and now provide the following 4 reasons relating to the town planning issues.

(1)    Three Walled Buildings
The 3 proposed buildings abut each other and there is no spacing between blocks. The 3 buildings are walled buildings with the width exceeding 70m. Adverse effect upon visual beauty, natural lighting and ventilation is to be expected. The new practice note concerning inflated buildings, taking effect on 1 APR 2011, is intended to avoided walled buildings and to ensure there are sufficient spacing between blocks. To our astonishment, the clock tower, because of no further construction, is considered to be a breezeway of this project. Development Bureau should not allow the exploitation of the loopholes of the regulations by CLP and definitely should not approve the project.

(2)     Near Mong Kok East Station   Excessive Car Parking Space
The concerned site is close to Mong Kok East MTR Station. In fact, it takes less than 10mins to walk to the station. However, there are 137 parking spaces provided. (The amount of flats provided are 175.) The government has years ago reviewed the problematic and outdated planning policy concerning the provision of parking spaces in private residential buildings. However, there is yet any new instruction.

(3)    No Modification Concerning the 80m Height Restriction Should be Allowed
The current height restriction of the area is 80m because the neighbouring buildings are of this similar height. There are lower buildings in the North of the concerned site. The applied modification to have 20m more is simply too much. The approval of such will become a very bad precedent, since only less than 10m would be granted previously. Moreover, the 5-storey podium is the main reason why the buildings are so tall. We will now explain why the carpark in the podium should not be granted concession from the calculation of plot ratio.

(4)    Alternative Regulations in relation to Non-accountable Gross Floor Area  Prefer the Stricter One
The podium under the proposed development has five storeys. Among them four are indoor podium and are mainly carparks. One floor is an open area for occupants. The site is between the lower Argyle Street (about 13m PD) and the higher Kadoorie Avenue (about 28mPD). For this kind of site, when calculating the concession of the plot ratio for carparks, there are two clauses applicable under the Practice Note of Buildings Department (APP-2 Practice Note for Authorized Persons, Registered Structural Engineers and Registered Geotechnical Engineers – Calculation of Gross Floor Area and Non-accountable Gross Floor Area Building (Planning) Regulation 23(3)(a) and (b)). One is the stricter APP-2 clause 15(b)(vii)(2). Another is the lenient APP-2 clause 15(b)(vii)(4).

We, Green Sense, prefers the stricter APP-2 clause 15(b)(vii)(2) to be applied in the concerned site, instead of allowing CLP to have its 4-storey carparks all disregarded and exempted from calculation. (All sites have to comply with the restriction of a designated maximum plot ratio in order to have its plans approved.) According to the clause, ground level is either the mean level of the streets abutting the site or 5m above the lower Argyle Street. Because the lower one prevails, the ground level should be 18mPD, and what is below 18mPD will be underground carpark, and can be exempted from calculation. But what is above 18mPD should not be considered as underground carpark and should have only 50% exemption. The remaining 50% area of the carpark should be included in the calculation of gross floor area and the development, as a whole, should not exceed the designated plot ratio. The relevant clauses are the following:

APP-2 clause 15(b)(vii)(2):

(vii) A carpark may be accepted as an underground carpark in the following circumstances: …
(2) If the site abuts more than one street, a carpark maybe accepted as an underground carpark if the structural ceiling soffit of the carpark is at or below the level obtained by dividing the sum of the mean levels of the respective portion of the streets on which the site abuts by the number of such streets on which the site abuts and subject to the level so obtained is not more than 5m above the mean level of that portion of the lowest street on which the site abuts;

Unfortunately, CLP may be granted application under APP-2 clause 15(b)(vii)(4), and have the carpark area all exempted from calculation of gross floor area (Secretary for Development Mrs. Lam publicly supported the project.)

APP-2 clause 15(b)(vii)(4):

15(b) For private carparking spaces which are intended for the use of the occupants and their bona fide visitors of the parent building, the BA may disregard them from GFA calculation under Regulation 23(3)(b) of the B(P)R subject to the following criteria :-
(iii) In order to help reduce building bulk, 100% GFA concession may be granted for underground car parks while only 50% GFA concession may be granted for aboveground car parks.
(vii) A carpark may be accepted as an underground carpark in the following circumstances:
(4) When there are site constraints that affect the design and location of the carparking floors e.g. there is significant difference in the levels of the street(s) on which the site abuts; there is an existing large platform that governs the carparking design; the carpark is semi-sunken and follows the slope profile of the site and adjoining land, etc., the BA may consider the special circumstances of the case in accepting a carpark as an underground carpark.

As evidenced above, the two clauses are conflicting as one stricter and one more lenient. We suggest the stricter one should be adopted in order to prevent excessively enormous carpark from being constructed.

For the above 4 town planning reasons, we, Green Sense, oppose the re-development project of the CLP Building.