Objection to Developing Country Parks and the Adjustment Mechanism

Make Use of Brownfield Sites, Military Camps and Spare Land

The Chief Executive Mr. CY Leung told the media that he has instructed relevant departments to conduct a study on developing country parks. Green Groups are furious and strongly opposed to this, as the public has already voiced opposition to the development of country parks.  However, the government still insists on doing so and, furthermore, devotes more resources to this, deliberately leading to conflict within our community.

In fact, there is still a lot of land available for development in Hong Kong. The housing shortage problem has originated from “Uneven Distribution”. Over the years, the government has avoided reviewing the “Small House Policy” (land designated for New Territories Exempted Houses), unused Military Camps and Brownfield sites. These are the main reasons for the present situation.   Moreover, the government has failed to address the problem of vacant housing units and private flats used for investment and speculation purposes, falsely presenting the situation as a “lack of land”. As there are other land resource options, it is totally unacceptable for the government to use the welfare of the elderly as an excuse for developing country parks.

Country Parks are important features and treasures in Hong Kong. Apart from the environmental value of preserving our precious ecology, they are also well-known for eco-tourism, community enjoyment (for public recreation) and even have a role to play in urban planning (for preventing over-expansion of the urban areas). Country parks are also important water catchment areas, which allow rainwater to flow into surrounding reservoirs. Furthermore, trees in country parks can absorb carbon dioxide and offset some of the greenhouse gas emissions from burning fossil fuels, which relieves global warming.

Mr. CY Leung pointed out that low ecological parts of country parks can be developed. We totally disagree with his claims. All the plants, flowers and birds in the country parks have their own meaning and value to the natural environment. Ecological value cannot be measured in objective criteria. He further suggested the “Adjustment Mechanism” in Country Parks, which we consider to be “weasel words” designed to mislead the public about conservation. The geographical location, the terrain, environment and the ecology of each existing country park are unique and should not be replaced by any excuses. The exchange of another “new” country park area is totally a mistake.

Mr. CY Leung hasn’t made good use of brownfield sites, military campsites or spare land before advocating the development of country park borders. Hong Kong’s housing problem could also be solved not just by finding land but also by controlling housing demand through a population policy. Once the natural environment is destroyed, it cannot be restored to what it was before. Therefore, the government should not develop our country parks, which are the pride of Hong Kong people.

Co-sign Parties (Alphabetical Order)

Ark Eden

Association for Geoconservation, Hong Kong

Clean The Air

Designing Hong Kong

Environmental Life Science Society, SS, HKUSU

Friends of the Earth (HK)

Friends of Hoi Ha

Friends of Tai Long Wan

Greeners Action

Green Community

Green Lantau Association

Green Peace East Asia

Green Power

Green Sense

HKWildlife.net

Hong Kong Bird Watching Society

Living Islands Movement

Range Education Centre

The Conservancy Association

The Green Earth

Society of Hong Kong Nature Explorers Kong Nature Explorers

Tai Po Green Belt illegal use for open storage and construction waste storage

Located next to The Education University of Hong Kong, area up to 9 of football field

The Satellite imagery shows the illegal storage covers areas are expanded, including lands owned by Wheelock Properties

Planning Department has been ineffective in its law enforcement regarding to years of complaints by the University and the residents nearby

Since the illegal land filling nearby at Tai Shui Wai, Kingswood Villas has been reported, the public were concerns about the fly-tipping and unauthorized developments. Green Sense have investigated an area in 9 hectares in Tai Po Located next to The Education University of Hong Kong. We found the illegal use of the land but the Planning Department has been ineffective in its law enforcement,   from the Land search and look over the Satellite imagery for past 10 years.

According to the Tai Po outline Zoning Plan, the land should be zoned as Green Belt. The vegetation cover was stripped and trees were removed since 2000. The green area have strunk and turned to open storage for construction waste, large machines, temporary containers etc. Now the violation of land use is up to 9 football fields (see below).

The Education University of Hong Kong and the residents nearby have complained many times. It is impossible that the Planning Department and Lands Department shut their eyes to this situation. However, the government has not enforced the law which allowed landowners to cut down the woodland and leave the land contaminated.

According to the Land registry, the Land is owned by many owners. Among them, Wheelock Properties owns most of the lots. We are concerned that the land was destroyed deliberately in order to turn it to “Brown Field” systematically. It is obvious a case of “destroy first, develop later”. The Government should not condone this.

Meanwhile, a piece of land at Tai Po Lo Fai Road with thousands of trees will be planned by the government to build luxurious residential units and it is already for the land sale. The proposed alteration of land use is still under judicial review.

The Chief Executive (voluntary) of Green Sense, Roy Tam said “ The Government’s land management in the New Territories is totally reckless, they allow landowners and properties developers to destroy the natural environment wantonly. On the other hand, the government alters the land use from Green Belt to build the luxurious residential house.”

We solemnly urge the Lands Department to clarify whether the 9 hectares of land is government land. We also requested to the Lands Department and the Planning Department to enforce the Town Planning Ordinance and the land lease conditions in order to request those landowners to restore the Green Belt as soon as possible.

Postscript: The follow up

After holding a press conference by Green Sense, the Planning Department replied the land is not covered by Development Permission Area Plans. Therefore, they cannot carry out prosecution.

Green Sense believes this is only an excuse. There was so much evidence proving the violation of land use stated in the outline zoning plan. If no department can carry out any enforcement in this situation, the legislation should be amended as soon as possible. The Planning Department should state clearly what action should be taken after the violation of the outline zoning plan. We cannot accept the department to turn a blind eye.

Note:

Development Permission Area Plans (DPA) – areas not covered by Outline Zoning Plan or the country park enclaves; the Planning Department can have control to unauthorized development in these areas. DPA will be replaced by Outline Zoning Plan later.

Outline Zoning Plan (OZP) – the violation of land use mentioned above is covered by Tai Po Outline Zoning Plan and listed as Green Belt.

Only 7 Sites “Genuine Housing Supply”

Even Less if Marketed as Luxurious Developments

22 Sites “Bogus Housing Supply”

Low Density Development or above HK$9000 per sq. ft.

60:40 Public Private Split of Housing Supply Non-scientific

Should Consider the Housing Policy of Singapore

“Bogus Housing Supply”? The Secretary for Development, Mr. Paul Chan, announced the new Land Sale Programme at the end of February, comprising 29 residential sites allegedly capable of providing about 16,000 flats. However, the devil is always in the details. How many of them are affordable flats?

Green Sense has analysed all sites in the latest Land Sale Programme and compared them with the recent and neighbouring second-hand property transactions. In our analysis, “Genuine Housing Supply” (i.e. affordable by the general public) and “Bogus Housing Supply” (i.e. Hard to afford or luxurious property) are differentiated by the following criteria: 1) whether the purchase price of a flat is HK$9,000 or above per square feet (saleable area); and 2) whether it is a low density development. Based on the analysis, we have estimated the purchase price of the flats of these 29 residential sites.

The research result reveals that only 7 out of 29 sites may have the purchase price of flats below HK$9,000 per square feet (saleable area). The price, at the end of the day, depends on whether or not the developers decide to package these sites as luxurious developments. The remaining 22 sites are mainly either of low density developments or likely to have flats priced at more than HK$9,000 per square feet (saleable area), which are unlikely to be affordable by the general public. We are of the opinion that these 22 sites are “Bogus Housing Supply”.

On one hand, the Government always alleges there is lack of land. On the other hand, it wastes so much land for developments which are unaffordable for the general public. The governmental policy for the public-private ratio of housing supply as 60:40 is not scientific. In fact, the Land Sale Programme is the main source for supply of housing for the general public. The Government should consider designating some of the sites in the Land Sale Programme for the Home Ownership Scheme, after taken into account the surrounding facilities and transportation. We suggest designating part of the site of Hong Kong Science & Technology Parks (Pak Shek Kok) as development under the Home Ownership Scheme, turning “Bogus Housing Supply” into “Genuine Housing Supply”.

There has been serious tension among the Government and the community and green groups because of the rezoning of Green Belt sites and Open Space. The Government should be focus on genuine housing supply but not casually dismiss or criticise the views of the local communities and the green groups. If there is no genuine housing supply after the rezoning, the sacrifice (including the ecology, the environment and the local culture) will be made for nothing. We sincerely hope that the Government will plan for affordable genuine housing supply, but not simply blames the members of the local communities or the green groups for its housing policy failure.

Develop properly but not blindly
Development in East Lantau should be reduced to preserve the precious peace of Mui Wo and Peng Chau
The issue is not lack of land supply, but flats are affordable
Green Marks for Policy Address: 20 marks (Fail)

There are a crazy number of land exploitation methods in dramatic scale proposed in the Policy Address 2014. Even if there is significant demand for housing in Hong Kong, we believe the need of increase of land reserve should at the same time be balanced with adequate recreational spaces, community facilities, breezeways of the city and the conservation of eco-environment.

Roy Tam, Chief Executive of Green Sense remarks, “The government is trying more and more fiercely to obtain land but with “blind” eyes. Mr. C.Y. Leung is determined to turn Hong Kong into a huge construction site, contrary to his another goal of air quality improvement.” Such Policy Address is to declare war against the environment and the ecological system. We give it 20 marks as regards to its environmental aspect. In other words, it clearly fails.

Mr. C.Y. Leung proposes that, except for the north of Hong Kong Island and Kowloon Peninsula, which are more densely populated, the maximum domestic plot ratio for all other areas should increase by 20%, which was worrying. There is high density of multi-stories buildings in Hong Kong. There is already too deep and too common an impression of “Concrete Forest” for Hong Kong. Many newly developed areas are designed to have lower density than the Kowloon Pennisula in order to provide a better quality of life and living environment. The proposal contradicts the current town planning principles and is sloppy.

Sai Kung and Lantau Island are gardens of Hong Kong people. Unfortunately, North Lantau has fallen in recent years (as construction of massive infrastructure in progress). Now, the Eastern of it may be developed to “Eastern Lantau Metropolis”. Such policy suggestion is not cost-effective and non-environmentally friendly. If it is to build an artificial island, it will surely cost thousands of billions. Mui Wo and Peng Chau are also famous holiday attractions for Hong Kong people and are quiet places to live in. Therefore, we in principle oppose reclamation and development of the “Eastern Lantau Metropolis” in the eastern waters off Lantau Island and neighbouring areas.

The issue of housing is not the lack of land supply and therefore the resolution is not the increase of the same. The major problem is that flats constructed are simply unaffordable. Such problem cannot be solved by increase of land supply to the developers, as they would hoard the new supply or to develop luxurious flats, as it is what they usually do with the current pieces of land. The price of flats will still be very expensive anyway.

It is regrettable that there is no mention of the capacity of Hong Kong in the Policy Address. If we are to tackle housing problems, not only should we look at the supply of land, but also the population growth.

$18b for 5 newly developed estates  35% flats bought by Mainland purchasers
Implement restrictions for non-locals  Ensure flats for locals
Estate Agents: road shows in Mainland to attract buyers
Distorted supply of flats
Oppose supply increase by reclamation

New flat salespeople outside Hung Hom Station

It seems that land in Hong Kong is scarce, and we have insufficient land for housing. Some people say that we need reclamation and cavern development. Unfortunately, a large number of our scarce flat units are bought by purchasers from the Mainland, just like how our hospital services are demanded by them. Developers keep constructing large flats and developing luxurious projects. Purchasers from the Mainland keep buying large luxurious flats. As a result, there is no hope in lowering the price of flats. There is no hope to have a home in Hong Kong for locals. Donald Tsang, Henry Tang and CY Leung, how do you respond to this “deep rooted problem”?

There were various estimations about the ratio of flat-purchasers from the Mainland without empirical studies. In order to give a clearer picture for the public, we, Green Sense, has conducted a research in mass scale (the study). We have investigated 5 major development projects, which have been put on sale this year. There are 4116 units in total. They are Festival City (Cheung Kong (Holdings) Limited)、Inland Crest (Kerry Properties Limited)、Imperial Cullinan (Sun Hung Kai Properties Limited)、The Hermitage (Sino Group) and Uptown (Cheung Kong (Holdings) Limited). We have identified the categories of purchasers and calculated the relevant ratio and contracted price. We concluded that purchasers from the Mainland have already crept deeply and firmly into the first hand private housing market of Hong Kong.

According to the study, 20% to 30% of the concluded sale involves purchasers from the Mainland (sole purchaser or joint purchaser with Hongkongers) (Table 1). The majority of purchasers are Hongkongers, and there is a certain percentage of company purchasers. The nationality of some purchasers cannot be identified. Excluding the categories of company purchasers, foreign purchasers and joint purchasers, the percentage between purchasers from the Mainland and local purchasers is 37.5% and 62.5% respectively (Table 2).

The ratio between purchasers from the Mainland and local purchasers calculated above is adopted in analysing the relative ratio of the company purchasers. Since the majority of sale under the name of a company is in fact concluded by individuals, the ratio above would indicate the amount of purchasers from the Mainland under the name of a company (Table 3). Lastly, the money invested by purchasers from the Mainland is ranged from 21.6% to 51.1% for the 5 new major development projects (Table 4). The difference among the 5 projects may be a result of different marketing strategies.

We have also investigated the money invested by purchasers from the Mainland in the 5 projects. An impressively 18 billion was invested by them. It shows that huge amount of hot money from the Mainland has been flown into Hong Kong and has gradually conquered local residential housing market (Table 4). Comparing the purchasing power of purchasers from the Mainland and local purchasers, it is evidenced that the purchasing power of Mainlanders is higher than the locals in all 5 projects (Table 5).

In addition, we have arranged “undercover” as potential buyers to the newly open Festival City Phase III and recorded conversation with several estate agents. It is proved that developers now adopted the marketing strategies targeting Mainlanders instead of the locals. Strategies include road shows in China and arranging shuttle bus travelling between the Mainland and show flats in Hong Kong. The following is part of the conversation:

“…which means Hongkongers 60%, Mainlanders 40%…”
“Yesterday, there were so many potential buyers from the Mainland. They have two-way exit permits in order to come here and queue for Hong Kong flats.”
“Many purchasers from the Mainland purchase flats here. Not necessary for home. Maybe for rental. Only one or two for personal residence.”
“There are many Mainlanders near East Rail Line. It takes only half an hour to travel to Shenzhen or Lok Ma Chau.”

According to statements from the estate agents, Mainlanders are clear marketing targets of developers. It may be because the purchasing power of Mainlanders is stronger than that of the locals. Green Sense has long criticized that, many residential buildings are now designed to luxurious 3-room large units, in order to cater the taste of Mainlanders. Many of the locals are prevented from a purchase because of the high price. Moreover, the names of the projects are deliberately designed to give an impression of superiority and magnificence, even though they are regarded as garish, hardly comfortably accepted by many Hongkongers.

Roy Tam, President of Green Sense, said, “How can Hong Kong possibly satisfy all the hot money from the Mainland, as Hong Kong having so little land? Locals are now hard to purchase a flat at a reasonable price in first hand housing market. And it is the reason why there are so many complaints from the public.” In Singapore, there is additional 10% stamp duty for non-locals flat purchasers, and as a result restricting the flow of hot money from coming. The Hong Kong government should take action now to tackle the problem of our residential housing market being conquered by purchasers from the Mainland.

We have the following suggestions:

1. As a major shareholder of MTR, the government should direct the supply of the properties above railways. Many of the property supply of the coming few years locate along the railway. It is appropriate for the government to have granted a land lot in Tsuen Wan West with flats with limited floor areas (i.e. the minimum number of flats as well as the smallest and largest floor areas of flats being specified in the conditions of sale). Such policy should be further implemented in the land lot in Tai Wai Station and the remaining phases of LOHAS Park. The said two developments can in total provide 20,000 flats with limited floor areas. These flats can better cater the needs of locals who seek to buy a home in Hong Kong.
2. Increase the proportion of the provision of flats with limited floor areas in the 2012 List of Sites for Sale by Application.
3. Available flats should first be ensured for locals. Non-local buyers should pay extra 10% stamp duty.
4. Since it is more difficult to know the identity of buyer under a company name and it is possible for non-locals to avoid the extra stamp duty as a result, company buyers should also pay extra 10% stamp duty.

We, Green Sense, sincerely hope Donald Tsang, CY Leung and Henry Tang to seriously address this “deep-rooted problem” of Hong Kong, and grant Hongkongers an opportunity of buying and having a comfortable home.

Research Data

Table 1  Categories of purchasers of new & major development

Table 2 The ratio of Mainland purchasers and Hong Kong purchasers

Table 3 Percentage of Mainland purchasers
(The calculated ratio above will be used to estimate the number of mainland purchasers in the form of company buyers)

Note: There may be other circumstances which cannot be reflected upon the above calculation, for example, company dormitory and foreigners.

Table 4 Money invested

Table 5 Purchasing power of Hongkonger vs Purchase power of Mainlander

Note: These are not company purchasers.

We, Green Sense, have endeavored to ensure accuracy. However, we do not guarantee there are no mistakes in the above data. The risk of mistakes should be one of your considerations before citing the above research.