Pitfalls in the land supply discussion
Environment and the society are sacrificed
Hong Kong is facing the problem of unaffordable housing and inadequate public housing supply, causing the general public to suffer from increasingly expensive housing rental prices, a heavy burden of home mortgage repayments, long waiting times for public rental housing, or increasing numbers of people being forced to live in cramped and tiny sub-divided flats.
The consultation document clearly admits the presence of all these problems but simplifies and blames it on the shortage of land supply, creating an illusion that increasing land supply is the ultimate solution. The Government irresponsibly delegated this highly sensitive issue to the Task Force on Land Supply (the Task Force) and encouraged the general public to “discuss”, which has furthered fuelled the divisions and disaffection in our community. Yet, without fixing the loopholes and injustice in the current housing, economy and planning system, the urgent need for public and affordable problems would not be solved; but instead would intensify the unnecessary dilemma between social needs and nature conservation, damaging both the public interest and the natural environment.
As an environmental NGO with a vision of “people and birds together” and “nature forever”, The Hong Kong Bird Watching Society (HKBWS) is particularly concerned with the environmental and ecological sustainability of the proposed land supply options. The strategic planning "Hong Kong 2030+: Towards a Planning Vision and Strategy Transcending 2030" released in 2016 aims to achieve the vision of Hong Kong becoming “a livable, competitive and sustainable Asian’s World City” with a planning goal to “champion sustainable development with a view to meeting our present and future social, environmental and economic needs and aspirations”. We consider the priority in the use of land should follow such principles to protect and respect our environment and for the sustainable development of our city.
However, among the proposed 18 land supply options, there are a handful of choices which would bring irreversible impacts to the natural environment, such as development of Country Parks, reclamation of marine habitats and reservoirs, and development of agricultural land. We are concerned these land supply options will inevitably accelerate the rate of ecological loss and other ecosystem services that provide public benefit to the whole community. This runs directly contrary to the intent of Hong Kong’s own planning laws and Hong Kong’s Biodiversity Strategy and Action Plan, but also the national direction under the Greater Bay Area initiative for a “green and healthy living environment” and the Ecological Protection Red Line system for conservation and the Convention on Biological Diversity at the international scale.
Misleading concepts in the development of Country Parks
In the January 2017 Policy Address the Government had already proposed to develop “a small proportion of land on the periphery of country parks with relatively low ecological and public enjoyment value for purposes other than real estate development, such as public housing and non-profit-making elderly homes”. The current public consultation document echoed with the Government’s proposal and included options to develop two sites at the “periphery” of Country Parks and even additional areas of the Country Parks in the future. Yet, the development of Country Parks completely undermines and challenges the good intentions of the Country Parks Ordinance (Cap. 208) for conservation and public enjoyment.
Moreover, the term “periphery” is misleading as it obscures whether the sites are inside or outside the Country Park boundary. It should be made clear the sites are in fact fully located within the boundary. The Government’s track record in rezoning vegetated Green Belts of “relatively low conservation value” for development, which has led to a loss of well-wooded Green Belts with high or medium ecological value and buffering effect (please refer to our reports of “Hong Kong Headline Indicators for Biodiversity and Conservation”), gives the public no cause for confidence that the Government’s stated intention to develop the Country Parks would be limited to areas with “relatively low” ecological and public enjoyment value. Development of the Country Parks should be adopted as the solution of last resort only when all other options can be shown to have been exhausted, a public consensus is reached, and under rigorous application of all relevant legislation and international best practice.
Pitfalls in the use of agricultural lands and public-private partnership
Agricultural lands not only bring income to farmers by selling their produce and secure food source and safety for Hong Kong consumers, they can also have ecological, landscape and cultural values within a city. Take Long Valley as an example. The HKBWS and The Conservancy Association has been carrying out a management agreement project there, which includes growing rice and wetland management. This has provided shelter, roosting, breeding and foraging habitats for a wide range of wildlife and enhanced the biodiversity in the area, even the globally critically endangered Yellow-breasted Bunting now regularly appears in Long Valley during the migration period. Besides, agricultural lands can act as buffer zones between urban, rural area, streams, woodlands and conservation areas, wildlife corridors allowing movements of wildlife between the fragmented habitats or between separated conservation areas/Country Parks, so as to enhance the integrity of the ecosystem within this highly urbanized city. In addition, fishponds are regarded as a type of agricultural land, where those in the Deep Bay area are of high conservation value. Together with the adjacent wetland habitats, they are important foraging, roosting and breeding habitats for birds and form part of the ecosystem of the Mai Po Inner Deep Bay Ramsar site of international importance.
However, agricultural land is not well-protected and has been under imminent development threat, leading to an ongoing incremental loss of arable agricultural land (please refer to our reports of “Hong Kong Headline Indicators for Biodiversity and Conservation”). In the past five years, the average approval rate of planning applications in AGR zone over 60%. Under the fear of land shortage in recent years, agricultural land is regarded as of high development and investment potential with paved agricultural land selling at a price five times higher than arable farmland. This creates a perverse incentive for more dumping, fly-tipping activities and site formation to facilitate development in the hope of securing this higher value.
One of the land supply options is to use the mechanism of public-private partnership (PPP) to “unlock the potential of large-scale private agricultural land”. However, little did the consultation document mentioned about the activities and business on agricultural land, or the current situation of hoarding of farmland. The economic, social and ecological value of agriculture lands and their functions in a city were not even mentioned. Instead, it focused on how to use the PPP mechanism for the development of agricultural land. Such presentation approach not only hinders the public’s basic understanding of agricultural land and its value, but also further commercialize agricultural land. As stated in the consultation document, PPP is still required to go through the existing statutory procedure to gain approval from Town Planning Board for rezoning the agricultural lots to development zonings and some may need to increase the development intensity as well. We are concerned PPP would rationalize the developers’ development proposal on farmland and fishponds, leading to more destruction and development of the farmlands and fishponds. As in the case of GB rezoning proposed by the Government, even though environmental NGOs have strongly opposed to several sites due to their ecological/conservation value and the inconsistency with the Government’s GB review criteria, the Town Planning Board would still consider “to meet the acute housing demand” and approved the rezoning sites. We are concerned that similar situation would occur for rezoning agricultural land to facilitate PPP.
Brownfield first and loopholes plugged
As in both the discussion paper for the Task Force prepared by the Development Bureau and the consultation document, it is frequently mentioned that the brownfields in Hong Kong are different from the ones in other countries, as they are not idle and have business operations which contributes to the society. As such, it is said that the process would be lengthy and challenging. From our perspective, brownfields in Hong Kong is caused by inappropriate use of land and inadequate land/planning enforcement. The Government should have the responsibility to fix these inappropriate and inefficient use of land. If there are industries which are beneficial to the society (e.g. recycling), the Government should consider relocate them in proper locations with facilities to avoid environmental degradation and subsidies to assist the business to survive. At the same time, loopholes in the planning and land system should be plugged to avoid further encroachment of brownfields to other areas of conservation concern.
Hong Kong is indeed a unique city in China and as well as in the world, with such a high population density but yet also with a large number of country parks that are easily accessible from every part of the city. This is increasingly valued by a community living in confined spaces and concerned about declining quality of life and opportunity. The HKBWS considers that the current land supply public consultation cannot address the current severe housing problem in Hong Kong, but instead has encouraged more conflicts between different levels of the society and unnecessary dilemma between social needs and nature conservation. We consider the Government needs to recognize and secure housing as a basic necessity of Hong Kong people, rather than an investment asset. Determination to change the current system, legislation and practice is also needed, such that development of the city would not be in the expense of the environment and social needs and the harmony in the society can be restored. In this way, there is hope that our vision of becoming a livable, competitive and sustainable Asia’s World City could be reached.
 Page 20 of the consultation document for the "Hong Kong 2030+: Towards a Planning Vision and Strategy Transcending 2030"
 HKSAR Government. (2017, January 18). Paragraph 117 of 2017 Policy Address. Retrieved from https://www.policyaddress.gov.hk/jan2017/eng/p116.html
 HKSAR Government. (2017, June 28). LCQ21: Study on two sites on the periphery of country parks [Press Release]. Retrieved from http://www.info.gov.hk/gia/general/201706/28/P2017062800421.htm
 Hong Kong Headline Indicators for Biodiversity and Conservation 2011 - 2017 reports. Retrieved from https://www.hkbws.org.hk/cms/index.php/reports
 From 2012 to 2016, the average (i) number of planning application received in GB and AGR, (ii) number of planning application approved in GB and AGR, and (iii) approval rate in GB and AGR are: (i) 100 and 225, (ii) 48 and 138, (iii) 48% and 61%. All numbers are calculated from the data collected from TPB Portal 2.
 The price of agricultural land can range from HK$250 per square foot for high quality arable farmland to HK$1,309 per square foot for formed and paved farmland ready for development. Data retrieved from www.28hse.com
 Town Planning Board meeting held on 21 June 2018 for the rezoning of GB sites in Tseung Kwan O. Retrieved from https://www.info.gov.hk/tpb/en/meetings/TPB/Minutes/m1171tpb_e1.pdf
------------------------------------------------------------- You are encouraged to participate in the following petitions and online survey for Land Supply :
【Online Survey: Land for Hong Kong: Our Home, Our Say! 】* https://landforhongkong.hk/en/#
* Please do not choose the options that will lead to irreversible impacts to the environment and society. When checking the boxes for the online land supply survey, it is not necessary to meet the suggested total land demand of 1200 hectares. Apart from the comments on the various land supply options, you are welcomed to submit ideas on how to solve the problem of "pricy, tiny and cramped" living environment.
【Sign Now: Protect Our Country Park, Farmland and Ocean】 https://landsupply.weebly.com/
【Sign Now: Save Our Country Park】 https://act.gp/2lTXPiQ