Our ref : 51/WKC/ 02417 May 2004Ms Olivia NipDeputy Secretary for Housing, Planning & Lands Housing Planning and Lands Bureau9/F Murray BuildingGarden Road CentralHong KongDear Ms NipConsultation Paper on Building Management and MaintenanceThe above Consultation Paper has been considered by the Chamber, especially our Real Estate Services Committee. We would like to submit our comments on the consultation as follows.The IssueThe problem of building neglect is a long standing and complex one. We recognise the efforts by government departments in encouraging building management and maintenance, such as through assistance provided to Owners' Corporation (OCs), the Coordinated Maintenance of Buildings Scheme (CMBS), the $700 million loan scheme, and various re-development projects. But these efforts are not enough.As pointed out in the consultation paper, there are 11,000 potentially problematic buildings that do not currently have an OC and are not serviced by a management firm. At the current rate, it would take 60 years for CMBS to cover all these buildings, and 18 years for OC's to be formed. This is not acceptable for a world class city like Hong Kong.The OptionsOf the solutions presented in the Consultation Paper, it is clear to us that status quo is not an option. Asia's world city cannot countenance growing urban decay and the associated problems of building safety.Between the two other options – mandatory inspection and Integrated Building Management and Maintenance (IBMM) – the Chamber supports the IBMM as the more sustainable solution.More importantly, the IBMM solution gives due weight to the principle of owners' responsibility. This is crucial for the long term, as ultimately it is the building owners who should be responsible for the proper building upkeep, including the necessary financial commitment.To make the scheme a success, we agree that the IBMM should be supplemented by the range of support measures outlined in the consultation document. However, in view of the large scale of the problem, we believe more innovative measures would also be needed.Innovative MeasuresGiven the various constraints of urban planning, the problem of building neglect could be potentially serious. Hong Kong as a world class city cannot afford to let the problem deteriorate – if it became serious then it might be too late or too costly for remedial action.We believe it is time for government to begin contemplating a more aggressive approach. Government could begin by studying the feasibility of more innovative measures such as the following:(a) Linking the rehabilitation of old buildings to public housing. Thus old buildings can be regenerated by the public sector whilst owners are accommodated in public housing. The value of the old buildings will be enhanced after rehabilitation, thus compensating for the cost of providing public housing.(b) A variation of this measure is to allow elderly property owners to be relocated to public housing, with public assistance, under a transitional period, in return for title of the old buildings.(c) Linking responsibility to property title. Landlords who neglect building maintenance are not only damaging their own property, but creating a social cost to be borne by society at large. For emergency cases, especially those of “invisible” owners, the government can consider paying up the repair work, and then hold the public outgoing against the title of the landlord.The Longer TermThe IBMM deals with buildings which are either visibly deteriorating or potentially problematic. For the longer term, however, all properly managed and relatively sound buildings today may have a potential to gradually deteriorate. A longer term strategy is thus needed to ensure that our city is not blighted by urban decay in the normal course of the recycling of buildings. The IBMM scheme could evolve to become part of a broader building-quality package, to include more general issues such as building design and urban design.I hope you will find the above views useful.Yours sincerelyDr Eden WoonCEO
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