Policy Statement & Submission


Working Towards a More Efficient Town Planning Process

11 December 2017

Mr Raymond Lee, JP
Director of Planning
Planning Department
17/F, North Point Government Offices
333 Java Road
North Point, Hong Kong

Dear Raymond,

Working Towards an Efficient Town Planning Process for a Better Hong Kong

Thank you for meeting with members of the Chamber’s Real Estate and Infrastructure Committee recently, who are equally keen to see continued improvements in the city we live in. On top of our discussion, the Committee would like to put forth some constructive suggestions.

Town Planning Board’s Deliberations and Role

1. Despite the best of intentions, there are still serious bottlenecks in the Town Planning Board’s (“TPB”) deliberations, leading to unintended consequences and reduced efficiency. This is exemplified by the spate of judicial review applications in recent years against the TPB’s decisions ostensibly due to procedural issues or meeting culture. To enhance the Board’s effectiveness and ensure that efforts and time are well spent, how could meetings be conducted more efficiently, and how would appropriate training or briefing of Board members be enhanced?

2. Another observation is the increasing number of regulations and practice notes set up by the TPB to protect against misbehavior, which has had the unfortunate effect of penalizing stakeholders with broader implications to the economic well-being of Hong Kong. In view of the existing ecosystem, is it possible to move a TPB which is able to allow ‘ring-fenced’ creativity, rather than ‘door-closing’ practice notes? Would there be benefits to ease the TPB from a regulator-centric to a facilitator-centric approach?

Development Business Issues

3. One-stop shop: With the dual aim of increasing efficiency and maximizing net benefit to the Government, would it be possible to have one unified authority that provides an integrated approach to streamline work process approvals and align differences among different departments? The concept is not dissimilar to existing and previously successful references such as the Development Opportunities Office, Energizing Kowloon East Office and Public Works Department. It may also be useful to draw on the experiences and approaches in other jurisdictions such as the UK, US and Australia where the practice of one-stop-shop has been adopted. In the Appendix we have outlined our proposals to enhance the building plans approval process.

4. Unified standards: A harmonized set of standards and requirements for all applicants, regardless of public or private sector, should maximize equity and efficiency, and minimize costs.

As with other leading metropolises, Hong Kong is faced with the ongoing challenge of meeting demands associated with a highly urbanized society while striving to remain competitive. We have made considerable progress but there are lingering issues. All stakeholders in Hong Kong not excluding the private sector or the Government are interested to collaborate and seek more effective solutions that will lead to a more livable Hong Kong that is globally competitive in multiple facets.

Yours sincerely,

Douglas Woo, JP
Real Estate & Infrastructure Committee
Hong Kong General Chamber of Commerce


Proposals to Enhance the Building Plans Approval Process:

1. Align key development parameters with respect to such aspects as gross floor area, site coverage, building height, and sustainable building design across the Planning Department (“PD”), Lands Department (“LD”) and Buildings Department (“BD”) when vetting building plans (please refer to the table below for detailed suggestions).

2. Require the LD to provide feedback on decisions for building plans in respect of lease conditions without having applicants obtain prior approval from the BD.

3. Simplify and combine the two-stage design, disposition and height approval process conducted by the Building Plan Unit (“BPU”) and District Lands Office of the LD.

4. Increase manpower at the BPU and BD to help expedite the process of approving building plans.

5. Maintain regular dialogue between stakeholders and key government departments (such as the PD, LD and BD) to collectively identify technical issues, narrow differences and resolve problems.

Key development parameters Proposals
a. Gross floor area

- Use the definition of gross floor area (“GFA”) as specified in Building (Planning) Regulation (“B(P)R”) 23(3) and 23A and in accordance with the BD’s practice of measuring GFA in buildings. It is noted that the PD has generally followed the BD’s practice (see Joint Practice Note No. 4) while the LD has a different interpretation of some key development control parameters.

- Exempt the inclusion of “pedestrian links” and certain uses such as GIC functions in measuring GFA as currently required in the B(P)R. We note that exemptions are already being practised in the case of lease conditions for some buildings, especially those involving modern leases.

b. Site coverage - Apply the BD’s practice to define and measure site coverage.
c. Building height - Apply the definition as specified in B(P)R 23(1) and in accordance with the BD’s practice of measuring building height.
d. Sustainable building design

- Apply the compliance standard as specified in the BD’s Practice Notes for Authorized Persons APP-152 (“PNAP APP-152”) in fulfilling the requirement on building separation.

- Align the definition and calculation of greenery areas by referring those set out under PNAP APP-152.

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