Policy Statement & Submission

4 July 2025

Ms Bernadette Linn, JP
Secretary for Development
Development Bureau
18/F, West Wing, Central Government Offices
2 Tim Mei Avenue, Tamar
Hong Kong

Dear Bernadette,

Re: Preliminary Development Proposal of Sites around Hung Hom Station
and Waterfront Areas

The Hong Kong General Chamber of Commerce welcomes the opportunity to provide its views on the Development Bureau’s re-planning of sites around Hung Hom Station and its waterfront areas (“the Zone”)[1] . We support the Government’s overall vision for the new zone, with a focus on enhancing commuting and connectivity, and transforming the Hung Hom and Victoria Harbour landscape into a new harbourfront landmark – such developments will benefit local businesses and residents, as well as enhance Hong Kong’s status as a world-class international city. 
 

At the same time, we would like to put forward the following views and recommendations from our members concerning the Zone’s land usage and design, for your Bureau’s consideration:

1.    Overall Land Planning Strategy

1.1. Holistic Development Approach: In general, we suggest that the Government could leverage on the Zone’s prime location – including proximity to the Tsim Sha Tsui terminals - and consider expanding development coverage to the Kai Tak Cruise Terminal, to establish Hong Kong as Asia’s marine and cruise tourism, as well as recreational and major events hub. This initiative would also appeal to a diverse range of visitors, including high-spending individuals, by providing seamless connectivity, exclusive experiences, and carefully curated retail and entertainment options.
 

1.2. Enhancing the Residential Catchment: To ensure the long-term success of the Zone, it is essential to maintain a balanced flow of tourist and local activity. The primary focus of the project should be on establishing a robust local community that provides consistent year-round patronage and spending. By fostering a community-oriented environment, the overall visitor experience could be enhanced. For this reason, we recommend expanding the residential footprint to include adjacent zones and reconsidering land use designations to the east, as well as the waterfront for potential conversion from commercial to residential or mixed-use zoning.

1.3. Residential and Commercial Ratio: We suggest the Government consider a higher ratio for residential development and allow greater flexibility for proposed commercial uses (the current proposal suggests 60% commercial (hotel included) to 40% residential Gross Floor Area (GFA) mix)[2] . This recommendation is premised on the current market sentiment and high office vacancy rates, short-term projected commercial floor area supply, and market responses to the Government's recent land sale program. Additionally, given the current volume of retail offerings in the Tsim Sha Tsui and Hung Hom areas, an oversupply could dilute business viability and strain the ecosystem.

1.4. Convention and Exhibition Facilities at Hung Hom: A portion of the commercial GFA could also be allocated to the development of convention and exhibition facilities to support the development of the mega events economy. This new facility would help ease the strain on the heavily utilized Hong Kong Convention and Exhibition Centre in Wan Chai, conveniently located just one MTR stop away. It is noted that Kowloon has been without similar venues since the closure of Kowloon Bay International Trade and Exhibition Centre. 

2.    Design Considerations

2.1. Building Height: We have some reservations on the proposed iconic mixed-use tower with a suggested building height of 230 meters above Principal Datum (mPD)[3],given potential construction and cost challenges, which may diminish its appeal to potential developers in future tenders. From urban design perspectives, we also recommend that the Government consider adopting the principle of stepped-down building heights to preserve landscape visual aesthetics, and promote public enjoyment of Victoria Harbour views, whilst complementing with other design measures to promote the tower as a "landmark".

2.2.  Connectivity and Transportation Infrastructure: We recommend that the Zone considers connectivity on all fronts to facilitate commuting within the ecosystem and provide the best experience for local visitors and tourists - including the installation of ample car park facilities with covered walkways to key attractions and areas within the Zone, and construction of adequate road connections to prevent spillover congestion to the nearby transportation networks such as the Cross Harbour Tunnel.

Specific measures could include:

•   Provision of sufficient parking spaces near the marina, including designated areas for short-term drop-off and pick-up, to enhance convenience for yachting passengers. The creation of shuttle boats or water taxi routes between the new marina, Ocean Terminal at Tsim Sha Tsui East, and the Kai Tak cruise terminal, could also be explored.

•  Further upgrading of pedestrian links with covered footbridges or underpasses to the nearby Tsim Sha Tsui East area and developments to the east of the Zone, leveraging the connections between existing commercial facilities such as hotels, offices, and shopping centers. 

• For a more integrated commuting experience, consideration could be given to further developing the underground facilities of Hung Hom Station and moving the storage and maintenance facilities of certain station areas to more remote locations.

•  As Hong Kong looks to developing the low-altitude economy, it is suggested that a helipad could be constructed along the Hung Hom waterfront to support potential future services involving passenger-carrying drones operating in the Victoria Harbour area. This forward-looking infrastructure could position the site as a hub for next-generation urban mobility.

2.3. Branding and Activities: To enhance the vibrancy and appeal of the Hung Hom waterfront, some recommended measures include:

• Extending the promenade from Tsim Sha Tsui and Tsim Sha Tsui East to the Zone, integrating a running track along the waterfront area. Additional commercial activities could also be considered along the promenade to enhance vibrancy.

• Developing more harbourfront activities, capitalizing on Victoria Harbour's international renown for its skyline and nighttime panoramic views. This could also include introducing nighttime entertainment, such as light and music shows, complemented by bars, restaurants, and retail-entertainment options, creating synergy with events taking place at the nearby Hong Kong Coliseum.

• Ensuring the marine club's facilities are of the highest standard, with adequate berthing provisions for larger yachts and boats, given the current high demand for such vessels.

• Incorporating trendy recreational amenities in the new public open spaces, such as padel/pickleball courts, skateboard park, glasshouse ice skating rink, or other active leisure facilities, to attract a diverse range of visitors and promote community engagement.

• Expanding residential opportunities by allowing mixed-use developments along the waterfront to draw in more residents and visitors, enhancing the area’s vibrancy and appeal beyond daytime hours.

2.4. Sustainability and Living quality: Given the positioning of the Zone, strategies for minimizing noise and activity disturbance on the local population should also be factored into the development proposals. Furthermore, integrating green design elements—such as solar energy, rainwater reuse, or native landscaping—would align with Hong Kong’s sustainability goals and elevate the Zone’s long-term value.

3.    Additional Considerations

3.1. Marina Club Consultation: We suggest that the Government further consult relevant private sector stakeholders on the construction and operation of yacht berthing facilities and the marina club. As a private marina club in Kowloon is rare, we recommend early engagement with potential private operating parties to assess the attractiveness of the proposal in terms of location and scale, prior to the finalization of the development proposal.

3.2. Waterfront Advertising Opportunities: Consideration could be given to the design of low-rise, horizontally oriented signage along the waterfront, available for lease to corporations seeking advertising exposure facing Victoria Harbour. This initiative could provide additional revenue generating opportunities for developers and enhance the commercial appeal of the area.

3.3. Future Use of the Hong Kong Coliseum: With the recent completion of the Kai Tak Sports Park, the utilization rate of the Hong Kong Coliseum may decline. The Government may wish to evaluate potential long-term alternative uses for the Coliseum to ensure the site remains vibrant and economically viable.

We hope that you will find the above comments useful, and look forward to the opportunity of continued engagement with your Bureau as the revitalization proposals develop.

Yours sincerely,

Patrick Yeung
CEO