HKR is highly dismissive of comments from owners and residents on the 6f and 10b applications in its latest Town Planning Board (TPB) submissions. It ignored most comments, and relegated the few that it chose to address to an appendix at the back. Even then, it resorted to half-truths and slight-of-hand in its replies.
Take HKR’s reply on population. HKR’s original submission advised: “There are currently around 8,300 nos. of residential flat with total population around 15,000.”
After numerous residents and owners raised concern about the veracity of this number, HKR’s latest submission made the following comments.
The existing and proposed population at Discovery Bay, in terms of population size, household number and average number of persons per unit, is questioned.
According to City Management’s latest record (property management company of all Discovery Bay residential units), there are about 19,585 persons living in 8,326 units, equivalent to 2.35 persons per unit. It covers all the residential units and is therefore complete and accurate. In contrary, Government census surveyed only occupied units with occupants responding to census staffs that is about 4,000+ units.
The Working Group on Population Distribution Projections indicate an average 2.2 persons per domestic household for Discovery Bay (and the surrounding area, in Tertiary Planning Units 932 and 934) for 2013-2021.
Development under the approved Master Plan 6.0E7h(a) is for 8,731 residential units. OZP only states maximum population for 25,000 persons. The number of household was not mentioned although it is understood that the rationale is to allow for maximum 10,000 nos of residential units i.e. 2.5 persons per unit.
Accordingly, the proposed Concept Plans at Area 6f and Area 10b creating about 1,601 units for 4,003 persons in total, equivalent to 2.5 persons per unit is considered reasonable.
Why does 25,000 matter? A population of 25,000 is not only the cap under the OZP; it is also the cap under the water supply agreement with the Water Supplies Department (WSD). At the planning ratio of 2.5 persons per unit, this means that the maximum number of flats that can receive government water is 10,000.
Note the following:
- HKR has admitted that the population figure given in its original submission to the TPB was understated by about 30%.
- HKR’s attempt to introduce different persons-per-unit ratios (2.35 and 2.2) is a red herring.
- No details or methodology are given to support HKR’s claim that the current population is 19,585. We are supposed to take this on faith. Much better to focus on the number of flats, which is verifiable.
- There are presently 8,326 flats in DB. However, the latest Master Plan, MP 6.0E7h(a), has approved an increase to 8,735 (not 8,731 as HKR claims).
- HKR points to MP 6.0E7h(a) to have us believe that adding an extra 1,601 flats is reasonable. However, this conveniently ignores the fact that the existing OZP already allows significantly more development than shown on the current Master Plan.
At Area R(C)2 on the OZP, HKR has permission to build an additional 157,100 sq.m. gross floor area (GFA) of residential units. MP6.0E7h(a) approved three new blocks at Amalfi, bringing the total for the six Amalfi blocks to 33,100 sq.m. GFA. That leaves 124,000 sq.m. GFA still to be built at Area R(C)2 in DB North.
Lands Department is currently reviewing an application from HKR to develop this additional GFA under the next Master Plan, MP7.0E. The Discovery Bay City Owners’ Committee was already consulted in 2014. The development will consist of four 25-storey blocks, four 15-storey blocks and approximately 12 five-storey blocks.
Again, the new development at DB North will total 124,000 sq.m. GFA. The applications for 6f and 10b combined total only 89,100 sq.m. GFA. 6f and 10b will produce 1,601 flats.
Scaling up proportionally, the new DB North development will produce about 2,240 flats. Adding this to the approved 8,735 flats, and the DB North development will bring DB’s total well above 10,000 flats. The 1,601 flats from 6f and 10b must then be added on top.
Only 10,000 flats can receive government water, at the official persons-per-unit ratio of 2.5. We can easily see why it is in HKR’s interest to understate the population in DB, as it did in its initial submission and as it continues to do by floating persons-per-unit ratios of 2.35 and 2.2.
Kenneth Chan of City Management claimed in his submission to the TPB (No. 1,338, Area 6f) that more development would allow the costs of maintaining DB’s infrastructure to be spread across more units. Obviously, that is not true for the water and sewage infrastructure. More development will only make management and maintenance more complicated and more costly.
There is a clear need to have a comprehensive view of future development in DB, in order to set out the full infrastructure needs accordingly. What is HKR’s target for population and number of flats? Any increase beyond the current approved population limit of 25,000 must be fully justified and supported with proper engineering and impact studies. At the end of the day, the costs of the piecemeal approach now being adopted will be borne by the owners and residents of DB.
Our voice must not be dismissed so easily. Please feel free to copy some or all of the above when replying to the TPB. Don’t wait until your submission is “complete”. You may make multiple submissions at any time on different topics, up to the 15 July deadline.