overall comments
Whilst we appreciate the conceptual nature of this study, that is still at an early stage, there are basic facts and assessments we consider are missing from the public engagement digest and summary of work completed to date. These include:
•Needs and demand assessment
•Analysis of alternatives
•General facts about the proposal, such as scale and type of use
•Broad financial and economic feasibility assessments
Specific Response
1. What are the major community needs in the four strategic urban areas?
In conjunction with the technical analysis we would expect to see a needs and demand analysis, in order to come up with proposed uses for the underground space and estimated demand for these.
The lack of any demand assessment is particularly worrying since it seems to be a growing trend in government studies to ignore demand! It is simply not good enough to come up with some vague ideas and then ask the general public about needs! Be rigorous, do some analysis, then by all means ask the public.
In order to provide suitable comment we would need to have a better understanding of the analytical evidence of the need and demand for community and commercial facilities.
Additionally, when assessing demand for retail and F&B facilities the demand will be driven, not just from within the local community but by Hong Kong residents and workers as well as visitors.
2. Do you agree the major community needs could be addressed by underground space development in the strategic urban areas?
•No we don’t agree, we need some evidence and analysis in order to provide a practical response.
•There should be an assessment of alternatives to examine various options for increasing land supply for community facilities before deciding on underground space as the most suitable option.
•This would include a proper analysis of all types of land (such as developing caverns or better utilisation of space at the fringe) to relocate all facilities that don’t need to be there, before developing underground spaces.
3. What are your vision and expectation of underground space development?
•The proposals presented in the PE digest are so vague as to be useless, we cannot comment as there is no detail given about the scale (e.g. GFA) or types of use. What is the target GFA or are there any other targets to achieve in developing underground space?
•At a conceptual level, additional connections underground would be useful, particularly for connections to existing subway networks, MTR stations and offices. However, any underground development should only be undertaken with a commensurate improvement to the public realm at grade and only once sensible rationalisation of land uses on the surface has been undertaken.
4. What are your concerns on underground space development in the four strategic urban areas?
•We are concerned about the major costs (capex & opex) and the disruption that construction would cause. The financial feasibility needs to be carefully assessed.
•We also have concerns about the waste of resources in this study in doing detailed technical assessments when the basic demand analysis, analysis of alternatives and broad order financial and economic assessments do not appear to have been undertaken. There is no point to proceed if these aspects of the study do not yield positive results.
5. Do you have other comments on underground space development in the four strategic urban areas?
•Consideration needs to be given to how to attract retailers and F&B operators to the underground space. Pedestrian flows need to be large enough to guarantee business for these operators otherwise they are unlikely to setup there. Connection to the MTR and existing offices is important.
•Valuing the land resources that are freed up by underground space needs further study, it depends on what land is being freed up, if any, its proposed use and the proposed uses of the underground space.