Representation made in accordance with S6(1) of the Town Planning Ordinance in respect of Draft Chap Lap Kok Outline Zoning Plan No.S/I-CLK/13
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Representation made in accordance with S6(1) of the Town Planning Ordinance in respect of Draft Chak Lap Kok Outline Zoning Plan No.S/I-CLK/13
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Objection will be sent directly to the Town Planning Board
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The Draft Chak Lap Kok Outline Zoning Plan No. S/I-CLK/13 (“Draft Plan”) was gazetted on 8 May 2015, which include the amendments covering a proposed reclamation area to facilitate the implementation of the new third runway proposed by the Airport Authority Hong Kong (AAHK). It has been claimed by the AAHK that the current two runway system has not been able to meet the current as well as projected demand. Increase of capacity is necessary to address such demand.
The two Amendments include:
Item A - Designation of an area on the proposed reclamation to the north of the Hong Kong International Airport as “Other Specified Uses” (“OU”) annotated “Airport”; and
Item B – Designation of two areas in the east and west of the proposed reclamation as “OU” annotated “Airport Service Area”
For the past few years the AAHK has not acted in a responsible and professional manner to inform the general public of options of how and where capacity can increase. All along the general public has only been given the third runway system “option” by AAHK. There has not been any proper public consultation conducted by the AAHK on the pros and cons of alternatives. It is not clear whether proper feasibility studies, which propose, examine and assess different options on the basis of a set of criteria agreed by the general public, have been carried out by the AAHK. For a project of this scale in terms of financial commitment as well as environmental impact it is not at all clear how and what the AAHK has done to arrive at the conclusion that the 3RS is the option to be adopted. The general public is entitled to be involved in the process as well as to have access to such information.
The public demands that proper studies be carried out and the assessment of options and public consultation to be conducted in a transparent and professional manner. Unfortunately the AAHK has failed to do so. Due to the lack of proper consultation carried out by the AAHK the Town Planning Ordinance procedure become the only possible channel for the public to express their view under the Town Planning Ordinance.
Against the above background we strongly object to the amendments to the subject Draft Plan for the following reasons:
Reasons
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1. AAHK Has Failed to Explained How the 3RS was Selected The amendments are intended to make provision for the implementation of the 3RS. The AAHK has failed to demonstrate to the public that proper feasibilities studies had been carried out with proper assessments done to identify the most feasible option in terms of financial feasibility, future expansion and environmental impact. Whether the 3RS is the most feasible option for the expansion of the HKIA is questionable. Neither the Town Planning Board (TPB) Paper No. 9877 prepared by AAHK for the consideration of the TPB on 10 April 2015 nor the Rural and New Territories Planning Committee (RNTPC) Paper (for consideration of the RNTPC in its meeting dated 17 April 2015) have provided substantial and adequate information to justify the 3RS advocated by AAHK. The TPB papers failed to provide adequate justification for the decision of selecting the 3RS. In this respect the decision of the TPB arrived at based on the information provided in the subject TPB paper is improper.
2. No Full Discussion on “Options” The public have in the past few years proposed various options for the expansion of the capacity of the airport including terrain removal recommended in the original Master Plan, co-ordination with neighbouring airports, installation of advanced technological equipment like the Heathrow Airport which operate on 2-runway system and training of air traffic controllers, etc. The AAHK has repeatedly fended off these options saying they are not feasible without any substantial figures or reasons, sometimes even using wrong information. It seems the AAHK has all along decided on the 3R system “option”. The way the studies and consultation were conducted by the AAHK has been promoting the 3R system instead of finding the most feasible option for the expansion of the HKIA. We do not even know what the criteria for selection are. As there is nothing to substantiate that 3R system is the most feasible option the amendments which relate to new reclamation should be deleted and AAHK should be requested to conduct proper technical studies in a professional and transparent manner.
3. Interfering with the Judicial Review of the Granting of the Environmental Permit The AAHK presented to the members of the TPB meeting that the EIA study conducted for the 3RS was the most comprehensive one ever done in Hong Kong. The fact is that. two applications for leave to judicial review against the decision of DEP to approve the 3RS EIA report and grant the EP were received by the High Court. In this respect the environmental impact on the reclamation area has not been ascertained. Para 13 of TPB Paper No.9877 has failed to mention this point. The RNTPC paper only showed it as a footnote. As the environmental impact is the most important aspect of the assessment for this project AAHK is suspected of misleading members of the TPB intentionally. It is therefore premature to amend the subject OZP to facilitate the implementation of the 3RS at this stage until a decision is made by the court. The decision of the Town Planning Board to amend the subject Draft Plan with no certainty of the environmental impact is subject to challenge.
4. Potential Vicious Competition between the XRL and Expanded HKIA The representative, Mr Wilson Fung Wing Yip in the TPB meeting dated 10 April 2015 admitted that “it was expected that the Mainland flights would remain to be around 25% of the total flight movements of HKIA in the foreseeable future up to 2030”. Nevertheless, he claimed that “it was considered that for those destinations that were within six hours of travelling time by express rail, direct competition between express rail and air flight did exist” but “they overlapped with less than 5% of the current flight destination of HKIA”. However, in the LegCo Paper of promoting the benefits of the Express Rail Link (XRL) prepared by Transport and Housing Bureau (THB) in Nov 2009 (LC Paper No. CB(1)503/09-10(2) refers), THB quoted the case in UK that the carbon emission on an Eurostar journey is only about 15% of that by plan on a per passenger-kilometre basis. The Government attempted to promote XRL would be more environmentally-friendly than flights. Now it is a question whether THB attempted to have strategic planning to coordinate the passenger flow between XRL and the expanded HKIA. AAHK have also claimed that it is the airlines (not the Government nor the airport) which determine the level of air services (including destination and frequency) in response to market situation (LC Paper No. CB(4)259/14-15(02) refers). So it is worrying that it turns out to be a vicious competition between the XRL and the airlines providing short-haul flights. And Hong Kong people are the ones paying the social and environmental costs for this uncoordinated transport planning.
5. No details of TIA Available There are no details of the Traffic Impact Assessment available for the consideration of the TPB or the public. AAHK has made known to the public its intention to build a huge shopping mall in the North Commercial District (NCD), the first phase alone would be about 2 million sq ft,. AAHK has explicitly made known to the press that the mall will aim to attract Hong Kong people. AAHK further indicated at the TPB meeting that it was expected that with the completion of the NCD and the 3RS the demand for convention and exhibition spaces at the AWE would be further increased. It is however not known if the capacity of the AEL is capable of carrying the additional traffic generated by HK shoppers, users of the airport and that of the AWE or if other means of public transport as well as parking spaces would be sufficient to cater for the demand of all these shoppers. Regrettably the TIA is only summarized in four lines in Para 14 of the TPB paper stating that “ The forecast results showed that all major roads will operate within the practical capacity in …”. Even when questioned by the member of the TPB about the capacity of the AEL the response was that the AEL would be able to accommodate the additional traffic demand. Such oversimplified response was not supported by any accompanied traffic studies. The 1 page summary of the TIA in the RNTPC paper also failed to address this issue. 5.2 The AAHK did not mention how many phases of development in the NCD nor the total commercial GFA envisaged. As a proper TIA requires information such as GFAs for various uses for calculation of trip generation. It will not be possible to carry out a proper TIA without such information, especially commercial GFA and convention and exhibition facilities which all generate large volume of traffic. The TIA is thus entirely not acceptable. It is not sure if the TIA is supported by the Transport Department without the benefit of the GFA breakdown. We must stress that priority should be given to airport passengers and proper studies should be shown that all means of transport should be able to meet the demand.
6. No Hydrodynamics Study The AAHK claimed that the EIA conducted was the more comprehensive one ever done in Hong Kong. It seems one important one which is missing is the hydrodynamic impact assessment. The water channel between Tuen Mun and Chap Lap Kok will become narrower as a result of the 650 ha of reclamation. The impact of the reclamation on existing marine traffic, such as the express ferry service between Macau and HKIA at the SkyPier and container traffic etc are not known. The constricted channel may create higher waves which may result in less marine traffic permissible or even limit the type of vessels to be used. There was absolutely nothing mentioned on this topic. On the other hand the AAHK indicated at the TPB meeting that there is a plan to expand SkyPier to cater for the increase of passengers from the Pearl River Delta region who come to HKIA by ferries. AAHK should be required to produce study results to show the impact of the reclamation on existing and future marine traffic before the approval of the reclamation.
7. Very Loose Control on the Permissible Uses regarding Amendment A The proposed Amendment A designates an area on the proposed reclamation “OU” annotated “Airport”. There is no restriction on maximum GFA and all the uses permitted are in Column 1. Recently AAHK announced that the less than 10-year old T2 will be demolished to make way for the construction of the 3RS. This is a clear demonstration that AAHK operate and plan on an ad hoc basis with no overall co-ordination on the expansion of the airport. Such ad hoc manner is not acceptable and is not sustainable. In view of the incompetence of AAHK there should be sufficient development control on the overall planning of the airport under the OZP. The “HKIA 2030 Master Plan”, though has gained in-principle support by CE in Council, was just a blue-print framework without statutory binding effect. The public would not know and have no way to get involved in decision making if HKIA are going to make minor amendments to the plan. In this respect all the permissible use should be put in Column 2 to allow control by the TPB to avoid repeated mistakes by AAHK in the future.
8. Very Loose Control on the Permissible Uses regarding Amendment B Likewise the proposed Amendment B designates two areas on the proposed reclamation “OU” annotated “Airport Service Area”. All the permissible uses should be placed under Column 2 particularly there are commercial uses such as eating places and shops and services etc. Such uses should be well defined in terms of GFA as these are uses which should attract premium and should be included in the assessment of traffic impact.
9. Issues on Airspace Unresolved There is no mention of airspace in the TPB paper nor the RNTPC paper. A member questioned at the RNTPC meeting whether the use of the proposed reclamation area should be considered without addressing the unresolved issue. The Chairman said that the Committee should focus on the land uses taking into account the relevant environmental and traffic issues of the proposed land uses. Unfortunately whether the 3RS could fulfil the promise of AAHK that it would accommodate the HKIA’s growing demand depends entirely on whether the third runway could reach the desired capacity upon its completion on the assumption that there is no restriction on the use of airspace under the control of the Mainland. Although both the Government and the AAHK claimed that agreement has been made between Hong Kong and the Mainland there is however no evident that this is the case. The situation is similar to that of the XRL: the Government claimed at the LegCo Finance Committee that the co-existence of border control would be resolved. However to this day the issue is yet to be resolved. In the event history repeats itself that the airspace issue could not be resolved upon the completion of the 3R system, which party would be responsible? By then the investment of over HK$140 billion would not only be a complete waste but also incur unnecessary and irreversible environmental cost. The prime objective of amending the subject Draft Plan is to facilitate the implementation of the 3RS. The amendment should only be made when it is certain that the 3RS can achieve the claimed capacity. The amendments should thus be postponed until the issue is satisfactory resolved with solid proof.
10. No Air Traffic Impact Assessment (ATIA) is Presented AAHK did not provide an Air Traffic Impact Assessment (ATIA) report when it presented the 3RS to the Town Planning Board (TPB). The TIA is an indispensible technical document whenever a development proposal is submitted to the TPB for consideration. According to AAHK’s estimation, the total passenger throughput of major airports atop the PRD estuary would reach 300 million by 2030. Yet, there is no agreed multilateral collaborative air traffic management scheme. No Safety Risk Assessment as required by the International Civil Aviation Organisation (ICAO) Annex 19. No Real Time Simulation test (not only Fast Time Simulation) of aircraft movement patterns under different scenarios considering flight paths, escape avenues and queuing loops. These uncertainties will cast doubts on the operation-effectiveness of the 3RS
11. Improper Public Consultation For a project of this importance the AAHK failed to conduct proper consultation with the public. Only information favouring the scenario of the 3RS screened by the AAHK has been released to the public. The consultation so conducted by the AAHK is biased and misleading, depriving the public of their rights of access to unbiased information. It is understood that the AAHK has spent huge amount of money on studies. It is however not known what AAHK has not done to arrive at the 3RS.The public however are denied of access to the outcome of these studies. It is also astounding that not only the public but also the TPB has been denied of unbiased information. As a matter of due diligence the AAHK has to explain why the original planning capacity of 86 million pax and 9 million tonnes of cargo under the 2R system cannot be achieved and what measures have been used to mitigate before the expansion plan. Similarly why should the public trust that this 3R system can achieve the projected capacity if the 2R system cannot achieve what was originally anticipated. Furthermore there seems to be no more opportunity for further expansion of the HKIA beyond the 3R system. Has AAHK done anything to look into this aspect when they realised the capacity of AAHK fall short of future demand? AAHK is requested to provide for satisfactory answer otherwise there is no justification for the new reclamation to be implemented.
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The action is initiated by People’s aviation watch, the form is provided by Friends of the Earth (HK).
Any question please mail to :
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