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Section 12A Application No. Y/I-DB/2
Area 6f, Lot 385 RP & Ext (Part) in D.D. 352, Discovery Bay
The Secretariat
Town Planning Board
15/F, North Point Government Offices
333 Java Road, North Point
(Via email: tpbpd@pland.gov.hk or fax: 2877 0245 / 2522 8426)
Dear Sir,
1 Introduction
In the process of making this submission, Hillgrove VOC has considered at the mission of the Town Planning Board.
Town Planning in Hong Kong aims to promote the health, safety, convenience, and general welfare of the community through the process of guiding and controlling the development and use of land, and to bring about a better organized, efficient, and desirable place to live and work.
The Discovery Bay experiment should be maintained as a benchmark for health, safety, convenience, and general welfare of the community. Discovery Bay is exceptional in the best sense and needs to be preserved through the controlled development of the use of its land.
Owners in Discovery Bay are known for embracing and improving its organization and efficiency. Electric vehicles have been tested, waste management is already exemplary but endlessly improving and the open spaces, both wild and managed, see imaginative green initiatives. Discovery Bay is a role model for the Chief Executive’s goal to make Hong Kong carbon neutral by 2050. Every development now being proposed should demonstrate how it will assist Hong Kong to reach net zero. The current proposal has failed to do so.
2 Access to the Site
Access to the site is by an extension to Parkvale Drive. All traffic would have to pass through Parkvale Village to access Area 6f. The Applicant has failed to show that the access along Parkvale Drive can meet the Hong Kong Planning and Standards Guidelines for roads.
3 Alternative Access to Area 6f
It seems inevitable, therefore, that an alternative access would need to be constructed and we are not aware of adequate feasibility studies having been conducted with attention to slope stability. The traffic from the proposed developments will be very significant and further comments are made in Hillgrove’s comments on Traffic below.
4 Sewage Treatment
HKR has acknowledged that the Siu Ho Wan Sewage Treatment Works (SHWSTW) has no spare capacity to cater for the additional sewage arising from the proposed development in Discovery Bay. The only alternative is, therefore, to build a local sewage treatment works in Discovery Bay to serve the proposed development in Area 6f. If a local sewage treatment works was built in Area 6f, its treated effluent would be discharged into the adjacent nullah, which also runs past Hillgrove Village, and from there into the sea. The submission notes that a local STW may cause “an offensive smell and is health hazard”. Due to its proximity to our village, we consider that it is inappropriate to locate a STW in Area 6f, due to the potential smell and health hazard, especially as the effluent will be discharged into the open nullah, and as no mention has been made of what would happen to the sewage in the event that the STW breaks down. The nullah runs below Elegance Court in Hillgrove Village.
5 Water Supply
HKR’s application has noted that the water supply from the Siu Ho Wan Water Treatment Works (SHWWTW) and the SHW Fresh Water Pumping Station may not be able to supply potable water to the proposed developments in Discovery Bay. HKR’s proposed alternative is to supply private water using the raw water stored in the private Discovery Bay Reservoir and building a private water treatment works to make a private water supply exclusively for the additional persons in Areas 6f.
The proposal originally applied to both 6f and 10b. No information has been supplied to show that it is cost effective to supply only Area 6f, and the Applicant may attempt to seek special dispensation from Water Supplies Department (WSD) at a later date. If the Application is approved, it should be approved on the condition that no water for the site may be supplied by the WSD.
HKR should also be required to confirm that the capital costs and the operating costs arising from adopting this alternative will be borne by either HKR or the undivided shareholders of the Area 6f and not by the owners of Hillgrove Village or by the owners of any other village in Discovery Bay, which have their water supplied using the Siu Ho Wan Water Treatment Works (SHWWTW) and the SHW Fresh Water Pumping Station.
6 Provision of Other Utilities
HKR should be required to confirm that the provision of new utilities, including LPG, would have no impact on the residents and owners of any Village or explain what the impact will be and how HKR will mitigate their impact.
7 Slope Safety
The site is defined as 8,300m2 on rising ground from 44mPD to 70mPD. What is unclear from this description is that the site is only partially formed and is predominantly a slope leading down towards Crystal and Coral Courts in Parkvale Village. HKR should be required to state how it will eliminate these risks. A major mitigation project was needed in recent years above Hillgrove.
8 HKR’s right to use Parkvale Drive as access to Area 6f
As there may be other interpretations, and as the owners of the undivided shares in Parkvale Village have been responsible for the costs of maintaining this “Passageway” for the past 28 years, Hillgrove supports the view that HKR should be required to present counsels’ independent legal opinions supporting its contention that it has the legal right to use the passageway as access to Area 6f.
9 Population of Discovery Bay
Before the change in use is considered, HKR must be required to demonstrate, in a fully accountable manner, that the proposed development in Areas 6f together with other areas in Discovery Bay being developed and planned, will not exceed the approved OZP maximum population of 25,000. This should include an accurate count of the existing population and the expected population of areas for which HKR seeks approval to develop before the proposed developments in Area 6f is expected to be occupied.
It is clear that the TPB is in danger of being persuaded by this incremental approach to considering projects, especially given the very small population difference of 1,412 mentioned above, to indirectly allow a breaching of the 25,000 population ceiling. There is an urgent need to address this issue.
10 Traffic-Assessment
Quote “The 476 units and 1,190 population increase as a result of the proposal is very modest development intensities”.
In the context of Hillgrove Village, we do not agree with this statement, as it is proposed that all traffic and people generated by the proposed development would have to pass by our village. Not only will the considerable construction traffic have to drive up a hill past the existing flats in the village, the significant increase in operational traffic, including the increase in the number of buses, required to service the proposed 476 flats, will cause ongoing noise, poor air quality and disturbance to the residents of Hillgrove Village.
Hillgrove owners wish to submit a further observation on traffic impact by refer to a recent accident between a bus and a golf cart. An owner asked the question: What would happen now if there was a fire and 999 call in the Woods or Midvale or the proposed development? Valuable, time, critical time would be lost? People could die.
NB> It is understood that Master Plan 7.0 has approved 10,000 flats. At 2.5 per flat, the population is already at 25,000.
11 Ownership – Property Rights
I urge the Town Planning Board to ensure that the property rights of all owners of the land “the remaining portion of Lot No.385 in D.D.352 and the extensions thereto”, of which Area 6f forms a part, are respected and upheld when members consider Application Y/I-DB/2 (the “Application”).
New information has been submitted to the Land Registry since the Application was last considered by the Board in 2017. It is vital that the full implication of this new information is considered and addressed by the Board before the Board comes to any decision.
The general public but also the co-owners of the land have not had the opportunity to review the grounds for the Applicant to claim the “right and capacity” to develop the site.
13 Record of Certified Shares
There is at present no accurate record of the number of Reserved Undivided Shares remaining for allocation to the proposed development at Area 6f.
Prior to deciding whether or not to approve the current Application, it is essential that the Board requests that the Applicant provides a comprehensive, certified record of the existing allocation of undivided shares incorporating not only those undivided shares allocated in sub-DMCs but also those undivided shares required to be allocated under the terms of the PDMC and the BMO.
14 Conclusion
For the reasons 1 -13 above, we consider that the Town Planning Board should renew its decision to reject HKR’s application to rezone Area 6f.
We again encourage the Town Planning Board to visit the site and meet residents. In doing so, many of the issues highlighted in this report would be self-evident.
Signed on behalf of the Hillgrove VOC: Date: 3rd December 2021