The site is Tsum Chuk Wan
A company called Golden Kingdom Investment Limited have applied to the Town Planning Board to build a residential care home for elderly people in the small Sai Kung village of Tsam Chuk Wan. The current zoning is “Village Type Development” and the proposal calls for a minimum of 110 bed spaces to be built on around 750 sq. m. of land, 249 currently owned by the government.
The application site map
The proposal is for a six storey building covering around 80% of the site. Full details of the proposals can be found at s16_A_SK-TMT_74_0_gist.pdf and objections can be submitted before 27 July.
The application site detail
The proposal has caused concern within the village. For example, Friends of Sai Kung have circulated the following letter to local residents,
We object to the s16 application for a residential care home for the elderly, A/SK-TMT/74, with the following reasons:
Excessive Development Intensity:
The proposed site lies within an environmentally and ecologically sensitive area and only low-rise low-density residential development of not more than 3-storey high would be allowed. The application site, comprising 499m ² of private land, can only accommodate around 5 units of low-rise residential development/Small House for 15 people. Yet, it is proposed to be developed into a 24m tall building with a plot ratio of 4 with 110 beds for 110 old aged people and 40 staff. The proposed development is considered excessive and incompatible to the environment in the vicinity.
Against the general planning intentions of the area and the “V” Zone:
The planning intention of the OZP area is to conserve the natural environment and the rural character by protecting the natural landscape, topographical features and ecologically sensitive areas from encroachment by development. The planning intention for the “V” zone in Tsam Chuk Wan is to designate both existing recognized villages and areas of land considered suitable for village expansion.
Therefore, the proposed residential care home for the elderly is not in line with the planning intentions of planning scheme area and the “V” zone. There are no exceptional circumstances or planning merits to merit a departure from the planning intentions of the planning scheme area and the “V” zone.
Poor Urban Design
Except Sai Kung Town and HKUST, developments in Sai Kung are generally low-rise and low-density developments of not more than 3-storey high. Yet, the proposed development (about 3m wide, 25m deep and 24m high) is a gigantic building, completely out of place in Tsam Chuk Wan and Sai Kung as a whole. The 24m high building, even discounting the unspecified height of big lift room and water tower, is equivalent to an 8-storey domestic building or about 2.9 times of the permitted building height of 8.23m for 3-storey Small Houses. Such a poorly designed bulky panel like development will be a visual eyesore along Tai Mong Tsai Road, destroying the rural characters in Tsam Chuk Wan and Sai Kung as a whole.
Adverse Sewerage Impact:
The is no proper sewer in the area. The 110 beds, a large laundry, a central kitchen and medication rooms for 110 old aged people and 40 staff will generate substantial waste, often related to medical and health care purposes. Septic tank for general domestic use is not suitable to treat sewage related to medical and health care uses. Yet, no Sewerage Impact Assessment (SIA) has been conducted in the application. Thus, the applicant fails to demonstrate that the proposed development will not cause any adverse sewerage impact on the environmentally and ecologically sensitive areas in the vicinity, in particular the Coastal Protection Areas across Tai Mong Tsai Road.
Adverse Traffic Impact:
Tai Mong Tsai Road, a two-lane single carriageway and the only road linking Sai Kung Town to the eastern part of the OZP area, is not planned for heavy vehicular traffic. The proposed excessive development will generate excessive traffic from old aged users, staff, visitors and emergency vehicles, overtaxing the already heavy vehicular traffic flow along Tai Mong Tsai Road. As no Traffic Impact Assessment (TIA) has been conducted, the applicant fails to demonstrate that the proposed development would not cause any adverse traffic impacts on the surrounding areas.
Adverse Noise Impact:
Tai Mong Tsai Road is subject to noise impact and technical assessments to address the development constraints in these areas should be submitted to the satisfaction of relevant government departments for any application for grant of land for Small House developments, as stated in the Explanatory Statement attached to the OZP. As no Environmental Impact Assessment (EIA) has been conducted, the applicant fails to demonstrate that the proposed development would not be adversely affected by the traffic noise from Tai Mong Tsai Road.
Setting a Dangerous Precedent:
Approval of the such a bulky panel-like development with excessive development intensity will set a dangerous precedent for other similar applications within the “V” zones in Sai Kung and the New Territories. The cumulative impacts of approving such applications would result in encroachment of the “V” zone by bulky and excessive developments and create adverse impact on natural landscape in the area and the New Territories.
Lack of Local Open Space;
Last but not least, according to the standard of 1m² per person in Chapter 4 – Recreation, Open Space and Greening of the Hong Kong Planning Standards and Guidelines, there should be a Local Open Space of 8300 m² for a planned population of 8,300 persons in the OZP area. Yet, there is not a single piece of Local Open Space planned in the whole OZP area. Instead of developing the application site into a residential care home for the elderly, the application site should be rezoned to “Open Space” and developed into a Local Open Space to serve the local community
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