With respect to the Town Planning Board’s proposed Amendments to the Approved Central District Outline Zoning Plan S/H4/14, the Hong Kong Institute of Urban Design (HKIUD) in pursuance to section 6(1) of the Town Planning Ordinance, hereby submits its representation to the Board as follows:

 1.The HKIUD considers the proposed additional commercial development comprising an office tower and shops and other commercial spaces in 5 levels of podium and 5 basements of commercial uses and parking at the Queensway Plaza as excessive, arbitrary, and unharmonious with the surrounding existing buildings at Admiralty.

2.Visual Impact - The HKIUD finds massing of the additional structure out of place from an urban design point of view. Urban design cares about the quality of the public realm and the spaces between buildings. Not all spaces in the urban area need be filled up whether it is for financial or other reasons. The massiveness of the development is self-explanatory as can be clearly demonstrated in the photomontages in the MPC Paper, such as figures 4.4.9 to 4.4.12. Even with the splayed façade – which happens to be westward facing and would likely be highly reflective at sunset times producing glare and great disturbance to motorists and pedestrians off work during those hours.

3.The tower encroaches very closely to the existing Admiralty Centre Towers on the northern side. Yet there is no illustration to highlight this interface and the oppressive encroachment. It is disappointing that the existing Admiralty Centre Towers are not even shown in the 3-D illustrations such as those in Plan 3a in the MPC paper dated 30.9.2015.

4.We are also concerned about the quality of the spaces at pedestrian level. The proposed additional development would aggravate the shadowing effects over the few remaining and existing spaces. The additional traffic brought by the proposed 5 basements of parking spaces would likely add to air pollution in this locality.

5.We have doubts about the traffic impact assessments and assumptions used in the planningThe opening of the Central-WanChai Bypass (CWB) may not necessarily help much to reduce the traffic attracted to or generated by this site. On the contrary, the additional commercial spaces would attract more traffic to this area. The traffic circulation pattern is not well illustrated. It appears that traffic going into the subject site would have to use Tamar Street and make a rather sharp turn into the site and the conflict is even greater upon exit. The irregular shaped junction between Tamar Street and Drake Street would be a point of great conflict. The place is already very busy at present. The additional development would only make the situation worse. Compared to the existing Murray Road M/S Carpark, the ingress/egress are serviced by a rather elaborate gyratory system with ample free play and queueing space if needed. It can also get onto the district and major roads more easily, whereas for the proposed development at Queensway Plaza, the external road system and junctions are very restricted and therefore much worse. 

6.We query why opportunity is not taken in the proposed plan amendment and the proposed development to improve the existing PTI, taxi ranks, mini-buses, coaches and private car drop off/pick up spaces and goods loading and loading areas.

7.We are concerned about the provision forIt is noticed in Tables 3.7b and 3.8b for the pedestrian flows at AM and PM peak Hours, for a number of vertical access points the predicted conditions are E and D respectively with the use of escalators. These conditions are considered unacceptable.

8.It is highly unsatisfactory that throughout the scheme, there is no clear illustration about the vertical movement aspects. This aspect is particularly important as we are supposed to build Hong Kong as a barrier free city in the era of ageing population.

9.The footbridge round Admiralty Centre is proposed to connect with the footbridges to Tamar. There may be constraints on the erection of supports due to the congested ground conditions and possible objections from Admiralty Centre. We have yet to be convinced that the proposed connection is feasible.

10.The proposed levels of landscaped podia may not be as user friendly as intended. Vertical movement and access are a pre-requisite yet to be assured. Past experience of gardens at upper levels being inaccessible and unpopular need to be addressed.

11.The feasibility study carried out prior to the amendments bring proposed and exhibited appears to attempt to justify an already determined move instead of being open and

12.The above concerns and queries collectively lead to the conclusion by HKIUD that the proposed amendments items B1 B2 and B3 are ill conceived, lack substantial justification, and we therefore unsupportable.

13.The HKIUD objects to the proposed Amendment Items B1, B2 and B3 for reasons stated in paras 1 to 15.

14.Since we object to Amendments B1, B2 and B3, we also object to the proposed amendment to the Notes (b), (c) and (e), as these are mainly technical amendments that are only necessary in a package if Amendment items B1, B2 and B3 are approved.