The Hong Kong Institute of Landscape Architects (HKILA) in collaboration with the Hong Kong Institute of Architectural Conservationists (HKICON)
Response to High Court’s Judgement on Conditional Approval given to the Environmental Impact Assessment (EIA) Report of the Proposed Housing Development at Fanling Golf Course
The Hong Kong Institute of Landscape Architects (HKILA) and the Hong Kong Institute of Architectural Conservationists (HKICON) welcome the recent court decision to overturn the conditional approval of the Environmental Impact Assessment (EIA) Report concerning the Fanling Golf Course. While we support the vision of the Northern Metropolis Development Strategy Report and the Northern Metropolis Action Agenda 2023, we recognise the exceptional cultural landscape and ecological value of the Fanling Golf Course and its significant role in the holistic design and planning of the Northern Metropolis.
We stress the significance of preserving the integrity of the Fanling Golf Course to uphold its exceptional cultural landscape and heritage value, which has been widely acknowledged locally and internationally. We urge the Government to thoroughly reassess all viable options for preserving the Old Course of the Fanling Golf Course and consider appropriate planning to preserve its integrity and authenticity. To achieve this mission, HKILA and HKICON have jointly established a Working Group on Cultural Landscapes, which engages interdisciplinary experts to offer constructive advice to the Government and the public.
We are also encouraged by the ruling’s recognition of the importance of the Cultural Heritage Impact Assessment (CHIA) and Landscape and Visual Impact Assessment (LVIA) in the EIA reports. We respectfully call upon the Government to pursue initiatives that enhance the conservation of existing cultural landscape assets in Hong Kong based on the following recommendations:
1. Holistic planning of Fanling Golf Course within the Northern Metropolis
Fanling Golf Course is located at the centre of the Northern Metropolis and holds strategic significance. With its rich cultural and natural assets, the Fanling Golf Course demonstrates a unique cultural landscape of the northern New Territories. In fact, it has received the prestigious recognition of the 2023 UNESCO Asia-Pacific Awards for Cultural Heritage Conservation. In the long term, cultural landscape should be incorporated into Outline Zoning Plans (OZP) to regulate, conserve, and manage such heritage assets in a sustainable manner. This approach could be adopted by referencing the successful area-based protection of natural landscapes and habitats in the OZP.
2. Formulating policies and guidelines on the cultural landscape
Currently, heritage conservation policy prioritises the preservation of buildings and structures yet overlooks the significant value of cultural landscape. We recommend that the Government to establish an interdisciplinary professional platform to review the definition of “site of cultural heritage” beyond buildings and structures to explicitly cover cultural landscape in heritage conservation. The Government should also develop policies and guidelines for cultural landscape that emphasises holistic conservation and management approaches to promote cultural continuity and sustainable development.
The Antiquities and Monuments Office’s (AMO) current grading system has covered a few clusters of buildings / cultural landscapes and non-building sites. It was a good step forward, and potentially, it could pave the way for a full review of the grading assessment process to include the setting of graded buildings and heritage sites in general.
3. Establishing a database on the cultural landscape
To ensure an effective regulatory framework for heritage conservation and to avoid inappropriate development or land-use changes that may impact the cultural landscape, we recommend the Government establish a cultural landscape database to identify and recognise significant historic urban and rural landscapes, heritage trails, and other important historic sites in Hong Kong by deploying Geographic Information System (GIS) and innovative technology for an accurate database. The initiative requires funding support for research, documentation, and conservation efforts for cultural landscapes while providing resources and technical assistance to aid private owners and local communities in preserving heritage assets.
4. Partnership on the promotion of cultural landscape
We recommend that the Government partner with relevant stakeholders and explore suitable use of land with cultural landscape value in Hong Kong, such as, but not limited to, the Fanling Golf Course. To promote public awareness and appreciation of cultural landscapes, collaborations with relevant stakeholders, including professional institutes, local communities, universities/schools, and non-governmental organisations, are essential. In this sense, the Working Group on Cultural Landscape, jointly established by HKILA and HKICON, is a suitable platform to cultivate partnerships with international organisations, such as UNESCO, government departments, and private and public institutions to facilitate knowledge exchange and localise the scope of cultural landscape in Hong Kong.
5. Nominations for registration of Old and Valuable Trees (OVTs) at the Fanling Golf Course
Fanling Golf Course has many beautiful mature trees which form an indispensable part of the cultural landscape. Concerning the mature trees within the 32ha land proposed to be resumed by Government on 1st October 2023, as suggested in the Judgement, “the starting point is to recognise that Old and Valuable Trees (“OVTs”) can only formally exist, or be registrable because they are, on unleased government land. But it is obvious that land which is about to be taken back and become unleased government land may have on it potentially registrable OVTs.”
The 32ha of the Old Course proposed to be resumed by the Government contains 222 potentially registrable OVTs. We recommend the addition of these trees to the OVT Register in accordance with DEVB TC(W) No. 5/2020 as an invaluable asset to our community that will positively impact the city.
6. Involvement of Registered Landscape Architects and Architectural Conservationists in Advisory Council on the Environment (ACE)
It is self-evident that Hong Kong’s landscape is a foundational element of our environment, and the preservation and protection of Hong Kong’s landscape should form a vital part of strategic policy on the environment. The case of the proposed housing development at Fanling Golf Course has revealed the need for quality assessments of Landscape Visual Impact Assessment (LVIA) and Cultural Heritage Impact Assessment (CHIA) under the EIA framework. We recommend the appointment of Registered Landscape Architects under the Landscape Architects Registration Ordinance (Cap. 516) and Architectural Conservationists to the Advisory Council on the Environment (ACE) to ensure the voices of relevant expertise are represented in the EIA assessment process. Both LVIA and CHIA reports should also be conducted under the supervision of Registered Landscape Architect and Architectural Conservationist.
7. Introducing Registered Landscape Architects to supervise and safeguard the quality of Landscape and Visual Impact Assessment (LVIA) and tree survey in EIA
One of the major arguments in the EIA report is related to the quality and accuracy of landscape resources and tree surveys. We strongly urge the Government to safeguard the quality of these surveys by enforcing the requirements that LVIA and tree surveys must be undertaken under the supervision and endorsement of Registered Landscape Architects listed under the Landscape Architects Registration Ordinance (Cap. 516) to ensure the quality of surveys and assessment in future EIA reports.
With the growing local engagement and international recognition of Hong Kong’s cultural landscape sites, HKILA and HKICON believe proactive conservation planning of the city’s historic and cultural landscape resources is essential for enhancing its reputation as a highly liveable and sustainable city. We are committed to supporting and contributing to Hong Kong’s sustainable development and look forward to collaborating with the Government and stakeholders in our shared mission of heritage conservation.