HKZM bridge unjustified

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    Here’s a letter to government from Clive Noffke of Green Lantau Association:

                                18 October 2008
    Mr Francis Ho
    Permanent Secretary for Transport and Housing
    14 – 16/F  Murray Building
    Garden Rd.
    Hong Kong

    Dear Mr. Ho

    Consultation on the HZMB (HKL), BCF, TMCLKL and TMWB

        The Green Lantau Association has been invited to take part in ‘focus group’ meetings on these 4 infrastructure projects.   This initiative, to seek prior public comments on massive infrastructure proposals, gives an appearance of open government. Also potentially encouraging is the coordination of the 4 related projects into a single consultation.  We therefore attended one such meeting for green groups in the hope, unfortunately unrealized, that this consultative process would allow fundamental examination of the proposals. 

        The administrative approach to public understanding and acceptance of its proposals remains seriously flawed. We would wish to place on record our concerns both over the substance of the consultation, and also the justification for the HZMB, the key driver of the 4 projects.  These concerns are such that it is difficult for us to take part in a process where the outcome is both pre-decided and inadequately justified.  In saying this we do not criticize the organisers of the present consultation, the Kadoorie Institute and others – the limits of what may be revealed, and achieved, were not set by them.

    Substance of the Consultation

    Unfortunately this consultation does not allow participants to question either the justifications of the projects, their scale, or their location.  These essential elements have been pre-decided for us, and the studies which have apparently established these are as ever, unavailable. 

        This consultation is therefore in essence, little different from previous exercises where minor changes might be entertained if sufficient local pressure,  and where concerns are flashed up to ensure consultants include matters they may otherwise overlook.  In short, comments on the design – ‘the colour of the paint’, are about all that is on offer.

      We had understood from statements made by the Chief Executive that such top-down decision making was no longer a feature of the administrative style, but clearly this is not yet so.

    Justifications for the HZMB

        We would preface our comments by observing that the Transport Bureau was reported in the SCMP on 3 October 2001 as saying that a bridge to the western delta would not be needed for 20 years. 

        We note that the only justification study that we are aware of was undertaken by the Institute of Comprehensive Transportation in 2003. This report remains confidential and no detailed findings have been released – even to LegCo.   There has however been a plethora of unsubstantiated statements of economic benefits that HK will derive. The lack of any quantification renders these impossible to verify, or accept.  Of particular concern is the expressed view that HK’s container port will benefit, when informed industry sources believe the port to be a sunset industry given the obvious financial and geographic realities.

        We note that that despite (a) the development of mass passenger rail networks in the western delta coupled with our own link to the airport and Tung Chung, and (b) the supposed HK cornerstone of railways as mass people movers, the HZMB is archaically, a road bridge only.

        We believe that with world oil prices at historic levels, and the likelihood of having reached the Peak Oil situation of rapidly reducing supplies, reliance on road transport for the movement of goods within the delta is an obsolete technology. Water transport as evidenced by the River Trade Terminal is far more sustainable.

        We note that any private sector enthusiasm to develop the HZMB under a BOT arrangement has evaporated. This is due to the extraordinary capital commitment coupled with the realization that likely traffic volumes and competitive tolls can never offer an economic return.   The decision of HKG to build the HZMB with public funds confirms this – the cruise ship terminal being another example.

        We note the avowed intention of the HZMB to open up the western delta to development using HK venture capital (the ‘3 hour driving distance’). We consider development of the western delta a massive setback to energy supply and air quality within the region, and do not support public funds being expended to provide external investment opportunities to private investors.

        We do not support the building of unneeded infrastructure as a means of reducing unemployment in the construction industry. The economic benefits are short lived but the environmental costs are perpetual.   The 1980s employment model seems to be entrenched however at the highest level.  We have earlier formally suggested that environmental rectification works can achieve both employment and an improvement of our built environment.

        We note that the HZMB will be massively damaging to the environment. The failure to yet undertake a formal EIA assessment open to public scrutiny is also noted. There will be loss of dolphin habitat, loss of visual amenity, and an increase in noise and air pollution. The cumulative effect of the HZMB, the 3 related road projects, and proposed reclamation projects at Tung Chung (the Town extension and the Logistics Park), will be immense. As ever the trade-offs have never been properly assessed in terms of true need versus real loss.

        We read that the HZMB is intended to promote social and economic integration with the delta.  So too would a rail link, or a bridge better positioned to reflect the needs of cross-delta transport.

        We are left with the realization that the HZMB is not justified on economic grounds, represents a transport solution that is outdated, is unsuited to realities within the delta, will contribute to further environmental degradation both in HK and the region, is a massively costly temporary palliative to unemployment, and is being built for reasons quite unrelated to measurable outcomes – in short for political reasons only.

        Having the benefit of the Policy Address, we are left in no doubt that these, our comments, will be completely ineffectual. 

    Yours sincerely

    Clive Noffke
    for Green Lantau Association

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