MPC Paper No.

Y/K10/4B
For Consideration by
the Metro Planning Committee
on 9.7.2021

APPLICATION FOR AMENDMENT OF PLAN

UNDER SECTION 12A OF THE TOWN PLANNING ORDINANCE

APPLICATION NO. Y/K10/4

Applicant : The Kowloon City Christians’ Church (KCCC) represented by

DeSPACE (International) Limited

Plan : Draft Ma Tau Kok Outline Zoning Plan (OZP) No. S/K10/27
(currently in force)

Draft Ma Tau Kok OZP No. S/K10/25 (in force at time of

submission)

Application Site : 40 Lung Kong Road, Kowloon City, Kowloon

Site Area : About 637.59m2

Lease : (a) New Kowloon Inland Lot (NKIL) No. 3646. Lease term
extended up to 30.6.2047
(b) Restricted to a non-profit-making school and subject to design,
disposition and height, cessation or diminution of user clause and
other conditions as contained in the lease
(c) The school’s assembly hall for religious services shall be
permitted at such times as the Secretary for Education may
approve in writing

Zoning : “Government, Institution or Community” (“G/IC”)

[Maximum building height (BH) of 3 storeys, or the height of the

existing building, whichever is the greater]

Proposed : To Amend the BH Restriction of the Application Site from 3 Storeys

Amendment to 45 Metres above Principal Datum (mPD)

1. The Proposal

1.1 The applicant proposes to amend the BH restriction of the application site (the Site)
(Plan Z-1) from 3 storeys to 45mPD to facilitate redevelopment of an existing
building, the Cornerstone Education Centre, for school and religious institution uses
(Plans Z-1 and Z-2). The Site falls within an area zoned “G/IC” on the draft OZP
No. S/K10/27 and is subject to a BH restriction of 3 storeys. Under the “G/IC” zone,
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‘School’ and ‘Religious Institution’ are Column 1 uses which are always permitted.
As the proposed redevelopment with a building height of 45mPD exceeds the BH
restriction of 3 storeys as stipulated on the OZP, amendment to the OZP under s.12A
of the Town Planning Ordinance (the Ordinance) is required.

1.2 The existing 3-storey building at the Site was constructed in the 1960s for school use1.
Since 1992, the building has been used by the non-profit making Cornerstone
Education Centre (operated by the applicant) providing various educational services to
the community, including tutoring classes for children and leisure classes for adults.
An assembly hall for religious services is located on the G/F of the existing building.
The Site is accessible via Lung Kong Road (Plan Z-2). According to the applicant,
there are currently no car parking facilities provided within the Site due to site
constraints.

1.3 The redevelopment proposal comprises a 9-storey (45mPD) school-cum-church

building over a 2-storey basement car park (Drawing Z-7). According to the Traffic
Impact Assessment (TIA) submitted by the applicant, a total of 31 private car parking
spaces will be provided in accordance with the high-end of Hong Kong Planning
Standards and Guidelines (HKPSG). A run-in/out point is proposed at the west of
the Site at Lung Kong Road (Drawing Z-11). A total of three meter parking spaces
outside the Site is proposed to be relocated to 20 – 26 Lung Kong Road (Drawing
Z-11).

1.4 The proposed floor plans, section plan, artist impressions, photomontages, proposed
buffer distance and access arrangement plan submitted by the applicant are at
Drawings Z-1 to Z-15. The major development parameters and floor uses are
summarized as follows:

Development Parameters Proposed Development

Site Area About 637.59m2
Gross Floor Area (GFA) Not more than 4,208m2
Plot Ratio (PR) Not more than 6.6
Site Coverage Maximum 92%
BH / No. of Storeys Maximum 45mPD / 9 storeys (plus 1 to 2
basement floors for ancillary car parks2)
Greenery Area About 76m2 (about 12% of the site area)
Parking Facilities
- Private Car 31 (including 1 for the disabled)
- Motorcycle 3
- Loading / Unloading Space 1
Major Uses by Floor B2/F to B1/F Ancillary car parks
G/F Entrance lobby of the
composite building
1/F Religious uses and worship
places (church hall)
2/F – 5/F* School (tutorial school /

1
According to record, the school building was previously occupied by Christ College, which was relocated to Sha
Tin Pok Hong Estate in 1990. Christ College is also operated by the applicant (i.e. KCCC).
2
According to the applicant’s submission, alternative arrangement such as double deck parking instead of two
basement floors may be used for provision of parking spaces. Detailed car parking arrangement will be finalised
and submitted in the GBP submission stage.
 - 3 -

Development Parameters Proposed Development

senior academy or a
learning school for the
elderly / interest classes)
6/F^ Assembly hall for school
and religious purposes
7/F# Ancillary school office with
meeting room(s)
8/F Ancillary management
office with conference
room(s)
Notes
* The applicant intends to reserve 2/F and 3/F of the redeveloped building for re-provisioning of
existing classrooms in the nature of tutorial schools. 4/F and the 5/F are proposed to incorporate
additional classrooms offering senior academy/learning school for the elderly and interest classes
respectively.
^ The applicant suggests that the assembly hall could be designed with flexible layout and open for
rental by the local community.
# The applicant proposes to provide two meeting rooms on the 7/F as alternative venues for the
community to hold district activities and events, on the basis of KCCC’s house rules and at a
reasonable rent.

1.5 In support of the application, the applicant has submitted the following documents:

(a) Application form received on 25.11.2020 (Appendix I)

(b) Supporting Planning Statement (SPS) (Appendix Ia)

(c) Further Information (FI) received on 1.4.2021 (FI_01) (Appendix Ib)

providing responses-to-comments (RtoC) table, revised
section plan, floor plans and photomontages, revised TIA,
revised Sewerage Impact Analysis (SIA), as well as
replacement pages of the SPS#

(d) FI received on 23.4.2021 (FI_02) including RtoC table (Appendix Ic)

and replacement pages of the TIA*

(e) FI received on 4.5.2021 (FI_03) including RtoC table, (Appendix Id)

updated SIA, replacement pages of the SPS and a letter
published by the Home Affairs Bureau (HAB)*

(f) FI received on 21.5.2021 (FI_04) including RtoC table, (Appendix Ie)

updated SIA and replacement pages of the SPS*

(g) FI received on 24.6.2021 (FI_05) providing further (Appendix If)

responses to comments from the Director of Social
Welfare and supplementary drawings*

# accepted but not exempted from publication and recounting requirement

* accepted and exempted from publication and recounting requirement

1.6 On 5.2.2021 and 11.6.2021, the Metro Planning Committee (the Committee) of the
Board agreed to defer making a decision on the application for two months and one
 - 4 -

month respectively as requested by the applicant so as to allow time for preparation of

FI in response to departmental comments. Upon receipt of FI on 24.6.2021, the
application is submitted to the Committee for consideration at this meeting.

2. Justifications from the Applicant

The justifications put forth by the applicant in support of the application as set out in the
SPS in Appendix Ia and FIs at Appendices Ib to If are summarised as follows:

Practical Need for Expansion of Existing Educational Facilities

(a) The existing building was constructed in 1960s and was used by the Cornerstone
Education Centre for education purpose since 1992. The building is in immediate
need for redevelopment due to its old age. There is a practical need to redevelop
the building so as to enhance its service provision.

Development Intensity Comparable with Nearby Lok Sin Tong Site

(b) Reference has been made to relaxation of BH restriction relating to a “G/IC” site at
61 and 63 Lung Kong Road (the Lok Sin Tong (LST) site) which has a site area of
about 1,830m2 and was proposed to be redeveloped into a welfare complex with a
PR of 8.8 and a BH restriction of 60mPD (Plan Z-2) proposed under the draft OZP
No. S/K10/23 in 2018. With a view that the LST site and the Site are located in
close proximity, the proposed redevelopment would be similar to the proposed LST
complex, but smaller in scale. The proposed scheme creates a harmonious synergy
with the neighboring LST welfare complex.

Provision of More Diversified Community and School Services to Meet the Growing
Demand

(c) According to the 2016 By-census, the increase in population of the Kowloon City
district is the second largest among 18 districts in Hong Kong over the past ten
years3. There is an urgency for the existing building with educational services to
undergo redevelopment so as to meet the local community needs. KCCC will
provide a diversified range of quality education services to all ages for continuous
learning, despite there is no requirement standard stated in the HKPSG for such
facilities.

Planning Merits of “Single Site, Multiple Uses” and Provision of Community Rooms

(d) Upon redevelopment, the proposed composite building could help optimize scarce
land resources and meet the community’s imminent demand for community services
(i.e. school services and church space). The goal of the redevelopment is for
expansion of existing services, which will include a wide spectrum of educational
and developmental activities.

(e) With regard to the Social Welfare Department (SWD)’s request to incorporate
subvented welfare facilities, the applicant indicates that maintaining sole ownership

3
2016 By-census shows that the population of Kowloon City district increased by 15.5% between 2006 and 2016,
second to the 22.3% increase in the Yau Tsim Mong district in the same period.
 - 5 -

of the Site is a key consideration. Renting premises to SWD or other operators

requires firm and long-term commitment of either parties; however, there may be
changes to the types of service provided, tenancies, rents, etc., to meet the changing
community and market demand. Besides, there is no room within 24m from
ground level for social welfare services as the spaces have been used for educational
services which also have the same requirements. In this regard, the proposed
community meeting rooms at 7/F will serve as alternatives for holding district
activities and events, subject to KCCC’s house rules and reasonable rents, and help
strengthen the sense of belonging of nearby residents. Similar services for the
elderly and youth have been and will continue to be provided under the scope of a
senior academy/learning school for the elderly, and the proposed interest school on
the 5/F will provide many of the functions that an Integrated Children and Youth
Services Centre provides.

Design Merits of Building Setback and Landscaping

(f) A building setback of 5m from the road kerb of Lung Kong Road is proposed in
compliance with the HKPSG requirement as an environmental mitigation measure
for air quality (Drawing Z-10). The street widening also allows better pedestrian
movement and more space for streel level greenery.

(g) A series of terraced roof gardens on the 3/F, 5/F, 7/F and the rooftop to the south
side of the building (Drawings Z-7 and Z-9) will improve the cityscape, as well as
provide sitting-out and enjoyment opportunities for future users. Full-height glass
doors to the terraces will provide visual connection between the indoor and outdoor
spaces.

(h) The building frontage on the G/F and 1/F will be designed with a view to increase
visual interest to pedestrians. The facade at the lower part of the building (up to
about 10.5m above ground) with special design elements will illustrate the concept
of bringing more energy, vitality and hope to the community (Drawing Z-8).

(i) About 76m2 (about 12% of the site area) of landscaped area will be provided on the
G/F, roof gardens on the 3/F, 5/F and 7/F and the rooftop (Drawings Z-7 and Z-9).
The landscaping will soften the building edges and enhance pedestrian walking
experience.

No Adverse Impacts

(j) No adverse air pollution impact from Lung Kong Road, Carpenter Road and South
Wall Road is anticipated with sufficient buffer distance provided (Drawing Z-10).
To mitigate the potential noise impacts, fixed window design with lockable sashes
would be adopted. Proper central air conditioning system would be provided to the
proposed redevelopment such that it will not rely on openable windows for
ventilation.

(k) The preliminary sewerage impact analysis concluded that there is no adverse impact
to the existing downstream sewerage network as a result of the proposed
redevelopment. No upgrading is required to serve the proposed redevelopment.
 - 6 -

(l) The provision of 5m building setback from the road kerb of Lung Kong Road,
stepped building height design and edge treatment with planting/greening on
multiple levels will mitigate the visual impacts.

(m) The TIA has demonstrated that the proposed redevelopment would not result in any
adverse traffic impacts onto the surrounding road network. Parking provision
would be provided on the high side according to HKPSG.

3. Compliance with the “Owner’s Consent/Notification” Requirements

The applicant is the sole “current land owner”. Detailed information would be deposited at
the meeting for Members’ inspection.

4. Background

4.1 In 2008, the Board imposed BH restrictions on the OZP for the “G/IC” and other
zones, including the Site. The BH restriction of 3 storeys for the Site reflects the
height of the existing building.

4.2 In 2018, the BH restriction on the OZP for the LST site (Plan Z-2) on Lung Kong
Road located to the west and directly across the street from the Site was amended to
facilitate a redevelopment proposal initiated by the Lok Sin Tong Benevolent Society
(LSTBS) under the ‘Special Scheme on Privately Owned Sites for Welfare Uses’
launched by the Labour and Welfare Bureau. The proposal involves redevelopment
of a 5-storey LSTBS headquarter and clinic and a 3-storey LST Primary School, into a
15-storey welfare complex for provision of various welfare facilities4. To facilitate
redevelopment of the LST site, BH restriction for the site was amended from 5 and 8
storeys to 60mPD under the draft Ma Tau Kok OZP No. S/K10/23, which was
exhibited for public inspection on 9.3.2018.

4.3 The Site was the subject of representation No. TPB/R/S/K10/23-1 (the representation)
on the draft OZP, submitted by KCCC (i.e the applicant of current application),
supporting the amendment item for relaxation of BH restriction of the LST site.
Whilst not providing any proposal on the amendment item (i.e. the LST site), KCCC
proposes to relax the BH restriction of its own site (i.e. the current application site)
from 3 storeys to 60mPD and supported it with a redevelopment proposal.

4.4 During consideration of the representations and comments in respect of the draft OZP
on 28.9.2018, Members generally agreed that there was a genuine need to redevelop
the existing building at the Site, however, the proposal to relax the BH restriction of
the Site should not be considered under the representation hearing of the plan making
process. No amendments were made to the draft OZP to meet the representations.
The draft Ma Tau Kok OZP No. S/K10/23 was approved on 8.1.2019 and
subsequently renumbered as S/K10/24.

4
Major welfare facilities in the proposed welfare complex include Nursing Home and Care and Attention Home for
the Elderly, Day Care Centre for the Elderly, Early Education and Training Centre, Primary Health Care Centre and
Ethnic Minority Supporting Service Centre.
 - 7 -

5. Previous Application

The Site is not the subject of any previous planning applications.

6. Similar Application

There is no similar rezoning application for relaxation of BH restriction on the Ma Tau Kok
OZP.

7. The Site and its Surrounding Areas (Plans Z-1, Z-2 and site photos on Plan Z-3)

7.1 The Site:

(a) is currently occupied by a 3-storey building, the Cornerstone Education Centre,

constructed in 1967 and operated by the applicant, providing mainly non-profit
making educational services to the community. The main roof level of the
building is at 22.4mPD; and

(b) is accessible via Lung Kong Road.

7.2 The surrounding areas have the following characteristics:

(a) the area, bounded by Carpenter Road, Sa Po Road, Prince Edward Road West
and Junction Road, is primarily zoned “Residential (Group A)2” (“R(A)2”)
dominated with low and medium-rise residential developments5 with ground
floor for shop and restaurant uses, and sporadically with recently redeveloped
high-rise residential developments. These “R(A)2” zones are subject to BH
restriction of 80mPD6;

(b) to the west across Lung Kong Road is the LST site (paragraph 4.2 refers)
currently occupied by the 3-storey former LST Primary School 7 and the
5-storey LSTBS headquarter and clinic, zoned “G/IC” and with a BH restriction
of 60mPD. Two street blocks to the further west along Nga Tsin Long Road is
a street block zoned “G/IC” occupied by the Kowloon City Municipal Services
Building, a clinic and an elderly health centre, subject to BH restrictions from 1
to 3 storeys;

(c) to the north across Carpenter Road is the Carpenter Road Park and Kowloon
Walled City Park within “Open Space” (“O”) zone; and

(d) to the south across a lane is a cluster of GIC facilities including a public toilet
and refuse collection point (RCP), a post office and a telephone exchange
station. These GIC facilities are subject to BH restrictions from 3 to 7 storeys.

5
The existing building height of the residential developments in the “R(A)2” zone within the same street block as
the Site is in the range of 3 to 10 storeys (about 19mPD to 39mPD).
6
“R(A)2” sites are subject to BH restriction of 80mPD as stipulated on the OZP, while sites with an area of 400m2
or more are allowed a BH restriction of 100mPD as stipulated in the Notes of the OZP.
7
The former LST Primary School was closed in August 2019 and converted into a transitional housing project for
use of not less than three years from August 2020.
 - 8 -

8. Planning Intention

The “G/IC” zone is intended primarily for the provision of GIC facilities serving the needs
of the local residents and/or a wider district, region or the territory. It is also intended to
provide land for uses directly related to or in support of the work of the Government,
organizations providing social services to meet community needs, and other institutional
establishments.

9. Comments from the Relevant Government Bureaux/Departments

9.1 The following Government bureaux/departments have been consulted and their views
on the application are summarized as follows:

Policy Aspects

9.1.1 Comments of the Secretary of Home Affairs (SHA):

(a) he has no objection to the application from religious perspective; and

(b) policy support for the application may be considered along prevailing
policy, upon receiving more details on the religious facilities, as well as
positive feedbacks from other relevant bureaux / departments.

9.1.2 Comments of the Secretary for Education (SED):

(a) no specific comments on the proposed educational facilities. In view

of the nature of the proposed school uses, no policy support would be
given; and

(b) school registration applications will be handled in accordance with

relevant provisions of the Education Ordinance (Cap. 279) and
established practice in consultation with relevant departments.
Proposed schools have to meet the statutory and administrative
requirements before granting approval for registration.

Land Administration

9.1.3 Comments of the District Lands Officer/Kowloon East, Lands Department

(DLO/KE, LandsD):

(a) no objection to the application subject to comments below;

(b) the Site is located at NKIL No. 3646 (“the Lot”), which is subject to a
lease term having been extended up to 30 June 2047. Pursuant to the
lease governing the Lot, the Lessee shall only be allowed to erect on the
lot building(s) for a non-profit making school (“the School”) whilst the
Lessee shall be permitted to use the School’s assembly hall for religious
services at such time as may be approved by the Director of Education
(i.e. Secretary for Education). The Lot is further subject to, inter alia,
(i) design, disposition and height clause; (ii) restriction on assignment
and underletting etc.; and (iii) cessation on user restriction;
 - 9 -

(c) the proposed redevelopment which comprises a composite

school-cum-church use with one floor specifically constructed for
religious purpose and an assembly hall for both school and religious
purposes will be in conflict with the existing lease; and

(d) if the planning application is approved by the Board, the owner of the
Lot has to apply to LandsD for a lease modification to implement the
proposal. However, there is no guarantee that such application would
be approved and if the application is eventually approved by LandsD in
the capacity as the landlord at its discretion, it will be subject to those
terms and conditions, including payment of any administration fee and
premium as considered appropriate by LandsD.

Traffic Aspect

9.1.4 Comments of the Commissioner for Transport (C for T):

(a) having reviewed the applicant’s responses and the revised TIA
(Appendices Ib and Ic), he has no further comments on the proposed
redevelopment. However, the applicant is required to follow up on
the following items:

(i) an assessment on the adequacy of pedestrian facilities, including

footpaths and at-grade/grade-separated road crossings to and from
the proposed development and major public transport facilities,
should be further updated after the commission of
Shatin-to-Central Link; and

(ii) agreement from stakeholders should be obtained regarding the

proposed relocation of on-street parking spaces affected by the
proposed vehicular access during the GBP or lease modification
stage.

9.1.5 Comments of the Chief Highway Engineer/Kowloon, Highways Department

(CHE/K, HyD):

consent from relevant departments, such as Transport Department and

LandsD, should be obtained regarding the location and arrangement of
run-in/out.

Environmental Aspect

9.1.6 Comments of the Director of Environmental Protection (DEP):

(a) no objection to the application from environmental perspective;

Air Quality

(b) having reviewed the FIs submitted by the applicant, he notes that
adequate buffer distance of 5m from Lung Kong Road, 25m from
Carpenter Road and 24.5m from South Wall Road would be provided
 - 10 -

by the applicant for the proposed redevelopment, and that the applicant
confirmed there are no chimneys identified within 200m distance from
the site boundary;

Waste Management

(c) the applicant is advised to minimise the generation of construction and

demolition (C&D) materials; reuse and recycle the C&D materials
on-site as far as possible; and observe and comply with the legislative
requirements and prevailing guidelines on proper waste management
for the proposed development. The applicant should observe the
relevant requirements under the Air Pollution Control Ordinance and
Waste Disposal Ordinance for asbestos control prior to demolition of
the existing building;

Noise

(d) to ensure the proposed noise mitigation measures will be incorporated

into the future development, and considering there is no mechanism to
impose approval condition for s.12A applications, control should be in
place under land mechanism by special conditions under the lease
modification to require the developer to submit a Noise Impact
Assessment (NIA) and implement the design and mitigation measures
recommended therein; and

Sewerage

(e) having reviewed the revised SIA, he has no further comments from
sewerage aspect.

Urban Design and Landscape

9.1.7 Comments of the Chief Town Planner/Urban Design and Landscape,

Planning Department (CTP/UD&L, PlanD):

Urban Design and Visual

(a) having reviewed the applicant’s responses and the revised Visual Impact
Assessment (VIA) at Appendix Ib, he has no further comments;

(b) the Site is located within the Kowloon City area to the south of the
Kowloon Walled City Park. The neighbourhood is primarily for high
density residential development with two-tier BH restriction of 80mPD
or 100mPD (for sites with an area of 400m2 or above), though it is
currently characterized by low-rise residential tenement blocks. The
other “G/IC” zone in the vicinity are subject to BH restrictions from 1 to
8 storeys and 60mPD for the LST site to the immediate west of the Site.
Given the context, the increase in BH for the Site will unlikely cause
any significant impact to the townscape character of the area;

(c) according to the applicant’s submission, a buffer distance of 5m

measured from the building line to the road kerb of Lung Kong Road is
 - 11 -

proposed. Landscape treatment at the edges of G/F and a series of roof

gardens on 3/F, 5/F, 7/F and the rooftop with vegetated edges arranged
in a slightly terraced built-form descending to the southern boundary are
adopted. Suitable transparent and articulated façade for the lower part
of the building have been provided. These measures may promote
visual interest and pedestrian comfort;

Landscape

(d) no objection to the application from landscape planning point of view;

(e) the Site is situated in an area of urban landscape character dominated by

medium-rise to high-rise residential developments with some GIC uses
nearby. No existing tree is identified within the boundary of the Site.
As indicated in the applicant’s submissions (Appendices Ia and Ib),
landscape treatments are proposed on various levels of the development,
including shrub planting on G/F and landscape areas with peripheral
planting on 3/F, 5/F, 7/F and R/F; and

(f) since there is no existing tree or landscape resource in the Site,

significant landscape impact of the proposed redevelopment is not
anticipated. The proposed redevelopment is not incompatible with the
surrounding landscape character.

9.1.8 Comments of the Chief Architect/CMD2, Architectural Services Department

(CA/CMD2, ArchSD):

having reviewed the applicant’s responses and FI at Appendix Ib, he has no

further comments from architectural and visual impact point of view. The
applicant is reminded to ensure the proposed redevelopment will comply with
all relevant Building Regulations in the detailed design stage.

Building Matters

9.1.9 Comments of the Chief Building Surveyor/Kowloon, Buildings Department

(CBS/K, BD):

(a) no in-principle objection to the application;

(b) all building works should in all aspects comply with the Buildings
Ordinance (BO) and its allied regulations. Detail comments under the
BO will be provided at the building plan submission stage;

(c) it is noted that the non-domestic site coverage (SC) of 3/F and above of
the proposed building has exceeded the permissible SC of 75% under
Regulation 20 and the First Schedule of Building (Planning) Regulations
(B(P)R). However, his department is in principle prepared to consider
applications for more flexible application of the requirements under
Regulation 20 of the B(P)R and modify the provisions thereof, on a case
by case basis. Application for modification in this respect would be
considered at formal building plans submissions stage; and
 - 12 -

(d) subject to compliance with the pre-requisite requirement of SBD

guidelines as stipulated in PNAP APP-151, the high headroom of
assembly hall for worship places on 1/F may be exempted from GFA
calculation.

Social Welfare

9.1.10 Comments of the Director of Social Welfare (DSW):

in view of the acute welfare demand, it is considered that there is a dire need
to provide sufficient welfare facilities in the area to cater for the ongoing
welfare service needs, both territory-wide and at the district level. The
applicant should consider to incorporate subvented welfare facilities at the
Site for the benefit of the community.

Fire Safety

9.1.11 Comments of the Director of Fire Services (D of FS):

(a) according to Cap. 279A Education Regulations, no part of any school

premises, except the parapet wall round a roof playground, shall be
situated at a height of more than 24m above ground level provided that
the Permanent Secretary of Education, with the advice of the Director of
Fire Services, may be notice in writing authorize that any part of such
premises be situated at such height greater than 24m as may be specified
in the notice; and

(b) the power to relax the height restriction of school at such height greater
than 24m would be dealt with under the future school licence
application, when received.

9.1.12 The following Government departments have no objection/no comment on

the application:

(a) Chief Engineer/Construction, Water Supplies Department;

(b) District Officer (Kowloon City), Home Affairs Department;
(c) Chief Engineer/Mainland South, Drainage Services Department (CE/MS,
DSD); and
(d) Commissioner of Police.

10. Public Comments Received During Statutory Publication Period

10.1 The application and the first FI (Appendices Ia and Ib) were published for public
inspection on 4.12.2020 and 7.5.2021 respectively. Within the two statutory public
inspection periods, a total of 45 public comments were received. Among the public
comments received, 43 support the application (Appendix IIa), one objects to
(Appendix IIb) and one provides views (Appendix IIc) on the application. The
major views are summarised as follows.

10.2 The Hong Kong Institute of Family Education, 2 shop operators in Kowloon City,
24 students/parents/teachers/working partner of the Cornerstone Education Centre,
 - 13 -

as well as individuals, support the application mostly on the following grounds:

(i) the Cornerstone Education Centre is already at its full capacity and services
could not be expanded to meet the demand for GIC facilities upon the pressure
of development and ageing population in Kowloon City. Amendment of the
existing BH restriction encourages a more effective land use and can increase
the variety of services provided, while utilising its strategic location of
proximity to the Sung Wong Toi Station to offer services to both residents and
visitors;

(ii) the Cornerstone Education Centre has been providing education of high quality
and opportunity should be granted to further enhance its services;

(iii) the redevelopment proposal of providing a welfare complex incorporating

religious institution and services for the children and elderly is in line with the
Government’s “single site, multiple uses” policy;

(iv) the current building is in a poor condition, bearing a heavy cost of maintenance
and in urgent need of redevelopment. The redevelopment can facilitate the
provision of barrier-free access to encourage those with special needs to enjoy
the services at the centre;

(v) various design merits including provision of greenery, landscaping and

widening of pavement in the proposal improve the streetscape and enhance
visual quality; and

(vi) the proposed redevelopment would not cause adverse environmental and traffic
impacts.

10.3 The Owners’ Corporation of 61 South Wall Road objects to the application on the
grounds that the proposed increase in BH restriction would create adverse impact on
traffic and air ventilation aspects, and that there are already many similar education
centres in the area such that the redevelopment will not bring forth any positive
impact.

10.4 An individual expresses the views that the outdated design of the current building at
the Site could not accommodate barrier-free access and deters the elderly and those
with special needs in using the services at the centre.

11. Planning Considerations and Assessments

11.1 The application is for amendment of BH restriction to facilitate redevelopment of an

existing 3-storey building which was constructed in the 1960s and currently occupied
by the Cornerstone Education Centre providing education services to the community
since 1992. The redevelopment proposal comprising a 9-storey (45mPD)
school-cum-church development over a 2-storey basement car park with a church
hall (1/F), schools (2/F to 5/F), an assembly hall for school and religious purposes
(6/F) and ancillary office facilities (7/F to 8/F). While ‘School’ and ‘Religious
Institution’ uses are always permitted in the “G/IC” zone under the OZP, amendment
of the BH restriction of 3 storeys to 45mPD for the proposed redevelopment is
required.
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Amendment of BH Restriction

11.2 The proposed redevelopment with a BH of 45mPD (9-storey) is not incompatible

with the surrounding residential developments with BH restriction of 80mPD (or
100mPD for sites with an area of 400m2 or above), and other nearby GIC facilities
subject to BH restrictions from 1 to 8 storeys and 60mPD for the LST site upon
redevelopment (Plans Z-1 and Z-2). Given the site context and as illustrated in the
VIA, CTP/UD&L, PlanD considers the proposed redevelopment is unlikely to cause
any significant impact to the surrounding townscape. CA/CMD2, ArchSD has no
objection to the application taking into account the BH restriction of adjacent
residential developments. The proposed uses are always permitted under the
“G/IC” zone and are considered not incompatible with the surroundings which are
mainly residential developments with retail uses at the lower floors, and GIC uses.

Planning and Design Merits

11.3 The applicant proposes to adopt various measures including a 5m buffer distance
from the road kerb of Lung Kong Road, terraced roof garden with vegetated edges on
the 3/F, 5/F, 7/F and the rooftop, as well as façade treatment at the lower part of the
building (Drawings Z-3 to Z-10). CTP/UD&L, PlanD considers these measures
may promote visual interest and pedestrian comfort. A total landscaping area of
about 76m2 with seating facilities is proposed at different levels of the development
to enhance landscape quality (Drawings Z-3 to Z-6). CTP/UD&L, PlanD has no
objection to the proposed redevelopment from landscape planning point of view.

Technical Aspects

11.4 On traffic aspect, C for T has no adverse comments but requires the applicant to
provide an updated assessment on the adequacy of pedestrian facilities after
commissioning of Shatin-to-Central Link, as well as agreement from stakeholders
regarding relocation of street parking spaces. Other concerned departments
including DEP and CE/MS, DSD have no adverse comments on the proposed
redevelopment. DEP is of view that the developer is required to submit an NIA and
implement the design and mitigation measures recommended therein. Such
requirements will be followed up in lease modification stage.

Provision of Social Welfare Facilities

11.5 The applicant explained in paragraph 2(e) above (Appendix If) that maintaining sole
ownership of the Site is a key consideration such that no welfare facilities as
suggested by DSW would be provided in the proposed scheme. Besides, the
applicant also explained that as various school facilities will be provided at the lower
levels of the building, there is no more rooms to accommodate the welfare facilities
suggested by DSW, of which most are required to be located within a level of 24m
above ground. The applicant has also proposed that two meeting rooms on the 7/F
could be available to the local community for holding district activities and events.
Also, the educational and developmental services for the elderly and youth will be
provided in the proposed scheme to meet community needs.
 - 15 -

Public Comments

11.6 The supporting comments are noted. Regarding the opposing public comment
concerning traffic, air pollution and the benefits of the proposal, comments from
relevant government departments in paragraph 9 and the planning assessments in
paragraphs above are relevant.

12. Planning Department’s Views

12.1 Based on the assessment made in paragraph 11 and having taken into account the
public comments mentioned in paragraph 10, the Planning Department has no
objection to the application to amend the BH restriction of the Site from 3 storeys to
45mPD to facilitate the proposed redevelopment.

12.2 Should the Committee decide to agree/partially agree to the subject application, the
proposed amendment to the Ma Tau Kok OZP would be submitted to the Committee
for agreement prior to its gazetting under the Ordinance.

12.3 Alternatively, should the Committee decide not to agree to the application, the
following reason is suggested for Members’ reference:

the applicant has failed to demonstrate that there are sufficient planning and design
merits for the proposed amendment of BH restriction.

13. Decision Sought

13.1 The Committee is invited to consider the application and decide whether to agree,
partially agree, or not to agree to the application.

13.2 Should the Committee decide to partially agree/not to agree to the application,
Members are invited to advise what reason(s) for the decision should be given to the
applicant.
 - 16 -

14. Attachments

Appendix I Application form received on 25.11.2020

Appendix Ia Supporting Planning Statement
Appendix Ib FI_01 received on 1.4.2021
Appendix Ic FI_02 received on 23.4.2021
Appendix Id FI_03 received on 4.5.2021
Appendix Ie FI_04 received on 21.5.2021
Appendix If FI_05 received on 24.6.2021
Appendices IIa to IIc Public Comments
Drawings Z-1 to Z-6 Floor Plans (G/F, 1/F, 3/F, 5/F, 7/F, Roof)
Drawing Z-7 Section Plan
Drawings Z-8 & Z-9 Artist Impression
Drawing Z-10 Proposed Building Setback/Buffer Distance
Drawing Z-11 Proposed Access Arrangement
Drawings Z-12 to Z-15 Photomontages
Plan Z-1 Location Plan
Plan Z-2 Site Plan
Plan Z-3 Site Photo

PLANNING DEPARTMENT
JULY 2021