Key Comments and Responses

5.1     Introduction

5.1.1  This section of the report sets out the key comments raised during the Consultation. Comments are grouped by subject. The consultee who made the comment is referenced by an abbreviation, which can be cross-referred to the Indexes of Comments in Appendix E. The response to each issue is set out below each key comment. 

5.2     Involving the Public in the Study 

5.2.1  There were concerns that the Consultation Digest and the subject matter in the First Stage Consultation were rather technical in nature (TPB/FGW) and that the public might find them difficult to grasp. Also, it was suggested that additional means, such as newspaper advertisement, should be made to publicise the Study. 

Response

5.2.2  The initial stage of the Study was mainly concerned with the approach and methodology, which are by their very nature rather theoretical and technical. The Consultation Digest, which contained more technical information of the Study, was targeted at stakeholders. For the general public, who might not have the necessary technical knowledge to fully comprehend the subject, an Information Pamphlet in simpler language was also prepared and deposited at District Offices, public libraries and the Planning Enquiry Counter at Planning Department to stimulate their participation in and awareness of the Study. Efforts will be made to further publicise the Study in the next stage of consultation.

5.3    The Scope and Objectives of the Study

The Scope of the Study

5.3.1  In the Focus Group Workshop, it was mentioned that the Study should take into account the South China context of the landscape and the continuity of landscapes with neighbouring Shenzhen.

5.3.2  Also during the Focus Group Workshop, it was enquired whether both urban and rural landscapes would be treated using the same set of criteria, and whether the Study would focus more attention on certain more sensitive landscapes. 

Responses

5.3.3  As the objective of the Study is to assess the landscape resources of Hong Kong, the study area is confined to the territory of Hong Kong. It would also be impractical for the Study to conduct field survey across the boundary in mainland China. However, in areas of Hong Kong close to the boundary, the effect of the visual setting of Shenzhen on the landscape of Hong Kong will be taken into account.

5.3.4  The objective of the Study has been to adopt an approach that is capable of dealing equally with urban and rural landscapes and the same set of criteria will be applied to both. Efforts will be applied equally to all areas of the Hong Kong landscape (see also Para.5.6.2).

The Relationship of the Study to Other Relevant Studies

5.3.5  A comment frequently made during briefings concerned the relationship between the Study and other recent or ongoing studies in related disciplines, such as:

Responses

5.3.6  The Study will take due regard of the findings of other relevant studies, where those findings have reached a reasonably finalised state and where they are available.

5.4    The Study Methodology

Background Material and Research

5.4.1  In setting out the best approach to undertake the Study, six relevant overseas studies have been reviewed, including studies in the United Kingdom, USA, New Zealand and Indonesia. With particular reference to the approaches adopted for historic, natural and cultural landscapes, the AAB enquired as to the reasons for the choice of these case studies.

5.4.2  In addition, a list of books and articles relating to the identification of local landscape features and areas of landscape value was recommended by certain consultees (A8/A9).

Response

5.4.3  The objective of choosing case studies was to draw on the best experience available world-wide and if possible, to find case studies covering landscapes similar to that of Hong Kong. Those countries with the longest and deepest experience in landscape mapping (including issues of historic, natural and cultural landscape) are the US and UK and so case studies were selected from these locations. However in the Asian Pacific region, no readily accessible and detailed accounts could be found of systematic approaches to landscape mapping, except in Indonesia. The case studies in New Zealand were chosen because New Zealand has a well-developed landscape mapping tradition and because they covered coastal and suburban areas, which are in some ways similar to the conditions in Hong Kong.

5.4.4  Other literature references provided by consultees (A8/A9) will be taken into account as the Study progresses.

Looking at Landscape in Three Dimensions

5.4.5  A point raised several times during the Consultation was that landscape should be considered in three dimensions. The HKIP (A11) considered that a 2-D 'landscape map' might fail to capture the true character and qualities of landscape. Participants in the Focus Group Workshop also pointed out shortcomings of a 2-D map, which could not reveal the physical diversity of landscape, blocking of views to a high landscape value area and the effects of degraded surroundings.

Response

5.4.6  The objective of the Study is to characterise and evaluate landscape as a three dimensional (3-D) entity. This will be achieved by making crucial decisions on site during field survey, when 3-D qualities can be best appreciated. It is at this point that a 3-D view of landscape will be taken and the concerns of consultees addressed. These 3-D judgements will then be captured in the database and represented on the Landscape Character Map, which is a common technique in the field of landscape mapping.

5.5    The Preliminary Landscape Classification

The Landscape Classification

5.5.1  Grouping and classifying landscapes into LCAs and LCTs is central to the Study approach. A member of the AAB commented that since every place was unique, the need and rationale for such landscape classification should be provided. 

Response

5.5.2  Although classifying landscapes into LCAs/LCTs is not the only approach to landscape assessment and mapping, the current landscape classification recognises that concurrences of geology, landform, topography, vegetation and land use give rise to landscape types which have a great deal in common. This approach establishes a practical framework for assessing a diversity of landscapes. It does not deny the unique characteristics of each landscape, as every landscape is assessed individually within this framework.

Landscape Character Types

5.5.3  During the consultation with the HKIP, a query was raised as to whether the LCTs identified were specific to Hong Kong. It was suggested that LCT titles should be self-explanatory as far as possible, and that the names of LCTs in Chinese and English might have subtly different meanings. Members of the HKILA also pointed out that it would be important to distinguish between 'land use' and 'landscape' as these were not the same thing.

Response

5.5.4  Because of the unique landscape characteristics of Hong Kong (in particular in the urban area), all LCTs have been developed specifically for this Study and for the Hong Kong landscape. For ease of reference, LCT titles need to be relatively concise and at the same time need to describe the essence of an LCT, which is often only subtly different from another LCT. We shall keep the titles under review so as to make them more intelligible. In addition, care will be taken in the translations of LCTs in different languages to avoid confusion and misunderstanding. Also, the landscape classification has been produced on the basis that 'land use' is only one of a number of factors which give a 'landscape' its character.

The Boundaries between Different Landscapes

5.5.5  The transition from one landscape area to another is usually gradual. In the Focus Group Workshop there was an enquiry on how boundaries between LCAs would be determined. The enquirer suggested that rather than using solid lines, 'gradients' or blurred lines should be used where appropriate to reflect gradual change.

Response

5.5.6  It is well recognised that landscape is a continuum and that character does not in general change abruptly. However, standard practice in the case studies examined is to use a solid line to define the boundaries between LCAs. Usually, for the sake of certainty, this boundary follows a definable feature on the ground, such as a ridgeline, road, woodland, coastal feature, fence or drainage channel etc. 

The Scale of Landscape Character Areas

5.5.7  There were some general concerns on the size of LCAs. A member of the CPC enquired if the less homogeneous urban area would be divided into smaller sub-units. The TPB considered that there might be a need to break down landscape features into even smaller components so as to identify individual characteristics and to generate patterns. Participants in the Focus Group Workshop and members of the HKILA also felt that if the size were too big, sufficient detail would not be captured. Conversely, a member of the CPC felt that if LCAs were too small, then wider patterns and connections in the landscape would be lost. The HKIP stated that the choice of the size would affect the applicability and effectiveness of the findings for use in landscape impact assessment (as part of the EIA process).

Response

5.5.8  Initially, the Study would use 5 hectares as a yardstick to delineate LCAs. This is the smallest size which can be reasonably classified as a 'landscape' If one goes to smaller units than this, the effect of land use on classifications tends to become unduly predominant. However, it is agreed that larger LCAs would be appropriate in rural area where landscape diversity is less, whilst smaller LCAs (in some rare cases slightly smaller than 5ha) would be more appropriate in urban area where landscape diversity is greater. In addition, the Study will include an overview of landscape at the sub-regional scale, to ensure that wider patterns and connections in the landscape are adequately captured. With regard to the use of the Study's findings in EIAs, the landscape/visual component of an EIA normally adopts a scale of classification appropriate to the particular EIA Study. However, there is no reason why the LCAs/LCTs identified in this Study could not be employed in certain EIAs.

Additional Landscape Character Types

5.5.9   In the Consultation Digest, an initial 67 LCTs were suggested at local level to cover the different types of landscape in Hong Kong. Some consultees suggested the list be extended in order to better explain or reflect the landscape of:

5.5.10  Some consultees suggested additional LCTs including:

Response

5.5.11 The preliminary list of LCTs will be reviewed in the light of these comments as the Study proceeds and all suggestions for additional LCTs will be taken into consideration. However, only areas of significant size and with a clearly identifiable character can be considered for incorporation as LCTs. A number of the suggestions above are of limited scale and might more appropriately be considered as landscape features rather than types. An interim list of revised LCTs is provided in Appendix F. It must be emphasised that the list will be continuously refined as the Study proceeds when more findings are avilable from field survey.

5.6     Landscape Evaluation

Minimising Subjectivity in Evaluation

5.6.1  A general issue that was repeatedly raised was the extent to which subjectivity is involved in the judgement of landscape value generally and in particular, in the evaluation of specific features such as buildings or 'eyesores' (ACE/HKIEIA/HKIP/FGW). The HKIP and TPB further pointed to the need to define evaluation criteria clearly to minimise subjectivity. The HKIEIA recommended setting up a special committee containing appropriately qualified professionals to provide input to the evaluation. The HKILA and other consultees (HKIP/FGW) suggested that the evaluation should not simply reflect professional values but also public views. Some consultees suggested a public perception survey would be a good way of eliciting public values (HKILA/FGW). Also, a Member of ACE proposed measuring landscape value in monetary terms, i.e. the extent that people were willing to pay to keep the landscape intact. 

Response

5.6.2   The Study recommended four evaluation criteria, namely: landscape character; landscape condition; landscape sensitivity and landscape value. Technical guidelines on the application and interpretation of the criteria are contained in Technical Report No. 2, which is available for reference at Planning Department's website. There is inevitably a degree of subjectivity involved in the evaluation process of landscape. However, this is not to suggest that such judgements are in any way covert, arbitrary or irrational. Key to the evaluation process are the principles that value judgements will be made by trained professionals:

5.6.3   When the results are presented to the public, it is hoped that a consensus could be reached through extensive community discussion on the landscape value determined.

5.6.4  Public perception surveys on landscape value have been used occasionally in some landscape studies around the world. However, considerable doubt has been raised in academic literature as to whether meaningful measurements of public opinion can be obtained from such surveys.

5.6.5  There are insurmountable practical obstacles to using monetary value to assess landscape value. In particular, almost every landscape is unique (and therefore cannot meaningfully be compared with others). There are also other practical problems in separating the aesthetic value of land from other aspects affecting people's willingness to pay and therefore its value, such as location, permitted land use, natural resource value, etc. 

Relative Weightings of Different Evaluation Criteria

5.6.6  The CPC and HKILA also questioned the relationships between different evaluation criteria and whether there would be any relative weighting among criteria.

Response

5.6.7  Each evaluation criterion will contribute to the Study in a different way. The results of each evaluation cannot be compared with the results of other criteria and so cannot and would not be weighted.

Evaluating Landscape Process

5.6.8   Whilst the Study mainly deals with the appearance of landscape, the TPB suggested that consideration could also be given to evaluating the natural process of landscape such as the influence of terrestrial and aquatic systems. One consultee (A2) went a step further and said that in the landscape evaluation, it was important to understand and include the forces which drive landscape change.

Response

5.6.9  The importance of ecological and natural processes in the formation of landscape is acknowledged. As such processes are generally well captured in ecological and cultural/heritage studies, this study will focus on the visual aspects of landscape but will include a broad overview of the processes which have helped to shape the landscape of Hong Kong. Future forces for change will be recognised by an analysis of major planned and committed developments and assessment of the condition and sensitivity of landscape to potential change during landscape evaluation. There is also opportunity to update periodically the completed Landscape Character Map over time to reflect change in the landscape.

Landscape Protection/Enhancement

5.6.10 The CPC, AAB, TPB and HKIP all enquired whether the Study would identify eyesores or areas of natural and cultural landscape for protection or enhancement (i.e. 'areas of landscape potential'). One consultee cited the example of major drainage systems that could have potential for enhancement as wetland-like ecosystem (A6).

Response

5.6.11 The main objective of the Study is to provide baseline information on the landscape resource of Hong Kong. Identifying specific landscapes for designation will not be carried out in the Study. Nevertheless, the Landscape Character Map will evaluate for each landscape area its character, condition, sensitivity and value. This data could be used as the basis for designation of special areas if necessary. Also general management strategies for LCAs will be suggested as part of the Study's recommendations to maximise landscape potential, though specific projects or enhancements will not be mentioned. 

Landscape Rarity

5.6.12 The HKIEIA suggested the issue of rarity as a potential criterion of value and wondered how rarity of landscapes could be judged.

Response

5.6.13 Rarity is an issue which will be considered during the evaluation of landscape value as one of the attributes to appraise the strength of sense of place of a LCA. It can be assessed at a number of levels, e.g. locally, nationally or globally.

Landscape Sensitivity

5.6.14 The sensitivity of landscape to development is one of the evaluation criteria proposed by the Study. Some consultees (HKILA and HKIEIA) suggested that landscape sensitivity depended on which scale one looked at the landscape. 

Response

5.6.15 The sensitivity of any landscape will be judged consistently for each LCA, which is the basic landscape unit in the Landscape Character Map.

Identifying Scenic Viewpoints and Routes

5.6.16 A common issue raised by CPC, ACE, HKIEIA, HKILA and other consultees (A8/FGW) was the relevance of viewpoints and routes to the appreciation of landscape. These consultees wondered whether the Study would identify 'scenic viewpoints', 'strategic view corridors' or 'scenic routes'. 

Response

5.6.17 The comprehensive identification of specific scenic views or view corridors would require a further much more detailed study to establish criteria for viewpoint selection and strategic importance. However, where the availability of major strategic views materially influences landscape character (as on Victoria Peak or Sunset Peak for example), this will be noted in descriptions of LCAs in the Study.

The Relationship of Landscape Value to Ecological and Heritage Value

5.6.18 Landscape is quite often associated with ecology and heritage issues. The CPC suggested including an assessment of ecological value in the Study. Similarly in the briefing of the HKILA and HKIEIA and in the Focus Group Workshop, participants also wondered to what extent ecology and heritage values might be reflected in the evaluation of landscape in the Study.

Response

5.6.19 There is definitely a relationship between landscape and the fields of ecology and heritage. The current Study focuses primarily on the appearance and visual characteristics of land. The ecological and heritage features will form part of the landscape character when they are visible in the landscape. (e.g. the visual effect of vernacular buildings on the rural landscape). Where features of ecological or heritage value do not have visual manifestations, they will not be considered as making a particular contribution to landscape character (e.g. buried prehistoric remains).

Other Evaluation Issues

5.6.20 Other consultees raised a variety of technical issues related to landscape evaluation. ACE and participants in the Focus Group Workshop asked how the effect of the surroundings of a given LCA on the value of that LCA would be taken into account in landscape evaluation. It was further pointed out by the HKILA and in the Focus Group Workshop that the character and value of certain landscapes in Hong Kong might change depending on whether they are seen during the day or at night (e.g. the northern Hong Kong Island shoreline). The HKIEIA and HKIP asked how buildings of architectural merit or other attractive built developments would be included in the evaluation. 

5.6.21 Another point made by the HKILA was that remoteness and tranquillity are attributes of landscape that could be regarded as enhancing landscape value. At the same briefing, one participant made the point that a landscape might be more valuable because it is accessible.

5.6.22 Finally, the HKILA asked if development currently planned would be taken into account as part of the Study.

Response

5.6.23 The effects of surrounding LCAs visible from any given LCA will be one of the criteria used to establish landscape value. Also where buildings such as landmarks contribute to landscape value, they will be included in the evaluation of the LCA in which they lie. The night-time characteristics of landscape, for example the night scenery of the harbour, will be considered, as suggested, where they have a significant effect on the overall image or character of the landscape.

5.6.24 Remoteness and tranquillity are attributes that can enhance sense of place and will be taken into account during the evaluation of different landscapes. Accessibility on the other hand is an attribute which is somewhat extrinsic to landscape - that is, it is not necessarily related to the actual qualities of a landscape but rather to available modes of transport to the landscape. As an example, pristine wilderness and degraded industrial landscapes can both be equally accessible or inaccessible. In addition, accessibility may change over time, but this need not affect the value of the landscape, which is otherwise unchanged. Nevertheless, accessibility might affect a landscape's likelihood of changing in the future.

5.6.25 Finally, major developments which are planned or committed will be noted for relevant LCAs to indicate that the developments have potential to impact on recorded values of the landscapes. No attempt however will be made to evaluate the effect of such development on the landscape because it is not yet built, and thus it is impossible to accurately determine its effect on value, condition, sensitivity or character.

5.7     Specific Landscapes and Landscape Features

5.7.1  A number of consultees mentioned generic types of landscape that they felt were of particular value. These include:

5.7.2   At the same time, specific landscape features were also brought to the attention of the Study Team as being of particular value. These include:

5.7.3  Consultees also mentioned landscape features that they felt to be detracted from landscape value. These include:

5.7.4  In addition to the generic landscapes and features mentioned above, the attention of the Study Team was also drawn to specific places and landscapes in Hong Kong that were felt to be of high landscape value. Areas perceived to have high landscape value include: 

5.7.5  Conversely, places that are felt to have low landscape value include: 

5.7.6  A number of consultees also mentioned landscapes that they felt are under threat from fragmentation and inappropriate development. These include:

Response

5.7.7   All the comments made regarding the perceived value of generic and specific landscapes and features will be taken into account in the Study during the evaluation process.

5.8      Application of Landscape Character Map

5.8.1   A question raised by the HKILA and in the Focus Group Workshop was how the Landscape Character Map would be used. Other consultees (A8/HKIEIA/HKIP) pointed to its potential use as a common baseline for EIAs.

5.8.2  Several consultees (CPC/AAB/HKILA/A11/TPB) also asked what format the Landscape Character Map will be in and whether it will be accessible to the public. They suggested that if it is publicly accessible, the Landscape Character Map should be comprehensive and user-friendly.

5.8.3  The Landscape Character Map will provide baseline information of landscape resource in Hong Kong and will be used as a tool to help Government evaluate the sustainability of proposed strategic development. It would also be a useful source of reference for EIAs (See also Paras.5.5.8 and 5.6.11).

5.8.4  The Landscape Character Map would be available to the public for inspection at Planning Department. It would also be uploaded to the Planning Department's website. Other ways of promulgating the Landscape Character Map would be further considered later in the study.

5.9     Updating the Landscape Character Map

5.9.1  The HKIEIA, HKILA, HKIP and other consultees in the Focus Group Workshop pointed out that with the relatively rapid pace of development in Hong Kong, it is likely that the Landscape Character Map would quickly go out of date, as new development takes place. They therefore enquired how this will be taken into account in the use of the Landscape Character Map and how consistency will be ensured in updating the Map in the future (A11/HKIEIA).

Response

5.9.2  It is recognised that the Landscape Character Map will require updating. One way to address this would be to review and update the Map on a 2-3 year cycle to ensure that changes to the Hong Kong landscape are fully reflected. Adequate documentation of the Study would be prepared to ensure that those who update the Map in future will be able to follow the same approach used in the Study.

5.10   Other Issues

5.10.1 A number of consultees made points which were not the subject of the Study. Such comments are summarised below:

Response

5.9.2  Whilst the above points may be relevant to planning and landscape issues in Hong Kong generally, they are outside the scope of this Study. However, they will provide useful information on the landscape concerns of the public for Government to take into account in future planning.

 

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