Relocation of Development Rights of Carrick, 23 Coombe Road
S.12A Planning Application, Representation to Draft The Peak Area OZP No. S/H14/12
The Historic Building and its Setting
Carrick is one of the oldest surviving European houses on the Peak. It was designed as a bungalow with the southern surrounding façade as veranda (which is now enclosed) to capitalise on the view of landscape presently known as Aberdeen Country Park (ACP). The southern facing veranda shielded the intense heat and allowed the residents to enjoy prevailing wind from the south during the hot and humid summer months. The veranda also served as a venue of social gathering. As such, the ACP is an important setting of Carrick and this side of the building is the most significant facade.
Assessment of Antiquities and Monument Office (AMO)
Carrick was first assessed as Grade 3 and later confirmed as Grade 1 historic building by the Antiquities Advisory Board (AAB) and AMO. This means that it is a building “of outstanding merit, which every effort should be made to preserve if possible”
The First Owner
Carrick was built in 1887 by J.J. Francis, a barrister. According to AMO record, he was in a committee of four persons to investigate the issue of mui-tsai (妹仔), indentured Chinese girls working as unpaid domestic servants. Mr Francis had helped draw up the Po Leung Kuk Incorporation Ordinance. He was also involved in some public duties. His connection with the house was very brief, only seven years.
Carrick is built on an elevated platform at a level higher than Coombe Road
Only a small part of Carrick can be seen from Coombe Road
Two Section 12A Applications
Present Owner’s S12A Application, No. Y/H14/4
In June 2015 the owner of 23 Coombe Road (the Carrick Site) submitted a Section 12A application, No. Y/H14/4 to the Town Planning Board (TPB) proposing to rezone an area of "Green Belt" ("GB") to "Residential (C)6" to facilitate the relocation of development rights. This would enable the preservation of “Carrick”, a Grade 1 historic building on site.
The proposed substitute site in application No. Y/H14/4 which is located opposite the Carrick Site in an area zoned Green Belt (GB). This GB site is located on top of the Aberdeen Country Park. It is very steep and densely vegetated which is not suitable for any type of development. It has unrestricted views over Aberdeen Country Park and the sea view beyond. The proposed development on the substitute site would lead to loss of public amenity and would set an undesirable precedent by exchanging land of much higher value for one of much lower value but has historic building.
The limitations of the content of that application Y/H14/4 meant that other possibly better solutions could not be considered by the TPB. Therefore, the Aberdeen Country Park Concern Group (ACG, the Concern Group) submitted another S.12A application in the public interest to facilitate heritage preservation and conservation of GB areas.
The Carrick Site and the GB Site (proposed for rezoning by the owner of Carrick as a substitute development site) are on either side of Coombe Road. To the south of the Aberdeen Reservoir Road is the Aberdeen Country Park.
Large area of vegetation (white circle indicative only) would be affected by the rezoning proposed by the owner
The proposed house and deck on the GB site under Y/H14/4 would remove large area of vegetation. (Source: TPB document)
Aberdeen Country Park Concern Group’s S12A Application, No. Y/H14/5
Masterplan was commissioned by ACG to prepare a S12A application to propose options to preserve Carrick as well as its important setting in relation to the ACP. The application put forward a preferred option (in-situ option) so that the development rights on the Carrick Site could be realised within the site itself. It also proposed an alternative, non in-situ option, to transfer the development rights on the Carrick Site to a less prominent location than that proposed in Y/H14/4.
The preferred option proposed to rezone the Carrick Site from Residential (Group C)2 (“R(C)2”) to OU (Historic Building Preservation and Residential Development) to preserve the existing historic building and allow additional residential development. The maximum GFA permitted is 549.98sqm in addition to the existing GFA of the historic building and maximum building height four storeys including carports, or existing building height whichever is greater.
As for the alternative option, it proposed to rezone a green belt site to R(C)2, same as that of the Carrick Site. This alternative site occupied a less prominent location and could reduce the loss of public amenity. Under this option, the Carrick Site was to be rezoned to OU(Historic Building Preservation).
Both the preferred option and the alternative option proposed in this application respect development rights. They could better balance the needs for heritage preservation and nature conservation than that proposed in Y/H14/4. The application considered that the preferred option was the most desirable as it affected the least vegetation and number of trees. If it was found infeasible, the alternative option was a more appropriate like for like substitution for the Carrick Site.
TPB’s Decision on the two S12A Applications
The two S12A Applications were considered by the TPB on the same day. The Board approved the owner’s application, but rejected the Concern Group’s application.
The decision of the Board was later shown on The Peak Area Outline Zoning Plan (OZP) No. S/H14/12.
Site 1 was considered in Application No. Y/H14/4. It lies a short distance north of the Carrick Site. Source of base plan: Planning report of Y/H14/4
Representation to Draft The Peak Area OZP No. S/H14/12
The Concern Group again commissioned Masterplan to submit a representation in respect to The Peak Area OZP No. S/H14/12. There were three Representation Sites: Amendment Site, Carrick Site and Northern Site. They were related to the above two S.12A Planning Applications.
The issues identified by the TPB in relation to the ACG’s previous submission had been addressed in the representation. Additional technical information was included - tree survey and ecology, geotechnical and structural engineering, architectural drawings and images, and a heritage assessment.
ACG supports heritage preservation. However, this needs to take account of other factors, such as nature conservation, the merits and heritage values of the historic building to qualify it for land swap, implications of the land exchange setting a precedent for potential land exchange for other Grade 1 buildings. Land exchange should only apply to Declared Monuments where their exceptional status had been clearly determined. It is also important that the land exchange site for the new building would not adversely impact on the context and setting of the historic building.
Carrick Site is the preferred site for realisation of development rights: Based on the available information for Carrick, it is insufficient to meet the ‘exceptional merits’ necessary for it to qualify legally for a land swap. Also, procedurally there should be a contemporaneous Rezoning of the Carrick site for historic building preservation before there can be a land swap. To overcome these safeguards, incentive to preserve Carrick should be in the form of allowing additional GFA within the site to compensate for the development rights, i.e. the ‘preservation-cum-in situ development’ model advocated by the government.
Northern Site is a better alternative site: If more information regarding the “exceptional merits” of Carrick could be provided by the owner or relevant government departments, the Northern Site should be considered for the land exchange as it is a “like-for-like” replacement for the Carrick Site.
Preservation of the Setting of Carrick: The proposed building on either the Carrick Site or the Northern Site will not obstruct the view of Carrick and the ambience and setting of the place is preserved. This is what the Heritage Conservation Policy wants to achieve.
The Three Representation Sites: Amendment Site, Carrick Site and Northern Site.
The Amendment site has much better view than Carrick Site.
Amendment Site is NOT an appropriate site: Carrick is situated on a platform of 254.2mPD. The proposed amendments included a Building Height Restriction (BHR) of 260mPD for development on the Amendment Site. This would obstruct the views of Carrick towards ACP and adversely impact on the setting of the historic building as stated in S2 above. In addition, the trees of ecological values within or adjacent to the site would also be adversely impacted due to construction works on the steep slope of the Amendment Site. Impacts on trees on either of the other two sites are a lot smaller from the new building proposed by ACG.
The proposed zonings for the three Representation Sites are summarised as follows:-
TPB Decision of the Representation
The options proposed Concern Group’s representation would preserve this historic setting of Carrick. The preferred option affects least vegetation, while the alternative option is a more “like-to-like” compensation.
However, the Amendment Site to accommodate the development rights of the Carrick Site would destroy Carrick’s original setting with the ACP. It is a pity that the Concern Group’s representation was not upheld by the TPB.