Home Affairs Bureau 41/F, Revenue Tower 5 Gloucester Road

Civic Exchange Limited (CE), an independent non-profit public policy think tank
based in Hong Kong, would like to submit its views on the above captioned
Consultation Document.

CE has previously published papers on improving both nature and heritage
conservation policy in Hong Kong including our report \u201cConservation in Hong Kong\u201d
June 2002 which includes three individual papers focussing on nature conservation,
heritage conservation and an economic valuation of the benefits of nature
conservation in Hong Kong, respectively. A copy of this report has been submitted to
the Home Affairs Bureau (HAB), the Leisure and Cultural Services Department
(LCSD) and indeed all Government and Non-Government Departments and bodies
that are associated with nature and heritage conservation. A copy of this report is
available athttp: //www.civic- exchange.org under Publications \u2013 June 2002.

Our response to the Consultation Document includes many references to the above-
mentioned paper on heritage conservation \u201cSaving Hong Kong\u2019s Cultural Heritage\u201d.
This paper provides an overview of existing heritage conservation legal and
administrative framework in Hong Kong including a summary of its problems and
constraints. This report also proposes a comprehensive list of recommendations for
improvement including a discussion of mechanisms that may be used to implement
conservation objectives. A summary of the papers recommendations is included as

Overall, while CE welcomes the Consultation Document, we feel that the
Government has failed to address the most important conservation issues including a
strategy for a comprehensive heritage management system inclusive of
implementation alternatives, and instead only raises broad theoretical questions on the

broad direction of built heritage conservation. While we are heartened by the
Governments invitation for the public of Hong Kong to comment on issues in relation
to overall policy questions such \u201cwhat and how to conserve?\u201d we hope that the
Government recognises and considers the discussion on these issues voiced by a range
of organisations including CE, The Conservancy Association, the Hong Kong Institute
of Architects, to name a few, which have appeared in newspapers, research papers and
in submissions directly to Government over the past 10 or so years. Furthermore the
Cultural Heritage Commission, who finalised their report in early 2003, made a
number of recommendations in relation to heritage conservation inclusive of need to
establish a Heritage Conservation Board to take on wider responsibilities.

We entirely agree that the Government should take a holistic approach in its review of
heritage conservation. In this regard we recommend that the Government not only
covers built heritage but extends its understanding and conservation of heritage to
include places that embody heritage values.

The Australian International Council on Monuments and Sites (ICOMOS) Charter for
Places of Cultural Significance ,1999, (\u201cthe Burra Charter\u201d) defines \u201cplace\u201d to mean a
site, area, land, landscape, building or other work, group of buildings or other work
and may include components, contents, spaces and views. It further defines
\u201cheritage value\u201d to mean the aesthetic, historic, scientific, social or spiritual value for
past, present or future generations. It is embodied in the place itself, its fabric, setting,
use, associations, meanings, records, related places and related objects. Places may
have a range of values for different individuals or groups.

The Consultation Documents sites limitations of the current Antiquities and
Monuments Ordinance, namely that it only allows for the conservation of declared
buildings that are of monumental quality and that stringent requirements are applied
to alteration of works after declaration. We agree that these inflexible requirements
do little to protect the bulk of Hong Kong\u2019s heritage, which can be witness by the fact
that only 78 monuments have been declared since the enacting of the Antiquities and
Monuments Ordinance in 1976. We note that the Antiquities and Monuments Office

To include only buildings of monumental quality excludes places and sites with
heritage value including vernacular village houses and areas and tenement buildings,
which form a part of the social landscape and collective memory of Hong Kong.
Again we refer to the above definitions of \u201cplaces\u201d that embody \u201cheritage values\u201d. It
is impossible to conserve more than a fraction of the heritage value of a place through
preserving only the built structure. Recently there has been much public discussion
about the preservation of whole neighbourhoods and streets including many of the
Wan Chai areas such as \u2018Wedding Card\u2019 Street and in the past there have been similar
discussions for areas such as the former \u2018Bird Street\u2019, which is mentioned in the
Consultation Document. In these cases many view that it is not only the clusters of
buildings inclusive of shop fronts, street patterns and pavements etc, but also the trade
customs within the buildings that merit attention and protection, as they form the
individual character of the place.

Indeed we agree that it is not only the built structures but also the usage of those
structures that creates the heritage value of a place. Where feasible, we believe that
the optimal solution is to capture the heritage value of a place including the
continuation of the existing use of that place, whether that involve a street that
exhibits a certain trade, a building that has operated as a fruit market for generations
or a park that has maintained open views of heritage or other special places.
However, we also appreciate that the optimal solution may not always be possible and
given this, other alternatives uses for heritage places must be found.

The Government should also consider creating a Heritage Conservation Master Plan
that includes the creation of specific Heritage Zones in certain areas. These Heritage
Zones would both limit the types of places that are able to operate in an area and
encourage compatible heritage places to develop in the area, so that a cluster of
special interest places forms. Announcing Heritage Zones would also provide a long-
term vision for the development of those areas of heritage significance, which appears
to have worked well in Singapore though the use of Conservation Areas. Ultimately
we believe that the overall aim is to maintain the heritage character and value of a
place through creating a vibrant ongoing use of the place. This will enable the long-
term sustainability of the place both socially and economically.

Promotion of community effort and support. For instance the initiation of
community awareness projects could help to identify areas within communities
that are \u2018valued\u2019 and are therefore in need of protection1.