A third public consultation on hotel at Lugard Road - we need you to act
Dear friends of ABHK,

Thanks to your help we have been able to keep up the pressure against the development of a hotel at 27 Lugard Road. As you may know the developer submitted a fresh application in November 2014 responding to some of the public's objections and there was a public consultation. 827 people sent in their comments by the 2 December 2014 deadline.

Now the developer has tweaked the plans further and the Town Planning Board is having a third public consultation on the tweaked plans!

The aim, as far as we can see, is to exhaust the public and reduce the number of responses to public consultations. We can't allow that to happen and need to you to pls email the Town Planning Board to oppose this plan yet again. The deadline for sending in your comments to the Town Planning Board is30 January.

In modifications to the November 2014 plan the developer has now reduced car parking spaces from 5 to 3 and also made a few other changes. But our concerns about traffic on Lugard Road remain. Who is to monitor the two round trips an hour allowed on Lugard Road on every day except Saturday, Sunday and public holidays and who will monitor the 9am to 7pm ban on traffic on weekends and public holidays?

We continue to believe that this plan is not good for all of us who enjoy walking on this stretch of Lugard Road. A hotel at 27 Lugard Road will be the beginning of the end of this beautiful trail that is mainly a road for pedestrians.

You could use the form letter below. Please forward this email to friends both in Hong Kong and outside – we need as many people as possible to act now. For more information please contact This email address is being protected from spambots. You need JavaScript enabled to view it. '; document.write(''); document.write(addy_text55136); document.write('<\/a>'); //-->\n This email address is being protected from spambots. You need JavaScript enabled to view it.  or go to our website www.abhk.org.

Join Petition Now

Vivian Leung
Alliance for a Beautiful Hong Kong Limited



您可選擇聯署以下的反對信。僅請將本電郵轉寄給在香港及以外的朋友。我們需要更多朋友立即行動。如需要更多資訊,請電郵我們 或瀏覽本會網站。謝謝您的支持!



Sample letter of Objection
Secretary for Development Mr. CHAN Mo Po, Paul,
Commissioner for Transport Mrs. YEUNG HO Poi Yan, Ingrid,
Director of Environmental Protection Ms. WONG Sean Yee, Anissa
Director of Fire Services Mr. LAI Man Hin,
Town Planning Board,
Central and Western District Council,

CC: Alliance for a Beautiful Hong Kong

Re: Object to Hotel Development on Lugard Road 27 (Planning Application No. A/H14/79)

Although the applicant submitted additional information, this still cannot response to my concerns. The reasons why I oppose to the hotel development are still valid. [I/We] object to Town Planning Board Application A/H14/79 for the following reasons:

●   Approval granted in September 2013 was wrong
The Town Planning Board (TPB) approved the hotel development at 27 Lugard Road last year with conditions (TPB Application A/H14/75).

However, the application was flawed. For instance, the estimated traffic flow on Lugard Road was misleading; a proposed septic tank would have to be built just above picturesque Lugard Road and on the government land. These elements would have severely compromised the beauty and tranquility of Lugard Road, which is the most accessible and popular scenic trail in Hong Kong.

In addition, while the applicant said they were preserving a heritage property, in reality its conversion to a hotel would have resulted in the building being significantly altered. This would have destroyed its heritage value. There were also significant problems with the plans with regards to fire hazard and emergencies. As such, TPB members should use the opportunity of the current application to look afresh at all these issues. The approval granted in 2013 should not guide their decision on the current application.

●   Please note over 125,000 people have signed petitions against the hotel development
Lugard Road is a significant part of the Hong Kong Trail, which was named as one of the top 10 urban hiking trails in the world by Lonely Planet. Alliance for a Beautiful Hong Kong (ABHK) has collected over 125,000 signatures against the hotel development since October last year. All the signatures are collected on-site on Lugard Road from Hong Kong residents and tourists, who said they were attracted to Lugard Road by the tranquility it affords and did not want a hotel there.

●   Misleading traffic data 
The applicant selected Hong Kong general statistics to argue the traffic flow generated by residences and hotels similar. In fact, the hotel development, according to their own statements, will generate 4 passenger car trips per hour and use alternative vehicles in between the allowed car trips. When 27 Lugard Road was a residence it generated only 2 passenger car trips a day (one trip out in the morning and another back in the evening), meaning a hotel development at the site will cause a significant jump in traffic flow of nearly 50 times.

●   Even small vehicles should not be allowed on this section of Lugard Road 
Although Lugard Road is gazetted as a road, it is mainly used by pedestrians. It is as narrow as 1.8m. The applicant proposes to use Mitsubishi Small Electric Cars (iMiEV) and/or Electric E-Tuks, which is 1.475m and 1.41m wide, respectively. Both will occupy nearly 70% of the road and inevitably cause inconvenience to pedestrians. Wheelchair and strollers are normally 0.65m to 0.8m wide. When there are large numbers of walkers, wheelchair users or walkers with strollers on Lugard Road, conflicts between pedestrians and vehicles will occur.

The applicant still does not give up to use multi-cycles to carry guests during periods when they have agreed to traffic restriction on Saturday, Sunday and public holidays. The proposed multi-cycle is 1m wide, and will be almost as much of a hindrance to pedestrians on Lugard Road as the electric vehicles operating during “normal” hours, rendering the restriction meaningless.

Please note that currently, ordinary bicycles are banned from the Peak Trail, so permitting the multi-cycles will set an unwanted precedent for additional bicycle traffic on the trail.

●   No benefit to Hong Kong tourism
Lugard Road was built as early as 1913. In addition to its scenic value, it is thus a precious historic trail, linking historical buildings on the Peak. The hotel development will downgrade the conservation and heritage value of the road and compromise the enjoyment of locals and tourists alike. The addition of 12 high-end hotel rooms (in a city which already has 70,000 hotel rooms) cannot possibly offset the damage the hotel development will cause to this precious spot.

●   Pollution to the country park
The hotel is not connected to the public sewer. The sewage treated by septic tank and soak away system will directly discharged into Pok Fu Lam Country Park. The applicant underestimates the quantity of sewage per day with only 75 public visitors. Septic tank and soak away system is not adequate to treat high volume of sewage and ensure the quality of discharge into an environmental sensitive area. Also, removal of sludge in hotel will be more frequent than residential use. This will inevitably disturb the pedestrians on Lugard Road, and causes poor hygiene and odor.

●   Failure to cope with emergency and fire hazard
Although the applicant proposes to build a water tank in the basement, only one fire engine can access Lugard Road from Peak Station. According to the FSD guidelines, a fire in a hotel has to be dealt with as a grade II fire and requires more manpower and equipment than fire in residential units. And no ambulance can enter Lugard Road.

For any emergency that occurs at the proposed hotel, ambulance personnel will have to run for 1 km from the entrance of Lugard Road at the Peak Tower. In view of the geographical restrictions, the hotel development can hardly meet the FSD requirement.

Accordingly, [I/we] request that the Town Planning Board rejects this application in order to protect the public interest and preserve one of Hong Kong’s most popular walking routes.




Re: 反對山頂盧吉道27號改建酒店(規劃申請編號:A/H14/79)

●   早前申請錯誤獲批:盧吉道27號於去年獲批改建為酒店(規劃申請編號A/H14/75),然而該次申請錯誤百出,包括交通流量估算誤導、改建化糞池涉政府土地、大宅內部作大幅改建損古蹟價值以及消防安全問題。城規會委員考慮今次申請是,不應以上一次獲批准作基礎。

●   逾十二萬五千人簽名反對改建:盧吉道是港島徑重要部份,更獲選為全球十山行山徑。本會去年至今,共收集得超過12萬5千人簽名反對大宅改建為酒店。全部簽名在盧吉道現場獲得,包括來自全國各地的遊客,他們認為山頂及盧吉道對他們的吸引力,並不是一間酒店,而是優閒的自然步道以及維港景色。

●   盧吉道行車不可行:盧吉道在法例上雖然屬道路,然而盧吉道屬人車共用道路,路面狹窄,部份路段僅闊1.8米,部份路段緊貼去水道、欄杆及山邊,在該處行車根本不切實際。申請人提出使用的電動車(Mitsubishi Small Electric Car)或電動人力車(Electric E-Tuk)分別閣1.475米及1.41m米,佔用路面闊度近七成,令行人無法安全使用。一旦遇上大量遊人或一般闊0.65至0.8米的嬰兒車和輪椅時將會構成危險,人車爭路甚至引發衝突。

●   行車限制形同虛設:申請人仍未放棄研究在星期六日及公眾假期的「禁車」時段,使用在目前法例上不能在道路上使用的多輪單車接送旅客,該車輛闊度近1米,同樣阻礙行人使用盧吉道,亦對行人構成危險。申請人所謂的「禁車」時段形同虛設。

●   申請人提交的數據誤導:盧吉道27號大宅的住戶,從來只於朝七前及晚七後行車,星期六及日一般均全日不會駕車。申請人以全港一般統計數字,「證明」住宅與酒店製造的車流近似,屬完全誤導,忽視盧吉道的實際路況。申請人提交的資料亦不齊全,行人統計上竟沒有列明調查日期,只含糊表示為七月份。難免令人質疑申請人是否挑選某一個天氣欠佳、行人較少的統計數字,誤導城規會。(註一)七月份本身,亦並非遊客高峰期。

●   酒店車流將佔領盧吉道:酒店每小時行車兩2次,每日(24小時,每小時四架次)車流最高可達96架次。相比現時住宅用途,每日只有2個架次,盧吉道的行車架次將急升94架次,急升50倍之多。酒店發展將令盧吉道平日每小時是有40分鐘有車輛佔用路面(每小時4架次,每次行車10分鐘),對行人構成極大不便,甚至危害安全。

●   污染郊野公園:酒店污水沒有接駁公共的排污接駁系統,污水經過化糞池與滲水系統處理過後,污水將會途經盧吉道,流入薄扶林郊野公園。申請人低估了每日的污水量,只預計每日僅得75名公眾遊客。化糞池處理污水不足以處理大量污水及確保環境敏感地區的水質。而且,相比現時住宅用途,需要更頻密清除淤泥,運送過程必會影響盧吉道行人,及帶來環境衛生問題。

● 盧吉道價值極高:盧吉道建於1913年至1914年之間,建成後被譽為「人工征服自然者之最偉大工程」,是本港難得的歷史步道,連接山頂區多幢歷史建築。酒店發展項目將會徹底改變盧吉道的保育價值,汽車駛入將破壞盧吉道整體的景觀、阻礙行人欣賞美景及破壞文物,根本無助推廣旅遊。

●   消防救護危機未減:發展商擬在酒店地庫興建水池,作為救火水源供應。但山頂消防局只有一部能駛入盧吉道的迷你消防車。消防處指引列明,一旦酒店發生火警,需以二級火警規格處理,調派的人手車輛均比住宅高。另外,救護車是無法駛入盧吉道,可見該處地理環境根本不可能達到消防處對酒店的要求。


基於上述原因,我/我們 要求城規會否決申請,以保障公眾利益及保護香港其中一條最受歡迎的步行徑。