Written Comments to the Town Planning Board Regarding S.12A Application No. Y/H4/10: Deletion of ‘Tram’ Service in the Notes of OZP No. S/H4/14


In response to Intellects Consultancy Limited’s application to the Town Planning Board (Application Number: Y/H4/10), Civic Exchange is writing to express our strong objection to the application and to dismiss the shaky arguments provided by the applicant.

Arguments on road use efficiency

Civic Exchange disagrees with the applicant that the phasing out or removal of the tram service along Des Voeux Road Central and Queensway from Jubilee Street to Arsenal Street would bring greater efficiency in road use for a number of reasons as stated below.

First, trams do not have exclusive right-of-way along Des Voeux Road Central, and the tram way there is actually shared by all road vehicles. Hence, taking away the tram service would not free up about 30 per cent of the road surface as implied by the applicant.

Second, freeing up road space from the tram service or other transport modes, irrespective of the amount of space reclaimed, would be quickly taken up by other road vehicles. Adding road capacity alone, without any complementary traffic control measures, is very often an ineffective way to improve transport network efficiency.

Third and instead, the best and proven way to improve road use efficiency in a congested carriageway is to accord priority to high-occupancy road users such as buses and trams over inefficient road users like private cars and taxis. Bus-only lanes and tram-only lanes should be put in place to enhance public transport service efficiency.

Arguments on the Mass Transit Railway (MTR) making tram service redundant

Civic Exchange disagrees with the argument that the MTR has diminished the function of tram as a public transport mode, as they are playing different roles in Hong Kong’s public transport system.

First, tram is a very popular public transport mode for short distance commuting. According to Hong Kong Tramways’ recent customer survey,  85 per cent of their patrons commute on trams for short distance ride up to 4 kilometres because it is convenient to hop on and off. Short distance business trips are common in commercial districts such as Central, and tram is serving that function better than any other modes.

Second, tram is an affordable public transport mode, and the choice mode for the low-income group and elderly people with little disposable income. It only increased its fare once over the last 15 years in 2011 to a low, flat rate of HK$2.3 for adults and HK$1.1 for senior citizens. In this respect, tram and the MTR are serving different market segments, and their roles are complementary.

Air quality concerns

Civic Exchange also wants to emphasise the poor state of roadside air quality in the application site, which should be a matter of concern for urban planners, but is neglected entirely by the applicant.

According to a recent research report published by Civic Exchange and the Hong Kong University of Science and Technology,  daily average PM2.5 concentrations along Des Voeux Road Central and Queensway exceed World Health Organization’s air quality guidelines in almost 280 days a year and over 200 days a year, respectively. The main sources of PM2.5 include diesel commercial vehicles such as franchise buses and heavy goods vehicles, as well as other road vehicles like private cars. Tram is driven by electricity and hence does not contribute to roadside air pollution.

From a health protection point of view, the most effective measure to reduce roadside air pollution is to take polluting vehicles off the road. Feasible plans include setting up low emission zones, zero emission zones or pedestrian-only streets, in which only low/zero emission transport and pedestrians are allowed. As a zero emission mode, tram should be kept, rather than removed.