Summary of Items Discussed in 2/2024 APSEC Discussion Forum (ADF) on 3 May 2024

Items proposed by Convenors for Discussion Summary of Discussion and BD’s Response
Items raised by HKIA
1. Provision of Telecommunications and Broadcasting (TBE) Room in
Existing Shopping Arcade

From our understanding, for alteration and addition (A&A) works For existing buildings without the provision of TBE room in the original
submissions for the comprehensive renovation of an existing shopping arcade approved design, BD advised that unless the proposed A&A works
which has NO provision of TBE room in the original design, it is not required would result in a new building where not less than one half measured by
to provide the access facilities for the telecommunications and broadcasting volume was rebuilt or the building was altered to such an extent as to
services in accordance to the requirements laid down in PNAP APP-84. necessitate the reconstruction of not less than one half of the superficial
Please advise if our understanding is correct. area of the main walls, the provision of the access facilities under
regulation 28A of the Building (Planning) Regulations (B(P)R) would
not be required.

2. Provision of Smoke Outlets in Fire Compartment in Basement

Clause C14.2 of the Code of Practice for Fire Safety in Buildings 2011 (June BD advised that the non-provision of smoke outlets at the basement area
2023 Edition) (FS Code) stipulates the requirements of smoke outlets for being served by gas flooding system would be favourably considered
basement and that every compartment of a basement should be provided with subject to the agreement by FSD.
smoke outlets. For large rooms in basement, it is common that the Fire
Services Department (FSD) accepts the provision of gas flooding system for
the exemption from the requirement to provide smoke extraction system.
The room adopting gas flooding system will form a compartment on its own,
and the smoke outlets therein are in conflict with the concept of gas flooding.
Can smoke outlets not be provided under such scenario?
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3. Hoarding Permit Application involving Water-filled Barriers

Usually, when the building is close to lot boundary, the hoarding has to be BD advised that for building/street works not posing any risk of falling
demolished for the carrying out of external finishing works at the lower objects to the public/occupiers, water-filled barriers might be used as
storeys of the building. It was our understanding that BD might favourably precautionary measures to isolate a construction site from the
consider the adoption of water-filled barriers with sufficient height (say, 2.3 public/occupiers. However, such water-filled barriers could not
m in general) as precautionary measures / hoarding to safeguard the public perform the function of a hoarding/covered walkway required under the
from certain kinds of construction activities, such as street works, Buildings Ordinance (BO) as measures to protect the public/occupiers
replacement of glazing panels for shops at ground level or minor A&A works from falling objects arising from buildings under construction or
at the external wall, etc. However, we have encountered recently that some demolition.
case officers might still have concern and were reluctant to allow the
adoption of water-filled barriers in hoarding plan submission / hoarding BD reminded that hoarding/covered walkway required under the BO for
permit application. Since such barriers might need to be erected outside the demolition and superstructure works should be structurally robust and
lot boundary and hence encroaching onto public pavement, it is imperative to not easily movable. According to paragraph 3.2.3 of the Code of
be shown on hoarding plan such that relevant departments (such as the Practice for Demolition of Buildings 2004, hoarding/covered walkway
Transport Department, Highways Department, etc.) could have the chance to should be designed to sustain the wind load, and roof of the covered
review the hoarding alignment and ensure the design could meet relevant walkway should be designed to support a uniformly distributed load of 5
requirements without prejudicing public convenience. Otherwise, upon kPa. Such requirements were also applicable to the hoarding/covered
erection of the water-filled barriers (without being illustrated on the hoarding walkway for superstructure works.
plan) on public pavement, relevant governments (including the Police) might
raise queries or even reject such water barrier erection, causing hiccup to In general, BD would consider on case basis to allow water-filled
ongoing construction activities. This is particularly problematic if barriers to be shown on the hoarding plans for information and
complaint from the public is subsequently received on the erection of such circulation to the relevant Government departments for their comments,
barriers. Would BD please consider allowing the provision of water-filled provided that:
barrier as protective/precautionary measures to be illustrated on hoarding (a) the barriers were only used to isolate a construction site from the
plan for formal acceptance? public/occupiers; and
(b) details of the water-filled barriers (including their height, width,
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 thickness, weight, interlocking systems, etc.) and the remaining
clear widths of the footpath, carriageway, etc. were clearly shown
on the hoarding plans.

4. Submission of Overall Thermal Transfer Value (OTTV) Report for

Building without Provision of Air-conditioning

For some development projects, there is no air-conditioning provided but BD BD advised that pursuant to section 3 and the Schedule of the Building
is still requiring the submission of OTTV report. (Energy Efficiency) Regulation (B(EE)R), buildings to which the
B(EE)R applied included commercial buildings and hotels, irrespective
Can BD consider waiving the requirement of submission of such report upon of whether such buildings were equipped with air-conditioning system.
the client submission of undertaking letter of non-provision of OTTV Report including information and calculations of the OTTV as
air-conditioning to the development? required by regulation 5 of the B(EE)R should be submitted in
accordance with PNAP APP-67.

5. Downloading of Electronic Copy of Approved Plans from Building

Records Access and Viewing On-line (BRAVO)

We understand that currently the purchase of electronic copy of approved BD advised that the same suggestion was raised in the Joint BSC and
plans in PDF format from BRAVO still involves the delivery of DVD-ROMs. APSEC 4/22 Meeting held on 22 September 2022. The enhanced
service of allowing direct downloading of electronic copy of building
Please see if BD can improve such process by allowing the downloading of records would require legislative amendment which was being
the relevant files online upon payments. considered.

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 Items raised by HKIE
6. Composite Column Design

According to Clause 10.5.3 of the Code of Practice for the Structural Use of BD advised that the simplified method of composite column design
Steel 2011 (2023 Edition) (Steel Code), application of “Simplified Method” provided in the Steel Code did not cover the examples given, and the
is limited to members of doubly symmetrical and uniform cross section over issue would be deliberated by the Technical Committee on the Code of
column length. It is not applicable to structural steel component which Practice for the Structural Use of Steel.
consists of two or more unconnected sections.

Would BD please clarify whether the “Simplified Method” provided in

Clause 10.5.3 of the Steel Code is also applicable to design of a “doubly
symmetrical composite column” when Clause 8.12 of the Steel Code is
adopted to demonstrate the connectivity for the multiple inter-connected
steel sections for their corresponding action effects whilst they are not
typical cross sections as shown in Figure 10.17 of the Steel Code.

Examples of the atypical cross sections are as follows:-

N.B. :- Batten plates for connecting multiple sections

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7. Presentation of Structural Information in Submission of Superstructure
Plan

According to PNAP ADM-8, lateral wind load shall only be provided in Part BD advised that the details of lateral wind loads were essential
I of the Structural Calculation. Meanwhile, design codes and standards, information to be shown in structural plans for approval, and such
materials strength and standards, concrete cover and corrosion protections as practice had been in place since the promulgation of the Code of
well as fire resistance requirements etc. are to be given in structural plans for Practice on Wind Effects in Hong Kong 2019. Nevertheless, BD
approval. would consider reviewing the essential information of lateral wind load
required to be shown in the structural plans for approval.
Please advise whether we need to show details of lateral wind loads,
including force coefficient, directional factor, size and dynamic factor and
wind load combination, and lateral wind loads with wind load combination
extracted from wind tunnel test report, which are subjected to changes
throughout the design and construction stages of the development, in the
structural plans for approval.

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 Items raised by AAP
8. Barrier Free Access (BFA) Facilities for University Student Dormitories

It has been accepted that student dormitories for tertiary institutions is not BD advised that pursuant to section 7 in Division 2 of the Third
regarded as “Hotels, Hostels and Guesthouses” even though sometimes they Schedule of the B(P)R and paragraph 7 in Division 2 of the DMBFA,
are named as “hostels” as the occupants will stay for a long duration. accessible guest rooms should be provided in every hotel, hostel or
guesthouse. Hence, the provision of accessible guest rooms in student
With regard to the above, the provision of accessible guest room required hostels for tertiary institutions was required.
under section 7 in Division 2 of the Third Schedule of the B(P)R and
paragraph 7 in Division 2 of the Design Manual: Barrier Free Access 2008 BD also reminded the owner/AP to observe the Disability
(2021 Edition) (DMBFA) is not applicable. There were cases that BD Discrimination Ordinance (DDO) for the provision of accessible guest
officers required accessible guest room to be provided and that the bathroom rooms in student dormitories.
and shower facilities serving these accessible guest rooms be integrated into
the rooms as depicted in Figure 2 of the DMBFA. This poses operational
constraint on the institutions as bathing facilities are often of shared
use. Would BD please clarify?

9. Exit at Ground Storey

Clause B9.2 of FS Code stipulates the minimum width of an exit route at BD advised that HKIA’s understanding was incorrect. Clause B9.2(a)
ground storey where the exit route from a ground storey also forms part of the to (c) of FS Code refers to the width required for exit route from ground
exit route from a required staircase. Would BD please clarify if the minimum storey and the widths required for required staircases from upper storeys
width of exit door locates along the exit route at ground storey, if any, should or basements, instead of the widths required for exit doors from such
follow the same token, i.e. the width of exit door should be not less than the storeys. As discussed in item 7 of ADF 2/2023 held on 5 May 2023,
sum of: the clear width of exit door measured between the vertical members of
(a) half the width required for the exit door from the ground storey; the door frame along the combined exit route at ground floor should not
(b) the width required for the exit door of the required staircase from the be less than the width of the combined exit route required under Clause
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 upper storeys; and B9.2 of FS Code.
(c) the width required for the exit door of the required staircase, if any,
from the basements.

Items raised by AREC

10. Site Formation Plan involving Permanent Soldier Pile or Pipe Pile Wall

To follow up with the discussion in item 15 of ADF 1/2024 held on 23 BD advised that their discussion with GEO was still in progress and the
February 2024, please advise if a sacrificing thickness of 0.05 mm/year on item would be advised separately.
steel section is acceptable for the design of permanent soldier and pipe piles.

Items raised by PBSCA

11. Application for Gross Floor Area (GFA) Concessions in Existing
Building as Surplus GFA for Future A&A or Extension Works

For the plant rooms in an existing shopping arcade which have not beenBD advised that the plot ratio (PR)/GFA calculation shown on a building
disregarded or exempted from GFA calculations in the original design, the
plan served the purpose to demonstrate that the actual PR/GFA did not
property developer would like to apply for GFA concessions for the plant
exceed the permissible limits under the B(P)R or relevant Outline
rooms without proposing any alterations to the plant rooms, so as to retain the
Zoning Plans. Any surplus PR/GFA shown on the calculation should
surplus GFA for better planning of future A&A or extension works. not be regarded as unused PR/GFA guaranteed available for works in
future submissions. GFA concession policy under the BO might be
According to item 5 of ADF 3/2019 held on 24 May 2019, in general, no reviewed and changed from time to time, such that the PR/GFA of a
surplus GFA should be resulted or left unused for any possible additions in building proposal in future submissions should be assessed in
future. This will result in hardship for the property developer to have better accordance with the prevailing policy at the time of the submission.
planning and flexibility for the future A&A and extension works. Would BA Therefore, BD’s response in item 5 of ADF 3/2019 was still valid.
revisit this issue in a pragmatic way to allow surplus GFA for future extension
works?
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 AOB Items
12. Completion of Exempted Building Works prior to the Grant of Consent
to the Commencement of A&A Works
(Item raised by PBSCA)

For an A&A works of an existing building involving the removal of some BD advised that unless the exempted building works obstructed the
partition walls, which are exempted building works and shown as blue dotted carrying out of the proposed A&A works and/or the proposed essential
lines in the diagram below, the BA requires the removal of these existing precautionary measures in occupied premises, generally such
partition walls before granting the consent to the commencement of the A&A pre-requisite for granting consent to the commencement of A&A works
works, upon approval of the plans. We would like BD to clarify that the would not be imposed. Nevertheless, PBSCA could provide details of
completion of such exempted building works shall not be a pre-requisite for the case for separate discussion.
granting consent to the commencement of A&A works.

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13. General Comments and Suggestions on BD’s Plan Processing
(Item raised by PBSCA)

Members of PBSCA have the following general comments and suggestions: BD advised that practitioners might contact BD officers by email with
1. Improve communication channel with BD officers. It is difficult to copy to their respective senior and/or chief officers for effective
contact them nowadays. communication as officers might not be able to answer telephone calls
2. ⁠Some BD officers cannot provide precise comments until the last few days due to other engagements at work.
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 of the statutory period of 60 days, and/or cannot provide comments at early
stage (i.e. on the 45th day of submission of new building plans). BD also advised that while BD would strive to provide feedback on
whether the submission of new building plans was fundamentally
The above problems may affect the timing of plan approval and fail to acceptable on the 45th day of submission in accordance with PNAP
facilitate early approval of plans. ADM-2, the availability of other government departments’ comments, as
well as the accuracy and timeliness of AP’s responses to address
comments from BD and other government departments, might hinder the
BD’s provision of feedback.

14. Last ADF of the Term

(Item raised by BD)

BD advised that this would be the last meeting of this Forum in the current Members noted.
term which would end on 30 June 2024, and expressed gratitude for
Convenors’ contribution. The respective institutes/associations of the
Convenors had been invited to nominate members to serve as Convenors of
this Forum from 1 July 2024 to 30 June 2024.

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