Mr Douglas So, JP
Chairman, Antiquities Advisory Board
9 December 2020
Dear Mr So,
As the Antiquities Advisory Board (AAB) prepares to meet for a brainstorming session to deliberate on the way forward regarding the assessment of post-1950 buildings later this month, Walk in Hong Kong is writing to make three calls to advance that specific subject and to improve the historic building grading mechanisms more broadly.
The three calls are:
- Fast track protection of post-1950 heritage architecture
- Reform five-member “expert panel” for historic building appraisals
- Make grading “score sheets” of AAB expert panel publicly available
1. Fast track protection of post-1950 heritage architecture
For more than two years, WIHK has repeatedly called on the government to make the protection of post-1950 heritage architecture or modern architecture a policy priority for heritage conservation in Hong Kong, and to actively involve the input of wide-ranging experts and the public in that regard. 
Regarding the design of a new assessment and grading system for post-1950 buildings, the government’s position is that any review should wait until work on the ‘1,444 Historic Buildings’ list is completed. This is despite the AAB chairman’s admission that “we are racing against time” in saving post-1950 heritage buildings in a May 2019 interview with the SCMP. 
It is not clear what the basis is for the government’s “wait” when it is patently clear efforts to protect Hong Kong’s post-war heritage architecture have to be prioritized as a matter of urgency. Behind the precarious state for the city’s modernist icons is a de-facto ruling by the AAB in 2013 to not grade buildings constructed in or after 1970. 
In the past year, the well-designed Excelsior hotel in Causeway Bay and the engineering feat that was the AIA building in Wan Chai have been demolished. More modernist landmarks, which include the General Post Office in Central and AC Hall in Hong Kong Baptist University, are set to meet the same fate before long.
In a recent commentary, Professor Ho Puay-peng, UNESCO Chair on Architectural Heritage Conservation and Management in Asia and former AAB member, argued that “work in this regard (protecting Hong Kong’s post-war heritage architecture) has to accelerate in parallel with the work on the 1,444 list and be given equal – if not greater – importance”. 
We call on the AAB to make a public commitment to prioritise and fast track the protection of post-1950 heritage architecture without further delay.
2. Reform five-member “expert panel” for historic building appraisals
Throughout the controversy over the grading of State Theatre in 2016, the AAB’s expert panel, which initially proposed a “Grade 3” for the building, had shown highly dubious ideas of heritage as well as a lack of requisite specialist knowledge (e.g. in post-war architecture and the history of Hong Kong popular culture) to carry out a fair appraisal of the cultural landmark.
More worryingly, a report by RTHK’s “This Morning” programme 《早辰‧早晨》 in late May 2016 revealed that some of the “expert panel” members ranked different historic buildings simply by age, while dismissing the importance of social value and collective memories, as well as the value of modern architecture like State Theatre. 
Their opinions exposed the fact that the grading mechanism and criteria for historic buildings in Hong Kong are both outdated and at odds with public expectations.  That it took a journalistic probe to uncover the arbitrary and anachronistic rationale (if it could be called one) behind a major heritage grading decision speaks volumes about the sorry lack of transparency around the panel’s work.
Had the proposed Grade 3 rating of the “expert panel” not been challenged by public scrutiny and the good sense of the AAB, State Theatre might have been lost to the dustbin of history. That the cultural landmark was finally, rightly recognised as a Grade 1 historic building and will now be restored into a cultural venue by its new owner is plain proof that it is now time for the “expert panel” to move on.
We are disappointed that our calls for the reform of this panel, which we first made in June 2016, have never been answered. We are also concerned how these same misguided “expert panel” members have been allowed to continue making appraisals of post-war heritage architecture. We also wonder if they are among the seven-member AMO task force that has been set up to carry out “Preparatory Work for the Assessment of Post-1950 Buildings”.
We call on the heritage authorities to reform the “expert panel”, which now only has five members, by bringing in more experts from different specialist areas. A wide-ranging pool of experts should be organised, with different experts engaged for each grading assessment depending on the nature of different buildings.
3. Make grading “score sheets” of AAB expert panel publicly available
Under the current “two-stage” historic building assessment and grading system, the AAB’s five-member “expert panel” first “scores” a building against six criteria and, in theory, with reference to the written appraisal AMO prepared for that building. The outcome of the panel’s scoring exercise is a proposed grade for the building, which is then put to the AAB for deliberation, endorsement or otherwise.
When the proposed grading goes before the AAB, a senior AMO member, usually a Curator (Historical Buildings), will make a powerpoint presentation of approximately 10 minutes to explain the basis of the rating. However, the individual “score sheets” of the five members of the “expert panel” are not made available, nor is the AMO’s written appraisal of the building. In other words, notwithstanding any questions that might be put to or clarifications sought from the senior AMO staff, the verbal presentation of the reasons for the proposed grading, aided by a set of powerpoint slides, is the only basis for the AAB members to decide the status of a building.
As the controversy over the initial proposed Grade 3 rating for State Theatre in 2016 showed, the exact decisions that the AAB’s “expert panel” made in their closed-door discussions have remained a mystery. 
We call on the authorities to make public the “score sheets” of the “expert panel” members in future AAB grading deliberations to increase transparency and public accountability of the process. This is for three reasons.
First, the “expert panel” has a duty to give reason to explain the logic and justifications for their proposed grading for a historic building. Second, making the “score sheets” available to AAB members will enable more informed, meaningful, and targeted discussion. Third, when the AAB puts the grading up for a one-month public consultation after a meeting, the public needs to know how the grading is arrived at in the first place. As it stands, while the AMO’s written appraisal of the building is made available during the one-month public consultation, there is no recording (neither audio or video) of the AAB’s grading discussion for public review, let alone the “score sheets” by the “expert panel”.
On 19 December 2015, the AAB had a retreat 「集思會」 on the grading and assessment of post-1950 buildings.  Five years on to the day, the AAB will be meeting again on the same subject. What meaningful progress has been made in the intervening years to systemically protect post-war heritage architecture is not at all clear.
We call on the AAB to not merely go through the motions at the brainstorming session on 19 December 2020, not least because Singapore recently made a landmark move to systemically advance the protection of modern architecture with their decision to conserve the Golden Mile Complex.  Hong Kong cannot afford to fall further behind the worldwide trend to appreciate and protect modern architecture.
We ask for the three calls we make in this submission to be earnestly considered by the AAB as the eyes of the public will be on how it advances the protection of post-war heritage architecture in Hong Kong.
Mr Paul Chan Chi Yuen
on behalf of Walk in Hong Kong
Mr Wong Wai-lun, Michael, Secretary for Development
Mr Ivanhoe Chang, Commissioner for Heritage, Development Bureau
Members of Antiquities Advisory Board
Ms Susanna Siu, Executive Secretary, Antiquities and Monuments Office
[^1] Walk in Hong Kong’s submission to the 2018-2019 Policy Address public consultation, 5 September 2018; Walk in Hong Kong’s submission to the 2019-2020 Budget public consultation, 11 February 2019; Walk in Hong Kong’s submission to 2019-2020 Policy Address public consultation, Walk in Hong Kong, 26 August 2019; Walk in Hong Kong calls on AMO to provide comprehensive update on “Preparatory Work for the Assessment of Post-1950 Buildings”, 2 June 2020.
 Officials in unprecedented move to protect Hong Kong’s heritage by creating new system to save modern buildings from developers’ wrecking ball, South China Morning Post, 14 May 2019.
 明報 – 古諮不評70年代建築 難民營遺址難逃清拆, 15/4/2019
 “Why conservation of State Theatre is a landmark project for Hong Kong”, Ho Puay-peng, South China Morning Post, 14 October 2020.
 香港電台 – 《早辰‧早晨》古物評級的疑惑足本篇, 3/6/2016
 明報 – 陳智遠：文物評級建議還可信嗎？ 從皇都戲院說起, 5/6/2016
 香港電台 -《早辰‧早晨》古物評級的疑惑足本篇, 3/6/2016; 明報 – 陳智遠：文物評級建議還可信嗎？ 從皇都戲院說起, 5/6/2016
 明報 – 戰後歷史建築評級 古諮委員倡1975年為界, 20/12/2015
 Supporting the conservation and commercial viability of Golden Mile Complex, Singapore Urban Redevelopment Authority, 9 October 2020; Proposed conservation of Golden Mile Complex – Joint statement, Singapore Heritage Society, ICOMOS Singapore, and the DoCoMoMo Singapore Working Group, 9 October 2020.
Walk in Hong Kong’s submission to the 2018-2019 Policy Address public consultation, 5 September 2018.
Walk in Hong Kong’s submission to the 2019-2020 Budget public consultation, 11 February 2019.
Walk in Hong Kong’s submission to 2019-2020 Policy Address public consultation, 26 August 2019.
Walk in Hong Kong calls on AMO to provide comprehensive update on “Preparatory Work for the Assessment of Post-1950 Buildings”, 2 June 2020.
Supporting the conservation and commercial viability of Golden Mile Complex, Singapore Urban Redevelopment Authority, 9 October 2020.
Proposed conservation of Golden Mile Complex – Joint statement, Singapore Heritage Society, ICOMOS Singapore, and the DoCoMoMo Singapore Working Group, 9 October 2020.
“Officials in unprecedented move to protect Hong Kong’s heritage by creating new system to save modern buildings from developers’ wrecking ball”, South China Morning Post, 14 May 2019.
“Why conservation of State Theatre is a landmark project for Hong Kong”, Ho Puay-peng, South China Morning Post, 14 October 2020.
明報 – 戰後歷史建築評級 古諮委員倡1975年為界, 20/12/2015
香港電台 -《早辰‧早晨》古物評級的疑惑足本篇, 3/6/2016
明報 – 陳智遠：文物評級建議還可信嗎？ 從皇都戲院說起, 5/6/2016
明報 – 古諮不評70年代建築 難民營遺址難逃清拆, 15/4/2019