A30SGROUP

RESEARCH
TABLE OF CONTENTS
EXECUTI VE SUMMARY
FOREWORD
TOURI SM I N HONG KONG
OVERVI EW
SOME FACTS ABOUT OUR VI SI TORS
TOURI ST ACCOMMODATI ON I N HONG KONG
HOTEL VS. GUESTHOUSE
NO. OF ROOMS AND I NCREASE I N ROOM RATE
NUMBER OF LI CENSED GUESTHOUSES
DI STRI BUTI ON
GUESTHOUSE OPERATI ON I S A GROWI NG BUSI NESS
FI ELD RESEARCH: GUESTHOUSE I N HONG KONG
ANNUAL UNACCOUNTED DEMAND = 6. 9M ROOMNI GHTS
INVESTI GATI ON ON UNLI CENSED GUESTHOUSES
EXTREMELY PROFI TABLE: $184 PER SQ. FT RENT
MORE TO BE FOUND ONLI NE
DI SCUSSI ONS
GUESTHOUSES TAKE UP RESI DENTI AL UNI TS
SHORTAGE OF AFFORDABLE HOUSI NG HI TS GRASSROOTS
INCREASE SHORTAGE I N HOUSI NG SUPPLY
I NCREASE DOMESTI C RENTS
VI NTAGE DMCS DO NOT REGULATE LAND USE
CHAI N EFFECT
LACKI NG DETAI LED STATI STI CS
POLI CI ES ON GUESTHOUSE
POLI CY ON HOTEL LAND SUPPLY
POLI CY ON LI CENSI NG AND ENFORCEMENT
RECOMMENDATI ONS
CONTROL THE GROWTH OF TOURI SM
COMPREHENSI VE STRATEGY ON HOTEL LAND USE
COMPREHENSI VE ASSESSMENT ON TOURI SM I MPACT
ENFORCEMENT AND PROSECUTI ON
OPEN DATA
WHAT I S OPEN DATA?
WHY SHOULD WE PROMOTE OPEN DATA?
WHAT THE GROUP HAS DONE?

ACKNOWLEDGEMENT
APPENDI X

EXECUTIVE SUMMARY

There are 862 licensed guesthouses in Hong Kong as of June

2014. They provide 8,080 rooms, which is equivalent to
approximately 1/10 of visitor accommodation available in
Hong Kong.

Calculating based on the available figures, it is estimated
that every 4 guesthouses found in Hong Kong, there
are 3 unlicensed. Unaccounted accommodation demand
amounts to 6.9 million room-nights per year, and it means
that roughly 2,273 unlicensed guesthouses have been
operating to cater for this unaccounted demand.

We believe the gap is filled out by the many unlicensed
guesthouses operating in town. The Groups field research
reveals that on Dundas Street, 7 out of 16 guesthouses
found within some 200-meter distance are unlicensed. In
just one single Hang Lung Mansion, 6 out of the 14
operating guesthouses are not found in the Governments
licensing database.

The business of guesthouse operation is extremely profitable.
Based on information collected in its field research, the
Group estimates that the income generated from a
guesthouse of 1,141 sq.ft averages to HK$210,366
per month (without deducting costs). (see Chapter 3)

Average income approximates to $184 per sq. ft,
while Tai Koo Shings rent is only $35-45 per sq. ft.
(see Chapter 3)

Most of these unlicensed guesthouses overspread in Yau
Tsim Mong, which are districts that have housed most low
income class. The impact of guesthouse business
operation is directly felt by this most vulnerable group.

Hong Kong already runs short of affordable housing.

Unlicensed guesthouses further reduce available flats for
lease by taking up residential units which are supposed to
house local people.

Hong Kong has bare hotel land use planning and there is no
segregation between tourist accommodation land use and
domestic land use.

Although the Government proposes to amend the Hotel and
Guesthouse Accommodation Ordinance (HAGAO) to
empower the Authority to refuse to issue/renew licences or
cancel the existing licences where the Deed of Mutual
Covenant (DMC) of the building concerned contains
explicit restrictive provisions stipulating that guesthouse
operations or commercial activities are not allowed, such
proposal will not resolve the problem to great extent.

As reflected in the field research, many unlicensed
guesthouses situate in buildings with vintage DMCs that
simply do not regulate the use of the premises. Owners are
free to use the premises for whatever purposes.
Although the relevant authorities have spared no effort to
combat unlicensed guesthouses from operation, our
research reveals that no convicted persons have been
fined for more than HK$20,000, even though the
statute has empowered the court to impose a
maximum fine of HK$200,000. Only 22 persons are
sentenced to imprisonment in the past 5 years for
committing the offence, and most of them stayed in
jail for less than 2 months.
We recommend Hong Kong to strategize its tourism
development. Master plan on hotel land use is welcome.
Consultation on master planning of hotel land use should be
introduced regularly to ensure democratic participation of
the planning process.

Review of existing hotel land use policy, including the
hotel-site only initiative introduced in 2008 but not
followed up afterwards, is most in need.

Taking into account our tourist carrying capacity, we should
consider accepting fewer tourists.
The Group pioneers to apply the Open Data Research
Method to conduct the current research with the aims to
introduce open data research to the civil society, as well as
to nurture a more transparent and accountable research
environment. All research data collected and material
referred to are available and open to public.

EXECUTIVE SUMMARY CHINESE

2014 6 862 8,080

1/10
6 9

2,273
4 3

200 16 7
14 6

1,141 $210,366
$184
$35-45

$200,000

$20,000 5 22
2

2008

FOREWORD

Tourists take up urban space. Other than making us to wait for
another MTR, they also take up our living space by occupying
residential units that have been converted into unlicensed
guesthouses.
Urban academics have been discussing the phenomenon, but no
systematic research has yet been conducted in this respect.
The 30SGroup is willing to take the initiative, and the preliminary
findings are astonishing. Turn to Chapter 3 and see the field
research results.
More significantly, we strive to open our data so that you and
everyone in the civil society can pick it up and continue with the
research. The Group pioneers to introduce the Open Data Method.
All of our research data are open and we expect the civil society to
take up and lead this journey further.
Now, lets turn over the page and face the reality.

The 30S Group
http://www.30sgroup.org/

1) INTRODUCTION: TOURISM IN HONG KONG

1. 1 OVERVIEW
While Hong Kong has only a population of 7.2 million
1
, we received
annual visitors arrivals of 54.3 million in 2013, which is 7.6 times of
our population.
Graph 1.1 Total Hong Kong Population and Visitors Arrivals in 2013
2013 vs. ()

1. 2 SOME FACTS ABOUT OUR VISITORS
Table 1.1: Visitors to Hong Kong
Total number of visitor
arrivals in 2013
2

2013
54.3M
(5.43 )
Number of overnight visitor
arrivals in 2013
3

2013
25.6M
(2.56

Visitors arrivals between
January and May 2014
4

2014 1 5

24M (13.6% year-on- year
increase)
(2.4 ) (
13.6%)
Visitors from Mainland
China between January and
May 2014
5

2014 1 5

18.4M (76.7%, a 17.6%
year-on-year increase)
(1.84 ) (76.7%,
17.6%)
Average length of stay of
overnight visits of mainland
visitors in 2013
6


3.4 nights, it peaked (4.8
nights) in 2003
7
and dropped
gradually to 3.4
nights in 2009
8

1
Population, Hong Kong Statistics, Retrieved from
http://www.censtatd.gov.hk/hkstat/sub/so20.jsp
2
Hong Kong Tourism Board, A Statistical Review of Hong Kong Tourism
2013, p.8-9
3
Hong Kong Tourism Board, A Statistical Review of Hong Kong Tourism
2013, p.8-9
4
Hong Kong Tourism Board, Visitor Arrival Statistics, May 2014
5
Ibid
6
Hong Kong Tourism Board, A Statistical Review of Hong Kong Tourism
2013, p.54, Part 3.2
7
Hong Kong Tourism Board, A Statistical Review of Hong Kong Tourism
2013, p.49, Part 3.2
8
Hong Kong Tourism Board, A Statistical Review of Hong Kong Tourism
2010, p.50, Part 3.3
54.3
7.2
VisitorsArrivials
HongKongPopulation
No.ofpeople(Million)

2) TOURIST ACCOMMODATION IN HONG KONG

2. 1 HOTEL VS. GUESTHOUSE
Table 2.1: Hotel vs. Guesthouse in Hong Kong (as of June 2014)
9

(2014 6 )

Hotel

Licensed Guesthouse

Number

229 hotels 862 guesthouses
Number of
rooms

71,066 rooms 8,080 rooms
Average
occupancy
rate

89% 87.5%
Average room
rate
(year-on-year
increase)

(
)
$1,463 (+2.8%) $546(+8.5%)
Distribution
of
guesthouses

80 in Yau Tsim Mong
40 in Wan Chai
41 in Central
21 in Eastern District
a few in other districts
706 in Yau Tsim Mong
76 in Wan Chai
a few in other districts

In 2012, total value-added of the tourism industries was $230.2

billion, or 11.4% of Hong Kongs Gross Domestic Product (GDP).
Among them, the retail trade generated VA of $82.0 billion and
contributed 4.1% to GDP, followed by food and beverage services
industry (2.2%)
10
.

2. 2 NO. OF ROOMS AND INCREASE IN ROOM RATE
The chart below shows the number of Hong Kongs four kinds of
hotel and guesthouse accommodation - High Tariff A Hotel (

9
Hong Kong Tourism Board, Hotel Room Occupancy Report, June 2014,
(Average from January to June 2014)
10
Census and Statistics Department, Tourism Satellite Account for Inbound
Tourism of Hong Kong, Hong Kong Monthly Digest of Statistics, May 2014,
para 2.4

), H
) and
Table
High

High

Mediu
Uncla

Tota
G


2. 3 N
There a
They p
1/10 of

Graph

11
Hong
2013
12
Hong
section
High Tariff
d Tourist Gu
2.2 Numbe
deca

Tariff A Ho

Tariff B Ho

um Tariff Ho

assified Ho

al number o
hotel

uesthouse

NUMBER O
are 862 lice
provide 8,0
f visitor acc
h 2.1 Numb

Kong Tour
Kong Touri
2 Part 4
862
B Hotel (
uesthouse (
er of Room
ade (full da

2
otel

9
otel

1
otel
1
tel

2
of
3

5
OF LICENS
ensed gues
080 rooms
commodatio
ber of Hotel

rism Board,
ism Board, H
34
83
9
)
()
11
s in Hotel a
ta available

2004
9,473
6,073
1,038
2,544
9,128
5,234
SED GUEST
sthouses in
s, which e
on availabl
and Licenc
2014)
12

(

Hong Kong
Hotel Room
2
6
H
H
M
U
G
), Medium T
1
.
and Guesth
e in Append
(

2013
17,52
26,99
20,04
5,448
70,01
7,630
THOUSES
Hong Kong
quivalents
e in Hong K
ced Guestho
2014 6
g Hotel Clas
Occupancy
HighTariffAH
HighTariffBH
MediumTariff
UnclassifiedH
Guesthouse
Tariff Hotel
houses in th
dix I)
)
3 2
22 17
99 27
48 21
8 5,
17 71
0 8,
g as of Jun
to approx
Kong.
ouses (as t
)

ssification S
Report, Jun
Hotel
Hotel
fHotel
Hotel
8
l (
he past
014
7,522
7,067
1,234
,243
1,066
,080
e 2014.
ximately
to June
System -
ne 2014,

2. 4 DISTRIBUTION
706 of these licensed guesthouses concentrate in Yau Tsim Mong.
76 guesthouses are in Wan Chai, with only a few in other districts.
2. 5 GUESTHOUSE OPERATION IS A GROWING BUSINESS
The business of operating guesthouse records significant growth in
all respects in recent years.
BETTER OCCUPANCY RATE
Occupancy rate of guesthouse went up to 88% by June since
2014
13
. It almost catches up with the occupancy rate of hotels, and
in any event, it has significantly increased by 35% in the past 11
years (compares with 2003
14
)

Graph 2.2 Occupancy rates of Hotel and Guesthouses

BETTER GROWTH I N ROOM RATE

Chapter 3 of this report reveals that the guesthouse business is
also growing relatively more profitable when compares with other
types of hotel operation. To be brief, in 2013, despite the room rate
of all other types of hotel has slightly decreased by 2.8%, the room
rate of guesthouse has, in contrary, surged by 2.4%
15
. Between
January and June 2014, average room rate of hotel increased by a

13
Hong Kong Tourism Board, Hotel Room Occupancy Report, June 2014,
(Average from January to June 2014)
14
Hong Kong Tourism Board, Hotel Room Occupancy Report, December
2003, section 1
15
Hong Kong Tourism Board, Hotel Room Occupancy Report, December
2013, section 2 Part 2
65
70
75
80
85
90
95
2008 2009 2010 2011 2012 2013 2014
June
P
e
r
c
e
n
t
a
g
e
HighTariffAHotel
HighTariffBHotel
MediumTariffHotel
Guesthouse

10

slight 2.8% while that of guesthouse sprang up by 8.5% on a year-

on-year basis
16
.
Table 2.3 Room Rate of Hotel and Guesthouse in the past decade
(full data available in Appendix II)
()
2004 2012 2013
2014
June
High Tariff A Hotel

1,356 2,457 2,382 2,446
High Tariff B Hotel

638 1,228 1,201 1,204
Medium Tariff Hotel

414 781 758 740
Average rate of hotel

803 1,489 1,447 1,463
Guesthouse

285 510 552 546

16
Hong Kong Tourism Board, Hotel Room Occupancy Report, June 2014,
(Average from January to June 2014)

11

3) FIELD RESEARCH: GUESTHOUSE IN HONG KONG

3. 1 ANNUAL UNACCOUNTED DEMAND = 6. 9M ROOM
NIGHTS
Given the huge volume of annual visitors we receive, it is
understood that there exists a shortage in the supply of hotel and
guesthouse in Hong Kong. But what is the scale?
The Group attempts to calculate the size of the shortage, and it is
estimated that the hostel demand unaccounted by all hotels and
licensed guesthouses in Hong Kong equivalents to 6.9M rooms-
nights per year.
The calculations are as follows:-
Unaccounted Demand (no. of room-nights):
= Annual Hostel Demand - Annual Hostel Supply
= 32.6 - 25.7 M = 6.9M room-nights

Assuming the average party size (i.e. number of guests sharing a
room) = 2 persons
17

Annual Hostel Supply:
79,146 Rooms X 365 days X 89% occupancy rate = 25.7M

Annual Hostel Demand:
25.6M overnight visitors X 75% of them stayed in
commercial hostel
18
X 3.4 nights (length of stay) / 2
(party size) = 32.6M

In that case, how many hotels or guesthouses are needed to
satisfy this Unaccounted Demand?
No. of extra hotel rooms in need:
= 6.9M room-nights / 89% occupancy rate / 365 nights
= 21,364 rooms

21,364 rooms more or less represent the total number of
households settled by almost 3 Choi Hung Estate ()
19
.
Given the average number of rooms in each guesthouse is 9.4

17
Party size is significant to our calculation. Yet, this figure is not available
from the Tourism Board or any relevant Government departments. The
Group has made enquiry to professionals in the hotel industry, and
understood that this number should be roughly 2.
18
Tourism Board, A Statistical Review of Hong Kong Tourism 2013, p. 54
(Types of Accommodation / All Country 2013)
19
According to the Wikipedia, the Choi Hung Estate contains 7,400 flat
units.

12

rooms
20
, these 21,364 rooms equivalent to roughly 2,273
guesthouses.
Taking into account that Hong Kong has 862 licensed guesthouses
(by June 2014), it is estimated that in every 4 guesthouses
found in town, there is 3 unlicensed.
The above is a very rough estimation based on the best available
data. The estimation may not be accurate but it gives a projection
of the actual demand, as well as the scale of the problem.

3. 2 INVESTIGATION ON UNLICENSED GUESTHOUSES
To satisfy the above unaccounted demand, numerous guesthouses
operate without licensed. The Groups field research reveals their
astonishing number.
6 OF 14 GUESTHOUSES FOUND IN ONE SI NGLE BUI LDI NG ARE
UNLI CENSED
Dundas Street: On Dundas Street, 7 out of 16 guesthouses found
within a 200-meter distance (between Nos. 33-46) are unlicensed.
In just one single Hang Lung Mansion, 6 out of the 14 operating
guesthouses are not found in the Governments license database.

Table 3.1: Guesthouses on Dundas Street, Yau Ma Tei
()

Guesthouse

Address

Building

Floor

With
license

33-35 1 Y
33-35 1 N
44-46 2 N
Q Q Hotel 44-46 4 Y
44-46 4 Y
44-46 4 Y
44-46 5 Y
44-46 6 Y
44-46 N
44-46 7 Y

21
44-46 7 N

20
The average room number of unlicensed guesthouse is deduced from figures
obtainedfromtheTourismBoard.AccordingtotheTourismBoard,asofJune2014,
there are 862 licensed guesthouses in Hong Kong, providing 8,080 rooms, so the
averageroomnumbershouldbe8,080/862=9.4rooms.
21
HADLA,updatedon11August2014

13

44-46 7 N
44-46 7 & 10 N
44-46 9 Y
44-46 9 Y
44-46 10 N
Shanghai Street: Of the 7 guesthouses found within 250m on
Shanghai Street, 6 are unlicensed.
Table 3.2 Guesthouses on Shanghai Street, Yau Ma Tei
()

Guesthouse

Address

Building

Floor

With
license

453-455 - 1 Y
453-455 - 1 N
453-455 - 1 N
459 - N
494-496 - N
512 - 2 N
516 - 2 N

Bute Street: 2 of the 5 guesthouses are unlicensed between Bute
Street No.60 and No.77.
Table 3.3 Guesthouses on Bute Street, Mong Kok
()
Guesthouse

Address

Building

Floor

With
license

75-77 1 Y
75-77 1 Y
64-66 N
60 - 2 Y
60 - 3 N

Although the distribution of guesthouse is quite uneven so the
above information is not capable to show the accurate and
complete picture of unlicensed guesthouse operation, the above
simple street count exercise already revealed the severity of the
problem.
METHODOLOGY
The Groups researchers paid site visits to selected districts and
observed name plates of buildings on a particular part of the
streets to locate the potentially unlicensed guesthouses.

14

Noting down the names of the operating guesthouses, researchers

matched the names with the Government license database.
Guesthouses which names were not found in the database would be
considered unlicensed.
Researchers then paid second visit to the unlicensed guesthouses
to confirm that they are operating. Researchers also made calls to
some of these guesthouses to check room rates.
Online research was also conducted. Some of the unlicensed
guesthouses were found in hotel booking websites.
All data of visits is open and exhibited in the appendix to this report.
Limitations:
Sampling may be biased. Streets in Yau Tsim Mong are
selected because most of the guesthouses (whether licensed
or unlicensed) concentrates there.
Shadow guesthouses might not be detected.

3. 3 EXTREMELY PROFITABLE: $184 PER SQ. FT RENT

Hugh profit can be derived from the operation of guesthouse
business. Table 3.4 below summarizes the monthly average income
generated per sq. ft. of some unlicensed guesthouses (without
deducting costs). Most of them triple the monthly yield of
residential leasing, see Table 3.5 below to compare the return of
the two investments.
Table 3.4: Monthly Average Income Generated per sq. ft. by Some
Unlicensed Guesthouses (see below for calculations)
()

Guesthouse

Location

Monthly Yield per sq.
ft($)

Yau Ma Tei 184

Table3.5:MonthlyYieldofResidentialLeasing

Property

Location

Monthly Yield per sq.
ft($)
(Saleable / Gross)

22
Wan Chai 54/42

22
2014 07 17

15

11 12
23
Hunghom 33/28
1
24
Shatin 43/35

25
Quarry Bay 45.9/40.6
2
26
Lai Chi Kok 38.5/27.0

Operating guesthouse is extremely profitable. Below are

calculations of income derived from some guesthouse businesses.
AVERAGE OCCUPANCY RATE (JAN J UN 2014)
27
:
YauMaTei/MongKok:93%
CASE 1
Guesthouse:
Address: 2
nd
Floor, No. 512 Shanghai Street, Kowloon (512 2 )
Floor area: not available
28

Total number of room: more than 9 rooms
29

Room rate: $500
30

Estimated monthly income: HK$125,550

CASE 2
Guesthouse:
Address: 4th Floor, Wah May Building, Block B, No.211 Portland Street, Kowloon
(211 B 4 )
Floor area: 1,141sq. ft
31

Total number of room: 13
32

Room rate: 580
33

Estimated monthly income: HK$210,366
Average rent per sq. ft: $184

CASE 3
Guesthouse:
Address:
Floor area: not available
Total number of room: 10
34

23
ibid.
24
ibid.
25
3 3.25 46 2014 07 09
26
Ibid.
27
Hong Kong Tourism Board, Hotel Room Occupancy Report, June 2014,
Table 3 Hotel Room Occupancy ( By District )
28
Centadata, 16 Years Transaction Web, accessed on 22 July 2014
29
Cold call on 24 July 2014
30
Cold call on 24 July 2014: rent depends on date, around RMB 400
31
Centadata, 16 Years Transaction Web, accessed on 22 July 2014
32
http://www.hkzhan.com/func/common/h-1-344.html
33
Cold call on 24 July, check-in date: 20 Aug 2014; 2
nd
cold call on 17
August 2014, check-in date: 1 Sep 2014
34
http://www.hkzhan.com/func/common/H-1-278.html

16

Room rate: 725

35

Estimated monthly income: HK$202,275

METHODOLOGY
Floor area of particular premises is found by searching through the
Centadata database.
Room rates and number of rooms of particular guesthouses are
available from the websites which provide booking service.
Researchers also made calls to some of these guesthouses to
double check room rates, extra charges and numbers of room.
Monthly income ( without deducting operative costs) is
calculated with the following formula:
Numbers of room X average room rates X occupancy
rate of that particular district X 30 days
Monthly average income generated per sq. ft is calculated with
the following formula:
Monthly income (without deducting operative costs) /
floor area of particular premises
Limitations:
Seasonal fluctuation of room rates is not reflected in the
results;
Actual occupancy rate varies between different guesthouses;
Floor areas (saleable and gross) of the premises might not be
accurate since no floor plan is available, this will affect the
accuracy of the average profit per sq. ft calculated;
Numbers of room might not be accurate since comprehensive
inspection of the internal structure of the guesthouses is not
available; and
Operative costs vary and no data is available.
3. 4 MORE TO BE FOUND ONLINE
Our online investigation also reveals that many guesthouses
operating in Hong Kong are unlicensed.
179.hk introduced guesthouse accommodation to travellers. 19 out
of 77 guesthouses it introduced are unlicensed. Details are included
in Appendix III.

35
Cold call on 17 August 2014, check-in date 1 Sep 2014

17

4) DISCUSSIONS

The Groups field research indicates the scale of the problem of
unlicensed guesthouses may be more severe than one have
imagined.
4. 1 GUESTHOUSES TAKE UP RESI DENTI AL UNI TS
Stiff competition exists between residential and hotel land uses
because Hong Kong lacks comprehensive hotel land use planning.
Both Hang Lung Mansion and Kingland Apartments, the two
sampling buildings examined by the Group, have almost been
converted entirely to guesthouse towers. According to the Home
Affairs Departments Database of Private Buildings in Hong Kong,
Hang Lung provides 56 and Kingland provides 128 flat units.
Amongst them, more than 100 units of residential flats have now
disappeared from the rental market by the aforesaid conversion.
In other words, tourists displace existing tenants. There is no
available data to estimate the actual floor area taken up by
guesthouses (whether licensed or unlicensed), but the scale must
be tremendous.
4. 2 SHORTAGE OF AFFORDABLE HOUSI NG HI TS GRASSROOTS
Most of these unlicensed guesthouses located in Yau Tsim Mok,
which are areas that have housed many of the lower income class.
A number of residents in these districts cannot afford reasonable
flats, but they are also not benefited from the public housing
system, either because they are not eligible or they have already
been waiting in the long queue. The raging business of guesthouse
displaces grassroots households, and mashes the most vulnerable
group in the housing supply hierarchy.
4. 3 INCREASE SHORTAGE I N HOUSI NG SUPPLY
Hong Kong already faces shortage of affordable housing. The
intrusive occupation by the guesthouse industry further tightened
supply.
4. 4 INCREASE DOMESTI C RENTS
Quite a number of these unlicensed guesthouses situate on or
above the 2
nd
floor of their respective buildings, and they take up
domestic units that were supposed to be let. This intensifies the
shortage of housing supply.
As more units have lost to the guesthouse market, the tightened
supply further drives up the rent.
4. 5 VI NTAGE DMCS DO NOT REGULATE LAND USE

18

In the latest Governments consultation on the amendment of the

HAGAO, the Government relies on the proposed provisions that
would empower the LAO to consider the DMC of the building before
granting license to particular guesthouses, as an allegedly effective
measure to counter the development of guesthouse in residential
areas.
However, this measure will only affect buildings which their DMCs
contain explicit restrictive provisions stipulating that
guesthouse operations or commercial activities are not allowed, or
the premises are for private residential use only. In other words,
mixed commercial / residential buildings (without such explicit
restrictive provisions) are not taken into account by the proposed
amendments. As a result, the proposed amendments would have
limited impact.
Both of the two sample buildings the Group has examined are with
vintage DMCs, and both DMCs do not restrict the use of the
premises as guesthouses. It implies that the owners cannot rely on
the DMCs to make injunction application to court against owners
who intend to use their premises to host visitors. In this case, the
proposed amendments of the HAGAO are of no assistance to the
owners.
4. 6 CHAI N EFFECT
The conversion of flats from domestic households to guesthouses
initiates a chain of events. Nearby shops, adopting to the
demographic shift, start changing their business strategy to cater
only the needs of tourists. Bye Bye Barcelona a recent
documentary
36
, reveals how tourism stifles ordinary and everyday
life of the local Spain. Shops which serve locals only would be
displaced when they could not pay the competitive rent affordable
by the jewellery chains, luxury brands and drug stores.
4. 7 LACKI NG DETAI LED STATI STI CS
The Group noted that much important data is missing from the
public eyes. At least, the followings are not made available to us:-
actual number of domestic leasing units available to the
market
actual demand of domestic leasing units (in other words, the
size of the domestic leasing market)
total floor area occupied by guesthouses business (both
licensed and unlicensed)
geographical distribution of guesthouses (both licensed and
unlicensed)

36
Eduardo Chibas, Bye Bye Barcelona, Youtube

19

assessment on the impact of guesthouse development on

nearby environment (i.e. traffic flow, density, air quality,
property price etc.)
The impact of tourism on the existing urban fabric needs to be
evaluated. Development of hotel and guesthouse will affect the flow
of pedestrians and traffic. They also displace original residence and
commercial blocks, dissolve and reorganize the urban fabric.
Without comprehensive data and full knowledge on hotel land use,
it is impossible to formulate any planning or policy, or to carry out
meaningful assessment on facilities in need to support the growth
of tourism.

20

5) POLICIES ON GUESTHOUSE
Chapters 3 and 4 of the report reveal the scale of our tourist
accommodation problem. In light of that, what is the Governments
vision on catering the increasing demand and tackling the sustained
shortage? After all, what are our existing policies on hotel land use?
5. 1 POLICY ON HOTEL LAND SUPPLY
Hotel land comes from the following sources:-
1. HOTELONLY SI TES
To increase supply, the Development Bureau introduced in 2008
some pilot measures to facilitate development of hotel land. The
2008-2009 Application List started to include sites specifically
dedicated for hotel land use. However, no follow-up action or
impact assessment has been initiated by the Development Bureau
after the launch of the pilot measures.
On a pilot basis, sites have been included in the 2008-2009
Application List (AL) to be disposed of specifically for hotel
development (the AL Method). The Conditions of Sale of the
respective site will provide that the whole site or part of the
permissible development on the site, as the case may be, will be
restricted to hotel purposes with the amount of GFA for hotel
stipulated (the hotel only sites). The reserve prices for triggering
and auctioning such hotel only sites from the 2008-2009 AL
should be set on the basis of Lands Departments assessed
premium for hotel purposes only.
2. CONVERSI ON
At the same time, applications for lease modifications / land
exchanges for hotel only development was allowed. (the Lease
Modification Method)
According to a report released by the Land Justice League Hong
Kong in February 2014, only 44 hotel projects developed after 2004
acquired land through the AL Method. On the contrary, most of the
other hotel projects acquired land by conversion: 98 residential
blocks and 105 office units have been converted to hotel land use
37
.
The above report also reveals the growing trend of conversion of
existing residential land use to hotel land use by making application
to the Town Planning Board (TPB). 35 hotel projects were
completed between 2004 and 2013 by applying to the TPB for
conversion, and another 65 projects were approved by the TPB and
yet to be built.

37
The Land Justice League , 10 90
, 23 February 2014

21

3. ILLEGAL CONVERSI ON
Meanwhile, many guesthouses are operating without license.
Premises of residential land use are converted to hotel and
guesthouse accommodation illegally.
However, such development also subject to certain limitations:-
RESTRI CTI ONS ON DEVELOPI NG HOTEL LAND
1. TOWN PLANNI NG REQUI REMENTS
Hotel is always permitted under Commercial zones and Other
Specified Uses annotated Mixed Use zones. In a number of other
zones, hotel use requires planning approval by the Town Planning
Board (TPB).
38

2. THE BUI LDI NGS ORDI NANCE
Concessions on GFA - To encourage hotel development for
supporting Hong Kongs tourism industry, the Building Authority
has been exercising discretionary power to grant concessions to
bona fide hotel developments since 1969, mainly in the form of
exempting certain hotel areas from GFA calculation under section
42 of the Buildings Ordinance (Cap. 123) (BO).
The concessions were formalized in November 2000 with the
introduction of Regulation 23A of the Building (Planning)
Regulations (Cap. 123F) under the BO, whereby a hotel
development will be treated as a non-domestic development so as
to enjoy a higher plot ratio and site coverage. In addition, certain
areas and facilities essential for hotel operation could be
disregarded for GFA calculation
39
.
3. LAND LEASE
The lease conditions governing each of these lots may be different
depending on when the lease concerned is executed and the
prevailing considerations at the time of execution:-
For instance, some old leases do not contain user clause and the
land use is virtually unrestricted. Lessee of such leases has the
flexibility to determine which use to pursue in developing the land
as far as lease conditions are concerned.
In other cases, the lease may contain a user clause, such as non-
industrial (residential use is allowed under such a user clause),
non-industrial excluding private residential and hotel purposes,
to cite a few examples.

38
Development Bureau, Administration's paper on development and
operation of hotels, CB(1)580/12-13(03), para. 3

39
ibid, para.12

22

In some cases, the minimum and/or maximum gross floor area

(GFA) for specific uses may also be stipulated
40
.
Land Premium - If the lessee wishes to develop his lot differently
from what is permitted under the lease, he may apply for lease
modification which, if approved, would be subject to payment of
additional premium as necessary, among other terms
41
.
Restriction on alienation - Sale of hotel developments in the
market is usually on an en bloc basis. The Lands Department
issued internal instructions in July 2003 requiring the imposition of
restriction on alienation of hotel developments, except as a whole,
in lease modification and land grant that permit development of
hotel, to curb possible misuse of hotels for residential purpose.
Irrespective of whether such an alienation restriction is included in
the lease, the lessee must comply with the lease conditions of the
site in question and the relevant legislation
42
. However, such
internal instructions are not made available to the public. It is not
possible to carry out assessment on its implementation and impact.
4. DEED OF MUTUAL COVENANT
Some DMCs also regulate land use of particular premises. However,
the DMCs are enforceable between owners only. If the Incorporated
Owners fail to take action against owners who have breached the
DMCs, other owners have no remedy.
5. 2 POLICY ON LICENSING AND ENFORCEMENT
Guesthouses in Hong Kong are managed by the Government under
a licensing regime.
LICENSING REGIME
1. THE LAW
The Hotel and Guesthouse Accommodation Ordinance (Cap. 349,
HAGAO) aims to, through a licensing regime, ensure that
premises intended to be used as hotels or guesthouses, meet the
building structure and fire safety standards specified in the BO and
the Fire Services Ordinance (Cap. 95) to safeguard the lodgers and
the public
43
. It has no ambition in controlling the Guesthouse
business.
Operating an unlicensed guesthouse commits a criminal offence
under the HAGAO, and such person is liable on conviction to a fine

40
ibid, para.6
41
ibid, para.7
42
ibid, para.. 8
43
Home Affairs Department, Consultation Document on Review of the
Hotel and Guesthouse Accommodation Ordinance, para. 1.1

23

of $200,000 and to imprisonment for 2 years, and to a fine of

$20,000 for each day during which the offence continues.
2. THE ENFORCEMENT AUTHORI TY
The Office of the Licensing Authority (OLA) under the Home Affairs
Department (HAD) is delegated by the Hotel and Guesthouse
Accommodation Authority (the Authority)
44
for implementing the
Ordinance, including issuing licences and performing relevant
regulatory and enforcement duties.
45

3. ENFORCEMENT
NO ONE HAS BEEN FI NED OVER $20, 000 I N THE PREVI OUS DECADE
The figures produced by the HAD shown that the Department has
strengthened its law enforcement action in recent years. Both the
number of enforcement actions taken and conviction in 2013 are
four times than those of five years ago.
Although the statutory penalty of potential heavy fine and the
possibility of defendant being sentenced to imprisonment can be
regarded as deterring, our in-depth research, which traces the
actual amount of fines, reflects that these statutory measures have
not been enforced in their full gear.
Most of the cases prosecuting operators of unlicensed guesthouses
were handling by the Magistrates' Court, the relevant decisions,
judgments and therefore details of the cases and the resulting
amount of fines are not recoverable from the Judiciary website.
Only pieces and bits of data can be found from the Press Release
issued daily by the Governments Information Services Department.
The 30S Group has reviewed the many Press Releases issued
between 2011 and 2013 and noticed that across the years, the
actual amounts of fine are low. The record-high fine was paid by
the convicted person of the 2006 Parkview case, but he has only
been fined for $20,000 in total despite the massive media coverage
of the breach of Parkview and its severity
46
.
Table5.1:Finesofconvictedpersonsbetween2011and2013
Amount No. of cases
Fined below HK$5,000 Around 170
Fined between HK$5,000 10,000 7
Fined between HK$10,000- 20,000 12
Fined above HK$20,000 0

44
In accordance with section 4(1) of the Ordinance, the Secretary for
Home Affairs is the Authority of the Ordinance.
45
Home Affairs Department, Consultation Document on Review of the
Hotel and Guesthouse Accommodation Ordinance, para. 1.2
46
2006 10 28

24

*There is no official statistics on fines, the above figures come
from the researchers review on press release issued by the
Government. Please note that the Government press releases
may not cover all the cases of conviction.

Table 5.2 Enforcement against Unlicensed Guesthouse Operation

Table 5.3 shows that only a few of the convicted were sentenced to
imprisonment, and none of them were put into prison for more
than 4 months.
Table 5.3 Convicted persons being sentenced to imprisonment
47


2009 2010 2011 2012
2013 (30
Jun)
4 months 1 0 0 0 0
3 months 0 1 2 0 0
2 months 2 2 0 4 2
6 weeks 0 0 0 2 0
Below 1 month 0 3 1 1 1
Total 3 6 3 7 3

4. DELAY: I N 2006, THE OLA TOOK 268 DAYS TO TAKE ACTI ON

The latest Consultation Paper provides that when suspected
unlicensed guesthouse operation is identified or such a report is
received, the OLA will conduct an inspection within eight working
days
However, there have been delays in previous enforcement action.
The report on Licensing of hotels and guesthouses by the Audit
Commission
48
in 2006 reflected that there was delay in
commencing enforcement action and the time span to complete
action on suspected unlicensed establishments were long. On
average, it took 268 days to complete action in respect of
suspected unlicensed establishments in the years 2001 to 2006 (up

47
, 10 July 2013
48
Audit Commission, Report No. 47 of the Director of Audit, 23 October
2006, Chapter 8 Licensing of hotels and guesthouses
2009 2010 2011 2012 2013 2014 Q1
Complaints 445 366 696 1418 - -
Enforcement
action
2430 2678 3125 6791 9889 3217
Prosecution 39 38 53 128 171 46
Conviction 36 44 39 110 161 43

25

to 30 June); in 343 cases (19% of 1,842), the time span was more
than 500 days.

5. POLI CY ON REPORTI NG
The Enforcement Unit of the OLA is responsible for taking
enforcement action against unlicensed establishments. Operators of
unlicensed guesthouses are sued under HAGAO Part II Section 5
Restriction on operating hotel or guesthouse unless exempted or
licensed. For guesthouses borrowing licenses, operators or
managers will be sued under HAGAO Part VII Section 21 Offences
in relation to certificates of exemption and licences.
The Enforcement Unit obtains information about suspected
unlicensed establishments from four sources :-
(1) complaints from the public,
(2) referrals from other government departments,
(3) referrals from the Building Safety Unit, and
(4) cases identified by the Enforcement Unit by field surveillance
and from search of advertisements.
Enforcement actions are taken under the Procedural Guidelines on
Conducting Policing Inspection and Particulars for Prosecution
Inspection for Suspected Unlicensed Operations. A team comprising
normally two Licensing Inspectors conducts one or more
preliminary inspections at the premises concerned to ascertain
whether there is evidence, prima facie, that an unlicensed
establishment is in operation. If there is such evidence and the
operator has not been warned before, a warning letter is issued; if
he or she has been warned before, the Unit will proceed to conduct
in-depth inspections. A team comprising normally three Licensing
Inspectors will collect evidence for prosecution. Investigation report
is then prepared and sent to the Department of Justice. If the
evidence collected is sufficient, the Unit instigates prosecution
under the HAGAO by applying for a summons.

26
6) RECOMMENDATIONS
The influx of visitors continues to put Hong Kong's tourism capacity
to test. Can we make a pass? What should we do?
6. 1 CONTROL THE GROWTH OF TOURISM
In 2013 Hong Kong received a total of 54.3M visitors, while Inner
Paris received only 29.3M. We have almost doubled Pariss volume.
Notably, Paris provides 81,000 hotel rooms, while Hong Kong
provides only 79,000 rooms. Although the occupancy rate is not
comparable, the shortage is obvious but incurable in short time
given the necessary time lapse between planning and hotel building.
Building more hotels is the quick answer but it might not be the
best answer considering Hong Kong already experiences shortage
in housing land supply. Given the long queue awaiting public
housing, the Governments effort in locating proper housing sites
should give priority to the local needy grassroots, instead of
locating accommodation for tourists.
In light of the above, the better idea would be to control the growth
of accommodation demand of tourist by reducing their numbers.
6. 2 COMPREHENSIVE STRATEGY ON HOTEL LAND USE
Hong Kong lacks comprehensive hotel land use planning and has
exercised no systematic control on hotel land supply. Facing a
drastic increase of tourist population, it is most in need that Hong
Kong starts to have her comprehensive strategy on hotel land use.
It is projected that visitor arrivals in 2017 would exceed 70 million
and that in 2023 would be over 100 million
49
. Assuming that the
percentage of overnight visitor arrivals remains at 48.9% and the
overnight visitor average length of stay is still 3.5, it could be
estimated that 445,400 sq. m of hotel land are needed by 2017. If
the land supplied falls below this figure, it is anticipated that some
existing residential and commercial lands will be taken up for
tourism
50
.

49
Commerce and Economic Development Bureau, Assessment Report on
Hong Kong's Capacity to Receive Tourists, December 2013.
50
Calculation: Number of visitors*nights they stayed:
70,000,000*48.9%*(3.5+1) = 154035000
Number of double bed room needed: 154035000/365/2 = 211,007
Number of double bed room needed to be built (Assume the existing hotel
rooms can accommodate 2 people on average): 211,007 - 78738 =
132269
Taking the area of one standard double bed room as 20 square meters,
and excluding the the auxiliary operational facilities, the area of hotel room
needed is: 132,269*20 = 2,645,380 square meters. Applying the same

27
6. 3 COMPREHENSIVE ASSESSMENT ON TOURISM IMPACT
There is little evaluation on the cultural and environmental impacts
of tourism development in the recent Assessment Report on Hong
Kongs Capacity to Receive Tourists
51
released by the Government.
In its Chapter 7 Impact on the Livelihood of the Community, only
the number of criminal offences by mainland visitors was inspected.
However, it is obvious that the impact of tourist on livelihood of
communities does not limit to criminal offences.
Take the report Defining, Measuring and Evaluating Carrying
Capacity in European Tourism Destinations
52
which was
commissioned to the European Commission, Directorate-General
for Environment, Nuclear Safety and Civil Protection as an example,
physical ecological impacts, social-demographic impacts and
political-economic impacts are examined.
The assessment was divided into areas with distinct geographical
characteristics. Indicators for social-demographic impacts include:
crowding-out, breakdown of host community values,
tourists/residents conflicts, overcrowding and occasional irritation
of local population, and adjustment of residents to tourists' life
styles. Indicators for political-economic impacts included: cost of
living for residents, land-use conflicts between activities,
seasonality of employment and income, as well as dependence on
tourism activity.
We suggest the government to carry out a complete assessment on
tourism which should be done district by district, as tourist
attractions and facilities are unevenly distributed. A set of
comprehensive indicators which can truly reflect the livelihood of
Hong Kong people and the health of economy is required. The
assessment just finished only reflected the trend of tourism
development, and the capacity of tourist attractions and facilities,
neglecting its impact on local people. It also lacks reflection on
whether it is healthy for our economy to continually depending on
tourism.

6. 4 ENFORCEMENT AND PROSECUTION

method, the hotel land needed in 2023 is estimated at least to be 445,400

square meters.
51
Commerce and Economic Development Bureau, Assessment Report on
Hong Kong's Capacity to Receive Tourists, December 2013.
52
Environmental Planning Laboratory of the University of the Aegean ,
Material for a Document, DEFINING, MEASURING AND EVALUATING
CARRYING CAPACITY IN EUROPEAN TOURISM DESTINATIONS, 2002

28
The Consultation Document on the Hotel and Guesthouse
Accommodation Ordinance
53
, suggested several amendments to
facilitate prosecution of unlicensed guesthouses establishment. It
proposed that (1) circumstantial evidence to be regarded as
sufficient to instigate a prosecution, (2) the OLA could apply to the
Magistrates Court for warrants to facilitate its public officers to
enter into, and break in if necessary, individual premises for
inspection and enforcement actions, (3) heavier penalties and
closure of premises would be implemented.
We welcome the amendment, though it is notable that the Audit
Commission has already recommended the Department of Home
Affairs in 2006 to consider drawing up guidelines that set out the
circumstances under which the OLA would invoke HAGAO Section
20(1) of the HAGAO to make an order in writing directing that the
hotel or the guesthouse shall close and shall cease to be used as a
hotel or a guesthouse.

53
Home Affairs Department, Consultation Document on Review of the
Hotel and Guesthouse Accommodation Ordinance

7) OPEN RESEARCH METHOD

The Group pioneers to apply the Open Data Research Method to
conduct the current research with the aim to introduce open data
research to the civil society as well as to nurture a more
transparent and accountable research environment.
7. 1 WHAT IS OPEN DATA?
Quoting the World Wide Web Foundation, in few short years open
data has moved from being a niche interest in a few countries, to
become part of the global policy mainstream, promoted widely by
civil society and multilateral institutions
54
. Joel Gurin, the current
Senior Advisor at the Governance Lab at New York University
provides a definition for open data:-
Open data is accessible public data that people, companies, and
organisations can use to launch new ventures, analyse patterns
and trends, make data-driven decisions, and solve complex
problems. All definitions of open data include two basic features:
the data must be publicly available for anyone to use, and it must
be licensed in a way that allows for its reuse. Open data should also
be relatively easy to use, although there are gradations of
"openness". And there's general agreement that open data should
be available free of charge or at minimal cost.55
7. 2 WHY SHOULD WE PROMOTE OPEN DATA?
It is agreed that open data, especially open government data,
would lead to
56
:
More efficient and effective government both through
government using its own data better, and through innovators
outside of government identifying improved ways to provide
public services, meeting the diverse needs of citizens through
digital technologies;
Innovation and economic growth acting as a 21st
Century infrastructure, and a raw material, for activity in the
information economy. Start-ups and established businesses
can use open data to generate new products and services, and
secure efficiencies, generating a net-gain for country
economies;

54
Justin Edwards, Launching Research: Exploring the Emerging Impacts of
Open Data in Developing Countries, accessed on 15 July 2014
55
Joel Gurin , Big data and open data: what's what and why does it
matter?, accessed on 15 July 2014
56
Tim Davies, Open Data Barometer 2013 Global Report, page 9

30
Transparency and accountability allowing citizens and
civil society to see, understand and monitor better what their
governments and the private sector are doing, challenging
corruption or unaccountable activity, and finding opportunities
to influence policy and
Inclusion and empowerment enabling marginalized
groups to get involved in the political process, and removing
imbalances of power created through information asymmetry.

7. 3 WHAT THE GROUP HAS DONE?

IT S OPEN, ACCESSI BLE, AND FREE!
The Group has decided to make available to the public all of the
raw data and material collected during the process of conducting
the current research. All of the data is at your fingertips, available
within seconds and absolutely free of charge. The data sets are
presented in user friendly format such as Excel tables and Google
diagrams, with the aim to reduce difficulty encountered in
subsequent data mining and sharing.
Although it is a general understanding that the highest priority of
most open data advocates is to open up the government database,
the Group thinks it would be good to start from itself. When the
Group decides to open up its research data, it anticipates more and
more civil organizations to perform the same so that a stronger
database on various social researches can be built within the civil
society to improve accountability of researches conducted.
YOU CAN DO THE SAME
Better data collection, data analysis and data availability will help
load bullets for social advocates who strive to convince the public
and thus pursuant the government on a particular social subject,
and the Group is here to fire the first shot. With this move, we
encourage the Government and stakeholders of the civil society to
reconsider the significant impact of opening data, and to bring
Open Data Research to their daily practice for the building of a
more democratic and transparent society.

ACKNOWLEDGEMENT
We are thankful to the kind assistance generously provided by Mr.
Chan Kim Ching .
RESEARCH TEAM
MR LAURENCE LI LUJ EN
Mr Laurence Li, the convenor and one of the founders of the 30S
Group, is a practicing barrister focusing on financial and financial
services law. He is a member of the Financial Services
Development Council and convener of its research committee. He
serves as a judge on the Regulatory Tribunal of the Qatar Financial
Centre in Doha, Qatar, and is an Honourary Fellow of the Asian
Institute of International Financial Law at the University of Hong
Kong. He is also a member of the Town Planning Board and the
Council of the Hong Kong Polytechnic University.
MS. FUNG WAN YIN KIMBERLY
FUNG Wan Yin Kimberly is currently studying towards a Bachelor of
Social Sciences in Urban Studies at CUHK. She is now the
committee member of the Hong Kong Urban Laboratory (
), which aims to develop diverse spatial practices and widen
public imagination through art. Projects included "Once There Was
a Factory" (2013) () and "Non-indigenous Lives - A
four-part installation" (2014)(
).
She believes that if you constantly strive to give your best effort to
something, you will gain insight into it (). She
hopes to become as creative and competent as members of the
Lunar Society of Birmingham, so that she can transform
imagination into real positive changes in the society.
MS. CHAN YUK FUNG MELODY
Grew up in this metropolitan, the development of urban landscape
and evolution of the city have always remained the interest of
research of CHAN Yuk Fung Melody.
This summer she proposed to the Group to conduct the current
research, and she is most happy to find the Home Affairs
Department shared the same view that the situation requires
immediate and urgent attention, when the latter announced the
commencement of consultation on the amendment of HAGAO
recently.

32
Appendix I
NumberofRoomsinHotelandGuesthousesinthepastdecade
57

2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013
2014
June
HighTariff A
Hotel

9,473 9,473 10,808 10,809 10,855 13,570 15,116 16,052 17,181 17,522 17,522 17,522
HighTariff B
Hotel

15,786 16,073 18,616 18,478 18,951 18,468 21,638 21,432 24,315 25,258 26,999 27,067
Medium
Tariff Hotel

11,465 11,038 11,475 14,435 15,496 16,735 17,432 17,591 17,072 19,566 20,048 21,234
Unclassified
Hotel

1,409 2,544 2,967 3,406 6,279 6,031 5,531 5,353 4,262 5,048 5,448 5,243
Total
number of
hotel

38,133 39,128 43,866 47,128 51,581 54,804 59,627 60,428 62,830 67,339 70,017 71,066
Guesthouse

4,803 5,234 5,025 5,384 5,068 5,469 5,759 5,926 6,211 6,818 7,630 8,080

57
Hong Kong Tourism Board, Hotel Room Occupancy Report, June 2014

33

Appendix II
Room Rate of Hotel and Guesthouse in the past decade
58

2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013
2014 Jan-
June
HighTariff A
Hotel

1,171 1,356 1,611 1,906 2,141 2,106 1,808 1,965 2,229 2,457 2,382 2,446
HighTariff B
Hotel

517 638 732 832 934 974 779 946 1,129 1,228 1,201 1,204
Medium Tariff
Hotel

334 414 460 537 570 586 481 585 710 781 758 740
Average rate of
hotel

674 803 934 1,091 1,215 1,222 1,023 1,165 1,356 1,489 1,447 1,463
Guesthouse

254 285 286 309 322 352 330 351 423 510 552 546

58
Hong Kong Tourism Board, Hotel Room Occupancy Report, June 2014

Appendix III
Unlicensed Guesthouse Introduced on 179.hk
59

179.hk

Guesthouse District Building Floor
18-24 5
37 10
312 3
26B G
105 3
376-380 1
12 3
4-6 -
33 - -
43 4

29-29A

- 7
36-42 6
101 -
80 8
83-97 7
52-54 13
731-733 15
6-8 -
78 2

59
Retrieved and checked on 13 July 2014