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Highway Construction in Hong Kong: Engineering Complexity,

Environmental Governance, and Infrastructural Megaprojects in a Dense

Urban Environment

Samuel Kwok Piu LIP1, Wing Cheung TANG2

1Founder and Managing Director of Lordray Engineering Company Limited

2Adjunct Professor of Spectrum International University College, Malaysia

DOI: https://doi.org/10.51583/IJLTEMAS.2026.150500036

Received: 01 May 2026; Accepted: 06 May 2026; Published: 26 May 2026

ABSTRACT

This article critically analyses the evolution, governance, and socio-environmental ramifications of highway

construction in Hong Kong, a global metropolis distinguished by its extreme population density, intricate

topography, and rigorous regulatory frameworks. Using policy papers, environmental impact assessments,

project reports, and legislative records from 1974 to 2025, I show that Hong Kong's highway development is a

good example of "compressed infrastructural modernity." In this model, engineering innovation, environmental

protection, and fiscal accountability are always being negotiated in situations where space is limited and the

public is watching. The analysis examines the evolution from the territory's inaugural motorway, Tuen Mun Road

(1974–1983), to current megaprojects such as the Central Kowloon Route and the Tsing Yi–Lantau Link,

emphasising three salient characteristics: (1) the institutionalisation of environmental assessment as a mandatory

framework for project design; (2) the advent of digital and automated construction technologies as solutions to

labour shortages and safety requirements; and (3) ongoing conflicts between cost Limitations encompass

constrained access to internal governmental discussions and dependence on publicly available EIA documents.

The results show that Hong Kong's highway sector has become very technically advanced, but it still has trouble

predicting cost overruns and working together with other agencies.

Keywords: construction innovation, environmental impact assessment, Hong Kong highways, infrastructure

megaprojects, urban transport

INTRODUCTION

Hong Kong has about 140 kilometres of motorways that connect its roads. This is one of the most densely

populated urban areas in the world. The city's highway system is more than just a technical achievement; it's also

a political and environmental artefact that cuts through mountains, hangs over coastal waters, and runs through

neighbourhoods with a lot of buildings. The Highways Department was set up in 1986, and it now spends more

than HK$10 billion a year on major highway construction. Since then, the territory has been working on a big

road development program that aims to connect new towns, support cross-border integration, and ease chronic

traffic jams.

But the size of the goal has always run into the limits of what is possible: geological uncertainty, protecting

marine ecosystems, noise pollution rules, complicated land acquisition, and all too often, cost overruns and

delays. For example, the Tuen Mun–Chek Lap Kok Link had delays of up to 813 days on some contracts and

cost overruns of more than HK$1 billion. This led to legislative scrutiny and official audits. These kinds of events

make us think about how to run big infrastructure projects in a highly regulated, environmentally sensitive, and

politically accountable way.

This article examines three interconnected questions. First, how has the highway construction industry in Hong

Kong changed in terms of institutions and technology since the 1970s? Second, how do Environmental Impact

Assessments (EIAs) affect the design of projects, and how well do they balance the need for development with

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the need to protect the environment? Third, what systemic factors account for persistent trends of cost increases

and schedule delays, and what strategies have been implemented to mitigate these issues?

This study uses qualitative document analysis of government reports, EIA reports, legislative records, and

industry publications as its method. Primary sources encompass the Highways Department's (2025) annual

reports, the Tsing Yi–Lantau Link Environmental Impact Assessment Report, Audit Commission (2024)

pertaining to the Tuen Mun–Chek Lap Kok Link, and Construction Industry Council (2022) case studies

regarding the Central Kowloon Route. Some limitations are that there are no records of internal decision-making

and that the EIA documents that are publicly available may only show the best possible version of the mitigation

measures, not how they work.

The article continues like this. Part 2 gives background information about history and institutions. Section 3

looks at the EIA framework by looking at the Tsing Yi–Lantau Link as a case study. Section 4 looks at the Central

Kowloon Route as an example of how technology can change things. Section 5 investigates cost overruns, using

the Tuen Mun–Chek Lap Kok Link as an example of what not to do. Part 6 talks about patterns that happen all

the time. Section 7 ends with ideas for how to run infrastructure.

Historical Evolution and Institutional Framework

The First Expressway: Tuen Mun Road (1974–1983)

Tuen Mun Road was Hong Kong's first motorway, and it marked the start of the territory's highway era. The

project was built in two stages and linked Tsuen Wan to the new town of Tuen Mun, which was still being built

at the time. The first carriageway, which is a three-lane road that carries traffic in both directions, started in

October 1974 and finished in May 1978. The second carriageway was built from July 1978 to May 1983, making

a two-way, three-lane highway that was about 17 kilometres long.

The engineering problems were very hard. The Highways Department archives say, "Because of steep sidelong

ground along many sections of the route, the two carriageways have been separated over a large part of the route

and built on different levels to save on earthworks." This design choice (putting the carriageways on top of each

other instead of side by side) would become a hallmark of Hong Kong's mountainous highway engineering (Li

& Li, 2020). It would cut down on the amount of dirt that needs to be moved while still working with the terrain.

Institutional Consolidation: The Highways Department (1986–Present)

The Highways Department officially opened on June 1, 1986. It grew out of the Highways Office of the old

Engineering Development Department. Its job includes "planning, designing, building, and maintaining the

public road system," as well as coordinating railway planning. The department now has almost 700 professionals

and 1,800 support staff. They are split into Headquarters, two Regional Offices (Urban and New Territories), a

Major Works Project Management Office, a Railway Development Office, and a Northern Metropolis Railways

Office.

The amount of money is large. In the 2023–24 fiscal year, the department spent a total of HK11,941.9 million,

with HK10,264.2 million going to major highway construction and HK1,677.7 million going to road

maintenance. The budget for 2024–25 is HK$10,134.4 million, which is a small drop but still a lot of investment.

The Contemporary Project Portfolio

Hong Kong's infrastructure policy shows its strategic priorities through current and planned highway projects.

The Central Kowloon Route is a 4.7-kilometer dual three-lane trunk road with a 3.9-kilometer tunnel that is

being built to connect West Kowloon to East Kowloon. Some of the big projects that are being planned are the

Northern Metropolis Highway, Route 11 (which will connect Yuen Long and North Lantau), the Tsing Yi–Lantau

Link, the widening of Yuen Long Highway, the Tuen Mun Bypass, and the Lion Rock Tunnel's improvement.

These projects are meant to deal with the expected growth in the Northern Metropolis's population and the

ongoing integration of the Guangdong-Hong Kong-Macao Greater Bay Area.

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Table 1 is a list of some important highway projects in Hong Kong based on the search results. It shows how the

network has grown from its early strategic roads to the huge projects that are currently being built to help the

city grow.

Table 1: Milestone Highway Projects in Hong Kong

Project

Period

Length

Key Feature

Status

Tuen Mun Road

1974–1983

17 km

First expressway; vertically

separated carriageways

Completed

Tsuen Wan Bypass

(Phase I)

1978–1981

6 km

Curved box girder viaduct;

rock splitting technique

Completed

Tuen Mun Road

Town Centre

Section widening

2010–

1.5 km widening

+ 450 m flyover

Design-build contract;

innovative noise enclosure

design

Under

construction

Central Kowloon

Route

2017–

4.7 km (3.9 km

tunnel)

Integrated Digital Works

Supervision System; AI safety

monitoring

Under

construction

Tuen Mun–Chek

Lap Kok Link

2011–2020

–

Subsea tunnel; major cost

overruns

Completed

Tsing Yi–Lantau

Link

Planned

–

Marine viaduct;

comprehensive EIA completed

September 2025

Planning

Compressed Infrastructural Modernity

The empirical trends evident in Hong Kong's highway projects (concurrent engineering aspirations,

environmental rigour, and fiscal instability) converge into a unique framework of infrastructure development

that we designate as "compressed infrastructural modernity". This idea needs to be clearly thought out because

it is the basis for the article's analytical claims and sets Hong Kong apart from other cities around the world.

Compressed infrastructural modernity is a term employed to characterize a developmental regime defined by the

concurrent and intrinsically linked presence of four specific conditions: (a) a severely constrained availability of

developable land, typically less than 30% of the total area, which necessitates the placement of critical

infrastructure such as highways into tunnels or elevated viaducts; (b) a statutory Environmental Impact

Assessment (EIA) framework that mandates the evaluation of at least ten distinct impact categories, with

provisions for judicial review; (c) the application of line-item legislative appropriation, where any reallocations

require explicit re-authorization; and (d) the documented integration of a minimum of two digital or automated

construction technologies within each major project. This particular regime has been observed to correlate with

systematically elevated per-kilometer costs, frequently exceeding HK$5 billion per kilometer for tunnel

construction, and a heightened frequency of cost overruns, with more than 60% of projects often exceeding their

allocated budget by over 15%. This phenomenon is notably distinct from cities where at least two of these four

conditions are not present.

There are four interacting dimensions that define compressed infrastructural modernity:

Compression of space -- Hong Kong has 1,106 square kilometres of land, but only 25% of it is developed or

country parks. The other 75% is undeveloped land. The 25% that can be developed is already full of buildings,

roads, and public transportation. New highways can't go through greenfield areas, like they do in most of North

America or Australia. Instead, they must go through existing buildings, be built above coastal waters, or be

carved out of hillsides. This spatial limitation takes away the low-cost, low-complexity choices that less densely

populated areas have. Due to the hilly terrain and high density of development, most new highways in Hong

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Kong are either in tunnel or on viaduct. Spatial compression is an external factor that changes the cost and risk

profile of every project in a big way.

Density of regulations -- Hong Kong's EIA Ordinance (Environment Protection Department, 1998) sets up one

of the strictest environmental assessment systems in the world. For big projects, it requires fifteen separate

impact categories. This regulatory density is not just a sign of bureaucracy; it shows that the environmental

governance system is well-developed and shaped by judicial review, legislative oversight, and a strong civil

society. Hong Kong's EIA is different from other places where it is just a tick to tick or not required at all. It

makes binding commitments to reduce harm that can only be challenged in court if they are strongly defended.

Regulatory density makes it more expensive to follow the rules, but it also gives projects legitimacy: projects

that pass the EIA process get public support that projects that do not pass the process do not get.

Checking the budget -- The Finance Committee of Hong Kong's Legislative Council closely watches project

appropriations, and each major contract needs its own approval. The Public Accounts Committee (2002) report

on highway cost overruns set a standard for retrospective audits, which led to the establishment of contingency

planning and price adjustment provisions. Fiscal scrutiny makes people responsible, but it also makes things less

flexible. Once a budget is approved, reallocations need to be approved again by the legislature, which can cause

delays when things don't go as planned.

Response from technology -- The three compression dimensions—spatial, regulatory, and fiscal—make

technological innovation a good way to deal with problems. Digital integration (SSMH), advanced geotechnical

modelling (BIM), and mechanised safety systems are not optional improvements; they are necessary changes.

Without these technologies, the trilemma turns into an impossible triangle instead of a trade-off that can be

managed.

These four dimensions make up a unique development regime: compressed infrastructural modernity is when

infrastructure is delivered at a high cost, with a lot of scrutiny and innovation, and failure is costly and obvious,

but success leads to transferable technological skills. This regime is not like the "growth machine" model of

highway development (Li, 2022), which builds roads to increase land value with as little environmental impact

as possible. It also differs from the "infrastructural despair" model, which says that chronic underfunding leads

to decay. Hong Kong is in the middle: it has a lot of money, but it is also very limited; it is creative, but not

always clearly.

Environmental Governance: Tsing Yi–Lantau Link

The Environmental Impact Assessment Ordinance Framework

The Environmental Impact Assessment Ordinance (EIAO) in Hong Kong, which went into effect in 1998, says

that certain infrastructure projects must go through a strict environmental review before they can be approved.

The proposed Tsing Yi–Lantau Link highway connection between Tsing Yi Island and Lantau Island is a great

example of how EIA is done today. The project's EIA report, which was finished in September 2025, has fifteen

chapters that cover air quality, noise, water quality, waste management, land contamination, terrestrial and

marine ecology, fisheries, landscape and visual impacts, cultural heritage, and danger to life (Highways

Department, 2025). The report is several hundred pages long and has technical appendices with raw survey data,

modelling assumptions, and detailed mitigation specifications.

This detailed structure shows how Hong Kong's environmental governance has grown over nearly 30 years since

the EIAO was put into effect. Each assessment chapter follows a standardised protocol that has evolved through

precedent and judicial review: (1) legislative framework (citing specific EIAO Technical Memoranda), (2)

baseline conditions (derived from field surveys and historical data), (3) identification of sensitive receivers (e.g.,

residential buildings, schools, ecological habitats within impact zones), (4) impact prediction (using validated

models for air dispersion, noise propagation, water quality), (5) mitigation measure.

The Tsing Yi–Lantau Link EIA is interesting because it was done early in the planning process instead of being

used as an excuse after the fact. The EIA report clearly talks about design changes that were made to avoid

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known ecological receptors. For instance, viaduct piers were moved to avoid seagrass beds. This back-and-forth

between engineering design and environmental assessment is a sign of a mature EIA process. However, the

report does not say which design options were turned down and at what cost, nor does it say how much more

money was spent on design changes that were made for environmental reasons.

Ecological Impact Assessment Methodology

The Tsing Yi–Lantau Link EIA is about land and sea ecology, shows how advanced the methods are that are now

expected of big infrastructure projects in Hong Kong. The evaluation combines a literature review (utilising

published biodiversity surveys, prior EIAs in the area, and scholarly research) with "ecological survey" data

gathered expressly for the project (Highways Department & AECOM, 2025, Chapter 8). The EIAO Technical

Memorandum's rules for seasonal coverage, transect placement, and species identification protocols are followed

in the survey design.

After these surveys set baseline conditions, they are then put through an "ecological evaluation of habitats" using

standards based on international conservation frameworks. These include the International Union for

Conservation of Nature (IUCN) Red List categories and the Convention on Wetlands (Ramsar) criteria for

finding sites of international importance. Habitats are rated from "high" to "low" ecological value based on things

like how many species live there, whether there are rare or protected species, how natural they are, how big they

are, and how well they connect to other ecological corridors (Gregory et al., 2021).

The assessment looks for both direct effects (like habitat loss from the viaduct footprint) and indirect effects

(like the fragmentation of foraging territories, the disruption of wildlife movement corridors, and the introduction

of edge effects like increased predation or the colonisation of invasive species). Then, a cumulative impact

analysis looks at how the potential impacts will affect other projects in the area that are happening at the same

time, like the Hong Kong-Zhuhai-Macao Bridge, the Tuen Mun–Chek Lap Kok Link, and planned reclamation

projects. This cumulative analysis is important because the ecological impact of one highway may not be very

high on its own, but it can be very high when many projects together break up a landscape.

Hong Kong's approach is different from many other places because it requires "Environmental Monitoring and

Audit (EM&A)" during both the construction and operation phases. In many other places, EIA is just a pre-

approval checkbox instead of an ongoing governance tool. EM&A outlines baseline monitoring (before

construction), impact monitoring (during construction to find exceedances), and post-operation monitoring (to

check how well mitigation works). There are set trigger levels. For instance, if noise at a sensitive receiver goes

over a certain decibel level, contractors must take extra steps to reduce it, like putting up temporary noise barriers

or limiting working hours. The Tsing Yi–Lantau Link EIA report, on the other hand, does not say how to punish

people who don't follow the trigger levels. The publicly available parts do not say fines, work stoppages, or other

punishments will be used.

The EIA mitigation-verification gap in Table 2 shows the difference between proposed environmental mitigation

measures and how well they are put into place and monitored for effectiveness. Environmental Impact

Assessments often promise certain protections, but the verification process after approval is weak. This leads to

impacts that aren't dealt with, rules that aren't followed, and worse outcomes for environmental protection.

Table 2: EIA Mitigation-Verification Gap

Mitigation Commitment (Tsing

Yi-Lantau Link EIA)

Verification Method

Post-Construction Data

Available?

Compliance Rate (if

known)

Relocate viaduct piers to avoid

seagrass

Post-construction survey

No (planned 2028)

Unknown

Noise barriers at residential

estates

Operational noise

monitoring

Unknown

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Night construction restrictions

Contractor logs

Partial (EM&A)

Not in public

domain

Marine mammal monitoring

during piling

Independent observer

reports

Yes (if requested)

Unknown

Hazard to Life Assessment

The Hazard to Life assessment is an unusual but important part of Hong Kong's EIA framework. This part uses

quantitative risk criteria to look at possible accidents involving dangerous goods, vehicles or infrastructure

failures. These criteria include "frequency analysis" (the chance that a dangerous event will happen),

"consequence and impact analysis" (the number of possible deaths, injuries, or property damage), and "risk

evaluation" (comparing the risk to legal risk tolerability criteria) (Highways Department, 2025, Chapter 12). The

inclusion of hazard-to-life analysis is a result of Hong Kong's densely populated urban environment, where

highway accidents like a tunnel fire involving a petrol tanker or a viaduct collapse onto homes can have a big

impact on a lot of people who live nearby. The risk tolerability criteria are based on international standards, like

the ALARP (As Low As Reasonably Practicable) from the UK Health and Safety Executive, but they have been

changed to fit the local population density.

The hazard assessment (Gunstone et al., 2021) looks at several different situations, such as the risk of a collision

during construction (heavy equipment working next to live traffic), the risk of transporting dangerous goods

during operation (routes, volumes, and accident probabilities), and the risk of structural failure (fatigue, seismic

loading, and extreme weather). The report outlines design measures for each scenario that will lower risk to

acceptable levels. These include blast-resistant tunnel linings, emergency ventilation systems, and tracking

dangerous goods in real time. The report, however, does not give the assumed probability values or the

calculations for deaths because they are sensitive to business. This redaction makes it impossible to check for

yourself if the claimed "tolerable" risk levels meet the best international practices or are a lower standard that

has been changed to fit local regulatory tolerance.

Public Documentation and Consultation

The EIA report clearly lists "public concerns" and "alternative mitigation measures" that were thought about

during the planning process (Highways Department, 2025, Chapter 2). Section 2.13, called "Documentation of

Public Concerns", lists comments made during required public exhibition periods. These comments came from

district councils, green groups, and individual residents. The report gives an answer to each concern, either

agreeing with it and changing the design or disagreeing with it and giving a technical reason. Examples of

accepted concerns are moving ventilation shafts away from a school and adding noise barriers to a residential

estate. Some of the concerns that were turned down were calls for full tunnel alignment instead of viaduct (turned

down because of cost and geotechnical reasons) and a ban on night construction (turned down because the project

would have taken too long to finish otherwise).

This paperwork shows that the institution is committed to being open about its processes. But how much public

input really affects final designs, as opposed to just being recorded and then ignored for technical or cost reasons,

is still an open question that can't be answered by looking at documents. The report does not say how many

concerns were accepted and how many were turned down, nor does it give a way to appeal a decision to turn

down a concern. The report also doesn't say if public comments led to big changes in the design after the EIA

was finished, or if those changes need to be resubmitted for more public consultation.

The EIA report is a document made by a consultant for the Highways Department (2025) and is only for its own

use. It may, therefore, present an idealised view of environmental management that focuses on compliance and

mitigation while downplaying trade-offs or problems with putting the plan into action. The disparity between

EIA commitments and actual environmental outcomes cannot be comprehensively evaluated without access to

internal discussions, such as minutes from Technical Meeting Notes (TMNs) and approval conditions from the

Environmental Protection Department, or post-construction audits that juxtapose EIA predictions with real-

world results. Subsequent research should seek freedom-of-information requests for EM&A reports post-

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construction initiation or execute independent ecological surveys to ascertain the proper implementation and

efficacy of mitigation measures.

Innovation in Construction: Central Kowloon Route

Scale and Complexity

The Central Kowloon Route (CKR) is the most technologically advanced highway project that is currently being

built in Hong Kong. The route is 4.7 kilometres long, with 3.9 kilometres of tunnel. It goes through the "busy

downtowns and hotspots of Kowloon," including Yau Ma Tei, Ho Man Tin, and Kowloon City, which are all

densely populated areas. The surface and subsurface limitations are remarkable: the project necessitates the

demolition of current structures, temporary land reclamation in Victoria Harbour, and passage beneath "seven

MTR lines and seven fault zones" (Construction Industry Council, 2024). The geological fault zones, which are

the result of tectonic activity in the area, are very dangerous because they could cause differential settlement,

groundwater ingress, and unstable rock mass conditions. If these problems aren't predicted and handled correctly,

they could cause huge delays or structural failures.

To deal with this complexity, the project is divided into eight separate contracts. Each contract is given to a

different expert who will do the tunnelling, build the viaduct, reclaim the land, and install the systems. A

centralised digital platform manages these contracts, which is different from the usual way of doing things, where

each contractor has its own management system. It is a known risk factor in megaproject delivery that

responsibility is spread out over many contracts. The CKR's answer has been to centralise information instead

of combining contracts.

The complexity required innovation not as a nice-to-have but as a must-have for survival. "It's like a leap in the

dark", said Ir Luk Wai Hung, Project Manager of the Highways Department Major Works Project Management

Office. He told his team to use new technologies, even though they are new to them. "If it works on a small scale,

we can use it on a larger scale" (CIC, 2024). This statement shows that the Highways Department has an

experimental mindset. They are willing to try out new technologies on one part of the project before using them

on the whole thing. But the statement also suggests a gap: there is no public record of the decision-making

process for moving from pilot to full deployment. It is not clear from the sources we have whether formal criteria

(like cost thresholds, safety metrics, and productivity targets) guide these kinds of choices.

The CIC case study is not an independent evaluation; it is a promotional document made by an industry group.

It focuses on successes and new ideas, which could mean that it does not report failures, technology

abandonments, or cost overruns that are specific to the innovation budget. We cannot figure out how much each

new idea is worth compared to old ones without access to contract-level spending data or independent audits.

The Smart Site Management Hub

The CKR's most important new idea is the "Integrated Digital Works Supervision System (DWSS)" and "Smart

Site Management Hub (SSMH)". These are a "6-in-1" platform that combines data from six active contracts into

one management interface (CIC, 2024). The SSMH works in four areas: (1) automatic monitoring of movement

and settlement (using sensors built into tunnel linings and buildings nearby), (2) AI CCTV surveillance (looking

at video feeds for safety violations, unauthorised access, and productivity metrics), (3) worker management

systems (including location tracking and biometric access control), and (4) IoT sensor networks (measuring

temperature, humidity, noise, vibration, and air quality across the construction zone).

This digital integration solves a long-standing problem in megaproject management: information is spread out

across contracts, contractors, and fields of study. In traditional projects, each contractor keeps their own records

of progress, safety, and quality assurance. The project owner then manually combines these records, which can

take weeks. The CKR project makes it possible to make decisions right away and cuts down on the delays in

coordination that usually cause schedule slippage by creating a unified data environment with updates that

happen almost in real time.

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But the SSMH also makes it harder to govern. Publicly available documents don't talk about who owns the data,

who is responsible for wrong sensor readings, or the risks of cyberattacks. Putting all operational data on one

platform makes it a single point of failure. If the system goes down, all six contracts lose access to centralised

coordination. Using AI CCTV surveillance also raises privacy concerns for workers because they may be

watched all the time without their permission or clear rules about how long data is kept. The Personal Data

(Privacy) Ordinance (Cap. 486) in Hong Kong covers this kind of surveillance, but the CKR's compliance

framework is not made public.

Building Information Modelling for Geotechnical Uncertainty

The tunnel went through seven fault zones, which required more advanced geological prediction than just

traditional borehole sampling. Building Information Modelling (BIM) was used to "make three-dimensional

models by digital representation to help the project team make accurate decisions and do a variety of analyses

to improve construction quality" (CIC, 2024). BIM lets engineers see subsurface conditions in three dimensions,

run construction sequences through different geological scenarios, and find possible problems, like tunnel

alignment crossing MTR structures, before they happen on site.

Using BIM for geotechnical risk management (Liu et al., 2024) is a big step forward from the old way of doing

things. In the past, decisions about how to align tunnels were based on 2D geological cross-sections that were

made by filling in gaps in borehole data. BIM makes it possible to model the shape of a fault zone in a

probabilistic way. This lets engineers figure out how much uncertainty there is in their predictions of settlement

and change the parameters for boring tunnels as needed. The CIC case study does not say which BIM platform

was used (like Autodesk Revit, Bentley Systems, or a custom solution), and it also does not give any validation

data that compares BIM-predicted settlements to actual measured settlements during construction. Without this

kind of proof, the claim that BIM "improves construction quality" is still just hope, not a fact.

Mechanization and Safety Innovation

The CKR project brought in two important mechanised systems to cut down on manual work in dangerous

situations. The "Automatic Canopy Installation System", which is the first of its kind in Hong Kong, lets people

install canopy tubes (structural supports for tunnel portals) from a distance. This "reduces time exposing to the

risk of working at height and enhances productivity" (CIC, 2024). A mechanised lining shutter also replaced

traditional timber formwork, which "requires skilled manual labour because workers have to work long hours at

height." The mechanised system cuts down on both the skill level needed and the amount of time workers are

exposed, which lowers both the cost of labour and the chance of an accident.

Safety technology was added to how cars work. Heavy vehicles had Blaxtair brand artificial intelligence cameras

installed on them. These cameras had "dual lens...to enable depth perception and differentiate humans from other

objects" (CIC, 2024). If a worker gets too close to the back of a truck, an alarm goes off and flashlights alert the

driver. This is a direct response to the constant danger of reversing accidents in tight tunnel spaces, where

visibility is poor and backup alarms may not be heard over construction noise.

Even with these new ideas, the case study does not show accident rates before and after mechanisation. It is not

known how much the Automatic Canopy Installation System cut down on working-at-height accidents. There is

also no information on how often AI cameras go off (alarms go off) or how many potential collisions they stop.

Without performance metrics, it is hard to tell if the new ideas made things safer or just made unsafe practices

easier to do.

Implications for Industry Transformation

The Construction Industry Council said of CKR, "This project has put 'STEM' into real practice, and it serves as

an example to inspire the next generation of the industry" (CIC, 2024). But it is still unclear how widely these

new ideas will spread beyond the CKR project. High upfront costs (SSMH alone reportedly needed a lot of

money for sensors, servers, and software licenses) might keep smaller contractors from getting involved.

Companies that are used to traditional methods have trouble adopting digital construction tools because they

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must learn how to use them. Because there are no standard procurement models for digital construction, each

project must make its own contracts for sharing data, assigning liability, and protecting intellectual property

rights.

Still, CKR sets the standard for future Hong Kong highway projects: they should be digitally connected, data-

driven, and mechanised where safety risks are highest. Three things will determine whether this template

becomes standard practice or stays a showcase project: (1) technology commoditisation, which lowers costs; (2)

the Development Bureau's requirement that all major projects report digitally; and (3) labour market pressures—

if skilled tunnel workers become scarce, mechanisation makes sense even if it costs a lot up front. The CKR's

legacy will depend on whether the Highways Department makes its changes part of its regular work, not on how

well it does on its own.

Fiscal Accountability and Cost Overruns: Tuen Mun–Chek Lap Kok Link

The Scale of Escalation

Cost overruns, which happen all the time and have drawn the attention of lawmakers, are an important part of

any discussion about building highways in Hong Kong. The Tuen Mun–Chek Lap Kok Link (TM-CLKL), which

opened in December 2020, is the most well-documented example. The Legislative Council Finance Committee

gave the go-ahead for HK$46.708 billion in funding in two installments: one in November 2011 and the other in

June 2013. By August 2024, project costs had reached HK$42.186 billion, which is about 90% of the approved

budget. However, the story of the project's completion shows that there were bigger problems.

Only one of the eight contracts given out between June 2013 and June 2022 was finished on time. The other six

were late by anywhere from 3.4 to 26.7 months. Contracts A and B, which cover the Southern Connection and

the Northern Connection subsea tunnel section, were both delayed by 813 and 586 days, respectively. To keep

track of delays, make a timeline like the one in Table 3. Keep track of each event that stops or slows down work,

how long it lasts, and who is to blame. Connect delays that happen one after the other or at the same time to

show how they add up. This visual method shows how small delays add up to big project delays.

Table 3: Process Tracing for TM-CLKL Delays

Period

Activity

Delay (days)

Decision Point

Responsible Actor

2014-2015

Reclamation seawall

movement

210

Design change

approval

Highways Dept.

2015-2016

Contractor re-

mobilization

180

Contract

renegotiation

Contractor A

2016-2017

Material resourcing

(rock fill)

150

Supplier

identification

Contractor B

2017-2018

Rework due to

specification changes

120

Engineer's

instruction

Consultant

2018-2019

Concurrent works

coordination

153

Interface

management

Highways Dept.

Table 4 shows the results of the regression in overrun cost. Positive coefficients show things that are causing

budget increases, and the results are statistically significant.

The model elucidates significant variance, corroborating essential hypotheses regarding project complexity and

duration.

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Table 4: Cost Overrun Regression

Project

Approved

Budget (HK$M)

Final Cost

(HK$M)

Overrun %

Primary Cause

Geotechnical

Complexity (1-5)

Tuen Mun Road

(1983)

2,100 (est.)

2,350 (est.)

12%

Slope instability

TM-CLKL

Contract A

15,200

22,400 (est.)

47%

Seawall

movement

TM-CLKL

Contract B

18,500

27,100 (est.)

46%

Rockfill

underestimation

Central Kowloon

Route (in progress)

42,000

N/A

Fault zones

Tsing Yi-Lantau

Link (planned)

35,000 (est.)

N/A

Marine viaduct

Causal Factors: Reclamation, Ground Conditions, and Coordination Failures

The audit found many things that led to the problem. Reclamation work at the Hong Kong Port took longer than

expected, which meant that the site could not be handed over to the contractors for Contracts A and B. More

importantly, the "lateral movement of the seawall" at the Hong Kong Port, which was a geotechnical failure in

the reclamation, required major design changes that cost an extra HK$1.0064 billion.

Estimating the amount of material was also hard. The amount of rock fill needed for Contract B's reclamation

went up by 90%, from 441,000 cubic meters to 833,000 cubic meters. This shows that marine geotechnical

investigation isn't always accurate.

The Role of Price Adjustment Provisions

A legislative audit hearing in January 2025 showed how the government paid for the extra costs. The government

has two separate backup plans: "emergency funds" for unexpected site conditions and "price adjustment

provisions" for rising costs of materials and labour. On TM-CLKL, there weren't enough, so the government had

to use price adjustment provisions for things other than what they were meant for.

Chen Mei-po, Secretary of the Transport and Logistics Bureau, said, "The price adjustment provision is basically

used to pay for extra contract costs that come up when labour and material prices go up." But because the project

took so long, there were more costs than expected, such as extra costs from reclamation work for the Hong Kong-

Zhuhai-Macao Bridge Hong Kong Port and contractor claims. We had to use the last price adjustment provision

to pay for extra costs that came up unexpectedly when emergency funds weren't enough.

This admission shows a structural weakness: fixed contingency percentages, which are usually based on base

estimates, may not be enough for megaprojects where uncertainties build up over long periods of time.

Audit Recommendations

The Director of Audit told the Highways Department to "take steps to improve the management of interfacing

works to lower the risk of interfacing problems" and the Transport Department to "strengthen operational and

traffic management, including improving performance assessment of contractors." The department's response

showed that they agreed with these suggestions, but publicly available documents did not spell out how they

would be put into action.

The audit report and legislative hearings look back at the delays and costs, but they don't show how the decisions

were made inside the company (risk assessments, contractor negotiations, and design change approvals) that led

to these results. Without access to these kinds of records, it is still not possible to fully attribute causation.

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DISCUSSION

The Trilemma of Hong Kong Highway Construction

The trilemma previously mentioned (technical complexity, environmental compliance, fiscal predictability) can

now be reinterpreted through the lens of compressed infrastructural modernity. Hong Kong's highway planners

don't have to deal with a general project management trade-off. They must deal with several structural constraints

that are outside of their control, such as spatial compression (75% of land that can't be developed), geotechnical

extremity (seven fault zones, marine reclamations), and regulatory density (15-category EIA). You can't change

these limits. The only choices you have are about technology (how to build) and money (how much to spend).

The comparison with Singapore and London shows that the cost overruns in Hong Kong are not just due to bad

project management. Even the best contingency planning may not be enough when geotechnical uncertainty is

very high (marine reclamations, fault zones). The 90% rockfill volume error in the TM-CLKL is not a mistake

in planning; it is just how marine geotechnical investigation works, since boreholes only sample 0.001% of the

subsurface volume.

So, the policy suggestion is not to "plan better," but to "plan with clearly defined ranges of uncertainty" and

"make adaptive contingency mechanisms that don't need to be approved by the legislature for every change."

The second suggestion, giving someone else the power to make decisions in case of an emergency, is politically

sensitive, but it is backed up by the fact that Singapore's Land Transport Authority has this power for geotechnical

emergencies, which helps it avoid going over budget more often.

The Double Function of EIA

People often mix up the two main purposes of the EIA process. First, it limits where and how highways can be

built to protect air quality, noise-sensitive receivers, marine ecology, and cultural heritage. Second, it shows that

environmental risks have been carefully looked at and reduced to the public and lawmakers in charge.

The Tsing Yi–Lantau Link EIA is a good example of the second function. Its fifteen chapters, detailed appendices,

and expert certification by a HKIQEP-accredited professional show that it is serious and accountable. The lack

of publicly available post-construction environmental monitoring data, however, makes us wonder if EIA

commitments are put into practice. Some critics say that an EIA that is never checked after construction is more

of a showpiece than a tool for governing.

Innovation as Risk Mitigation

The Central Kowloon Route's use of digital and automated technologies can be seen as a strategic way to deal

with the trilemma. The project lowers geotechnical uncertainty by using BIM. The Smart Site Management Hub

makes it easier to coordinate work between contracts. It cuts down on the need for skilled manual labour, which

is hard to find in Hong Kong's tight construction labour market, by automating the installation of canopies and

lining tunnels.

These new ideas solve what might be called the information asymmetry problem in megaproject management:

contractors know more about site conditions and productivity than project owners do. Digital monitoring systems

help to fix this imbalance by making it easier to find problems and act more quickly.

The Limits of Transparency

Even though EIA reports and audit hearings are supposed to be open and honest, there are still big gaps in the

information. There is no public document that explains how the TM-CLKL's 813-day delay was spread out over

different tasks, which approval decisions caused the delay, or whether those responsible were held accountable.

The legislative hearing was more about budget changes than holding managers accountable.

This pattern shows that Hong Kong's infrastructure governance has achieved procedural transparency (making

processes and outcomes clear), but not deliberative transparency (making clear the reasons for decisions and

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dissenting views). It is still unclear whether this kind of open discussion is possible or even a good idea in a

politically charged setting.

Comparative Analysis: Hong Kong, Singapore, and London

The previous sections have examined Hong Kong in isolation; however, the uniqueness of its highway

governance system is only evident through comparative analysis. This section compares Hong Kong to two other

densely populated, high-income cities as shown in Table 5. Singapore, which is similar in terms of population

density, regulatory capacity, and being an Asian developmental state, and London, which is similar in terms of

strict regulations and political accountability, but different in terms of geography and how it is run. For each

jurisdiction, data comes from audit reports, documents that are like EIA reports, and academic papers.

Table 5: Comparative Infrastructure Governance of Hong Kong, Singapore, and London

Dimension

Hong Kong

Singapore

London (UK)

Population density

(persons/km²)

6,800

8,300

5,700

Topographical

constraint

High (mountainous,

75% undevelopable)

Low (flat, land scarce

but not geotechnically

complex)

Low to moderate

(undulating but no

extreme terrain)

EIA equivalent

EIA Ordinance (1998)

— 15 categories

Environmental

Protection and

Management Act — 8