Practice Note for Authorized Persons,

Buildings Department Registered Structural Engineers and APP-2

Registered Geotechnical Engineers

Calculation of Gross Floor Area and Non-accountable Gross Floor Area

Building (Planning) Regulation 23(3)(a) and (b)

Calculation of Gross Floor Area

Regulation 23(3)(a) of the Building (Planning) Regulations (B(P)R)

stipulates that gross floor area (GFA) is the area contained within the outer surface of
external walls of a building measured at each floor level. Any portions of this area not
floored over should also be included in the GFA calculations.

Voids in Buildings

2. However where large voids occur, a modification of regulation 23(3)(a) of

the B(P)R may be granted on application for voids in the following circumstances and
subject to compliance with the pre-requisites (for items (a) to (g)) and the overall cap on
GFA concessions (for items (f) and (g) only) stipulated in PNAP APP-151 on Building
Design to Foster a Quality and Sustainable Built Environment :-

(a) in front of cinema and theatre balconies;

(b) in banking halls;

(c) in shopping arcades provided that the total area of voids in the
shopping arcade does not exceed 10% of the total GFA of the
shopping arcade;

(d) in single-staircase buildings in which cockloft floors for storage

are provided in the ground storey;

(e) in auditoria, sporting halls (including squash courts), school halls

and religious institutions;

(f) in main common entrance lobbies of non-domestic buildings;

and

(g) in duplex domestic flats or houses if they satisfy the criteria set
out in Appendix A.

3. In the case of "split level" designs where the difference in level between
adjoining floors is less than 1 m, the floor may be regarded as being level for the purposes
of this regulation. For greater differences in level, the authorized person should clarify
with the Buildings Department (BD) before embarking on the project.

/Facilities …..
 -2-

Facilities and Features in Buildings

4. Subject to the special circumstances of each case and compliance with the
pre-requisites (for all items except item (e)) and the overall cap on GFA concessions
(for items (a) to (d) only) stipulated in PNAP APP-151, the Building Authority (BA) is in
general prepared to consider favourably application for modification of regulation 23(3)(a)
of the B(P)R in respect of :-

(a) chimney shafts;

(b) filtration plant rooms for swimming pools in hotels or for water
features in communal gardens/ landscape area;

(c) a room of a size not exceeding 1.2m(W) x 1.2m(D), housing

satellite master antenna television equipment in accordance with
paragraph 33 of PNAP APP-42;

(d) genuine and properly designed pipe-ducts / air ducts with adequate
access for inspection and maintenance which form part of the
distribution network for non-mandatory feature or non-essential
plant1;

(e) genuine and properly designed pipe-ducts / air ducts with adequate
access for inspection and maintenance which form part of the
distribution network for mandatory feature or essential plant1; and

(f) plant rooms for environmentally friendly systems and features

such as rainwater / grey water recycling system and battery room
for solar panels.

5. A modification of regulation 23(3)(a) of the B(P)R may also be granted on

application for refuge floors which comply with the Code of Practice for Fire Safety in
Buildings.

Curtain Walls and Claddings

6. Under regulation 42 of the Building (Construction) Regulations (B(C)R),

curtain wall means a non load-bearing enclosure fixed onto the load-bearing structure with
its dead loads, imposed loads and wind loads transferred to the structure through fixings.
Where a curtain wall system (including other similar non load-bearing enclosure system)
forms the external face of a building, the BA is prepared to accept the outer face of the
structural elements, e.g. beams, columns and floor slabs, as the external wall for the
purpose of measurement of GFA and site coverage (SC) where :-

/(a) …..

1
Please refer to PNAP APP-151 for examples on plant rooms that are considered mandatory / essential
or non-mandatory / non-essential plant.
 -3-

(a) The curtain wall system itself does not form part of the structural
system of the parent building;

(b) The system does not result in any additional floor area at a floor
level by providing a reinforced concrete dwarf perimeter wall
not less than 300 mm high measured from the floor level;

(c) The projection of the system from the outer face of the structural
elements does not exceed 200 mm for a domestic building and
250 mm for a non-domestic building; and

(d) The external reflectance2 of the glass used in the system does not
exceed 20%.

The method of measurement of GFA and SC is illustrated in the sketches at Appendix B

for reference. The requirements stipulated in item (d) above are applicable to all new
building plans or major revision of building plans for development proposals or
alteration and addition works submitted to the BA for approval on or after 1 September
2015. For the avoidance of doubt, a purpose built hotel building including the hotel
part of a building or a hotel converted from a non-domestic building is treated as a
non-domestic building or non-domestic part of a building for the purpose of item (c)
above.

7. For the provision of curtain walls to existing facades in the case of

wholesale conversion or refurbishment of industrial buildings or other types of
buildings, exemption from section 31 (1) of the Buildings Ordinance (BO) to allow the
curtain walls to project over streets will be favourably considered if low-energy
absorbent type glazing / energy efficient materials with energy efficient design of the
curtain walls that could achieve 40% in the categories of Energy Use (EU) and Indoor
Environmental Quality (IEQ) with the BEAM Plus Certification conferred by the Hong
Kong Green Building Council (HKGBC) are incorporated in the proposal. As the
pre-requisites for the granting of the exemption, the applicant in applying for approval
of plans should submit the official letter issued by the HKGBC acknowledging the
satisfactory completion of project registration application for BEAM Plus Certification
and a letter by the applicant undertaking to submit to the BD the following
documents :-

(a) Result of the Provisional Assessment under the BEAM Plus

Certification conferred by the HKGBC to demonstrate
achievement of 40% in the categories of EU and IEQ to be
submitted prior to the application for consent to the
commencement of the building works shown on the approved
plans; and

/(b)…..

2
“External reflectance” means the percentage of daylight reflected from any external surface of the
glass used in the curtain wall system.
 -4-

(b) Result of the Final Assessment under the BEAM Plus

Certification conferred by the HKGBC to demonstrate
achievement of 40% in the categories of EU and IEQ within 6
months of the date of the BA's letter of acknowledgment of the
Form BA14 for the project.

8. For partial conversion or refurbishment of industrial buildings or other

types of buildings, application for exemption from section 31(1) of the BO to allow the
curtain walls to project over streets should be accompanied with justifications
including information of low-energy absorbent type glazing / energy efficient
materials with energy efficient design to be incorporated in the design and construction
of the curtain walls. In this connection, the provision of curtain wall to existing
balconies over a public street or only at localised portion of the facades will not be
accepted. Curtain walls system projecting over streets, if permitted, will not be
accountable for GFA and SC under the B(P)R.

9. Under regulation 37 of the B(C)R, cladding means a facing or architectural

decoration additional to the external walls of any building. External wall finishes of
nominal thickness or claddings with overall thickness of not more than 90mm (75mm in
the case of cladding to non-structural prefabricated external walls) as the external wall
finishes may be disregarded for the purpose of measurement of dimensions under
regulation 23(3) of the B(P)R. However, no part of any wall finishes, including
claddings, should project beyond the site boundaries. For the refurbishment of buildings,
application for exemption from section 31(1) of the BO is required if the claddings will
project over streets.

10. For curtain walls and claddings as mentioned in paragraphs 7 to 9 above

projecting outside the lot boundary over public streets, authorized persons are reminded to
ensure that the relevant lease conditions are complied with.

Non-accountable Gross Floor Area

11. Under regulation 23(3)(b) of the B(P)R, the BA may disregard from GFA
calculation floor space occupied solely by machinery or equipment for lift,
air-conditioning, heating system or any similar service. The phrase "any similar service"
may generally be interpreted to include fire control centre, water tanks, electrical switch
rooms, meter rooms, transformer rooms, generator rooms, pump rooms, telephone
equipment rooms, cable riser duct room, CO2 rooms, hose reel closets, sewage treatment
plant rooms and smoke extraction system. In each case, both the premises for and the
size of any such feature should be justified. To guard against possible abuse, the BA will
take the following into consideration when disregarding the above features from GFA
calculation for single-family residence or house type developments :-

(a) There should not be any duplication in the provision of services

when GFA exclusions are also being separately applied for; and

/(b)…..
 -5-

(b) Only the minimum amount of GFA necessary for

accommodating and maintaining the services and commensurate
with the development would be allowed to be disregarded. The
authorized person may be required to demonstrate why it is not
possible to consolidate the provision of all related services into
multi-purposes or centralised rooms such that the area which is
disregarded from GFA could be used for efficiently.

12. For plant rooms and other features that are to be disregarded from GFA
calculation, the enclosing walls and the associated protected lobby, if any, solely serving
the said rooms or features and do not serve any other function, may also be disregarded
from GFA calculation. The maximum thickness of such wall to be disregarded from
GFA calculation should normally be not greater than 100mm.

13. The granting of GFA concessions for plant room occupied solely by
machinery or equipment for air-conditioning or heating system is subject to compliance
with the pre-requisites and the overall cap on GFA concessions stipulated in PNAP
APP-151 on Building Design to Foster a Quality and Sustainable Built Environment.

14. The horizontal area of staircases, lift shafts and vertical ducts should
normally be measured for GFA together with the floor through which they pass, except
refuge floors. However, where these features solely serve floors (i.e. not serving GFA
accountable floors above or below) accepted as not being accountable for GFA (by reason
of the captioned regulation), the area of the features may also be discounted. If these
features serve underground car parks as well as other floors, the BA may consider
discounting the portion of these features at underground carpark floors from GFA
calculation.

Carparking and Loading and Unloading Areas

15. Under regulation of 23(3)(b) of the B(P)R, the BA has the discretionary
power to disregard from GFA calculations any floor space that he is satisfied is
constructed and intended to be used solely for, inter alia, parking motor vehicles and
loading and unloading of motor vehicles. The BA generally accepts that public and
private car-parks, and public transport termini provided in buildings are space for
parking or loading and unloading of motor vehicles falling within the meaning of
regulation of 23(3)(b) of the B(P)R. In exercising his discretionary power under
regulation of 23(3)(b) of the B(P)R to disregard or not to disregard such area or any
part thereof from GFA calculation, the BA will determine each case on its merits and
take into account all relevant considerations including the design of the car-park and the
effect on public interest such as impact on infrastructure, density and building bulk.
In general, the BA will follow the lines as mentioned in paragraphs 16 to 18 below in
his exercise of discretion.

/Carparking…..
 -6-
Carparking Spaces

16. (a) When a lot is subject to lease/grant conditions requiring the

provision or incorporation of a public carpark within a
building or buildings, all the required facilities and
associated works, including service core areas of such public
carpark should be accountable for GFA calculation.

(b) For private carparking spaces which are intended for the use
of the occupants and their bona fide visitors of the parent
building, the BA may disregard them from GFA calculation
under regulation 23(3)(b) of the B(P)R subject to the
following criteria :-

(i) In deciding on the number of car-parking

spaces that could be disregarded, the BA will
make reference to the standards set out in the
Hong Kong Planning Standards and Guidelines
(HKPSG) and the advice of the Commissioner
for Transport (C for T).

(ii) All car-parking spaces to be disregarded from

GFA are electric vehicle (EV)
charging-enabling, as follows :-

(1) the EV charging facilities, which may

comprise main switchboards, distribution
boards, electrical wiring and socket outlets,
should be installed, tested and
commissioned in accordance with the
Technical Guidelines for Electric Vehicle
Charging-enabling for Car Parks of New
Building Developments (TGNBD) issued
by the Environment Bureau and Electrical
and Mechanical Services Department
(EMSD) and the Technical Guidelines on
Charging Facilities for Electric Vehicles
issued by the EMSD (the guidelines can be
downloaded from the following websites
respectively:
http://www.enb.gov.hk/en/resources_publi
cations/guidelines/files/guidelines_on_ena
bling.doc and
http://www.emsd.gov.hk/emsd/e_downloa
d/pps/pub/EV_guidelines.pdf);

/(2)…..
 -7-

(2) the design of the fixed electrical

installations for the EV charging facilities
shall be certified by a Registered
Professional Engineer (RPE) under the
Engineers Registration Ordinance (Cap.
409) of either the Electrical or Building
Services discipline and the design
information as mentioned in the TGNBD
should be submitted together with the
relevant building plans prepared by the
Authorized Person (AP) to the BA for
consideration;

(3) prior to the application for an occupation

permit, a certificate of completion of the
works for the EV charging facilities shall
be signed by the RPE and submitted to the
BA through the AP; and

(4) for the avoidance of doubt, meter rooms (if

provided) being part of the EV charging
facilities are considered as essential plant
rooms and will enjoy 100% GFA concession
and not subject to the 10% cap as mentioned
in PNAP APP-151, irrespective of whether
the carparks they serve are underground or
above ground.

(iii) In order to help reduce building bulk, 100% GFA

concession may be granted for underground car
parks while only 50% GFA concession may be
granted for aboveground car parks.

(iv) 100% GFA concession may be granted for

aboveground car parks if it is proven with
sufficient evidence that it is technically infeasible
to construct an underground car park due to site
constraints in a specific site or that the
above-ground car parks will not pose adverse
environmental or visual impact to its surrounding
areas.

(v) Examples of site constraints 3 making

underground car parks technically infeasible
include sites located above major underground
utilities, within Areas Number 1, 2, 3 or 4 in
Schedule 5 of the BO or with other complex
geotechnical constraint.

/(vi)…..

3
These serve as examples only and each case should be considered on its individual merits based on
relevant information or justifications submitted.
 -8-

(vi) Examples for accepting above-ground car parks

as not posing adverse environmental or visual
impact to its surrounding areas include ancillary
car parks in low-rise low-density sites such as a
development with plot ratio not exceeding 1 and
not more than 6 storeys in height with maximum 5
storeys on top of one storey carpark.

(vii) A carpark may be accepted as an underground

carpark in the following circumstances :-

(1) If the site abuts on only one street, a carpark

may be accepted as an underground carpark
if the structural ceiling soffit of the carpark
is at or below the mean level of that portion
of the street on which the site abuts and
subject to such mean level to be not more
than 5m above the lowest level of such
portion of the street;

(2) If the site abuts more than one street, a

carpark may be accepted as an
underground carpark if the structural
ceiling soffit of the carpark is at or below
the level obtained by dividing the sum of
the mean levels of the respective portion
of the streets on which the site abuts by the
number of such streets on which the site
abuts and subject to the level so obtained
is not more than 5m above the mean level
of that portion of the lowest street on
which the site abuts;

(3) For the purpose of allowing the provision

of natural lighting and ventilation to the
topmost carpark floor, a carpark may be
accepted as an underground carpark if not
more than half of the height measured
from the structural floor to the structural
ceiling soffit of the topmost carpark floor
and subject to a maximum height of 2.5m
protrudes above the level as determined in
(1) or (2) above for a site abutting on only
one street or more than one street
respectively; or

/(4)…..
 -9-

(4) When there are site constraints that affect

the design and location of the carparking
floors e.g. there is significant difference in
the levels of the streets on which the site
abuts; there is an existing large platform
that governs the carparking design; the
carpark is semi-sunken and follows the
slope profile of the site and adjoining land,
etc., the BA may consider the special
circumstances of the case in accepting a
carpark as an underground carpark.

(viii) For underground carpark to be granted with

100% GFA concession as stated in (iii) above,
any entrance lift lobby, lift shaft or ramp for
vehicles which is above-ground, solely serving
the underground carpark, may be allowed to be
granted with 100% GFA concession if the area
involved is of a reasonable size. However,
any entrance lift lobby/lift shafts which serve
the development as well as the underground
carparks should be fully accountable for GFA.

(ix) Subject to paragraph 18(b) below, associated

ramps and facilities passing through floors
accountable for GFA may be excluded from
GFA calculation if they are physically separated
from and do not provide access to the
accommodation on the floors they pass through,
the extent of GFA concession of which will
follow that of the carpark served by the
associated ramps and facilities.

(c) Where both private and public carparking spaces are

proposed in the same building and upon being satisfied with
the design of the carpark, the BA will assess the
accountability of GFA on the following basis :-

(i) Where private and public carparking spaces are

provided on separate floors, the floor space
exclusively provided for private carparking
purposes on that floor may, subject to paragraph
16(b) above, be considered for disregarding from
GFA calculation under regulation 23(3)(b) of the
B(P)R whereas the floors provided exclusively for
public carparking purposes would be accountable
for GFA under Regulation 23(3)(a) of the B(P)R.

/(ii)…..
 - 10 -

(ii) Where both private and public carparking spaces

are provided on the same floor, only the areas,
including carparking spaces, driveways, ramps, lift
halls and staircases solely serving the private
carpark would be considered for disregarding from
GFA calculation under regulation 23(3)(b) of the
B(P)R. Those public car parking spaces,
associated driveways, lift halls, staircases, ramps
which serve either the public carpark or both the
public and the private carparks will not be
disregarded from GFA calculation. Moreover the
areas used by the public carpark and its associated
facilities should be delineated on plans.

(d) The area of driveways, ramps, staircases and lift halls at the levels
providing access to / from a building for use by both private and
public carparks should be included in the GFA calculation.

(e) For the avoidance of doubt, any parking provision on open areas
of a site, or on an open podium roof, need not be measured for
GFA.

Public Transport Terminus (PTT)

17. The BA would take the advice of the Planning Department in determining the
effect of excluding PTT from GFA calculation on the infrastructure, density and building
bulk. As Planning Department has advised that the town planning intention is that all
PTT should count for GFA calculation unless otherwise provided for in the relevant town
plan, hence as a general rule, unless otherwise specified in the relevant town plan or any
specific planning approval for the site, all PTT should be accountable for GFA.

Loading and Unloading Areas

18. (a) Areas for loading / unloading purposes would only qualify for
disregarding from measurement of GFA if they are directly
associated with spaces specifically earmarked for parking of
motor vehicles for loading and unloading purposes and are
designed to the satisfaction of the BA and the provision are not
excessive with reference to the standards set out in the
HKPSGor requirements stipulated by the C for T. For
instance, areas set aside for loading / unloading detached
container boxes in a container yard should be measured for
GFA.

/(b)…..
 - 11 -

(b) If ramps are provided in association with loading/unloading

areas which have direct access to the accommodation on the
floors e.g. warehouse / godown in logistics centre
developments, the ramps are considered to serve the same
function as lifts for vertical transportation, and the area of the
ramps should be accountable in full for GFA under regulation
23(3)(a) of the B(P)R.

(c) 100% GFA concession may be granted for such loading and
unloading areas if they are provided at ground level or
underground but may only be qualified for 50% GFA
concessions if they are provided at upper storeys above ground
level. For cases where run-in/out or driveway at ground level
serve loading and unloading areas at ground level or
underground but also serve car parking spaces aboveground
entitling only 50% GFA concessions, the percentage of GFA
concessions of such run-in/out or driveway areas will be
calculated on a pro-rata apportionment basis judging on the
merits of each individual cases.

(d) Apart from (c) above, areas for loading and unloading
purposes and parking space for refuse collection vehicle next
to a refuse storage and material recovery chamber may be
disregarded from GFA calculation if vehicular access is
required to be provided to the refuse storage and material
recovery chamber under the Building (Refuse Storage and
Material Recovery Chambers and Refuse Chutes) Regulations.
100% GFA concession may be granted for such space solely
for refuse collection vehicle, which is provided either
underground or above-ground.

(HUI Siu-wai )
Building Authority

Ref. : BD GP/BREG/P/9 (X)

This PNAP is previously known as PNAP 13

First issue December 1974
Last revision November 2013
This revision March 2015 (AD/NB1) (Para. 6 amended)
 Appendix A
(PNAP APP-2)

1. Exemption Criteria for Exclusion of Voids in Duplex Domestic Flats and Houses
from Gross Floor Area Calculations

Duplex Flats Houses

UFS(1) of premises 150 m2 (min.) 250m2 (min.)

% of void to UFS 10% (max.) 5% (max.)

of premises

% of void to total Only two levels of voids will be allowed

domestic GFA for each residential tower block, subject
to a maximum of 0.5%(2) of the total N.A.
domestic GFA of the development.

Headroom of 6.5m (max.) 7.0m (max.)(3)

void

Location of void Living/ dining room or entrance foyer Living/ dining

room or
entrance foyer

(1) “UFS” means any floor space other than staircases, staircase halls, lift landings, the space used in providing
water-closet fitments, urinals and lavatory basins and the space occupied by machinery for any lift,
air-conditioning system or similar services.

(2) The “0.5% cap” will be applied with some flexibility for low-rise and low-density flat-type development which
is similar to house-type development. Each case will be considered on individual merits.

(3) In case of sloping ceiling resulted from a pitch roof, the headroom should be measured to the mean level of the
underside of the portion of ceiling that is above the void area.

2. Conditions of Exemption

(i) The Building Authority (BA) is satisfied that the void design is compatible with
the type of residential development and that effective measures to prevent any
possible abuse are provided, such as up-stand beam design, voids fronted by
large glazing panels facing the exterior, no adjoining structural wall or beam,
etc.

(ii) The development after excluding the area of voids from GFA calculation will not
contravene the development restrictions relating to building height, GFA, etc. in
the relevant statutory town plan and any specific provisions or restrictions in the

-1-
 lease conditions.

(iii) To support an application for exemption of voids from GFA calculations, the
developer or owner is required to submit a letter of undertaking for the proposed
development. It shall include an undertaking from the developer or owner to
the BA to designate the area of the voids as ‘voids’ in the Deed of Mutual
Covenant (DMC) with their locations clearly indicated. The DMC should
contain binding and enforceable conditions for the control, management and
maintenance of the features. Where no DMC is to be in force for a
development, such designation shall be incorporated into the Sales and Purchase
Agreement, Assignment, Tenancy Agreement or conveyance document such
that the future owners or tenants are aware of their rights and liabilities.

(iv) Applications for exemption of voids from GFA calculations in duplex domestic
flats or houses or in the case of a development with houses and flats on the same
site, would be considered on the special circumstances of each case.

(Rev. 7/2013)

-2-
 Appendix B
(PNAP APP-2)

Section of Curtain Wall System installed at New Building

External wall of the building for the purpose of

measurement of GFA and site coverage
Curtain wall system

MINIMUM 300 mm
Projection of the curtain wall from floor level
system not exceeding 200 mm
(domestic building) / 250 mm Internal finishes
(non-domestic building) from the Raised floor
INTERIOR
outer face of structural elements

Fire seal
GMS bracket
Glass
Insulation panel

Suspended ceiling

Section of Curtain Wall System installed at Existing Building

External wall of the building for the purpose
of measurement of GFA and site coverage

Curtain wall system Existing window

External finishes
Projection of the curtain wall MINIMUM 300 mm from floor level
system not exceeding 200 mm
(domestic building) / 250 mm Internal finishes
(non-domestic building) from the
outer face of existing external wall Raised floor INTERIOR

Fire seal
Glass GMS bracket
Insulation panel

Suspended ceiling
Existing window

(Rev. 11/2013)