Civic Exchange’s Written Submission to the Biodiversity Strategy and Action Plan for Hong Kong Consultation (by Environment Bureau and Agriculture, Fisheries and Conservation Department)


  1. In January 2016, the HKSAR Government launched a three-month consultation on the Biodiversity Strategy and Action Plan (BSAP) for Hong Kong. In the public consultation document, the Government highlighted the challenges faced by Hong Kong in terms of balancing the competing demands for land and other consumables, and the need to protect the city’s natural resources. The document also identified the Government’s priorities and agendas to conserve Hong Kong’s biodiversity in the proposed BSAP.
  2. In 2011, the Convention on Biological Diversity (CBD), an international treaty that aims at sustaining the rich biodiversity on Earth, was extended to Hong Kong. The Government therefore needed to chart the city’s first-ever BSAP through a participatory process involving the Hong Kong community as a whole.
  3. Starting officially from mid-June 2013, the Government began the 18-month engagement process through setting up the Steering Committee, three Working Groups and then twelve Focus Groups to gauge community wisdom to consider ways to protect Hong Kong’s biodiversity.
  4. Civic Exchange is pleased to see the Government’s stated commitment, in the consultation document, to “develop a city-level BSAP with a view to stepping up conservation efforts and support the sustainable development of Hong Kong in the next five years.”1Vision, Mission and Principles of Hong Kong’s first BSAP
  5. Civic Exchange supports the proposed vision and mission stated in the consultation document. In the first city-level BSAP for Hong Kong, however, there should also be specific principles, priorities and targets.
  6. There is, unfortunately, no mention of any principles in the consultation document. The Government only stated that it “has taken into account the objectives and principles of the CBD ……” in formulating Hong Kong’s first BSAP. The Steering Committee agreed upon a proposed set of principles during the 18-month engagement period, but the principles have not been included in the consultation document. Civic Exchange urges the Government add those principles in the final BSAP for Hong Kong.Priorities and Targets of Hong Kong’s first BSAP
  7. In terms of priorities, the Government proposed conservation, mainstreaming, knowledge, and community involvement as the four major action areas for Hong Kong’s first BSAP. While Civic Exchange is pleased to see “mainstreaming” being considered as a focus to help different sectors better understand biodiversity in Hong Kong, it is rather disappointing to know that the Government is not prepared to make major changes, such as changing existing policies and legislation (see 13 below for more.)
  8. The key elements of the Strategic Plan 2011-2020 (five strategic goals), including 20 Aichi Biodiversity targets, were adopted by the COP to CBD at the 10th meeting. These contain specific deadlines and quantifiable targets. Civic Exchange urges the Government develop goals and targets of at least comparable specificity if not more aggressive (and with detailed specific action items) in the first Hong Kong BSAP. This will help with monitoring and evaluation, another key aspect of a sound strategic plan.
  9. In addition, even though Hong Kong is not a Party to the CBD on its own, the HKSAR Government stated in the consultation document that it had “to assist the Central People’s Government in fulfilling its obligations under the CBD insofar as the HKSAR is concerned”.2 Civic Exchange believes that it is now an opportune time for the HKSAR Government to craft and implement a BSAP of ambition which can also contribute to China’s National BSAP.Threats and Challenges to Hong Kong’s Biodiversity
  10. The Government listed in the consultation document the efforts made and achievements so far. Civic Exchange sees the need to also highlight the threats and challenges to Hong Kong’s biodiversity, such as the impacts of Small House Policy3, encroachment on country parks4, and destruction in private land on biodiversity. This will inform the public about how the suggested actions could help address the threats and challenges.Specific Actions in Hong Kong’s First BSAP
  11. Civic Exchange has reservations regarding the way the needs of people are suggested to be in conflict with those of the ecosystem. There is a fundamental and unavoidable dependency between the two, and it would be unfortunate to impose an artificial distinction that complicates decision-making. Identifying and acting upon identifiable synergies would be a more beneficial way for the Government to approach the request for specific actions and simultaneously to counter the unhelpful perception that this conflict is unavoidable.
  12. Civic Exchange supports the possible actions proposed under the four action areas in the consultation document and would urge the Government to turn them into concrete actions. In addition, the Steering Committee, three Working Groups and 12 Focus Groups compiled a list of over 400 specific actions during the engagement period which was re-grouped and categorised into a list of 33 key actions. Civic Exchange highly recommends the Government refer to these lists and to their specific actions, in particular, as much as possible when charting the city’s first BSAP. The actions should be as specific as possible with relevant timelines, which will facilitate monitoring, evaluation and revision at a later stage.
  13. Civic Exchange would like to specifically highlight the fact that Hong Kong needs more than the possible actions mentioned under “Mainstreaming” (Action Area 2). Incorporating biodiversity considerations in updating the HK2030+ and Hong Kong Planning Standard and Guidelines are just first steps: other actions – such as incorporating important enclaves, lowland rivers, freshwater marshes and feng shui woods into country parks, halting the destruction of natural habitats on private land through blocking loopholes in the Town Planning Ordinance, and reviewing the Small House Policy without further delay – are also of high importance. Deliberate action to pre-empt greater cost or uncertainty is an inevitable reaction to change that potentially affects people’s economic circumstances, and therefore it should be anticipated that efforts to take advantage of any such loopholes or ambiguities will increase in any extended window of time between their proposal and implementation, leading to accelerated damage to or loss of habitats. The action plan to address this therefore needs to be both timely and extensive.Resources required to implement Hong Kong’s First BSAP
  14. To ensure implementation of the actions in the final version of the BSAP for Hong Kong, resources will need to be allocated. These will need to include human resources as well as technical and financial support. Civic Exchange sees mainstreaming within the Government as extremely important. Preserving biodiversity in Hong Kong is a cross-cutting task and should involve multiple government bureaux and departments, including, (but not limited to) Development Bureau, Food, Environment & Hygiene Department, Water Services Department, Drainage Services Department, Planning Department, and Lands Department.
  15. Civic Exchange also sees the need to ensure there will be a designated office with resources to handle the implementation, enforcement and the follow up work of the BSAP.
  16. Civic Exchange urges the Government to be transparent in terms of how the sum of money being allocated to the implementation of BSAP will be used.Conclusions
  17. Civic Exchange reiterates our full support to a BSAP plan for Hong Kong that will reflect the value of Hong Kong’s exceptionally rich biodiversity, especially the endemic species that can only be found in Hong Kong. A lot of the efforts were put in during the 18-month engagement period, there were certainly high hopes that the city’s first BSAP can provide new energy to biodiversity conservation in Hong Kong. Civic Exchange would like to see the group of experts and NGO representatives who took part in the engagement process continue to be engaged in the crafting and the finalisation of the first Hong Kong BSAP.


1 Environment Bureau, & Agriculture, Fisheries and Conservation Department. (January 2016). Biodiversity Strategy and Action Plan (BSAP) for Hong Kong: Public Consultation Document. HKSAR Government, p. 37.

2 Ibid., p. 38.

3 Small House Policy II: An Update, a research report published by Civic Exchange in April 2013, stated the significant adverseimpacts of haphazard e development on the natural environment and ecological habitats. See Mandy Lao Man-lei, Small House Policy II: An Update, Civic Exchange: April 2013.

4 See Adaptive Governance for Hong Kong’s Country Parks Network: As assessment of the parks management regime, and proposals for ways forward. Civic Exchange: August 2011. This report highlights the importance of having a proper country park management system (which is guided by principles, vision and strategies) for Hong Kong in order to fulfil the priorities of conservation and recreation. This is particularly important because country parks in Hong Kong have been threatened by development encroachment and other systemic concerns like climate change, hill fire episodes.