其他倡議
Secretary for Environment, Transport and Works
10/F, Citibank Tower
3 Garden Road
Central, Hong Kong
Comments from Green Student Council on
Nature Conservation Consultation Paper
Green Student Council (GSC) is a registered Environmental Organization founded by a group of enthusiastic university students since 1993. Our members become young professionals and keep on concerning environmental issues and promoting environmental consciousness to different sectors in the society, especially to younger generation. We have examined the consultation paper on nature conservation policy and would like to give our comments as below:
Generally speaking, we are pleased to see there is a public consultation on nature conservation policy. However, it is disappointing that this consultation only focuses on ecological sensitive areas under private ownership that have long received public concerns. The policy fails to shed lights on many key conservation options including nature conservation policy's mission and vision, ecotourism development and its management, habitat enhancement and management, setting up for the biodiversity/habitat/species action plan. On the other hand, some of the options should not be neglected as they are regarded as infeasible in the consultation paper.
Conservation Policy:
The existing policy was enacted in 1993; it is out-dated and unable to meet the international conservation standard such as European Commission’s Habitat Directive (92/43/EEC) 1. Also, the policy statement is rather passive as it stated to “…by protect the existing conservation areas” rather than “thorough active management and appropriate measures to enhance or improve the existing habitats”. It has not integrated the concept of sustainable development in it.
* It is suggested that the conservation policy should include “through preservation, protection, restoration and improvement meaures to obtain a favourable conservation status for environment and native biodiversity”
* Conservation department should design appropriate management plan for those areas/sites identified with high conservation value e.g. SSSI, CA, CPA in OZPs.
* Government should also take appropriate steps to avoid, in the areas of conservation, the deterioration of natural habitats as well as disturbance of the species in which have been designated as ecologically important.
Outdated and ineffective conservation measures:
The paper suggests that there are various conservation measures currently. We think that these Ordinances only play a passive role in nature conservation that restricts any development on natural habitats. There is a strong need to review its effectiveness and strengthen its function on conservation.
* In Town Planning Ordinance, in order to have better control of land uses, Green Student Council suggest that PD should extend the power to specify the land use of some zoning areas e.g. CA, fishponds and arable lands with high conservation value. The landowners should be notified with a corresponding management plan. The conservation values should be determined by a committee with public participation.
* Environmental Impact Assessment Ordinance also has its weaknesses and it is illustrated in many controversial issues like Long Valley in recent years. In the existing system, applicants hire private consultation to prepare the EIA report themselves. For the sake of the employee, private consultant would only emphasize those evidences which support the view of applicants as well as the developers. The private consultants may fail to provide an independent and objective EIA report to the Director of EPD. We suggest that government can act as a coordination role by setting up an independent agency to centralize those licensed consultant firms. It can avoid the direct and undesirable relationship between applicant/developer and consultant.
* Country Park Ordinance is a major nature conservation measures in Hong Kong. Again, it is a rather passive nature conservation tool. The ordinance is out of dated to meet the contemporarily the public expectation on nature conservation. It lacks proactive action plans to enhance the native bio-diversity.
Habitat Enhancement /Management/Restoration:
* Country Parks
Although Hong Kong has more than 40% areas are designated as country parks, these areas are not well managed in the view of preserving bio-diversity. Over the past decades, only some plantation works were conducted without other measures to manage a suitable habitat or food sources for some endangered species. Experiments and surveys concerning native biodiversity are seldom. In order to enhance carrying capacity of our natural habitats, extensive researches, experiments and more important a habitat and species action plan should be conducted.
* Wetlands
Wetlands and fishponds are very important in conservation as they support a high biodiversity and biomass. Hong Kong is beset by estuary wetland and has very long coastal line. Nevertheless, many of these wetlands and ponds are not managed and subjected to pollution and development (e.g. road construction) pressure. Many wetlands or mangroves are not managed or protected. Uncontrolled human activities lead to disappearance or degradation of these ecological important areas. There is no plan to restore the ecological value of degraded habitats. Identification of these sites should be conducted with a scheduled restoration and management plans.
* Urban fringe and city's ecology
Despite a high degree of development in Hong Kong, the close proximity between urban areas and countryside is unique worldwide. The environment of urban areas is critical for local wildlife. Sub-urban areas also provide a linkage or a corridor for different kinds of avifauna. Better management of public parks can optimize their ecological functions and capacities.
* Freshwater course
A lot of river canalization projects are implemented in the past years for flood control reasons. The projects unavoidably destroy many precious fresh water habitats as well as any species of fresh water fishes to dragonflies inhabiting. Rivers being canalized lose their natural morphology with modification of meanders and also many unique characters rendering rare species. River restoration works and technique have been comprehensively developed in western countries. Future works should minimize the disturbance.
Ecotourism Management:
Eco-tourism becomes increasingly popular. Most of the tours are operated by private travel agencies. Those tour guides receive no proper environmental training. The so-called eco-tourism often exerts detrimental environmental stress on ecologically sensitive areas.
It is suggested that the government should conserve those ecologically sensitive areas such as Tsim Bei Tsui, Lai Chi Wo and some out-lying islands. A licensing system should be employed to provide professional training and examination to the guides and agencies. Daily quota for visitors can greatly minimize the disturbance.
More touring facilities such as information boards, bird watching screens/hides and waste recycle bins should be established in order facilitate better practices in ecotourism.
Scoring System:
* We support the use of scoring system ranking the priority of habitat conservation. The system should encompass a security mechanism and policy to protect habitats in lower priority.
* Sites with high degree of disturbance will rank a low priority for protection. We suggest the ranking should base on the biodiversity of habitat with special emphasis on the rare species inhabiting. The probability of habitat rehabilitation should be taken into consideration. Disturbed habitats with high ecological value should bear a higher priority.
* In Hong Kong, many habitats such as fresh water wetland and farmland disappear due to the human activities in the last decades. Most of them are of high ecological value supporting many special species. In EC's Habitat Directive 1, habitats with "danger of disappearance" are ranked with high priority of conservation. Our scoring system should include this important criterion to protect those habitats from human disturbance or development.
Private–public partnership:
We strongly agree the Private-public partnership system in order to achieve a management plan for some ecological sensitive areas under private ownership. However, the system should widely consult the public, especially the green groups.
The best practice is to set up an independent committee formed by different social groups. The function of committee is to implement and monitor the conservation project with respect to the facilitation of bio-diversity. The management plan must be sustainable (e.g. the developer set up a fund and ensure it can keep running) and can achieve net increase in bio-diversity within a definite period of time.
Infeasible mechanism:
Compared to last decade, the public awareness towards environmental affairs increases considerably. People tend to devote more on protecting nature heritage and are more willing to scarify (e.g. money, traffic jam) in order to obtain a better environment.
We strongly disagree that the consultation paper treats many of the conservation options as infeasible. Besides economic development, government should place the nature conservation policy in a high priority.
* Existing Conservation Measures:
As aforesaid, the TPO is not an effective tool to control human activities. We should consider "land use management plan" as a statutory tool to control human activities and to make sure those activities are compatible to the environment. Works should be done to strengthen the TPO's power on this aspect.
We disagree the paper mentions that "policing and enforcement against illegal land uses require tremendous resources" as it is a necessary mission. It is the responsibility of the government responsibility to conduct the corresponding enforcement. There is no excuse to stop the enforcement work.
* Land Resumption
We totally disagree land resumption is neglected in the consultation. Having considered the financial burden, we consider it is not an option for all the ecological important sites but not some exceptional cases. Some areas of high ecological values should consider land resumption with a conservation management plan. Amendment of legislation can also help to tackle multiple ownership problems. It can be designated as a nature reserve or national park for wildlife watching, organic farming and hiking tour base.
Hong Kong should have a well-defined insight on conservation issues. We own a large area of countryside next to our city and a thousand kilometers of coastline. In terms of long-term economic development, we believe that tourism would be more and more important in the near future. Resumption of some ecological important sites can help to develop eco-tourism hotspots in Asia. We believe long- term investment in nature conservation would not give us financial burden but a sustainable economy in the future and innumerable benefits for our future generations.
Reference:
1. The Council of European Communities – Directive on the conservation of natural habitats and of wild fauna and flora http://europa.eu.int/comm/environment/nature/habdir.htm
10/F, Citibank Tower
3 Garden Road
Central, Hong Kong
Comments from Green Student Council on
Nature Conservation Consultation Paper
Green Student Council (GSC) is a registered Environmental Organization founded by a group of enthusiastic university students since 1993. Our members become young professionals and keep on concerning environmental issues and promoting environmental consciousness to different sectors in the society, especially to younger generation. We have examined the consultation paper on nature conservation policy and would like to give our comments as below:
Generally speaking, we are pleased to see there is a public consultation on nature conservation policy. However, it is disappointing that this consultation only focuses on ecological sensitive areas under private ownership that have long received public concerns. The policy fails to shed lights on many key conservation options including nature conservation policy's mission and vision, ecotourism development and its management, habitat enhancement and management, setting up for the biodiversity/habitat/species action plan. On the other hand, some of the options should not be neglected as they are regarded as infeasible in the consultation paper.
Conservation Policy:
The existing policy was enacted in 1993; it is out-dated and unable to meet the international conservation standard such as European Commission’s Habitat Directive (92/43/EEC) 1. Also, the policy statement is rather passive as it stated to “…by protect the existing conservation areas” rather than “thorough active management and appropriate measures to enhance or improve the existing habitats”. It has not integrated the concept of sustainable development in it.
* It is suggested that the conservation policy should include “through preservation, protection, restoration and improvement meaures to obtain a favourable conservation status for environment and native biodiversity”
* Conservation department should design appropriate management plan for those areas/sites identified with high conservation value e.g. SSSI, CA, CPA in OZPs.
* Government should also take appropriate steps to avoid, in the areas of conservation, the deterioration of natural habitats as well as disturbance of the species in which have been designated as ecologically important.
Outdated and ineffective conservation measures:
The paper suggests that there are various conservation measures currently. We think that these Ordinances only play a passive role in nature conservation that restricts any development on natural habitats. There is a strong need to review its effectiveness and strengthen its function on conservation.
* In Town Planning Ordinance, in order to have better control of land uses, Green Student Council suggest that PD should extend the power to specify the land use of some zoning areas e.g. CA, fishponds and arable lands with high conservation value. The landowners should be notified with a corresponding management plan. The conservation values should be determined by a committee with public participation.
* Environmental Impact Assessment Ordinance also has its weaknesses and it is illustrated in many controversial issues like Long Valley in recent years. In the existing system, applicants hire private consultation to prepare the EIA report themselves. For the sake of the employee, private consultant would only emphasize those evidences which support the view of applicants as well as the developers. The private consultants may fail to provide an independent and objective EIA report to the Director of EPD. We suggest that government can act as a coordination role by setting up an independent agency to centralize those licensed consultant firms. It can avoid the direct and undesirable relationship between applicant/developer and consultant.
* Country Park Ordinance is a major nature conservation measures in Hong Kong. Again, it is a rather passive nature conservation tool. The ordinance is out of dated to meet the contemporarily the public expectation on nature conservation. It lacks proactive action plans to enhance the native bio-diversity.
Habitat Enhancement /Management/Restoration:
* Country Parks
Although Hong Kong has more than 40% areas are designated as country parks, these areas are not well managed in the view of preserving bio-diversity. Over the past decades, only some plantation works were conducted without other measures to manage a suitable habitat or food sources for some endangered species. Experiments and surveys concerning native biodiversity are seldom. In order to enhance carrying capacity of our natural habitats, extensive researches, experiments and more important a habitat and species action plan should be conducted.
* Wetlands
Wetlands and fishponds are very important in conservation as they support a high biodiversity and biomass. Hong Kong is beset by estuary wetland and has very long coastal line. Nevertheless, many of these wetlands and ponds are not managed and subjected to pollution and development (e.g. road construction) pressure. Many wetlands or mangroves are not managed or protected. Uncontrolled human activities lead to disappearance or degradation of these ecological important areas. There is no plan to restore the ecological value of degraded habitats. Identification of these sites should be conducted with a scheduled restoration and management plans.
* Urban fringe and city's ecology
Despite a high degree of development in Hong Kong, the close proximity between urban areas and countryside is unique worldwide. The environment of urban areas is critical for local wildlife. Sub-urban areas also provide a linkage or a corridor for different kinds of avifauna. Better management of public parks can optimize their ecological functions and capacities.
* Freshwater course
A lot of river canalization projects are implemented in the past years for flood control reasons. The projects unavoidably destroy many precious fresh water habitats as well as any species of fresh water fishes to dragonflies inhabiting. Rivers being canalized lose their natural morphology with modification of meanders and also many unique characters rendering rare species. River restoration works and technique have been comprehensively developed in western countries. Future works should minimize the disturbance.
Ecotourism Management:
Eco-tourism becomes increasingly popular. Most of the tours are operated by private travel agencies. Those tour guides receive no proper environmental training. The so-called eco-tourism often exerts detrimental environmental stress on ecologically sensitive areas.
It is suggested that the government should conserve those ecologically sensitive areas such as Tsim Bei Tsui, Lai Chi Wo and some out-lying islands. A licensing system should be employed to provide professional training and examination to the guides and agencies. Daily quota for visitors can greatly minimize the disturbance.
More touring facilities such as information boards, bird watching screens/hides and waste recycle bins should be established in order facilitate better practices in ecotourism.
Scoring System:
* We support the use of scoring system ranking the priority of habitat conservation. The system should encompass a security mechanism and policy to protect habitats in lower priority.
* Sites with high degree of disturbance will rank a low priority for protection. We suggest the ranking should base on the biodiversity of habitat with special emphasis on the rare species inhabiting. The probability of habitat rehabilitation should be taken into consideration. Disturbed habitats with high ecological value should bear a higher priority.
* In Hong Kong, many habitats such as fresh water wetland and farmland disappear due to the human activities in the last decades. Most of them are of high ecological value supporting many special species. In EC's Habitat Directive 1, habitats with "danger of disappearance" are ranked with high priority of conservation. Our scoring system should include this important criterion to protect those habitats from human disturbance or development.
Private–public partnership:
We strongly agree the Private-public partnership system in order to achieve a management plan for some ecological sensitive areas under private ownership. However, the system should widely consult the public, especially the green groups.
The best practice is to set up an independent committee formed by different social groups. The function of committee is to implement and monitor the conservation project with respect to the facilitation of bio-diversity. The management plan must be sustainable (e.g. the developer set up a fund and ensure it can keep running) and can achieve net increase in bio-diversity within a definite period of time.
Infeasible mechanism:
Compared to last decade, the public awareness towards environmental affairs increases considerably. People tend to devote more on protecting nature heritage and are more willing to scarify (e.g. money, traffic jam) in order to obtain a better environment.
We strongly disagree that the consultation paper treats many of the conservation options as infeasible. Besides economic development, government should place the nature conservation policy in a high priority.
* Existing Conservation Measures:
As aforesaid, the TPO is not an effective tool to control human activities. We should consider "land use management plan" as a statutory tool to control human activities and to make sure those activities are compatible to the environment. Works should be done to strengthen the TPO's power on this aspect.
We disagree the paper mentions that "policing and enforcement against illegal land uses require tremendous resources" as it is a necessary mission. It is the responsibility of the government responsibility to conduct the corresponding enforcement. There is no excuse to stop the enforcement work.
* Land Resumption
We totally disagree land resumption is neglected in the consultation. Having considered the financial burden, we consider it is not an option for all the ecological important sites but not some exceptional cases. Some areas of high ecological values should consider land resumption with a conservation management plan. Amendment of legislation can also help to tackle multiple ownership problems. It can be designated as a nature reserve or national park for wildlife watching, organic farming and hiking tour base.
Hong Kong should have a well-defined insight on conservation issues. We own a large area of countryside next to our city and a thousand kilometers of coastline. In terms of long-term economic development, we believe that tourism would be more and more important in the near future. Resumption of some ecological important sites can help to develop eco-tourism hotspots in Asia. We believe long- term investment in nature conservation would not give us financial burden but a sustainable economy in the future and innumerable benefits for our future generations.
Reference:
1. The Council of European Communities – Directive on the conservation of natural habitats and of wild fauna and flora http://europa.eu.int/comm/environment/nature/habdir.htm
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