The HKIUD Public Affairs Committee’s Comments on the “Biodiversity Strategy and Action Plan (BSAP) for Hong Kong” Public Consultation in April 2016

1. Among different guiding principles for the promotion of good urban planning and design, the more important and commonly shared ones are about people oriented and sustainable development, as well as concepts for eco-cities evolved through the last three decades, and the more recent visions for smart cities. In view of menaces of hostile environments arising from global climate change, lately regional organisations and city governments also start planning to make their cities “resilient” to disasters andIn line with the objectives of HKIUD, we believe that good urban design makes sustainable and quality places for people, and that good urban spaces should be, inter alia, vibrant and interesting, organic and adaptable, healthy and safe, connected and integrated, convenient and comfortable. Such attributes should prevail even though we are coming under ever greater development pressure. We thus concur with the proposed Vision that  “ The rich biodiversity of Hong Kong is valued, conserved, restored, sustainably managed and wisely used, thereby maintaining essential ecosystem services, sustaining a healthy and liveable place and delivering benefits for all people”.
2.  It is understood that this Biodiversity Strategy and Action Plan (BSAP) for Hong Kong is mainly a framework for more detailed actions in the next five years. The Public Consultation asks consultees to come up and join as partners “to share knowledge, spread the message, and work together toward a common goal with a view to looking for opportunities to conserve biodiversity and support sustainable use of natural resources.”  We fully support this initiative. In fact, we have already made a lot of progress in designing for urban public spaces and strived to design by bringing nature to the city. Open spaces are no longer left-over spaces, and are these days designed as an integral part of the whole urban greenspace system, and where possible, integrated with the water bodies and with the interface between land and sea, and the relationship between man and nature in mind.
3. The Public Consultation pitched our BSAP at a city level since Hong Kong is not itself a Party to the CBD, but as a world city, it anticipates Hong Kong’s BSAP should also contribute to the achievement of global targets and China’s national BSAP “according to the particular conditions and capabilities of Hong Kong”. We think this is a pragmatic approach. Like our strive for sustainable development and control of pollutions, we have to tackle our territorial issues and participate in wider regional cooperation. Locally, we have marine parks, country parks, restricted areas and SSSIs. In terms of spatial coverage, arguably we are quite well off as the built up areas only covered about 24% of the total land area while some 60% are country parks. However, whereas most of the land outside country parks is covered by statutory outline zoning plans, the implementation of the green zonings is not a function of the Town Planning Board. The zonings on the plans are also subject to prolonged processes of challenge, including judicial reviews by stakeholders holding opposing views for and against conservation. It would be unfair to either party if the decision is left entirely to the legal process instead of comprehensive scientific knowledge and research. The quality of a decision is only as good as the correctness of the data. There are many gaps in the knowledge about the complex ecosystems and the many animal and plant species. Thus, we support the proposed Action Area # 3 “Knowledge” that more resources should be allocated for carrying out biodiversity surveys and studies to fill in present knowledge gaps.
4. Para.2.1.8 refers to “Greening” of urban ecosystems. We recognize that even in urban parks there are biodiversity potentials and that greenspaces should preferably be connected than inIn recent years, we also noticed a number of enhancement and retrofitting projects like the Kai Tak River and the Tsui Ping River projects where government departments are gradually restoring green spaces to the urban areas.  We did compliment these efforts. They are however possible probably because they fall on Government land. On the urban fringe, especially the Green Belt zones on the periphery of new towns in the New Territories, Government actions appear to be rather minimal in curbing damages made on private land. Land ownership and the land owners’ right to develop still thwarts the conservation objective.  For Action Area #1: “Conservation”, it should be an issue of some priority to be addressed.  We would also suggest that in the urban areas, mechanisms for reinstating or introducing greening and biodiversity opportunities upon redevelopment of urban sites should also be explored in the Action Plans.
5. Regarding the Sustainable Building Design (SBD) Guidelines requiring building separation, building setback and site coverage of greenery to facilitate ventilation and mitigate heat island effect, whilst we would continue to support this policy which helps to improve ventilation and amenity in general, it would be necessary, for biodiversity purposes to go one step further to see that the greening area is suitably managed after completion.
6. Action Area # 2 : Mainstreaming It has been less than 30 years since the concepts of Eco city and sustainability were conceived. The pace of emergence of newer ideas was so rapid that existing mechanisms and laws could not cope. There are likely to be discrepancies and outdatedness of the standards and guidelines of practice in different departments. This can be very confusing and even frustrating. When a new problem emerges, it may be insufficient for just a policy bureau to change its policy as the issue may straddle different policy areas. Besides, it would be better to be proactive than reacting to issues when they arise. We therefore concur with the Mainstreaming approach in Action Area #2. i.e. to make conservation and biodiversity as “a consideration in plans made at every level and, in every sector of society” integrating biodiversity into existing processes and systems and in new policies (including HK2030+ and HKPSG). We understand that it is not meant to complete all actions within 5 years time. Through making progress on all fronts, engaging different sectors in the dialogue and action, (Action Area #4 “Community involvement”) would nevertheless help gaining of public support and consensus more smoothly in the long term. 
7. The Paper suggests professional bodies or frontrunners of various sectors of the economy to introduce to their partners the linkages between sustainable development and biodiversity (“Connector”education in the Mainstreaming ) and “to share knowledge about how sustainable operation can lead to better economic performance, social responsibility and environmental benefit”. As Urban Designers our work has a spatial dimension, even before we are presented with this Biodiversity concept, we need to work closely with planners, architects and landscape architects in the government as well as in the private sector. Whereas biodiversity is a relatively new concept, may be not every party would see the issues in the same light in the beginning. We are however optimistic that we share the common vision and could reach a common language through the mainstreaming, and make biodiversity become an integral part of planning and decision making. The more comprehensive and open the data would become available (from Action Area 3 : Knowledge) the easier the consensus could be reached. To this end and for bringing up of the younger professionals we also need to consider including the teaching in the curriculum of urban design and urban planning courses in the respective universities.
8. On the whole, we support the BSAP in principle. Government may however have to anticipate challenges by some stakeholders and the problem of quantifying the value of greening and biodiversity, or alternatively the damages (or benefits) brought about by some developments or actions. The rights of land owners should be respected and compensated for as appropriate, in order to forge consensus in the community.

Public Affairs Committee of

The Hong Kong Institute of Urban Design

14 April 2016