香港生物多樣性策略及行動計劃意見書
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以下是我對諮詢文件的意見（只有英文版本），
已經電郵至 ：bsap@afcd.gov.hk：
My
view on AFCD's consultation for BSAP
My view on AFCD's consultation for BSAP
Chapter 3.2 Paragraph 2
“To this end, we do not intend to initiate major changes at this
stage, such as changing existing policies and legislation. ”
The existing policy and legislation have many inefficiencies.
The existing legislation such as Environmental Impact
Assessment Ordinance (EIAO), Town Planning Ordinance,
Buildings Ordinance,Foreshore and Seabed (Reclamations)
Ordinance, Roads (Works, Use and Compensation) Ordinance,
Country Parks Ordinance and Marine Parks Ordinance, etc. are
outdated and with many loop holes. They are ineffective in
protecting our environment and hence biodiversity.
One recent case is “嘉湖山丘泥頭山 '' , which already drawn
attention and complaints from many Hong Kong citizens.
Many of the green belt areas are now changed or to be changed
for development purposes due to existing policy.
Regarding to Sites of Special Scientific Interest (SSSIs),
although on Page 15 of BSAP consultation document has
cited “ ... the Environmental Impact Assessment Ordinance
provides that any major development to be carried out
within or near any existing or planned SSSI would
potentially be a “designated project” and will have
to meet a set of statutory requirements.”, however, no
Environmental Impact Assessment Study (EIA) was
carried out and submitted to EPD for the residential
development in the vicinity of Fung Yuen Valley.
Fung Yuen Valley was designated as a SSSI since 1980.
I have witness the development work. My causal observation
is that there is a great reduction of butterfly count close
to the SSSI zone. No mitigation measures were performed
because of the existing EIAO caters only for a very large
development work. The real case is that the development
of around 1400 flats near a SSSI did not need to submit an
EIA report to be approved under EIAO. The requirement
for submitting an EIA report for approval should be lower.
Without a major change, the proposed BSAP would not be
successful. As mentioned in Chapter 1.3 of the same paper,
the “tremendous need for land and financial resources to
meet the housing aspirations ….” will create a great conflict
between development and environmental protection and
cannot be resolved.
The proposal for development of Lantau Island to attract
more tourist. In addition, massive infrastructure, reclamation
projects are also proposed for the development of Lantau Island.
The HKSAR Government seems neglect the cumulative impacts
of these projects . The community needs and lifestyle,
conservation of cultural heritage have not been considered.
For the proposed questions in the BSAP consultation document :
Question : In relation to proposed Action Area 2 (Mainstreaming):
The Government currently tries to incorporate biodiversity
considerations into its plans and policies. Under this BSAP, it
would try to encourage other sectors to do the same. Which
sectors are more ready to do this? Which sectors need the most
support in adopting biodiversity considerations in their work?
Answer : I think most of the professionals such as Registered
Professional Engineers (RPE), Authorised Persons (AP), Town
Planners, Environmental Consultants lack the knowledge in
biodiversity. They should be trained as continued education.
The proposed actions are supported.
Question : With reference to proposed Action Area 3 (Knowledge):
We have identified various gaps in our knowledge of biodiversity in
Hong Kong. We need to fill them to facilitate stakeholders in making
informed decisions. In your opinion, which of these gaps should we
focus on in the coming five years?
Answer: Base line studies should be carried out to ascertain the current
situation of biodiversity. The survey results and findings should be opened
for public access in an open platform. Suggest to put onto the public sector
information portal of the Government of the Hong Kong Special
Administrative Region (https://data.gov.hk/) for easy access by the public.
Question : With reference to proposed Action Area 4 (Community
Involvement): The Government and non-governmental organisations have
taken a number of initiatives to promote biodiversity and nature
conservation. In your opinion, which of these have been most successful?
Can you suggest how we could improve them? Do you have other ideas?
Answer : Besides funding support for NGOs and academics,
Government should play more active in the training and community
involvement of biodiversity.
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