Policy Comments & Advocacy

As one of the major green groups in Hong Kong, Green Power has long been engaging in habitat and biodiversity conversation for the betterment of Hong Kong’s environment and sustainable development. We recognizes the achievements and values of the first Biodiversity Strategy and Action Plan launched by AFCD in 2016. Green Power would like to draw your kind attention to our opinions on the “Updates to Hong Kong Biodiversity Strategy and Action Plan Public Consultation Document (BSAP Update)” released in May 2025.

General Comments

1. We support the global goals outlined by the Kunming-Montreal Global Biodiversity Framework (K-M GBF), and the update of Hong Kong's BSAP should align comprehensively with these goals.

2. However, the current consultation document primarily presents a strategic framework for the BSAP update, with only few actions and initiatives proposed. We urge for a comprehensive action plan for further public consultations on its effectiveness and feasibility.

3. Undoubtedly, climate change has become a major threat to both global and local biodiversity, as well as main challenge to conservation in future. Four strategic areas are covered by the BSAP update. However, it lacks detail strategies and measures to improve the resilience of local biodiversity against climate change risks.

Views and Recommendations

4. We would like to suggest several initiatives to achieve selected global goals of the K-M GBF in the local context.

5. Changes in land use should not compromise the habitats with high ecological value (K-M GBF Goal 1). Therefore, any development projects and town planning applications affecting these areas (including but not limited to the Sites of Special Scientific Interest (SSSI), Ramsar Site, Wetland Conservation/Buffer Areas, Ecologically Important Streams (EIS) and Coastal Protection Areas, etc.) should prioritize biodiversity conservation, adhering to the fundamental principle of not proceeding with any new developments that would degrade the original ecosystem. Additionally, for areas of high ecological value not regulated by the Town Planning Ordinance (e.g. Lung Kwu Tan), authorities should promptly establish statutory landuse plans to effectively regulate local land use.

6. In addition, for completed Designated Projects under Environmental Impact Assessment Ordinance (EIAO) and applications under Town Planning Ordinance (TPO) in areas of high ecological value, authorities should independently conduct a comprehensive review of the actual conservation effectiveness of the ecological mitigation/compensation measures proposed by project proponents in addition to the requirements under EIAO and TPO. If the expected conservation outcomes cannot be achieved, the same kind of measures proposed for similar future development projects should be deemed ineffective in the statutory assessment processes.

7. Proactive restoration of degraded ecosystems should be implemented (K-M GBF Goal 2). Abandoned wetlands (e.g. fishponds, marshes, wet agricultural land), rural villages, urbanized rivers and coasts, and devegetated hillsides should be prioritized for ecological revitalization.

8. At least 30% of terrestrial, inland water, and of coastal and marine areas should be effectively conserved and managed (K-M GBF Goal 3). Authorities should make effective use of the Biodiversity Geographic Information Systems (BGIS) to designate unprotected areas of high ecological value as ecological sensitive zones. This includes designating new Country Parks, Nature/Wetland Parks, Marine Parks and Special Areas, as well as updating SSSI, EIS in order to more comprehensively protect local biodiversity. Biodiversity-friendly facilities (e.g. ecological corridors, fish ladders, escape routes along catchwater system, and etc.) should be retrofitted in the protected areas. In addition, Large-scale reclamation development projects should be avoided to halt permanent loss of marine habitats.

9. Threatened species should be protected from human-induced impacts and human-wildlife conflict (K-M GBF Goal 4). Authorities should review and update the list of protected wild animals and plants under the Forests and Countryside Ordinance (Cap. 96) and Wild Animals Protection Ordinance (Cap. 170) to cover all locally threatened species. Besides, authorities should timely update the controlled species list under the Protection of Endangered Species of Animals and Plants Ordinance (Cap. 586) according to the latest Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES). To minimize human-wildlife conflict, authorities should strengthen efforts to combat the feeding of wildlife in urban areas and countryside, including enhancing enforcement of the Wild Animals Protection (Amendment) Ordinance 2024 (Cap. 170) and increasing penalties.

10. To combat illegal poaching activities in countryside (K-M GBF Goal 5), authorities should streamline the enforcement and evidence collection procedures to increase the effectiveness and efficiency of prosecution. Additionally, they should enhance patrols in hotspots of illegal poaching and consider using smart technologies for real-time monitoring and alerts. In response to the issue of mainland fishing vessels illegally operating in Hong Kong's protected marine areas, authorities should systemize the joint departmental maritime patrols and enforcement action.

11. Impacts of invasive alien species on biodiversity should be eliminated, minimized, reduced and/or mitigated (K-M GBF Goal 6). We recommend that authorities tighten the entry controls on flora and fauna, restricting travelers from bringing or mailing any undeclared and unquarantined plant and animal parts into Hong Kong, in order to reduce the risk of invasive species entering the territory. In addition, authorities should legislate to regulate mercy release activities and educate the public about the harm that such release activities can cause to the ecosystem and well-being of the released animals.

12. Pollution risks should be eliminated or reduced to levels that are not harmful to biodiversity and ecosystem functions and services (K-M GBF Goal 7). We recommend that authorities research and establish water quality standards based on biodiversity indicators. Ecological Water Quality Objectives aimed at conserving aquatic ecosystems should be established to safeguard the health of freshwater and marine ecosystem, improve the ecological carrying capacity of local water bodies and protect the biodiversity of aquatic life and fishery resources. Additionally, light pollution should be included in the Ecological Impact Assessments under Technical Memorandum for EIAO to reduce the adverse impacts of Designated Projects on nocturnal wildlife.

13. Impact of climate change and ocean acidification on biodiversity should be minimized (K-M GBF Goal 8). We believe that climate change is one of the greatest threats to biodiversity today. Authorities must effectively implement the carbon reduction targets set out in "Hong Kong's Climate Action Plan 2050", such as increasing local carbon sinks through the restoration of native forests.

14. Agriculture, aquaculture, fisheries and forestry should be managed sustainably (K-M GBF Goal 10). Authorities could encourage conventional farmers to transform to biodiversity-friendly farming practices through subsidies and/or payment for ecosystem services, and consider developing a certification system for biodiversity-friendly farming in addition to the organic farming, to enhance the market competitiveness of eco-crops. Moreover, authorities should consider establishing legally designated fishing moratorium in Hong Kong waters to avoid overexploitation of local marine resources.

15. Nature’s contributions to people should be restored, maintained, and enhanced (K-M GBF Goal 11). We opine that citizens must first recognize that human survival and economy depends on healthy ecosystems. Authorities need to actively promote environmental education to foster a connection between citizens and biodiversity. The proportion of environmental education topics in regular primary and secondary school curricula should be increased, and schools should be encouraged to arrange outdoor learning opportunities for youth.

16. Ecotourism is undoubtedly one of the most direct ways for people to enjoy nature’s contributions; however, we are concerned that the development of ecotourism in Hong Kong may negatively impact ecologically sensitive areas. Therefore, authorities should take into account the local carrying capacity when developing ecotourism and assess the potential impact of tourists on the destination. Visitor and transport/traffic control measures need to be established in advance to avoid excessive visitors. All new facilities built for ecotourism should be compatible with the local natural environment and should not compromise the local ecosystem and ecotourism resources. Monitoring and regulatory system for the commercial activities and facility operation should be established to effectively protect the biodiversity, Authorities should also promote sustainable ecotourism, ensuring that the benefits derived from ecotourism directly contribute to the long-term conservation of local ecosystems and awareness of the public.

17. To enhance green spaces and urban planning for human well-being and biodiversity (K-M GBF Goal 12), biodiversity-inclusive urban planning should be promoted in Hong Kong. For example, urban parks should incorporate layouts that mimic native natural habitats by replacing exotic plants with native flora. Connection of urban green spaces to neighbouring natural habitats should be provided. Additionally, facilities such as ecological ponds and butterfly gardens could be created to enhance urban biodiversity.

18. Biodiversity should be fully integrated into all policies, regulations, planning, and development processes (K-M GBF Goal 14). It is expected that more government departments will be involved in the updated BSAP to promote biodiversity conservation in all aspects. Therefore, we recommend that the authorities form a high-level interdepartmental working group to coordinate the implementation of the updated BSAP and review the progress of its execution.

19. We recommend that authorities promote a culture of sustainable consumption in the market (K-M GBF Goal 16), including encouraging the use of sustainably certified products and supporting the research and development of local biodiversity-friendly technologies or products through funding.

20. To ensure that knowledge is available and accessible to guide biodiversity action (K-M GBF Goal 21), we recommend that authorities disseminate local ecological data without disclosing sensitive species location information, and regularly coordinate a territory-wide biodiversity status report to assess local species trends, serving as a basis for adjusting the BSAP adaptively.

21. Participatory decision-making is crucial in the BSAP (K-M GBF Goal 20), we recommend that authorities regularly communicate with stakeholders during the ten-year implementation of the updated BSAP to promote ongoing collaboration among all parties.

Thank you very much for your kind attention. For any inquiries, please contact the undersigned at Green Power (T: 3961 0200, F: 2314 2661, Email: info@greenpower.org.hk).