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Consultation Document on Sustainable Development in Hong Kong

12 January 2000

 SUSDEV21
Planning Department
Government of the HKSAR
16/F North Point Government Offices
333 Java Road
North Point, Hong Kong
Attn: Director of Planning

Dear Sirs,

We are responding with our comments on the consultation paper on the second consultation exercise on Sustainable Development for the 21^st Century (SUSDEV 21).

Our comments are based on the document available to us, i.e. the paper as included in the Government consultation paper web-site. It appears that there is further documentation of the methodology and rationale for the paper's proposals; however this has not been available to us.

Overall, we are supportive of the Administration's initiative to address the important and hitherto neglected issue of the sustainability of Hong Kong's development. We appreciate much of the thinking that has gone into the present exercise. However, we question whether the decision support tool developed and set out in the consultation paper is the optimal mechanism to ensure sustainability, or the highest priority for action now. We recommend instead that the priority be set on developing and enforcing environmental standards. Finally, we have some comments of detail on the decision support tool as presented in the document.

1. Comments on the idea of a decision support tool

We understand that the objective of the decision support tool is to provide analysis of the impact of policy decisions on sustainability, i.e. to be a secondary mechanism supplementing analysis from other sources and on other bases. The objective is laudable, however we see a number of shortcomings or potential risks in the approach taken.

• Firstly, the scope of the tool is extremely broad – so much so that the indicators it comprises cover most areas relevant to "quality of life" in the broadest sense. However, indicators relating to air quality, say, appear to have almost nothing to do with those for social mobility. There is a danger of lack of focus, and of consequent failure of the tool to produce meaningful analysis.
• Secondly, we understand that the methodology to generate outputs or indicators from the tool is by way of structured question-and-answer. There is the danger of subjectivity creeping into the analysis, especially since, as noted above, the scope is so very broad.
• Thirdly, individual indicators may conflict with each other, or be subject to trade offs between each other. For example, efforts to maximise the indicator "Gross fixed capital formation as percentage of GDP" may well conflict with some of the environmental indicators. Hence the consolidated output of the tool as a whole may not be very meaningful.
• Fourthly, "sustainability", as commonly understood, means the sustainability of economic development in terms of its impact on the environment. Including economic indicators in the tool may introduce circularity and so render the output of the tool questionable.

We would suggest that the Administration's policy on sustainability should follow as closely as possible the principles of the 1992 Rio Declaration. The Rio Declaration is concerned essentially with preserving and enhancing the natural environment of individual countries and of the world as a whole, in particular protecting the environment against the forces of economic development. We recommend, therefore, that the Hong Kong Government should interpret "sustainability" in the same manner as the signatories of Rio, i.e. focusing in the environment.

This is a much narrower focus than the present document. We suggest that a narrow focus on environmental sustainability should be the highest priority for the Administration now. We face serious environmental problems that are affecting our health, our living standards and even our economic competitiveness now. If not addressed, these problems will rapidly grow more serious, and may also cause us to breach international environmental covenants as and when these come into effect. Targeted and vigorous action is needed to address these environmental problems. Such action should include setting standards for emissions, air quality, etc, i.e. standards – the breach of which is an offence subject to punishment as in many other countries – rather than mere "objectives" as at present.

With this in mind, we would suggest emphasising the environmental components of the decision support tool, i.e. the environmental indicators. The "Biodiversity" and the "Environmental Quality" indicators would appear the most important in this regard.

We suggest further that the kind of decision support tool set out in the paper may be suitable for implementation at a later stage, perhaps as a guide to our progress in becoming, or maintaining our status as, a "world-class city" – the goal set by Chief Executive Mr Tung in his recent Policy Address. However, we suggest that the urgent and fundamental problems on the environment need to be addressed as a higher priority.

2. Detailed comments on the paper

We set out below some detailed comments on the ideas in the paper as they are.

1. Section 3, definition. The definition does not seem specific enough. "Balancing" social, economic and environmental needs does not constrain policy-making sufficiently: a balance can be struck anywhere. The definition seeks to add specificity by adding that the balancing must simultaneously achieve "a vibrant economy, social progress and better environmental quality", but this is not very helpful: what if there are trade-offs? Which of the three goals will take priority? If there is a route to optimise all three goals, how is this route to be discovered?
   
   
2. Sustainability Unit. It is a good idea to have such a unit. However, unless it is housed in a policy branch with high-level and broad authority to address environmental issues, little effective policy-making can be expected. We recommend that the Environmental Protection Department be made independent of the Planning, Environment and Lands Branch, with which it conflicts, and made into a more powerful Environmental Branch on its own.
   
   
3. Sustainability tracking system. We note that it is not the objective of the tool to perform this function. However, we believe that it is a high priority to develop such a system.
   
   
4. Indicators.

• We do not understand the indicator "Economic return as determined through cost-benefit analysis". How can such an indicator be calculated for the economy as a whole?
• Public satisfaction with the cleanliness of Hong Kong may not be an ideal indicator since it depends on perception which may change over time. An objective measure would be preferable.
• Deaths per 100,000 population due to diseases of the respiratory system should certainly be tracked, but this is a lagging indicator, i.e. the deaths come through a considerable time after the high pollution levels that cause them. It would appear better to monitor the pollution levels themselves in order to have more timely warning.
• Total remaining landfill capacity does not appear to be an acceptable indicator: excessive use of landfills is a major problem in Hong Kong.
• Waiting time for public rental housing, while widely accepted as an indicator, may, if used in this exercise, lead to suboptimal overprovision of public housing. Analysis is needed of why the demand for public housing arises in the first place, and then track such underlying factors. Alternative solutions may be preferable to simply building more public housing.
• On leisure, we are sceptical of the value of tracking annual ticket sales as an indicator of "Leisure and Cultural Vibrancy".
• Environmental quality. In our view, this section is by far the most important and should be given as much priority as possible. The indicators are easily quantifiable and can be linked directly to health and environmental effects.

We hope these comments are helpful.

Yours sincerely,

Alan LUNG ka-lun
Chairman