Environmental and Conservation Policy


Since Governor Sir David (now Lord) Wilson's speech on 12 October 1988, there has been a marked increase in environmental awareness in Hong Kong. The Foundation acknowledges the steps the Government has taken to improve the environment. However much remains to be done before the pollution of our territory is reduced to an acceptable level. And environmental policy needs to be combined with a policy for conservation, which Hong Kong still lacks.

Environmental policy in Hong Kong has so far been defined almost solely in terms of the control of pollution. This is an important goal. However it is also important that we actively seek to preserve Hong Kong's natural and cultural resources, and for this a conservation policy is needed. A policy is needed for the preservation of our natural environment and of Hong Kong s unique cultural heritage: both are under threat.

This paper considers environmental and conservation policy under the following headings:

  • General principles
  • Government organisations
  • Environmental policy
  • Conservation policy
  • Global responsibilities


The following general principles should guide Hong Kong's environmental and conservation policy:

2.1 Sustainable development

The concept or sustainable development has gained worldwide acceptance, as evidenced at the recent world environmental summit at Rio, and must form the starting point for any environmental and conservation police for Hong Kong.

No territory can be self-sufficient, and therefore the concept of sustainability must be considered in a global context. For Hong Kong, with its very limited natural resources and heavy dependence on world trade, the global implications are especially relevant. A sustainable development policy for Hong Kong must consider the impact Hong Kong's development has on the consumption of resources and the environment world-wide. Hong Kong, totally dependent upon the flow of international trade and investment, has an obligation to be an environmentally responsible citizen of the world community. Some implications of this principle are discussed further under 6 below.

Sustainability also has local implications. The pressure on Hong Kong's natural environment from the demand for accomodation and industrial space is very obvious. Sustainable development means the as much of the natural environment as possible should be preserved. Hong Kong is fortunate in that much of its land area is designated as country park. The enforcement of country park regulations (see 5.1 below), would ensure sustainability of development on land. However the impact of development on the air and waters around Hong Kong needs serious attention (see 4.1 and 4.2 below).

2 2 Relation to economic development

Environmental objectives are often seen as conflicting with economic objectives, and the "price" of environmental protection is seen as a slowing of economic growth. However the Foundation does not believe that this view is necessarily correct. A sensible environmental policy pays economic dividends; there can be a happy congruence of economic and environmental goals.

In a simple sense Hong Kong draws economic benefit from its environment. Hong Kong's magnificent scenery and the unique culture of many of its older urban and rural areas, are obvious economic assets in themselves, being important attractions for the tourists who spend annually here in excess of HK$40 billion. The preservation of these environmental features will maintain help Hong Kong's comparative advantage over competitors like Singapore that have few natural attractions and have eradicated much of their traditional culture.

Yet the economic argument for environmental policy does not rest on tourism alone. To succeed economically, Hong Kong has to be, in Lord David Wilson's words, "a place where people want to go on living and working." If Hong Kong is to retain the best of its workforce, to attract former emigrants back from the superior living environment of the developed countries, to attract international investment and to play a leading role in the development of China which is itself becoming more environmentally aware; - then Hong Kong must adopt stronger environmental and conservation policies.

Our regional economic competitors are already leaving us behind on this issue. Singapore has made a major environmental effort for some years. Now the high quality of life it offers is a major part of the package with which Singapore is successfully attracting international investment. Singapore is even selling its environmental expertise to its polluted neighbours. Even Thailand is to spend more than US$7 billion on advanced sewage treatment plants over the next few years.

A further spur to Hong Kong's improving the quality of its environment is expectation in our market countries. Consumers and governments in North America, Europe and to a lesser extent Japan, increasingly demand products that are not only environmentally friendly themselves, but have been produced in an environmentally friendly manner. Astute Hong Kong manufacturers have already seen this trend and are adapting their production processes to cater to it. A sensible approach to the environmental is likely to become increasingly important to Hong Kong's economic survival.

2. 3 Government's role

The Government must play a leading role by introducing and enforcing appropriate environmental regulations. More resources will be needed. However it is also important that there is the political will to enforce existing regulations. We feel that the Environmental Protection Department lacks the will, or perhaps the support, the use the powers that it has. The fines applied are also too low to act as a deterrent.

The Government should also ensure environmentally sound practices in the Civil Service and quasi-governmental organisations. For example, the Housing Authority should give a lead to the construction sector by insisting on the use of steel forms for concrete and substitutes for tropical hardwood flooring in the its estates. We are also pleased to note that the tenderer's environmental record is now one of the criteria by which tenders for the airport projects are judged.

The present confused alignment of departmental responsibilities must be clarified, as set out in section 3 below. The Government-affilitated Productivity Council and Industrial Technology Centre can assist by promoting knowledge of pollution-reducing technology in industry.

Duties should be imposed on harmful substances such as CFCs discourage their use. However we do not recommend that tax incentives for example special allowances for environmental technology, are introduced. Such allowances complicate the tax system and tend to be abused.

2.4 Market solutions where possible

Where possible we prefer the use of market mechanisms and the private sector to improve the environment, rather than over-reliance on regulation and inspection. For example we would favour:

  • Privatisation of waste collection. In a recent experiment it was found that private sector firms collected five times as much rubbing from the habour at only twice the cost of the Marine Department. We regret the delay in privatising the collection of rubbish in the habour. We recommend the privatisation of all waste collection services; such privatisation has been carried out successfully in Britain and elsewhere.

  • Consideration to be given to levies on the import of polluting agents such as industrial solvents and CFCs that are intended for consumption in the territory and which pose a risk to health.

  • On-the-spot fines for the owners of poorly maintained vehicles, which are a major source of air pollution.

  • Charges for dumping at landfills.

2. 5 The polluter must pay

Both businesses and individuals must contribute to the cost of controlling the pollution they generate. We would support a levy on water rates to pay for the proper sewage system that Hong Kong needs. This levy should be paid not only by businesses in proportion to the pollution they cause, but also by households. We would also support the introduction of charges for dumping at Government landfills. There should be on-the-spot fines for drivers whose vehicles emit excessive exhaust. Consideration should be given to imposing levies on dangerous chemicals, where these are not banned outright.

2.6 Education

The Education Department should review the teaching of environmental principles in schools and tertiary institutions, with a view to improving environmental awareness. We acknowledge that a start has been made in this direction, but believe that the resources devoted to such programmes must be increased. The Government needs to promote environmental awareness by various means in the community generally, and must seek to cooperate with the private sector in such efforts wherever possible. We believe that that many businesses would be prepared to participate in well-managed public campaigns on the theme of environmental awareness.

2. 7 Cooperation with China

As the economic integration of Hong Kong with the Pearl River delta and Southern China progresses, it is increasingly necessary to coordinate with the Chinese authorities on environmental policy. The Hong Kong-Guangdong Environmental Protection Liaison Group must be reactivated. In the long run it is not acceptable for Hong Kong s former worst-polluting businesses merely to reestablish themselves over the border. Their effluent washes back to Hong Kong down the Pearl River while polluted air blows back over our border.

China, and Shenzhen in particular, is becoming more environmentally conscious. A survey by China's Environmental Protection Agency published in June 1992 showed that four-fifths of those questioned were concerned over the worsening pollution associated with China's industrialisation. There will be major opportunities to assist in the upgrading of China's most polluting industries over the coming years Hong Kong businessmen could take an important part in this, particularly if encouraged by a sensible environmental regime in their own territory


At present too many Government departments and Governmental organisations are involved in environmental policy, resulting in duplication of resources and conflicting aims:

  • Environment, Planning and Lands Branch
  • Agriculture and Fisheries Branch
  • Environmental Protection Department (EPD)
  • Antiquities Advisory Board
  • Country Parks Board
  • Environmental Pollution Advisory Committee (EPCOM)
  • Environmental Campaign Committee (ECC)

The Foundation has the following recommendations:

(1) To ensure that a higher priority is given to environmental issues consideration should be given to making Environment a separate branch of Government in its own right, with enlarged responsibilities an resources.

(2) No Government department has been designated responsibility for conservation. Consideration should be given to either creating a Conservation Department under the proposed new Environment Branch, or creating a new conservation section within an enlarged EPD.

(3) The Foundation is in favour of reducing the number of advisory committees. They are not so necessary in their consultative function now that the legislature includes elected members; indeed they tend to detract from the status of the legislature. ECC and EPCOM tend to divert resources and attention from the independent environmental groups and in ECC's case have done little to promote environmental causes. We therefore propose the abolition of the ECC.

(4) In approving the proposed development at Shalotong the members of the Country Parks Board demonstrated their indifference to public opinion - and indeed to the proper interpretation of the Country Parks Ordinance - and their subservience to vested interests. We recommend that the membership of the Board be reviewed with the aim of ensuring better representation of public opinion. The procedures under which the Board operates need to be radically revised to ensure proper accountability and transparency to the public.

(5) The Antiquities Advisory Board has performed reasonably well in the projects that it has undertaken. We therefore propose that it continue; in operation and a review conducted to ascertain whether its resource could usefully be expanded. However, a fully-fledged Government Conservation Department is needed to take on the large tasks of conservation policy.


The Government's present environmental policy is mainly concerned with pollution control and waste disposal. We have the following recommendations:

4.1 Air

We acknowledge that some steps have been taken over the last few years to improve the quality of our air, for example the prohibition on high sulphur fuel oil. However the air quality in many urban areas remains dangerously low, and according to Government statistics appears to be worsening. We recommend:

  • The speedy decommissioning of the incinerators in Kennedy Town and Kwai Chung;

  • The introduction of a strict regime for controlling exhaust emissions. We understand that the Government has been considering two alternatives: (l) the mandatory replacement of diesel engines by petrol engines in taxis, public light buses and vans or (2) the enforcement of proper maintenance by inspection. Both options are expensive. We recommend that diesel engines are retained as, properly maintained, these are less polluting and more efficient than petrol engines. While there must be an inspection facility, which should recover most of its costs through inspection charges, we strongly recommend the introduction of on-the-spot fines to enforce proper maintenance. Such fines could be administered by the police or by traffic wardens in a similar manner to parking tickets; the vehicle owner could submit to an inspection in cases of dispute.

  • Power stations should introduce more scrubbers to reduce polluting emissions.

  • Encouragement should be given to Hong Kong s power companies, perhaps through the schemes of control, to convert from coal to natural gas. We are pleased to note the progress one power company has made in obtaining natural gas from Hainan Island.

  • The concept of demand management of energy and other resources needs to be introduced into Government policy. Many of Hong Kong's buildings are wasteful of energy, as the developers usually sell them on completion and so have no incentive to make them more energy efficient. We recommend that consideration be given to introducing building regulations that encourage a minimum standard of energy efficiency. While such regulations would increase the capital cost of buildings marginally, there would be considerable savings in running costs.

  • Industrial emissions should be controlled through the enforcement of regulations for the reduction of such emissions.

  • Planning policy should endeavour over time to segregate industrial from residential areas.

  • The identification and elimination of hazardous asbestos needs to be given much higher priority.

4.2 Water

The key to control of water pollution is the installation of a proper sewerage system, including modern drains and sewage treatment plants. We are disappointed that the Government seems to be wavering in its resolve to implement the sewage strategy announced in 1988. With the commencement of PADS the strategy is more urgently needed. At present around half of Hong Kong’s sewage is piped into the harbour untreated. When PADS restricts water flow at the Western end the whole harbour could become like the Kai Tak nullah if nothing is done.

We recommend:

  • The speedy implementation of a comprehensive sewage strategy. We urge greater attention to the proper treatment of waste in the sewage strategy, rather than over-reliance on dispersion in the sea. To finance the strategy we would accept a levy on water rates, although we would wish the producers of large volumes of industrial waste to make the largest financial contribution.

  • More of the cost of treating chemical waste should be borne by the industries that generate such waste. We would approve of a levy on appropriate imported chemicals to help pay for the proposed Chemical Waste Treatment Plant on Tsing Yi, or alternatively, charges for waste treatment. The general taxpayer should not bear the whole burden.

  • We support the proposal in the First Review of Progress on the 1989 White Paper for existing premises within a specified distance of a new or existing foul sewer to connect discharges to it. The developers of new buildings should likewise bear the cost of connection to sewers.

  • The ban on marine dumping should be strictly enforced. We are also concerned at the effects on marine life of dredging for the PADS and Metroplan projects, and urge a study of the effects with a view to restricting dredging zones.

  • Further Water Control Zones should be speedily introduced.

  • Coordination with the PRC authorities is necessary to effectively combat pollutioon in the waters around Hong Kong.

4.3 Other waste issues

Hong Kong needs policies to encourge waste-minisation. While better waste disposal facilities are also needed, Hong Kong badly lags the developed countries in that waste minimisation receives almost no Government attention.

  • The Government must make more effort to promote recycling, e.g. by assisting with arrangements for segregating different types of rubble for easy processing.

  • New landfills are needed to deal with the increasing quantity solid waste.

  • There should be charges for the use of such landfills for example by the construction industry. This would encourage industry to reduce the quantity of waste it produces

  • More of the waste disposal function should be privatised, as per 2.3 above.

4. 5 Noise

We note measures introduced to reduce noise such as the restrictions on percussive piling and the low noise surfaces laid on certain roads. However noise in residential areas remains a problem. We recommend making the use of modern silenced piling machinery mandatory, and giving consideration to relaxing the time limits on its use. Action should also be taken against excessive industrial noise near to residential areas.


Conservation is linked to the environment. However conservation police goes further than the mere reduction of pollution; it is aimed at preserving Hong Kong's natural and cultural assets, which enhance the quality of life for those who live in or visit the territory. Our recommendations are as follows:

5.1 Country Parks

Hong Kong is fortunate in having its magnificent Country Parks. However the Shalotong episode has shown how vulnerable these parks are. We recommend:

  • Strengthening the legal protection for the parks in the Country Parks Ordinance. There needs to be a clearer statement that the Parks are to be enjoyed by the whole of the Hong Kong people in their natural unspoilt state, and that any development on Country Park land should be solely to facilitate that enjoyment, for example, by providing paths, access roads, barbecue pits, toilets or limited parking. It should be clearly stated that no part of Country Park land may be taken from the people of Hong Kong and used for private commercial purposes. While local interests have a right to be consulted on issues affecting the Parks near to them, the Parks belong to the whole people of Hong Kong, and it is not up to local interests to determine their use.

  • As described in 3 above, the Country Parks Board should be radically reformed so that it better reflects public opinion.

  • Development immediately adjacent to Country Park land should be subject to an environmental impact assessment if it is likely to spoil the public s enjoyment of the Park. This would apply particularly to land actually encircled by Country Park, as is the case with many New Territories villages such as Shalotong. 5.2 Other laud use issues

5.2 Other Lend use issues

  • The provisions of the Town Planning Ordinance should be applied as soon as possible to the New Territories. Zoning regulations should be speedily introduced to prevent the unauthorised conversion of agricultural land to container depots and light industry sites which at present blight so much of the rural New Territories.

  • There needs to be proper public consultation, such as takes place in most democracies, on major land developments, particularly where such developments affect the enjoyment of a public asset such as a Country Park. In the Shalotong episode, approval was given to a major development behind closed doors; this approach is no longer acceptable.

  • The identification of Sites of Special Scientific Interest needs be given a higher priority.

  • A proper environmental impact assessment is essential in appraising any development project. However many such assessments are performed by the developer himself, and without independent appraisal they are of little value. Where the developer is to conduct the assessment there must be an independent audit by experts either within the Government or the private sector. The concept of the environmental audit needs to be introduced.

  • Degraded areas, such as former quarries and landfills, need to be restored for example by the replanting of trees if they are not converted to some other use.

  • The listing and preservation of endangered species also needs more attention.

5. 3 Marine marks

The concept of the marine park needs to be introduced and enshrined in statute. A marine park would be an area of sea of outstanding natural or scientific interest, for example, shallows containing coral reefs or the breeding grounds of rare species of fish. Dumping in such areas should be prohibited and they should be protected from the effects of dredging.

5.4 Cultural conservation

As noted in 3(5) above, at present the Antiquities Advisory Board does limited although useful work in identifying buildings or areas of cultural and historical significance, and arranging for their gazetting and preservation as monuments. However this work is carried out in a piecemeal fashion without adequate resources or an overall policy. We recommend:

  • The establishment of a policy for the identification and preservation of historical areas and buildings. This policy should encompass not only individual buildings but also traditional areas within the urban connurbation, such as markets and areas of older housing. The duty of carrying out of this policy would be given to the proposed Conservation Department (see 3(2) above).

  • The Hong Kong Museum of History should be expanded to record and display more of Hong Kong’s unique past. Private sector donations should be encouraged for this purpose.


As a developed and wealthy territory, dependent upon trade, Hong Kong has a responsibility to abide by international agreements on the environment As set out in 2.1 above, this is important in ensuring that Hong Kong follows the path of sustainable development. Hong Kong’s record in this area is poor. We recommend giving a higher priority to participation in international measures to reduce pollution. In particular, we draw attention to the following:

  • Hong Kong’s policy of deriving its electricity entirely from burning coal makes a large contribution to global warming, and produces noxious gases that affect not only the territory’s inhabitants but those of nearby regions of China as well. As noted above, we recommend the use of natural gas in as many power stations as possible.

  • Hong Kong ranked in 1991 as the fifth largest importer of tropical logs, contributing to deforestation in tropical Asian countries. The construction industry should be encouraged to use steel forms rather than tropical hardwood. The industry should also use soft wood or other alternatives to hardwood in the flats themselves; as noted in 2.3 above the Housing Authority could give a lead on this.

  • The use of CFCs and other ozone-depleting substances should be moderated by the application of levies.

  • Hong Kong should be represented at major environmental conferences. We were disappointed that the Hong Kong Government did not attend the Second World Climate Conference at Geneva in November 1990, or the United Nations Conference on Environment and Development in June 1992 in Brazil. We urge Hong Kong government participation in future international efforts on the environment.