Early Stages

Problem: "Insufficient public consultation during the EIA process." Solution: "Government to be more open at an early stage and discuss with concerned groups those projects which may have adverse impacts on the environment." NGO employee

Problem: "Lead consultants, usually engineers and architects, see EIA as a palliative measure at best and a hoop to be jumped through at a stage in the development process where plans are close to finalisation. This problem is exacerbated by the Hong Kong planning system where planning applications are not required for developments conforming to zoning plans." Solution: "Ideally introduce planning application requirements more widely, if not universally. Architects and engineers will only take EIA seriously if they are forced to. Introduction of planning controls early in the process (e.g. through lease conditions) provides an early opportunity for the introduction of EIA before the development form is too far advanced." Ecological scientist/former Consultant

Problem: "Alternative sites/plans are seldom presented." Solution: "Alternatives should be considered at the planning stage." Ecological scientist

Problem: "Lack of guidance from EPD/AFD on whether an Ecological Assessment is needed." Solution: "Be more specific in the Technical Memorandum." Consultant/Ecological scientist

Problem: Ecological Assessment usually low in priority, low-budgeted and not given enough time in an EIA. Solution: Government regulation, perhaps? Consultant/Ecological scientist

  EIA Preparation

Problem: "Because of competition with other companies, consultancies will be forced to carry out EIA at the lowest possible cost, which may jeopardise the amount of useful data collected and its accuracy." Solution: "For projects in environmentally sensitive areas, the methodology for the EIA may need to be peer-reviewed to ensure that the EIA will be able to accurately predict the environmental effects of the project." Ecological scientist Problem: "Some consultants carry out work outside their field of expertise." Solution: "Consultants should self-regulate. Perhaps Government should produce a register listing consultants and their professional training/ expertise and experience (both positive and negative)." NGO employee Problem: "Little effort is normally given to the good presentation of surveys and findings of ecological scientists. Government officials therefore spend a lot more time to digest the information submitted." Solution: "Presentation such as habitat maps indicating the sensitivities of different habitats or different species would be useful." Government employee/ Ecological scientist

Problem: "Misuse of statistics by some consultants to give misleading conclusions on data." Solution: "Adopt standard statistical measures -alternative measures only take up more Government time! " Government employee Problem: "A tree survey approach is usually adopted by some terrestrial ecologists, hence arriving at conclusions like 'only common species of not particularly large size...' . Ecological attributes like woodland structure, microclimate, representativeness, species diversity, rarity, isolation etc. are seldom mentioned." Solution: "Incorporation of these ecological attributes into the survey." Government employee/ Ecological scientist Problem: "Discrepancies between identifications of species, and between conclusions on impacts. " Solution: "Let specialist sub-consultants write the conclusions on ecology." NGO employee

Problem: "Consultants are often constrained by time and money not to do a good job." Solution: "When drawing up proposals, consultants should take into account seasonal occurrence of wildlife and the need to employ local specialists." Ecological scientist Problem: "Failure to consult specialist amateurs." Solution: "Draw up a list of individuals / organisations with specialist knowledge." NGO employee Problem: "Tendency to dismiss impacts if no rare or endangered species." Solution: "Technical Memorandum may help prioritise the importance of sites." NGO employee

  EIA Review

Problem: "Inadequate manpower/ expertise to review ElAs." Solution: "Employ more staff. Utilise informal channels better (e.g. with universities, NGOs.)" NGO employee Problem: "Inadequate quality control over important ElAs." Solution: "For projects which may cause adverse effects in ecologically sensitive areas, the results and conclusions of the EIA should be subject to peer review." NGO employee Problem: "...Where is the quality control?? As a scientist I have to qualify and justify and show my theories to be true - or probable - and published papers (which are the only way to present data that can be confidently quoted) have to be reviewed. Although ACE has its share of ecologists, there is little provision for inviting guests who may be knowledgeable in the field and indeed may even be impartial. (Note ACE at one time allowed this then quickly disallowed it again although 'developers' are allowed to bring in their 'specialists'!)" Solution: "ElAs should be subjected to peer review." Ecological scientist/ NGO representative Problem: "The reviewing process sometimes misses important ecological issues." Solution: "Consult experts in NGOs, universities etc. whenever appropriate. Validation in the field should be undertaken more often." Ecological scientist Problem: "Not enough staff with ecological expertise - absolutely ridiculous comments from Government (AFD) on some ElAs." Solution: "Hire more staff who have a background in ecological impact assessments. TRAIN staff in the EIA process." Consultant Problem: "...Additionally, reports often arrive the day before the ACE meeting, allowing no time to investigate the facts, and are also in the form of executive summaries which contain such statements as 'analysts shows...'(usually ...there are no detrimental impacts)." Solution: "Supporting documents should be available well in advance and brought on the day. If the developer does not fulfil requirements (i.e. getting EIA submitted in time) then developmental decisions just shouldn't be considered." Ecological scientist/NGO representative

Problem: "Is ACE capable of vetting/ passing comment on specific ecological sampling designs/ assessments?" Solution: "Should there be a specialist panel?" Ecological scientist Problem: "Lack of background data." Solution: "Maybe the Biodiversity Survey will help? But when, and how much information would be available?" Consultant/Ecological scientist Problem: "There seems to be a double standard in treating Government projects and private projects. " Solution: "A standard well-defined guideline should be adopted for reviewing ElAs." Ecological scientist Problem: "Too many consultants treat ecology as a necessary evil which hinders the approval of their projects, and shirk on the ecological work." Solution: "Tighter controls from Government and ACE on shoddy ecological work." Consultant Problem: "Projects are considered on a case to case basis. Cumulative effects are often ignored." Solution: "Cumulative effects be made an integral part of the EIA statement."

  General Comments

Problem: "Lack of explicit ecological standards." Solution: "Research into threshold levels (e.g. toxic effects on aquatic life)." Problem: "[The ecologist is] usually a part-time consultant from academia. We need field ecologists covering flora and fauna, as well as experienced ecological scientists to review, report and make recommendations. They can't be only ONE person." Solution: "The scale of Ecological Assessment work should be specified by Government so that undertaking EA is a must for certain projects. Then the market will be able to absorb more professional ecological scientists." Problem: "No adequate consideration of mitigation measures for projects which may cause adverse environmental effects." Solution: "Standard quantifiable mitigation guidelines should be produced in cases where there would be adverse environmental effects due to a particular project." NGO employee Problem: "Environmental consultancies are businesses and as such, they need to make money to survive and expand. Therefore, they will infrequently recommend that a project not be given the go-ahead because they will have queered their pitch with the client, who will never employ them again. At most, the consultancy will recommend that the project be given the go-ahead as long as a number of strict mitigation measures are enforced." Solution: "Consultants to be made independent of the group initiating the project, so they are not under pressure to necessarily approve the project." NGO employee

Problem: "EIA standards as interpreted by EPD appear to be geared primarily to dictating standards for putative residents of new developments. In particular, noise standards severely restrict development opportunities even in an urban context and are frankly unrealistic compared with the levels that most of us cope with! Overall the existing Ordinance is too narrow and pays insufficient regard to impact on the natural environment and visual impact. Tree preservation is seen as a different (aesthetic) issue, hence conservation of such important habitats as shrublands, orchards, bamboo clumps etc. is covered by neither EPD nor AFD." Solution: "Caveat emptor! Pay more attention to protecting the environment rather than the interests of future residents who can choose not to buy. Extend the range of the Ordinance to cover impact on habitats." Ecological scientist / former Consultant Problem: "There seems to be inadequate check on mitigation measures and monitoring." Solution: "A more active approach should be taken." Ecological scientist Problem: "lnadequate appreciation of ecology by other Government departments." Solution: "Government circular or in-house training." NGO employee

  Follow-up

Problem: "...mitigation (the current real purpose of ElAs): who the hell follows that through!!?? The developers certainly don't seem to. Case study - the lovely luminescent (contaminated) pink dolphins. Though ACE (sub) initially did not allow the development, WITH addition of substantial mitigation the AFRF (Aviation Fuel Receiving Facility) was situated in the Marine Park of Sha Chau. That little 'cost effective' clause just sneaked on in there though and thus the most practicable mitigation promise, to reduce underwater noise levels by 90% by placing a Bubble ‘curtain’ around the offending seabed construction, only actually operated once. This neat little trick involves deploying a plastic pipe, with lots of little holes along its length, on the sea bed, then pumping air through, it thus creating a 'curtain' of bubbles which reflects sound back into the construction area. Ingenious Watson - but apparently too expensive AND this only admitted when undercover agents voluntarily spied on the proceedings and noted only one occasion out of the many weeks of construction that the curtains were actually deployed. Even air is becoming too expensive in Hong Kong. Without the spy there would have been no report so who does the buck stop at? And what if the developers don't actually carry the mitigation measures through? Doesn't this then also make ElAs as a means of mitigation farcical?" Solution: "If mitigation measures are to be incorporated then there must be monitoring and feedback to ACE and/or the regulatory body." Ecological scientist / NGO representative

  Role of Academia

Problem: "A lot of gaps are still present in our knowledge of Hong Kong ecology." Solution: "More research in this field should be carried out." Ecological scientist Problem: "Little information about habitat management, mitigation measures, and survey methods in this region." Solution: "More applied research should be carried out especially in terrestrial components." Ecological scientist

Problem: "WHY ARE SO FEW PEOPLE STUDYING SOMETHING WHICH ANSWERS 'BIG' QUESTIONS? Major gripe -too few people in the universities etc. are aiming their research in a direction which will help decision-makers." Solution: "Supervisors: Pure research is great but applied research is vital - don't forget this when taking on students. Students: Do something useful!" Consultant Problem: "Difficult to put Hong Kong in the regional perspective due to lack of data." Solution: "Should collaborate more with Chinese researchers, and should not confine research projects within Hong Kong." Ecological scientist Problem: "Researchers are often bad at communicating results of surveys/ research to the general public/Government/NGOs, so that valuable data lies in a dusty thesis, rather than being used in the EIA process." Solution: "Greater use by researchers of relevant publications read by the ecological/ conservation community, e.g. Porcupine! (here's a plug for you!), to present interim/final results of their work." NGO employee Problem: "University researchers! academics are often under pressure to produce papers for publication in order to 'get ahead', rather than conduct research/surveys for urgently needed applied conservation purposes. " Solution: "Government/ researchers/ NGOs to think ahead and identify topics which may become environmental issues in the future and which may need ElAs. Scientists can then collect baseline information on these topics before they become an issue and an EIA required." NGO employee

  Role of NGOs

Problem: "Not sufficient time and staff to adequately review ElAs." Solution: "Gizzus some money to employ more people! " NGO employee Problem: "Quite often there is very little interest in potential impacts of development projects by the general public." Solution: "More publicity work should be carried out to inform NGO members, the media and the general public." Ecological scientist Problem: "Sometimes NGOs seem to compete with each other or have conflicting views." Solution: "Better communication would be useful. Joint actions are a valuable asset in fighting development projects." Ecological scientist

Problem: "Tendency to criticise AFD for inadequacies in system." Solution: "Establish better working relations by greater contact. Address inadequacies through Technical Memorandum and research." NGO employee Problem: "Band-wagons unite! III-informed statements to the press etc. only serve to lower the credibility of NGOs. They have a valuable role to play and could improve on this." Solution: "NGOs have a responsibility to be well-informed and should remember this. If in doubt - ask people who know!" Consultant

P.26-29