Environmental assessments in Hong Kong force decision makers to consider impact of their rulings
Ecological considerations are an integral component of an environmental impact assessment, especially if the proposed development is located in or near places of high ecological value
Geoff Carey is a director of AEC, an independent ecological consultancy based in Hong Kong. He talks about the ecological assessments needed to get planning permission for building projects.
When is a development project subject to an environmental impact assessment (EIA) in order to obtain planning permission?
The Environmental Impact Assessment Ordinance was enacted in 1998 to avoid, minimise and contain the adverse impact of development on the environment. In theory, any development project or proposal that may have an adverse impact on the environment is subject to EIA. Schedule 2 under Appendix 1 of the ordinance specifies designated project types, from public works to specific residential developments, that require environmental permits. Schedule 3 requires that engineering feasibility studies of large-scale development/redevelopment projects include EIA reports in their planning proposals. Not all EIAs must include an ecological study. If the proposed development site is in an urban area, such as Mong Kok, in most cases no ecological study is required, or at least not within the EIA scope.
What is an ecological consultant’s role in an EIA? How do you measure the ecological impact of a proposed development? What advice do you usually have for the project proposer or developer?
In a broader sense, the purpose of an EIA is to ensure that decision makers account for environmental values, and consider the environmental impact, including ecological, in their decisions, and find ways to avoid, minimise or compensate for such impact. Ecological considerations are an integral component of EIA, especially if the proposed development is located in or near places of high ecological value. Maintenance of biodiversity and ecosystem functions is often required as a strategic consideration for conservation reasons, it is also likely to result in recreational and lifestyle benefits to the community. Our role is to help integrate ecological considerations into business strategies and project developments. This ensures minimal environmental degradation but not at the cost of compromising overall project objectives or budget considerations. When we carry out an EIA we would first think about how to minimise the ecological impact. We would ask if it is possible to avoid or minimise impact by redesigning the development? We consider all of these in the early stages of the project. As we carry out surveys, we obtain more information that allows us to make more comprehensive assessments. All developments have a bottom line to consider, for instance what is feasible in terms of costs, design, functionality and other constraints. And if it’s a government project, can the adjusted development still meet the public needs? So there is a bottom line we have to take into account. Once we get to the bottom line, and if ecological impacts are still predicted, we would advise them what is the minimum they should do to reduce residual impacts to acceptable levels, and the minimum they can do. After coming up with ways to avoid or minimise the ecological impact, we would also think about compensation. Ideally, we would like to see ecological benefit in the form of enhanced value, but this is not a requirement; I think biodiversity and Hong Kong would benefit if some ecological benefit was a requirement for certain kinds of development. I think it is the same process when it comes to development planning.
Why are EIA reports rarely rejected by the government?
Some green groups question why an EIA is rarely rejected by the EPD once it has been formally submitted. The process of writing an EIA report involves making sure what is proposed is going to be acceptable under the terms of the Ordinance. The ultimate goal is to get an EIA accepted by the government, including proposals to develop the project in a sustainable way. Submitting a substandard EIA that is rejected would be a waste of everybody’s time. Our responsibility is to explore ways to protect the existing ecological value while at the same time facilitating development, where both are possible.