Policy Statement & Submission

Our ref : ENV/WKC/042

1 February 2000
Mrs Ava S Y Ng
Deputy Director of Planning
Planning Department
North Point Government Offices
Hong Kong


Dear Mrs Ng

Comments on "Susdev21" Second Stage Consultation

Thank you for the opportunity to comment on the Susdev21 study. Following consultation among our members, particularly members of the Chamber Environment Committee, we would like to offer our brief comments as below.

1. The Chamber supports the principle of sustainable development and we are pleased to see the launch of the Susdev21 study as a major effort to put the principles into practice in Hong Kong.

· One important part of Susdev21 has been to communicate to the community the meaning and relevance of sustainable development. We believe this has been a very valuable exercise. Its effect is apparent as seen from the lively debate in the community which the Susdev21 consultation has engendered.

· Apart from the educational exercise, however, we are concerned that the Susdev21 study seems not to be delivering what it has been set out to do. All that has been achieved seems to be a computer model and a checklist of 39 indicators for use by government departments when assessing potential projects and policies. While the indicators are useful, what is more important, in our view, is the formulation of "the bigger picture", such as a comprehensive sustainable development strategy and the roadmap for getting there.

· We would emphasise the need for that "bigger picture" in that without it there may be the risk of a project simply being deemed sustainable after going through the impact assessment through the 39 indicators. Clearly, going through the indicators is but one aspect in assessing sustainability impact. The assessment exercise will be meaningful only if sustainability has been firmly established as a principle that is "given", that is, if all government departments develop their strategy and operation plans in accordance with the total strategy and roadmap for the whole territory. This requires no less than a change of mindset and culture within all government departments, which needs to be driven by that "bigger picture".

5. On the indicators themselves, many are very specific and probably too specific to be applicable for many projects. It might be better to adopt broader bands along the lines of the guiding principles and then have sub-bands or sub-categories of criteria.

6. There also seems to be some confusion as to whether the tool is to be used only for new projects (roads, reclamation, railways etc.) or for new policies as well. In the latter case the checklist will have to be much wider and more extensive, particularly in the context of the social, economic, regulatory, fiscal and political acceptability of each new policy proposal.

7. On the institutional set-up, we would like to express our support for the creation of the Council for Sustainable Development under the Chief Executive, and our interest in being involved. In this connection it would be very useful if we could have more details about the terms of references and composition of members of the Council. In our view, the representation of the Council should be as wide as manageable, and should doubtlessly include a substantial presence from the business sector.

I hope you will find the above views useful.



Yours sincerely

Dr Eden Woon
Director