Setting standards for Singapore’s biodiversity conservation efforts

Academic Views / Saturday, May 13th, 2023

NIKHIL DUTT SUNDARAJ (National University of Singapore) argues that national biodiversity conservation regimes should be science-based, clearly articulated, robustly enforced, and feasible. Assessed on these criteria, Singapore’s regime shows strengths but also significant gaps.

“What we choose to do, individually and collectively, could have more of an impact on the future than ever before.” – Ivan Heng, presenting ‘Pulau Ujong’ by Alfian Sa’at

In Article 2 of the Convention on Biological Diversity (CBD)[1], biodiversity is defined as “the variability among living organisms from all sources including, inter alia, terrestrial, marine and other aquatic ecosystems and the ecological complexes of which they are part”.[2] The world’s biodiversity has been dwindling for decades, with far steeper drops in tropical areas.[3] What’s worse, progress to reduce or reverse this loss is much slower than needed. Singapore, right in the middle of the Sundaland Biodiversity Hotspot[4], is uniquely placed to lead the fightback. It’s not just the lives of animals and plants at stake, but ours too.

Reasons for slow progress are state- and context-specific.[5][6] Conservation requires consistency across national biodiversity conservation regimes. I define a “biodiversity conservation regime” as encompassing the legal and governmental bodies that help with biodiversity conservation and the tools these bodies have at their disposal to achieve it.  This consistency should take the form of certain salient qualities, in each nation’s biodiversity conservation regime, as a basic standard to adhere to. These qualities need to be broad enough to allow each country to adopt them in its own way. I set out four essential qualities, which I describe below, elucidated by examples from Singapore’s own regime.

A grey-headed fish eagle rises from Pandan River with its catch of the day in its claw. A native of  Southeast Asia, this bird made Faber Heights Park its home, but its habitat is under threat from encroaching construction. Top photo: Two kingfishers near Kent Vale. The photos on this page were contributed by economist Vinod Thomas.

Quality 1: Reliable science-driven and transparent decision making

Biodiversity decision-making should be grounded in science which has gone through a robust process of research, testing and cross-review. Additionally, transparency comes from involving stakeholders and, where possible, the wider public in this decision-making.

Singapore’s biodiversity conservation generally makes good use of reliable science in legislation and policy. To focus conservation efforts, natural areas and species are monitored routinely by Singapore’s authority on biodiversity conservation, the National Parks Board (NParks). NParks prioritises sound science and involvement of other stakeholders through a citizen science programme involving private citizens as well as nature groups.[7] We need to be science-based to build on the fundamental premise that human activity can harm the environment. Seeing as the two serve often opposing goals, this routine monitoring is essential in knowing how that harm occurs.

However, Singapore underutilises a useful tool called Environmental Impact Assessments (EIAs). EIAs help gather information using the latest science to determine how human activity (usually a large project) impacts local flora and fauna. In the Cross-Island Line’s (CIL) planning, for instance, there were two possible routes for the line: either under or around the Central Catchment Nature Reserve. The former is far more disruptive to nature but significantly cheaper. Amidst public concern, the Land Transport Authority (LTA) conducted an EIA.[8] While the route was not altered, the EIA recommended (and LTA implemented) “mitigation measures” to ensure the safety of vulnerable species within the reserve.[9] I believe that EIAs could have limited local extinctions in years past, like those of the Malayan Tiger and 46% of local butterfly species.[10] EIAs are crucial for protecting the survivors.

Singapore needs targeted legislation to comprehensively address issues highlighted by scientific research. Currently, despite international recommendation, Singapore does not have all-encompassing legislation which addresses the pressing problem of invasive species.[11][12] For instance, current legislation does not account for potential effects of invasive species such as Eurasian Rats[13] and Common Pigeons[14], both of which have greatly affected local species and thrive here. There are also numerous other invasive species in the region which could potentially reach Singapore, through maritime and airborne travel.[15]

I further suggest that Singapore codify a statutory obligation to take advice from authorities in scientific research when making policy decisions. For instance, the USA codified scientific bases on how protected species are designated in section 4 of the Endangered Species Act (ESA). Were it not for the ESA, scientists estimated that at least 227 species would have likely gone extinct. More than 100 species have seen a more than 90% recovery rate since its implementation.[16] Countries need to keep their legislation and governance in conservation efforts scientifically based to ensure efficacy. While Singapore evidently does that in practice, codification would make that obligation legal, which is critical in ensuring these best practices continue.

While Singapore is transparent on other fronts, like explaining legislative amendments on protected areas to Parliament on public record, there is more to be done. Codifying the scientific bases or criteria for a species or space to be offered higher protection in law or policy could deepen this transparency and help educate the public, as well as stakeholders of Singapore’s biodiversity conservation efforts.

A juvenile spotted owl in West Coast Park. [Photo by Vinod Thomas]

Quality 2: Clarity in language, substance and purpose

We need clarity to ensure that the roles that each public body has in conservation are clear to those playing them, and those tasked with monitoring their execution and progress.

Singapore’s regime presents a clearly defined role for NParks. Having a single agency looking after biodiversity conservation helps streamline decision-making. By contrast, jurisdictions like the United States have multiple agencies which combine to oversee various aspects of biodiversity conservation, with some un-coordination.

However, legislatively, Singapore does dual-address certain overlapping offences under multiple acts. For instance, both the Endangered Species (Import and Export) Act (ESIEA) and sections 8 and 9 of the Wildlife Act (WA) prohibit the import and export of wildlife unless permitted. This would probably require any legitimate permit-seekers, including for research/conservation purposes, to obtain dual approval. This could be streamlined through agency-level coordination or by legislative amendment.

There should also be a general lack of legislative ambiguity in laws which afford protection to species and natural habitats. In some cases, Singapore’s regime is clear in the scope of prohibited actions through catch-all provisions in legislation. For instance, S.5C of the WA clearly and unambiguously forbids catching, trapping or killing any wild species.

However, Singapore lacks legislation which explicitly offers protection to marine areas, as the PTA and WA do not appear to cover offshore commercial activity which could harm marine habitats. The Wildlife (Protected Species) Rules 2020 and WA are even more unlikely to adequately protect marine species given that most harm comes from commercial activities taking place in their habitat — not from catching, trapping or killing. Singapore needs to address these legislative gaps to offer more comprehensive biodiversity protection.

Quality 3: Robust avenues for enforcement

Any regime has to also be able to effect protection for vulnerable local natural communities and areas. The Courts and other independent bodies must be able to enforce the obligations owed by authorities in conserving biodiversity and hold actors to account by stopping or preventing harm.

In Singapore, relevant authorities can bring action against parties who commit statutory environmental offences, such as illegal dumping or trapping. For instance, under the WA, any police officer, officer of customs or authorised officer may, under s.12, arrest without warrant anyone whom in their view commits an offence under the WA. These are strict liability offences and can therefore be enforced expediently. However, the PTA does not enable NParks to enforce against harm taking place outside “natural” areas, even though flora and fauna live there too. Their powers should be expanded to cover this gap.

Singapore is less forthcoming with biodiversity (civil) lawsuits. Court cases develop law in Singapore, because higher courts’ decisions bind lower courts and therefore become law (until overruled). The USA and Ecuador have seen landmark biodiversity-positive decisions.[17] To enable biodiversity-positive litigation, Singapore should make its courts more accessible. Firstly, on principle, financial means should not bar access to justice. India’s class action suit model, as an example, allows costs to be shared equitably among multiple parties such that none of them are priced out of access to courts individually. Secondly, the rules of legal standing for bringing environmentally focused civil claims to the courts should be relaxed to allow any environmentally concerned person to do so. People must not be excluded just because they cannot causally prove personal harm. It has been proven scientifically that harm befalling nature in one jurisdiction may continue to affect biodiversity in another, and some species like pollinating insects are globally important to both man-made and natural food chains.[18] While not necessarily having a clear causal link to individuals, this harm is both wide and lasting. Getting over this hurdle would allow the courts to effectively make new law to protect biodiversity.

Looking internationally, Singapore has plenty of room to grow on this front. Laws, legal norms and policies carry far more weight if they are enforced.

Long-tailed parakeets at Goldhill Park. [Photo by Vinod Thomas]

Quality 4: Feasibility

To keep conservation measures feasible, a country needs to balance biodiversity conservation goals with competing policy aims and not overburden its resources. This balancing act acknowledges the limitations of countries which may not be in a strong position to engage in expansive biodiversity conservation without significantly hampering economic goals.

Singapore has deferred a lot to arguments of economic concerns weighed against conservation concerns. For instance, while Singapore’s low carbon tax under the Carbon Pricing Act (CPA) of $5/tCO2e will be gradually increased to $50-80/tCO2e in the next decade, the threshold for taxability remains astronomically high[19] and it is not clear whether this will change. Naturally, there might be a fear of the effect widespread carbon tax liability would have on fossil fuel, energy, transport and manufacturing industries, which are all key sectors for Singapore.[20] A more conservation-positive Singapore needs to flip this weightage.

Singapore also permits derogations from codified legal obligations if approved by the relevant authorities. On one hand, this makes it easier to square off conservation with other policy aims. On the other hand, it does leave a lot of discretion to the Executive, and they are under no obligation to give reasons for their decisions. This is especially problematic if they allow a derogation which has a potentially large impact. An example of this was when a fully forested area of Singapore’s Kranji Woodland was “erroneously” cleared by the Jurong Town Corporation (JTC). Despite this and NParks’ own investigation of the incident, it seems unlikely that any further action will be taken against the JTC, though 2 JTC officers have been charged in Court over the incident.[21] While these derogations promote efficiency, they do so at the expense of conservation efficacy and should therefore be granted sparingly.

Singapore’s nature lovers quip that the crane is now the country’s national bird. [Photo by Vinod Thomas]

Arguably, the Singapore government proceeds with caution by using less enforceable “guidelines” for conservation concerns instead of hard law where these issues arise. However, this may not adequately protect the purported beneficiaries.[22][23] To strengthen backing for conservation goals, we need to separate the scientific/ecological considerations from political (including economic) considerations. NParks could be given a statutory selection function to designate areas of “high biological importance”, like the National Heritage Board’s role in designating important heritage sites.[24] Fundamentally, economic considerations should not factor ab initio into Singapore’s conservation laws and policies. The ultimate decision makers should strike the final balancing act. Conservation focused authorities such as NParks should have the power and freedom to recommend actions without being burdened by concerns of whether their proposals are too ambitious or unfeasible.

Singapore does, however, participate actively in resource sharing for biodiversity conservation as a regional hub for citizen research and city biodiversity.[25] Being a research hub facilitates global technology transfer and exchange of ideas which helps developing countries reach their economic goals more sustainably. These policies and practices are feasible, being low in both absolute and opportunity cost, while yielding present and future benefits. I think it’s important that Singapore continue growing its information sharing and technology transfer efforts.

Conclusion: Moving forward

I believe that these four qualities represent the basic blocks which should form the foundation of a national biodiversity conservation regime. Of course, they should manifest differently in each regime, in a manner tailored to suit that jurisdiction. Singapore needs to build on the strengths of its own regime and look to improve where it falls short. While we chart our own path and hopefully lead the way, we have plenty to learn from other jurisdictions.

From local films and plays to campaigns and tours, Singaporeans are taking an ever-growing interest in our biodiversity. This heightened awareness and enthusiasm are crucial foundations for change.

NIKHIL DUTT SUNDARAJ is a Visiting Researcher at the Asia-Pacific Centre for Environmental Law, National University of Singapore, and a graduate of the University of Cambridge (class of 2020). This article is based on a working paper, “What are the Essential Qualities of a National Level Biodiversity Conservation Regime? – Lessons for Singapore and Other Countries” NUS Law Working Paper No. 2023/001, NUS Asia-Pacific Centre for Environment Law Working Paper 23/01, January 6, 2023. Available at SSRN: or

– Economist and amateur nature photographer VINOD THOMAS, who contributed the photos, is the author of Risk and Resilience in the Era of Climate Change (Palgrave Macmillan, 2023). He is currently Senior Visiting Fellow at ISEAS–Yusof Ishak Institute, having finished a six-year term at the Lee Kuan Yew School of Public Policy as Visiting Professor. He was previously Senior Vice President, Independent Evaluation, at the World Bank, and Director General of Independent Evaluation at the Asian Development Bank.


[1] 1992 Convention on Biological Diversity 1760 UNTS 79, 31 ILM 818 (1992)

[2] Latty Senior Lecturer, Tanya, and Timothy Lee Associate Lecturer in Life and Environmental Sciences. “How Many Species on Earth? Why That’s a Simple Question but Hard to Answer.” The Conversation. The Conversation, June 29, 2021.

[3] Anon. “Living Planet Report 2014.” WWF. World Wildlife Fund. Accessed August 14, 2021.

[4] Rep. 5th NATIONAL REPORT TO THE CONVENTION ON BIOLOGICAL DIVERSITY (2010-2014) 5. Vol. 5. Singapore: National Parks Board, 2015.

[5] Anon. “The United Nations Must Get Its New Biodiversity Targets Right.” Nature 578, no. 7795 (2020): 337–38.

[6] IISD Reporting Services. (2018). Summary of the UN Biodiversity Conference: 13-29 November 2018. Earth Negotiations Bulletin, 9(725).

[7] Anon. “Our National Plan for Conservation.” National Parks Board. NParks, May 28, 2019.

[8] Tan, Audrey. “Cross Island Line: Concerns about Wildlife Linger despite Plans to Reduce Impact.” The Straits Times. Singapore Press Holdings, March 15, 2021.

[9] Mahmud, Aqil Haziq. “Cross Island Line Environmental Impact on Nature Reserve Can Be ‘Adequately Managed’: LTA Study.” CNA. Mediacorp Singapore, September 2, 2019.

[10] Pavid, Katie. “Almost Half of Butterfly Species in Singapore Have Disappeared.” Natural History Museum, January 22, 2020.

[11] Chun, Joseph, and Lin Heng Lye. “Wildlife Protection.” Essay. In Environmental Law in Singapore, 696. Singapore: SAL Academy Publishing, 2019.

[12] The only piece of legislation in Singapore which can be said to indirectly address invasive species is the Pollution of the Sea (Ballast Water Management) Regulations 2017. However, the general legislative framework has not addressed it beyond this.

[13] YK, Raynold Toh. “Rats Are Back in Bukit Batok, Raising Fears of Repeat of Infestations in 2014 and 2016.” The Straits Times. Singapore Press Holdings, February 6, 2017.

[14] Co, Cindy. “Need to Understand Motivations to Counter Persistent Pigeon Feeders: NParks.” CNA. Mediacorp Singapore, April 18, 2020.

[15] Corlett, R.. (2022). Ten lessons from Singapore for the conservation of tropical biodiversity. 10.26107/NIS-2022-0068.

[16] Anon. “THE ENDANGERED SPECIES ACT: A WILD SUCCESS.” The Endangered Species Act: A wild success. Center for Biological Diversity. Accessed November 23, 2021.

[17] “’Conservation Litigation’ Tries to Put a True Price on Wildlife Crime.” Mongabay Environmental News, June 15, 2021.

[18] Rader, Romina, Ignasi Bartomeus, Lucas A. Garibaldi, Michael P. Garratt, Brad G. Howlett, Rachael Winfree, Saul A. Cunningham, et al. “Non-Bee Insects Are Important Contributors to Global Crop Pollination.” Proceedings of the National Academy of Sciences 113, no. 1 (2015): 146–51.  

[19] The tax is levied on a registered and taxable facility. This is a two-stage process under S.7 of the Act. Firstly, a facility would have to be registered, which entails reporting its emissions regularly, if its emissions cross the first threshold of 2000 tCO2e. If the second threshold is met for at least 1 year of registered operation, then the facility will have to register as a taxable facility. However, the second threshold is much higher than the first, being 25000 tCO2e.

[20] Dutt Sundaraj, Nikhil and Lin, Jolene, Singapore: Breaking Circuits and the Norm (October 1, 2021). “Integrating Climate Change Concerns into Post-COVID Recovery Packages in the European Union, United States and Asia: Reconciliation with the Needs of Industrial Development” (editors: Chien-Te Fan, Anton Ming-Zhi Gao), Kluwer Book Series: Energy and Environmental Law (Forthcoming), NUS Law Working Paper No. 2021/022, NUS Asia-Pacific Centre for Environment Law Working Paper 21/04, Available at SSRN: or

[21] Tham, Davina. “Kranji Woodland Clearance: 2 JTC Officers among 3 People Charged in Court.” CNA. Mediacorp Pte Ltd, April 22, 2022.

[22] Anon, “Sustainable Finance” (Monetary Authority of Singapore November 2, 2020) <> accessed February 10, 2021

[23] Anon, “MAS Debuts Grant Scheme to Support Green and Sustainability-Linked Loans” (CNA November 24, 2020) <> accessed February 10, 2021

[24] Chun, Joseph, and Lin Heng Lye. “Protecting and Creating Nature Sites.” Essay. In Environmental Law in Singapore, 624. Singapore: SAL Academy Publishing, 2019.

[25] Anon. “City Biodiversity Index (or Singapore Index).” Convention for Biological Diversity. Accessed May 2, 2022.