- Centre for Civil Society and Governance, The University of Hong Kong, Pokfulam, Hong Kong SAR, China
Cross-jurisdictional cooperation on the management of coastal wetlands in China's Guangdong–Hong Kong–Macao Greater Bay Area (GBA) had long been limited to information exchange. This study finds that NGOs, tasked with crucial policy-entrepreneurial responsibilities, aroused new dynamics to coastal wetland conservation in the GBA's Deep Bay (also known as Shenzhen Bay). This paper provides an in-depth analysis of the implications of non-state policy entrepreneurs' positions as well as their collective policy entrepreneurial strategies in promoting cross-jurisdictional environmental cooperation. Selected studies in the literature reveal cautious and skilful ways in which Chinese NGOs conduct policy advocacy. This paper deviates from these as NGOs' attempts to influence management practices and policy are studied in the delicate transboundary context, where added complexities are expected. NGOs' success documented in this case study is highly unusual because, conventionally, culturally and/or politically in this region, cross-jurisdictional environmental management is heavily dominated by governmental actors. This paper analyses the reasons accounting for their success in triggering collaborative coastal wetland conservation. The availability of resources to the NGOs, in terms of funding from its private donations and knowledge from experts and scientists, as well as their autonomy, were important factors. This paper goes on to explain the implications of a more recognized role of non-state actors, including ECR, who have become more active in research related to wetland conservation in the GBA.
1 Introduction
Following a period of state-dominated cross-border cooperation in North America and Europe, during the twentieth century, increasing attention was paid to the importance of the non-state sector (Blatter, 2004; Scott, 1999). This coincided with a broad paradigmatic shift from “government” to “governance” in public administration that was driven by the argument that the governing of society should no longer be left to the state alone. Consequently, scholars have documented an increasing tendency for authorities in border regions to involve non-state actors when managing cross-border issues (Hooghe and Marks, 2003). This trend has been buttressed by intensified criticisms of the inadequacies of formal institutions, accompanied by the rising capacity of non-state actors to handle the complexities of cross-border issues (Dürrschmidt, 2002; Macrory and Turner, 2003; Meadowcroft, 2002).
This research builds on previous attempts to examine cross-boundary environmental management in the Greater Bay Area1 from broader institutional and political perspectives (Chan, 2002; Hills and Roberts, 2001; Hills et al., 1998; Hopkinson and Stern, 2003; Jo and White, 2013; Lee, 2002a,b; Loh, 2011; Ma and Tao, 2010; Yang, 2006; Yang and Li, 2013). Focusing on a unique case study of non-state driven cross-jurisdictional cooperation that took place between 2013 and 2016, this paper examines these actors' interactions with institutional structures and political context in depth. The role of the non-state in relation to this cross-jurisdictional issue has received more recognition since 2013 and the paper identifies the corresponding implications, namely ECRs' involvement in supporting wetland conservation in the region, some of whom have also adopted a cross-jurisdictional perspective.
This study contributes to the literature by explaining how and why non-state actors can propel cooperative efforts amid adverse institutional and political circumstances.
Section 2 offers an overview of policy entrepreneurship as a conceptual lens. This is followed by important contextual information which prepares readers for a better understanding of a concise account of the case study. The key findings will then be shared, pertaining to the characteristics of the NGOs involved, which empowered them to become transboundary policy entrepreneurs, as well as broader enabling factors. Finally, the paper draws attention to the subsequent increase, over the past 10 years, in ECR research and knowledge exchange for wetland conservation in the region.
2 Conceptual lens: policy entrepreneurship
The theory of policy entrepreneurship is adopted in this paper to provide an analytic construct to help interpret and analyse the repertoire, structure and consequences of actions taken by policy entrepreneurs (Christopoulos, 2006, p. 757–778; Guldbrandsson and Fossum, 2009, p. 434–444; Kingdon, 1984, p. 240; Roberts, 1996, p. 280). Since it was developed by John Kingdon in Agendas, Alternatives, and Public Policies (Kingdon, 1984), policy entrepreneurship has maintained its popularity amongst policy scholars. It has continued to feature, as both the anchor and a useful supplement to a variety of conceptual approaches, in abundant literature to explain different circumstances of policy change (e.g., Brouwer and Biermann, 2011; Guldbrandsson and Fossum, 2009; Hammond, 2013; Hopkins, 2016; Mintrom, 1997, 2000; Mintrom and Norman, 2009; Palmer, 2015; Roberts and King, 1991; Roberts, 1996; Zhu, 2008).
Widely understood as advocates of policy innovations, policy entrepreneurs take advantage of opportunistic moments, termed “policy windows,” to advance innovative solutions toward the government's policy agenda, thereby triggering policy change. They may operate as individuals or as an organization. While only non-state policy entrepreneurs were discovered in this case study, there is no shortage of these savvy individuals/organizations from both the public and non-state sectors in the literature. Studying non-state policy entrepreneurs in the context of the GBA is unique because in this transboundary region, environmental management within and across jurisdictions is heavily dominated by governmental actors.
The policy entrepreneurship framework facilitates a systematic delineation of the complexities of the policy processes. Making use of this framework, this paper's attention is directed to the full range of actions undertaken by these critical change agents. It also enables one to identify key contextual factors that have helped shape the outcome of actions undertaken by these actors in their pursuit of improved wetland protection through transboundary cooperation.
The positions held by policy entrepreneurs have significant implications on the constellation of opportunities and obstacles they face and the strategies they employ (Brouwer and Biermann, 2011; Huitema and Meijerink, 2010; Roberts, 1996). Scholars recognize that access to resources and the level of autonomy were the two key factors that set state and non-state policy entrepreneurs apart (Huitema and Meijerink, 2010; Roberts, 1996; Zahariadis, 2007). This paper argues that access to resources is a prerequisite for policy entrepreneurship, and autonomy is a factor that affects the entrepreneurial strategies and their outcomes. State policy entrepreneurs, in general, have access to greater resources in terms of personnel, material (technology or equipment) and financial resources than their counterpart in the non-profit sector. Non-state actors who lack access to sufficient resources will face significant difficulties when attempting to conduct policy entrepreneurial actions. In response to this, many non-state actors opt to advocate for policy change in partnership, known as collective entrepreneurship (Roberts, 1996). This allows them to gain strength and influence by pooling together scattered resources and networks.
Bound by their positions in the government, state policy entrepreneurs tend to be prevented from proposing radical policy proposals. Instead of giving up, they divide their policy proposals into incremental stages and present them to policy makers sequentially increasing the chances of ultimately achieving full adoption (Huitema and Meijerink, 2010; Roberts, 1996; Zahariadis, 2007). Free from similar confines, non-state policy entrepreneurs have a greater tendency to propose more innovative or revolutionary policy ideas.
In addition to the differences in resources accessibility, a further prerequisite sets state and non-state policy entrepreneurs apart in the context of the GBA region: the presence of corresponding actors on the other side of the border—counterpart(s). Not only do state policy entrepreneurs in the region possess greater material, personnel and financial resources, their official status usually grants them access to their direct counterpart across the border (Chu, 2017; Lee and Chu, 2017). This means that hypothetically, state policy entrepreneurs at least have the means to contact their mainland counterparts and persuade them to support their proposals. Contrarily, a generally underdeveloped civil society on the mainland, especially over a decade ago, has caused collective entrepreneurship between non-state actors across the border to be impracticable on many policy issues.
Governmental actors with the capacity to operate in a transboundary setting, i.e., with a presence in regional working groups and/or regular inter-jurisdictional meetings, have a low tendency in advocating more transformative cooperation measures. Given the political and institutional structures governing cross-jurisdictional interactions in the GBA, they tend to propose more incremental joint initiatives on well-established issues such as air pollution through conventional means, i.e., with their immediate counterparts on the equivalent political and administrative rank.
Section 4 delves into the ways in which the interactions between contextual factors and characteristics of relevant NGOs in this case study shape the trajectories and strategies of the policy entrepreneurs' pursuit and the influence it may have on spurring subsequent interest shown by ECRs to conduct relevant research in the region.
3 Materials and methods
3.1 Case study background: Guangdong-Hong Kong-Macao Greater Bay Area (GBA)
The socioeconomic status varies across the Guangdong-Hong Kong-Macao GBA. In Guangdong Province, manufacturing remains dominant (accounting for 40% of GDP), while the service sector accounts for over 90% of the GPD in the Hong Kong Special Administrative Region of the People's Republic of China (HKSAR) and the Macao Special Administrative Region of the People's Republic of China respectively (Liu et al., 2024). The Basic Law gives legal effect to the “One country, Two systems” framework, which means that the HKSAR has a legal system that is different from that of the Chinese Mainland. Effective environmental management across the region has been hampered by different priorities by the various governments, as well as a lack of unified ecological targets, institutional gaps, and cumbersome cross-border coordination (Liu et al., 2024).
Decline in the GBA's marine ecological conditions was recorded between 2003 and 2013 indicated by sea area pollution, coastal shrinkage, decline of marine biodiversity and weakened marine disaster resilience was recorded between 2003 and 2013 (Gao et al., 2022). Similar studies supported that urban sprawl had caused the most significant decrease in ecological function in this period (Wu et al., 2021). As a first-tier megacity, Shenzhen's economic development has been the most advance amongst various cities in the mainland, high population influx as well as economic activity led to it contributing to the highest discharge of industrial wastewater and domestic sewage in Guangdong Province (Gao et al., 2022). Efforts to rectify the damages caused began after the Central Government's introduction of the concept of ecological civilization in 2007 (Wu et al., 2021). Due to varying efforts made by the local governments in Guangdong province, improvements in ecological resource protection began to take effect from 2010 to 2018 (Gao et al., 2022; Wu et al., 2021).
This case study zooms into the Deep Bay/Shenzhen Bay wetlands in the GBA which is at the intersection of Hong Kong and Shenzhen. Despite international recognition of the civil society's role in cross-border environmental management (Alves et al., 2019; Downie, 2022), there is limited room for them in formal or informal environmental cooperation platforms in the GBA (Liu et al., 2024). It was therefore surprising to find NGOs spear-heading transboundary cooperation in wetland conservation in this paper's case study.
3.2 The Deep Bay/Shenzhen Bay wetlands
The boundary separating the HKSAR from the adjacent Shenzhen Municipality of the Chinese Mainland intersects Deep Bay (also known as “Shenzhen Bay”) and its surrounding wetlands. Situated at the mouth of the Pearl River Delta, the Deep Bay wetlands is the sixth largest mangrove forest in China and it is located in Shenzhen Municipality which is a part of Guangdong Province (Tam, 2006).
Ecologically, mangrove areas have expanded in both the Hong Kong and Shenzhen reserves from 1973 to 2015, with greater integration and restoration success in the Hong Kong reserve, while restoration in the Shenzhen reserve relied on mono-species and exotic replanting, posing risks to biodiversity and ecosystem sustainability (Jia et al., 2016). At present, the surface area of the Futian Nature Reserve located in Shenzhen is 368 hectares, and the Mai Po nature reserve located in Hong Kong is 378 hectares. Although the numbers are similar, mangrove cover in Futian is significantly less than Mai Po, and the former's landscape fragmentation is higher (Li et al., 2017; Morton, 2016). In addition, the shape of the Futian reserve and its proximity to dense urban development severely compromises the habitat quality for birds (Li et al., 2013; Ren et al., 2011; Figure 1). Both Mai Po and Futian are threatened by water pollution in Deep Bay, caused by untreated or partially treated domestic, livestock and industrial waste water mostly originating from Mainland China (Tam, 2006; Zhang et al., 2012).
Figure 1. Map of Deep Bay region with the locations of the Futian National Nature Reserve and the Mai Po Nature Reserve.
Different political systems and development goals created substantial obstacles for Hong Kong and Shenzhen authorities to cooperate on wetland conservation. Shenzhen was the first city to be declared as a Special Economic Zone in the early 1980s as a part of the country's economic reforms to attract foreign investment. The economic zone, by its nature, developed at an extremely rapid pace in the 1980s and 1990s. One of the most significant developments that effectively dissected this piece of wetland was the establishment of the Shenzhen Futian Free Trade Zone in 1991. The Free Trade Zone was strategically built on a section of the wetland which was adjacent to Hong Kong, and which was connected to the Mai Po wetland in Hong Kong. Along with other developments, up to 147.2 hectares of the Futian Nature Reserve, making up 48% of the total area of the reserve, was sacrificed accumulatively over the two decades of rapid development (Li and Chen, 2007). Almost its entire coastline is now made up of reclaimed land, except for a sliver that is the Guangdong Futian Mangrove Nature Reserve.
The wetlands within Hong Kong SAR has been protected as a Ramsar2 site, called Mai Po since 1995, while the Futian nature reserve was listed as a Ramsar site in 2022. This is despite China having been a treaty member of the Ramsar convention since 1992 and multiple attempts made, since 1994, by the Chinese Ministry of Forestry to recommend the Shenzhen municipal government to apply for Futian to be listed as a Ramsar Site.
The two nature reserves have been managed as though they were two isolated pieces of habitat with completely different approaches to conservation and management practices. In Shenzhen, the Futian Reserve Management Bureau manages the daily affairs of the Futian reserve, and the Shenzhen Urban Management Bureau oversees its work and is responsible for the policy dimension of the reserve's management (Table 1). Across the boundary, WWF HK has been actively managing the Mai Po reserve while the Hong Kong Agriculture, Fisheries and Conservation Department (herein referred to as the “Hong Kong Agricultural Department”) controls access to and administers the legal aspects of the reserve (Table 1). Since the Hong Kong Agricultural Department is a technical department, the responsibility of making decisions on major policy change such as coordination with the mainland rests on the HK Environment Bureau.
In general, the management of transboundary environmental problems in this region has been restricted to formal intergovernmental platforms. Such platforms focus on pre-determined issues such as the protection of air quality, marine water and drinking water quality, causing issues of lower policy priority, such as ecological conservation to be neglected.
3.3 Methodology
A case study approach was adopted and the analytic technique of explanation building was selected. This involves a type of pattern matching procedure with the goal of generating an explanation about the case study in question (Yin, xbib2009). In asking a “how” question, I am seeking to explain the phenomenon being studied by clarifying the causal links between all the key parameters. This involves an iterative process, as explanation building is not a linear process, where I continue to return to previous explanations built through earlier stages of data analyses, and refine them as new evidence is being collected. Primary and secondary data collected were organized with the aim of formulating a chain of events in the development of the case study. This method is particularly useful for understanding complex and real-world situations, and is found to be highly effective for analyzing this case study due to the complex mix of external factors and intricate interactions between different organizations.
Documentary evidence was analyzed and triangulated with observation data and interview data. Sixteen informants were interviewed, which included individuals working in the Shenzhen Urban Management Bureau, Futian Reserve Management Bureau, Hong Kong Agricultural Department, Forestry Department of the Guangdong provincial government, WWF HK, MCF and other active non-state actors on the issue. The data collection period took place between September 2015 and March 2016. A full list of the interviewees and the dates of the interviews can be found in the Appendix.
A summarized account of the case study is divided into two key phases, marked by the establishment of the Shenzhen-based NGO, MCF, to highlight the changes in cooperation dynamics before and after its efforts.
3.4 The case study: Part I—Pre-2013 limited technical exchanges between managers of the wetlands
Since the late 1980s, cross-jurisdictional cooperation on wetland conservation in Deep Bay had predominantly lingered at the level of limited information exchange. WWF HK and the Futian Reserve Management Bureau began knowledge exchange in around the mid-1980s after the Futian Nature Reserve was established. Prior to 2013, there was an absence of NGOs in Shenzhen for any inter-NGO collaboration across the boundary.
Meetings were held sporadically between the Futian Reserve Management Bureau and WWF HK to facilitate WWF HK's annual waterbird survey at both reserves (A current expert and a former expert at WWF HK). An expert from WWF HK and a retired official from the Futian Reserve Management Bureau explained that neither WWF HK nor the Futian Reserve Management Bureau attempted to propose cooperative measures beyond the water bird survey. The responsibility of the Futian Reserve Management Bureau mainly involves law enforcement against activities such as illegal fishing and hunting of birds (An expert from WWF HK and a retired official from the Futian Reserve Management Bureau). WWF HK, on the other hand, had been actively managing the fishponds in Mai Po since 1984. Hence, the scopes of the management responsibilities undertaken by WWF HK and the Futian Reserve Management Bureau were very different.
Interactions between the Futian Reserve Management Bureau and the Hong Kong Agricultural Department, earlier in this phase, was limited to occasional visits to one another's nature reserves. A retired official from the Hong Kong Agricultural Department expressed that they had no particular intention for cooperation, because the protection of wetlands depends heavily on a jurisdiction's laws and regulations, and Hong Kong has its own set of laws and regulations to protect Mai Po. Although the two government departments' exchanges became more regularized since 2010, their collaboration or relationship did not appear to have strengthened nor changed with much significance over the years.
Cooperating with Futian in managing the Deep Bay wetlands has never appeared on WWF HK's agenda as they knew the slim chance of a non-Mainland-based NGO (WWF China was not active in Southern China at this stage) to engage in cooperation with an official authority across the border. Neither was the Futian Reserve Management Bureau able to engage in such cooperative measures with WWF HK or Hong Kong Agricultural Department without the support of the SZ Urban Management Bureau, which was lacking due to its priority of economic development.
3.5 The case study: Part II-−2013–2016: the debut of NGO policy entrepreneurs in Transboundary Wetland Conservation
The deadlock described in the previous section finally eased when the Shenzhen Mangrove Wetlands Conservation Foundation (MCF) was established. MCF formed a strategic partnership with the Hong Kong office of the WWF which eventually made it possible for WWF HK to cooperate, indirectly, with the Shenzhen management bureau in managing their nature reserve. Toward the end of 2015, WWF HK and WWF China (which had just started to establish a presence in the area) facilitated the first ever inter-bureau discussion between the SAR and Shenzhen. MCF worked with WWF HK to organize a Symposium on Shenzhen Hong Kong Coastal Wetland Protection in January 2016.
Founded in 2012 by a group of successful entrepreneurs, MCF had a significant financial advantage over other local NGOs. Its president and one of the founders, Wang Shi, is also the founder and chairman of China Vanke, China's largest real estate enterprise. Wang and other South China-based entrepreneurs became concerned about the destruction of Shenzhen's coastal wetlands, and decided to establish MCF with funding from Society of Entrepreneurs and Ecology (SEE3; two million RMB) and 26 Southern China-based entrepreneurs in the name of the individuals or their companies (200,000 RMB each; a representative from MCF).
MCF was founded with the goal of eventually being able to manage the Futian Nature Reserve, although this was a huge ambition, as it was highly unusual for the Chinese government to allow an NGO to manage a national nature reserve (a representative from MCF, a representative from the Shenzhen Bird Watching Society and a senior official of the Futian reserve management bureau). Between 2012 and 2014, MCF worked on public education while building and strengthening its relationships with WWF HK, the Futian Reserve Management Bureau and the SZ Urban Management Bureau.
Since 2013, MCF and the Futian Reserve Management Bureau began lobbying the SZ Urban Management Bureau to allow MCF to conduct experiments with the Futian Reserve Management Bureau at their nature reserve (a representative from MCF and a senior official of the Futian reserve management bureau). As part of the lobbying activities, MCF arranged, with the help of WWF HK, for the SZ Urban Management Bureau to visit Mai Po, presenting it as a role model of an NGO managing a nature reserve of international importance. Eventually, in 2015, the SZ Urban Management Bureau and MCF signed the Futian Mangrove Protection Cooperation Framework Agreement (2015–2020).
“With the help of WWF HK's expertise, [MCF] would discuss and derive plans with the Futian Reserve Management Bureau to experiment management practices from Mai Po in a part of the Futian Nature Reserve.” (A representative from MCF)
Under the supervision of the Futian Reserve Management Bureau, MCF and WWF HK began implementing active management practices, which include managing the water levels of two of the fishponds and modifying the vegetation surrounding the ponds in the experimental zone of the Futian Nature Reserve.
In order to secure technical support for their work in Futian Nature Reserve and the Futian Mangrove Ecological Park, MCF signed an agreement with WWF China (on behalf of WWF HK) in 2015, pursuant to which WWF HK would offer its expertise and knowledge in wetland management. The general aim of this agreement, titled the “Shenzhen Bay ecological protection cooperation framework agreement,” was to strengthen the ecological protection of Deep Bay and facilitate Shenzhen-Hong Kong cooperation in this aspect (MCF 2015 - 12 - 28). WWF HK supported MCF in its cooperation with the Futian Nature Reserve Management Bureau effectively transferring management practices from Mai Po to Futian. MCF offered monetary rewards to WWF HK as compensation for experts from WWF HK to work with MCF (A representative from MCF).
As MCF demonstrated its capacity in implementing innovative management measures at the Futian reserve, supported by its partnership with WWF HK, the Futian district government saw their potential and agreed to trial a new management approach in its newly established mangrove park (restored wetland that was previously destroyed to build a golf course). In December 2015, Futian district government officially opened the Futian Mangrove Ecological Park (Figure 2) and authorized MCF to manage the park.
Under the cooperation framework agreement between MCF and WWF HK, the NGOs agreed to hold a Shenzhen—Hong Kong Coastal Wetland Conservation Symposium on a regular basis (Representatives from WWF HK and MCF). The first one was held in Shenzhen in January 2016 featuring presentations or speeches from the Futian district government, the Futian Reserve Management Bureau, the Hong Kong Agricultural Department, WWF HK, MCF and various experts and researchers. A representative from WWF HK explained that the aim of the symposium was not to discuss strategic cooperation, such as the idea of the cross-boundary national park, which requires the input of the HK Environment Bureau. The symposium lacked the input of the strategic decision-making departments from either side of the border: the SZ Urban Management Bureau4 and the HK Environment Bureau. The second symposium was held in Hong Kong in February 2017 and the focus was on monitoring and conserving biodiversity, which coincided with the absence of officials from Shenzhen and the HK Environment Bureau.
Intergovernmental platforms on wetland management in Deep Bay have been severely inadequate. While the SZ Urban Management Bureau and the HK Environment Bureau are the relevant decision-making bureaux in this region, they are absent from the current intergovernmental platform on wetland conservation (Figure 3). The only Hong Kong-Shenzhen intergovernmental platform which exists is between the Hong Kong Agricultural Department and the Futian Reserve Management Bureau.
Figure 3. Cross-jurisdictional communication channels between key players in the management of wetland habitat in Deep Bay prior to December 2015 (the double-ended arrows refer to the existence of communication channels).
At the end of 2015, the SZ Urban Management Bureau wanted to discuss the possibility of establishing a cross-boundary national park in Deep Bay with the HK Environment Bureau. The SZ Bureau chose not to set up this new communication channel with an SAR bureau through the Hong Kong Macao Affairs Office, which was the official procedure. Instead, the SZ Bureau asked WWF China to convey their wish to the HK Environment Bureau, through WWF HK, suggesting that it had some degree of trust in WWF China and WWF HK to reach out to the HK Bureau on their behalf. The two bureaux had their first meeting in Shenzhen in December 2015. Conducted in two sessions, the first involved MCF, WWF HK and WWF China, where the idea of the cross-boundary national park was introduced, and the second was a closed-door discussion between the bureaux.
Short of the Central government's direction on cooperation in Deep Bay, the materialization of a cross-boundary national park is dependent upon the municipal government's own motivation, which remains low as of 2016 (Senior officials at the Futian reserve management bureau and the Forestry department of Guangdong Province). According to a senior official at the SZ Urban Management Bureau, there were mixed voices in the municipal government and it was very difficult for the idea to progress any further, as there were still plans to continue developing the Bay area. Across the boundary, an intermediate official at the Hong Kong Agricultural Department admitted that the government has significant reservations about the proposal due to the associated political sensitivity and said that they were “intentionally hold[ing] back.”
4 Key findings
4.1 Non-state policy entrepreneurship in a transboundary setting
This study identifies the emergence of the Shenzhen-based non-state organization as pivotal to the breakthrough in the cross-boundary cooperation documented in this case study. In the past and in other environmental issues, non-state collective entrepreneurship has not materialized due to a lack of experienced and financially equipped NGOs present on both sides of the boundary. With the presence of the resourceful MCF, change agents in the civil society of Shenzhen and Hong Kong were able to conduct collective entrepreneurship, triggering newfound enthusiasm and cooperation on wetland conservation. Once the prerequisites were fulfilled, the advantages NGOs have over state actors in facilitating and pursuing transboundary cooperation became apparent. Their immunity from political or official considerations grants them the autonomy and flexibility that arguably makes them more fitting facilitators of inter-sectoral and inter-jurisdictional collaboration than state actors.
4.2 Resource mobilization
Conventionally, state actors in the GBA are equipped with more resources to advocate and pursue cooperative initiatives compared with the civil society. However, because wetland conservation remained under-prioritized as a transboundary policy issue, little time and resources have been allocated by the responsible departments to engage in any substantial cooperation. In contrast, MCF was established with a clear aim to address this issue specifically, and WWF HK possessed the relevant experience and expertise. Therefore, on this particular issue, the non-state actors, collectively, possessed more resources (in terms of financial resources, scientific and practical knowledge) than governmental actors.
Collective entrepreneurship is an important strategy that enables non-state actors such as NGOs to be effective policy entrepreneurs (Roberts, 1996). Non-state policy entrepreneurs operating in a cross-jurisdictional setting made the sensible and tactical move to engage in collective entrepreneurship. This study argues that it is, in fact, even more important for non-state policy entrepreneurs working on cross-border issues to exercise collective entrepreneurship across jurisdictional boundaries. This is due to three key reasons. First of all, working with NGOs in a neighboring jurisdiction helps one to extend their network and gain knowledge on their local environmental management practices and policies. Secondly, NGOs may find it difficult to justify investing their resources outside of the local jurisdiction. Thirdly, in the GBA context, even if WWF HK was willing to sponsor work outside of its local jurisdiction, it would not have been able to work directly with the Futian Reserve Management Bureau. Identified as a non-local organization, it is considered politically sensitive for the Chinese authority to engage in any substantial collaboration with it beyond basic information exchange.
A strategy integral to collective policy entrepreneurship is the formation of partnerships that help organizations address their weaknesses and/or benefit all participating organizations. MCF's key assets include abundant financial resources (enabling them to secure necessary management expertise and scientific support, implement active management practices in the nature reserve and the ecological park), and acquaintance with the local government (the scale of MCF's founders' businesses suggests that they have at least amicable relationships and some form of trust with the local government). Through affiliating with WWF HK, MCF gains the crucial knowledge and expertise in wetland management to pursue their goals. In return, MCF offers WWF HK financial compensation. As a non-local NGO, WWF HK could not transfer its wetland management practices to Futian without MCF. The partnership enabled WWF HK to better protect Mai Po as the wetlands share the same ecosystem.
4.3 Autonomy
A key persisting obstacle to effective transboundary cooperation in the GBA has been rooted in the limits of existing cross-jurisdictional platforms. Recognizing the necessity of a multiplicity of cross-border institutions for effective cross-border environmental governance (Blatter, 2001; Meadowcroft, 2002), this study is pleased to discover that non-state actors, including ECRs, empowered by their inherent characteristics of autonomy and informality, have attempted to contribute to the diversification of transboundary platforms. What is surprising is that the benefits of their autonomous nature even extended to enabling them to act as middlemen for inter-governmental exchanges across jurisdictions. This section discusses the origins of their autonomy and its implications on the roles played by NGOs including creating cross-jurisdictional platforms for ECR to present their work and conduct knowledge exchange with other researchers, NGOs and government officials.
An NGO's autonomy, to a significant extent, stems from its diverse funding sources (Van der Heijden, 1987; Wu, 2003). Some NGOs run into the risk of reinforcing social inequality when they attempt to establish coastal ecosystem management programmes in areas where there is limited government funding support, as they resort to relying on funding from local elites, as demonstrated by case studies in Bangladesh (Khan et al., 2022). Having diverse funding sources prevents NGOs from becoming overwhelmingly accountable to the interests of one or two funders, and being directed by their funders' goals. Young NGOs tend to fall prey to this problem as they have yet to establish sufficiently diverse sources of funding. Compared with WWF HK (established in 1981), MCF is a novice in the non-profit sector. However, it is relatively autonomous because it is privately funded by its founders and their entrepreneur peers. Given this privilege, they were able to set wetland conservation as their focus when salience was low.
4.4 Informal diplomacy
A second determinant of an NGO's autonomy is its capacity, which refers to its “[abilities] to implement projects, [derive] innovative solutions for problems, and influence policy outcomes independently” (Wu, 2003, p. 42). This can be developed through accumulating experience, and learning from local or international non-governmental communities. As demonstrated in this case study, MCF strategically established a partnership with WWF HK in order to enhance its capacities in terms of practical and scientific knowledge on wetland management. It was based on this partnership, that they were granted the opportunities to work in the Futian nature reserve and later become the manager of the new ecological park in Shenzhen.
NGOs' flexibility has been found in previous studies to be beneficial in facilitating greater participation and improved environmental governance (e.g., Borges-Méndez, 2008). Their roles in facilitating or even leading coastal habitat restoration programmes, working closely with local communities, with or without the input of local governments have been heavily documented in different review studies (e.g., Khan et al., 2022; Sam et al., 2023). In the context of this case study, their autonomous nature is especially important for their operation in the GBA and for them to assume their roles as policy entrepreneurs. It allows them to partake in policy entrepreneurial activities that would be too sensitive for actors with state identities, such as interacting with non-local NGOs (Thiers, 2009). Unlike mainland governmental actors, MCF has the freedom to sign a partnership agreement with WWF HK.
“There is no protocol that we need to follow in the way that government departments do, and there is not a fixed corresponding department that restricts who we communicate with. [MCF] simply contacted all the relevant stakeholders at the same time and we started interacting with all of them since the beginning.” (A representative of MCF)
Their ability to build networks with local governmental actors, local and non-local non-state actors puts Chinese NGOs in a position to act as middlemen.
An example of one of their collaborative policy entrepreneurial strategies is that MCF organized a Symposium on Shenzhen Hong Kong Coastal Wetland Protection in January 2016 in Shenzhen in collaboration with WWF HK. The Symposium brought together the state and non-state actors within their networks, creating an informal platform for cross-sectoral and cross-jurisdictional exchanges on the issue. It was organized again by the two NGOs under the name of Symposium on Deep Bay Wetland Conservation in February 2017 in Hong Kong. Again, it included opportunities for a number of ECR to present their research between the formats of scheduled and poster presentations.
In this boundary region, complex political and institutional factors create difficulties for official communication channels to be established between government departments. Acknowledging NGOs' autonomous nature, a Shenzhen department sought their help to facilitate inter-governmental communication with Hong Kong. In its attempt to set up a first meeting with the HK Environment Bureau, the SZ Urban Management Bureau opted for a seemingly circuitous route, reaching them through WWF China and then WWF Hong Kong„ instead of the official process. NGOs could help government departments bypass rigid protocols, and open up a new intergovernmental channel of communication.
Although the independent status of NGOs brings them autonomy, at times, it is accompanied by a certain degree of skepticism from the government. While the SZ Urban Management Bureau had built a level of trust with WWF China and WWF HK to relay their messages to the HK Environment Bureau in the process leading up to their first meeting (an expert at WWF HK), the NGOs were excluded from the discussion. This is not unusual as inter-governmental meetings between Hong Kong and mainland China delegates are usually only attended by officials.
This case study has demonstrated that independence from sensitive inter-governmental relations and administrative protocols puts non-state organizations at an advantage in facilitating cross-boundary and cross-sectoral networks. Table 2 provides a summary of the roles of the two NGOs, their resources and strategies. However, the uniqueness of MCF needs to be emphasized amidst enabling contextual factors contributing to the breakthrough documented in the case study.
4.5 Enabling contextual factors for transboundary non-state policy entrepreneurship
It is recognized that non-state policy entrepreneurs' achievements were significantly expedited by changing contextual factors, namely the attitude of the central government toward civil society organizations and ecological conservation. The policy direction of the central government is vital to local governments' motivation and approaches toward respective policy issues.
In the late 2000s, the Chinese government began to recognize the benefits of the procurement of public services from civil society organizations (Tuan et al., 2015). Eventually in the early 2010s, the national authorities decided to relax its stringent non-profit organization registration requirements. This resulted in a sudden and considerable rise in the number of civil society organizations established in China. Among this surge of budding bodies was MCF.
Noting changes in the central government's attitude, the Shenzhen municipal government also began fostering the growth of civil society organization (Tuan et al., 2015). The support of the Shenzhen municipal government is a prerequisite for the Futian district government to procure the services of MCF in managing the Futian ecological park. Although MCF is not funded by the municipal government, the fact that it was founded by locally bred business tycoons is expected to have helped MCF gain the government's trust.
An equally important facilitating contextual factor relates to the central government's emphasis on “ecological civilization” since the late 2000s. This was believed to have motivated leaders of the Shenzhen municipal government to place wetland conservation on its policy agenda (A senior official at the Guangdong Forestry Department). Increasing awareness of the problems of ecological degradation has apparently led national leaders to look for officials “who can do a good job and will be made a role model for officials in other Chinese cities” (A retired official from the Futian Reserve Management Bureau). This means that some officials might see their achievements in remedying the environmental degradation as a potential ticket to higher political ranks.
4.6 NGOs' and ECRs' contribution to wetland conservation in GBA since 2016
Two trends can be observed among greater attention being paid to wetland conservation by the Central Government and Hong Kong civil society (due to the SAR's Northern Metropolis Development). (i) More ECRs have adopted a regional perspective when studying wetland changes to better inform conservation efforts. (ii) ECRs and NGOs have made more substantial efforts to conduct research and highlight the importance of conserving wetlands in GBA which has been supported by increased resource availability.
While the paper focuses on NGOs and their policy entrepreneurial efforts, it is necessary to recognize that ECRs have simultaneously contributed to wetland conservation in the region by examining habitat loss (Xie and Ng, 2013; Choi and Ng, 2017) and the impact of land reclamation on the health of the mudflats (Yang and Chui, 2017) while treating the transboundary region as one watershed. Their research design and findings help to inspire more ECRs to adopt this regional perspective (such as Gao et al., 2022; Sung et al., 2021; Wu et al., 2021), accumulating further evidence to demonstrate the importance of understanding conservation needs and adopting conservation measures in accordance with natural boundaries instead of jurisdictional boundaries.
As the issue receives a higher priority in the Central government's policy agenda, respective policies have been updated in Guangdong,5 and the Hong Kong government and Shenzhen government also signed a framework arrangement for the conservation of Shenzhen Bay (Deep Bay) wetlands in January 2023 which establishes the Mai Po Inner Deep Bay Ramsar Site and the Guangdong Futian Mangrove Wetlands6 as sister wetlands. Meanwhile, more funding has also become available to support ECR and NGO to conduct research and knowledge exchange on wetland conservation in the region.
The availability of research funding as well as cross-boundary platforms for researchers and practitioners are both important to facilitating knowledge exchange and to enhance management practices for coastal habitat conservation. Unfortunately, such opportunities and support for exchanges are not always available. This was illustrated by Khan et al. (2022) in Bangladesh and, more generally, by Moore and Kumble (2024) who reviewed 55 studies covering 20 countries where fewer than 10% documented community-based coastal wetland conservation or restoration efforts that involved researchers or scientists.
Fortunately, in this case the Shenzhen Municipal Government hosted the first International “High-level Forum on Mangrove Conservation” (hereinafter referred to as “the Forum”) in July 2023, attended by representatives from 29 countries and relevant international organizations, which was considered the first of its kind in China. At the Forum, the International Mangrove Conservation Fund, which was jointly initiated by MCF and Shenzhen-based Ping An Group, was officially launched to support international cooperation, scientific research and mangrove restoration. Most recently, HSBC supported WWF HK and Shenzhen One Planet Foundation to conduct research on nature-based solutions in the GBA where coastal wetland conservation and restoration features heavily (WWF HK, 2024).
To enrich our understanding of this recently emerging crop of policy entrepreneurs, future research efforts should be dedicated to identifying and analyzing other cases of non-state policy entrepreneurship in promoting cross-boundary cooperation in the GBA region. Such research would enable us to gain a deeper understanding of the factors leading to, and conditions favoring, a fertile ground for non-state entrepreneurship in this transboundary context.
5 Conclusion
This study is centered on a case of non-state policy entrepreneurs' success in initiating the first wave of transboundary cooperation in the conservation of the Deep Bay wetlands. Building on studies comparing state and non-state policy entrepreneurs and research on state policy entrepreneurs operating in this boundary region, this paper finds that in order to conduct effective policy entrepreneurial actions in cross-jurisdictional regions, an actor (or organization) must possess the necessary resources and/or access to such resources and capacity through corresponding with actors/organizations in both jurisdictions. Usually with limited resources and legitimacy, non-state policy entrepreneurs have a greater tendency to work collectively than state policy entrepreneurs.
While, in general, state actors have more resources and authority in managing environmental issues than NGOs, we discovered a different phenomenon when examining this case on wetland conservation in the GBA. NGOs consolidated their resources through collective entrepreneurship, enhancing their capacities and amplifying their voices to advance the agenda of collaborative coastal wetland conservation. The lessons learned from this case study suggests that under certain conditions, non-state actors can be more capable candidates to perform policy entrepreneurship across jurisdictions. These conditions include where inter-governmental relationships are tense, or at least sensitive, and cooperation is complicated by administrative protocols.
While Kingdon's multiple streams framework was originally developed to understand the agenda-setting stage of the policy-making process, this study corresponds with (Howlett et al.'s, 2015) and Mintrom (1997) approach to extend the application of this framework to understand other stages of the policy process. The concept of policy entrepreneurship, extracted from the multiple streams framework, has offered substantial explanations for how changes to wetland governance and management in the case study region have arrived on the policy agendas of the Shenzhen government. Subsequent to placing such items on the policy agenda, the non-state policy entrepreneurs have continued to play important roles in the formulation and implementation of cooperative measures, such as continuing to support wetland management practices transferred across the boundary. Hence, the policy entrepreneurship framework can be applied to offer explanations for different stages of the policy process that go beyond the agenda-setting phase in environmental cooperation of other border regions.
In the presence of a rapidly developing non-state sector in Southern China, environmentalists hoped that more NGOs would gain the capacity to steer and implement regional environmental initiatives. However, the institutional environment for non-state actors, whether they are considered to be foreign or domestic, is immensely complex and ever-changing. For example, the Overseas NGO Law, effective since January 2017, has been argued to cause a shrinking or closing of space for NGO activities (Holbig and Lang, 2021).
Although this case study documents pro-active NGO involvement, there is limited public participation, contrasting with conservation approaches which emphasize collaborative networks of mangrove conservation areas to foster community-driven stewardship (Sam et al., 2023). The absence of grassroots engagement highlights a critical gap in aligning with Liu and Ma (2024) and Sam et al.'s (2023) calls to diversify stakeholder collaborations as Moore and Kumble's (2024) global review argues for the tremendous potential for community-based approaches to safeguard biodiversity and contribute to the recovery of important ecosystem functions. In this case study, where NGOs and governments have dominated coastal wetland management, retroactive strategies—such as public awareness campaigns or volunteer programs—can help to bridge institutional efforts with community initiatives, ensuring sustainable outcomes that mirror the inclusive, adaptive approaches advocated for mangrove ecosystems. This points to the need for further research to inform policies and government-NGO collaboration that can facilitate such community initiatives.
Nonetheless, coastal wetland conservation has received greater government attention in the past few years, which corresponds to an increase in the availability of support for research and knowledge exchange for ECRs. This paper finds that ECRs have increasingly adopted a regional perspective, contributing to knowledge on the impact of land use changes on wetland and marine environments from a cross-jurisdictional perspective. Additional research aimed at documenting and analyzing the shifts in research efforts and thematic patterns related to mangrove management in this region—such as the study by Agduma et al. (2024) in the Philippines—could offer valuable insights. Such efforts may also help identify correlations with contextual factors, thereby guiding future research in the area.
Data availability statement
The raw data supporting the conclusions of this article will be made available by the authors, without undue reservation.
Ethics statement
The studies involving humans were approved by the University of Hong Kong Human Research Ethics Committee (HREC). The studies were conducted in accordance with the local legislation and institutional requirements. The participants provided their written informed consent to participate in this study.
Author contributions
VC: Conceptualization, Data curation, Formal analysis, Investigation, Methodology, Resources, Software, Validation, Visualization, Writing – original draft, Writing – review & editing.
Funding
The author(s) declared that financial support was not received for this work and/or its publication.
Conflict of interest
The author(s) declared that this work was conducted in the absence of any commercial or financial relationships that could be construed as a potential conflict of interest.
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Supplementary material
The Supplementary Material for this article can be found online at: https://www.frontiersin.org/articles/10.3389/focsu.2025.1575438/full#supplementary-material
Footnotes
1. ^The GBA region consists of nine municipalities in Guangdong Province that make up the Pearl River Delta (PRD) region, plus China's two Special Administrative Regions (SARs): Hong Kong and Macao. These two SARs were returned to Chinese sovereignty in 1997 and 1999 respectively, and are separated from the nine municipalities by an administrative boundary.
2. ^The Ramsar Convention is an intergovernmental treaty that provides the framework for national action and international cooperation for the conservation, as well as the wise use of wetlands and their resources.
3. ^SEE is a China-based environmental organisation that was co-founded by eighty entrepreneurs in 2004 to protect the ecological environment of the country.
4. ^Although the Director of the Urban Park and Forestry Office of the SZ Urban Management Bureau attended the symposium, she explained to MCF that she would not participate in the sharing sessions because she had only been in her current position for 5 months (A representative from MCF).
5. ^The Guangdong Wetland Protection Regulations was recently revised and the Guangdong Wetland Protection Plan (2023-2035) was recently published to strengthen wetland ecosystem restoration.
6. ^It finally became listed as a Ramsar site in 2022.
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Keywords: policy entrepreneurship, non-state, cross-sector collaboration, environmental governance, wetland conservation
Citation: Chu VHY (2026) Non-state actors in transboundary coastal environmental cooperation: a case study from Southern China's Greater Bay Area. Front. Ocean Sustain. 3:1575438. doi: 10.3389/focsu.2025.1575438
Received: 12 February 2025; Revised: 10 November 2025; Accepted: 24 December 2025;
Published: 23 January 2026.
Edited by:
Ashley Deevesh Hemraj, Aarhus University, DenmarkReviewed by:
Roberto Alonso González-Lezcano, CEU San Pablo University, SpainFederica Montesanto, Aarhus University, Denmark
Copyright © 2026 Chu. This is an open-access article distributed under the terms of the Creative Commons Attribution License (CC BY). The use, distribution or reproduction in other forums is permitted, provided the original author(s) and the copyright owner(s) are credited and that the original publication in this journal is cited, in accordance with accepted academic practice. No use, distribution or reproduction is permitted which does not comply with these terms.
*Correspondence: Vivian H. Y. Chu, dml2aWFuaHlAaGt1Lmhr