Response to Air Quality Objectives Review Public Consultation

 In Environment

Air Policy Group
Environmental Protection Department
33/F., Revenue Tower
5 Gloucester Road
Wan Chai, Hong Kong


Dear Sir/Madam,


Response to Air Quality Objectives Review Public Consultation


We are writing with our response to the above public consultation. Our completed Questionnaire is attached.


Overall, we welcome the consultation paper, which is long overdue. We are generally in agreement with the thrust of its recommendations, and hope that these will be vigorously pursued.


The quality of Hong Kong’s air is for much of the year poor or very poor. This affects the health quality of life and ultimately the longevity of its citizens. Poor air and low visibility deter businesses and people from coming to Hong Kong, thus affecting people’s livelihood as well. Hong Kong’s current air quality is incompatible with the aspiration of becoming a sophisticated knowledge economy. Improving Hong Kong’s air quality should be a very high priority for the government. The proposals of the consultation paper to update Hong Kong’s air quality standards and bring them more into line with WHO standards are therefore welcome, and in fact overdue.


The analysis in the paper is somewhat misleading, however. The substantial reduction in Hong Kong’s emissions is welcome, and government’s efforts in this direction are appreciated. However, the reduction is at least partly attributable to the migration of industry out of Hong Kong to the Mainland, with which government policy had little to do. It is also misleading to present Hong Kong’s pollution incoming from the PRD as wholly exogenous. In fact, much of this pollution is generated by factories operated by Hong Kong owners, and channels are available to encourage and support these owners in converting their factories to more environmentally-friendly modes of operation (particularly in terms of power-generation). We are aware that Hong Kong-based organizations have been working in this direction for some years.


The impact of Mainland-originating pollution on Hong Kong can be alleviated by facilitating good air flow and better location/design of building clusters. The ‘wall’ effect of many recent developments has exacerbated the problem by trapping incoming smog, as has the location of Tung Chung town at the base of a mountain. While it may be too late to alleviate existing problems of this nature, more attention should be focused on facilitating air flow in future town and building design.


Contrary to what the paper says, Hong Kong is not a city like other cities. It has the most densely-populated urban concentrations on earth and, while to a certain extent relieved by sea breezes also has mountains that trap pollutants. Given such conditions, and given our wealth and aspirations, Hong Kong should not be a late follower of standards established elsewhere but should be leading the way in reducing experienced pollution to the extent possible.


Some examples of more vigorous but appropriate steps that do not receive enough attention in the paper (or in some cases any attention) are as follows.


  • Migration of all private cars to LPG (or electric or hybrid) over a period of years (like the successful migration of taxis earlier in the decade);
  • Migration of all light buses, buses and lorries to the highest Euro standards within a set timetable;
  • Electronic charging for vehicles in congested areas;
  • Ban on engine idling, at least in congested areas;
  • Development of more rail transport to replace present bias toward roads;
  • Mandatory energy-efficiency standards for new buildings;
  • Encouragement for retro-fitting older buildings to more energy-efficient mode.


We acknowledge that improving air quality will entail costs and life-style changes. However, we find the paper’s presentation of the issue too hesitant and weak. Firstly, the problem is very serious and worsening, and has accumulating long term consequences for the health and well-being of our society. Political commitment and leadership are needed to convince the community that the problem can and will be addressed. Secondly, we do not agree that the public needs to pay for the improvements dollar for dollar and item-by-item. Since reductions in pollution have a large public goods element, it is not appropriate to expect particular individuals or groups to shoulder the entire cost. There is room for substantial government support to facilitate the process of change – the more so since government has very substantial reserves which are far beyond what is needed for other foreseeable purposes. The government should welcome the opportunity to use a portion – and it will be a relatively small proportion – of these immense reserves on such a worthwhile goal.


As for the standards themselves, further consideration is needed of their implication and use. We acknowledge that action to bring experienced pollution levels down will take time – although we believe many measures should be expedited beyond what is envisaged in the paper – and that therefore ‘mandatory’ standards cannot be raised too quickly. However, the effect on health, visibility, etc, of the actual experienced pollution on a particular day remains the same, no matter what the standard on that day might be. There may therefore be a case for a two-tier system – a lower ‘mandatory’ standard, breach of which would result in definite action or sanction of some kind, and a higher ‘true’ or ‘best’ standard for health reference, for example, a level beyond which residents are advised to stay indoors. Further consideration of this is needed.


We hope that our above comments are helpful. We reiterate our hope that the Government will take the issue of air quality seriously, and vigorously pursue means to improve it.



Yours sincerely,
Alan Lung Ka Lun (龍家麟)
Chairman, Hong Kong Democratic Foundation (香港民主促進會主席)
9 November 2009



Public Consultation on Air Quality Objectives Review




問題(1): 你認為現行空氣質素指標需要更新嗎?
Q (1) : Do you agree that the existing Air Quality Objectives(AQOs) need updating?


問題(2): 你認為更新空氣質素指標時,應否以保護公眾健康為主要考慮因素?
Q (2) : Do you agree that protection of public health should be the key consideration in updating the AQOs?


問題(3): 你認為空氣質素指標應否參考世衛頒布的指引和中期目標制訂?你是否認同為了達致世衛的空氣質素指引這個長遠目標,應採納分期策略以更新空氣質素指標?
Q (3) : Do you agree that the AQOs should be set with reference to the guidelines and interim targets (ITs) published by the World Health Organisation (WHO) and that a staged approach be adopted to update the AQOs with a view to achieving the WHO Air Quality Guidelines (AQGs) as a long-term goal?
Yes, but full achievement of the AQGs should be achieved as soon as possible, not as a long term goal.


問題(4): 你認同參考世衛的空氣質素指引及中期目標所制訂的建議的新空氣質素指標嗎?
Q (4) : Do you agree to the proposed new AQOs which have been set with reference to a combination of WHO AQGs and ITs?
Yes, but see answer to Q3 above: there should be a timetable to full achievement, and it should not be too long.


問題(5): 你認為應否設立機制以定期檢討空氣質素指標,最少每五年檢討一次?
Q (5) : Do you agree that a mechanism should be put in place to regularly review the AQOs no less than every five years?


問題(6): 請問你在多大程度上認同應實施所建議的排放管制措施,以達致新空氣質素指標及改善本港整體空氣質素?你認為政府還應考慮哪些其他措施?
Q (6) : To what extent do you agree that the proposed emission control measures should be implemented for achieving the new AQOs and improving local air quality in general? What other measures do you think the Government should consider?
Generally, they should be implemented. Other measures to consider include ban on engine idling, improvement of the rail network, mandatory replacement/upgrading of old-engined vehicles on a tighter timetable, controls on ‘wall developments’.


問題(7): 你認為有關建議的排放管制措施應最快何時實施?
Q (7): How soon do you think these proposed emission control measures should be implemented?
Generally, as soon as possible. However, the implications of each need to be studied. An implementation strategy is needed.


問題(8): 你是否願意負擔實施建議排放管制措施引起的費用,例如多付一點電費、巴士車費及改變你的生活習慣?
Q (8): Are you willing to bear the costs arising from the implementation of the proposed emission control measures, such as higher electricity tariff and bus fares, as well as adjustments in your way of living?
In principle, yes. However, there is no need for the public to pay extra since the Government has enormous reserves – i.e. the public has already paid the government once for future benefits such as this; they should not be asked to pay again.


問題(9): 你對空氣質素指標檢討有其他意見嗎?
Q (9): Do you have any other views on the Review?
Air quality should be a high priority for the government, and needs political commitment to realise.





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