Public Consultation on Air Objectives Review

Clear The Air's Views

1. Do you agree that the existing Air Quality Objectives (AQOs) need updating?

Answer: Yes. There are many factors involved in the air quality issue, but what is very clear is that it is now time that the outcomes of this specific debate drive a change in policy to fight air pollution in a truly decisive and effective way, as well as in the shortest possible period. Since Hong Kong AQO’s were last revised in 1987, there is now a pressing need to update the objectives. As the WHO updated their air quality objective in 2006, Hong Kong should use these objectives as a guiding model to be followed in updating Hong Kong’s own. Updating the AQO to drive policy change is the only way to sustainably improve air quality. Therefore we think the government should update the AQOs now, helping the implementation of other measures on air pollution.

2. Do you agree that protection of public health should be the key consideration in updating the AQOs?

Answer: Yes. Pollutants in the air harm us in different ways. Accounting to School of Public Health of the University of Hong Kong, pollutants damage the sensitive cells in the respiratory and circulatory systems, such as the cells lining airways and arteries, causing inflammation which can spread throughout the whole body. The damages lead to short-term and long-term diseases, especially in people who are most susceptible, for instance, children and the elderly. Children have higher breathing rates than adults and so are at risk of higher exposures to pollution. In the long run, if their lung growth and development is affected, they may begin their adult lives with less lung capacity than is necessary to ensure good health and long life. Air pollution also affects pregnant women and their babies. Babies born to mothers exposed to high levels of air pollution are more likely to have health problems in the last few months of pregnancy and shortly after birth, and have a higher risk of sudden infant death syndrome (SIDS). It is no doubt that air quality affects our health directly, and let us not forget that health costs associated to air pollution is nearly HK$2 billion per year. Therefore we agree that the updating of the AQOs need to be based on the principle of protecting public health.

3. Do you agree that the AQOs should be set with reference to the guidelines and interim targets (ITs) published by the World Health Organization (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?

Answer: No. To clean up the air on the roadside and territory wide and to restore Hong Kong’s quality of life and international image, we need to have the clear and resolute objective of improving air quality now. Safeguarding public health should never be a “long term goal”. What can possibly be more important and pressing for any government than that? In order to fix a clear benchmark on which to align specific air pollution reduction objectives, Clear The Air is requesting that the Government adopts the highest AQO standards and not interim targets (ITs) published by the (WHO). The longer the people of Hong Kong have to wait, the more unnecessary deaths, health problems and other costs directly as a consequence of air pollution there will be; and that is totally at odds with the government’s, and our, stated key consideration in updating the AQO’s; namely: the protection of public health.

4. Do you agree to the proposed new AQOs which have been set with reference to a combination of WTO AQGs and Its?

Answer: We agree the proposed new AQOs should be set with reference to WTO objectives, as these have been soundly based on scientific research. However, we do not agree that the new objectives should be a combination of WTO AQGs and Its. The highest AQO standards can encourage the government to adopt concrete measures to tackle air pollution. We want to have clean air as soon as possible, and the highest AQO standards can boost the process of the policies implementation effectively.

5. Do you agree that a mechanism should be put in place to regularly review the AQOs no less than every five years?

Answer: We agree with that the government should put in place such a mechanism, but we would like to see the government go further than this and have a regular review of the AQOs every three years.

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?

Answer: We agree that the proposed emission control measures can improve air quality in Hong Kong, and they should be implemented as soon as possible. Beside the 19 measures proposed by the government, we think that some other measures can be implemented at the same time in order to tackle Hong Kong’s air pollution problem. It is also imperative that the government should define and adopt a clear time-frame to implement these measures.

7. How soon do you think these proposed emission control measures should be implemented?

Answer: Immediately wherever that is possible or at least as soon as possible.

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?

Answer: We are willing to do that. And we think that all people who care about the environment are willing to do so. But the costs need to be borne across the board. The power companies and the bus companies have to be willing to, or if not made to, bear the costs of using greener forms of fuel and energy, and in adopting green technologies. As without which we cannot improve Hong Kong’s air quality effectively.

According to the published statistics, the power companies in Hong Kong emitted 76,273.97 tons carbon dioxide per day, approximately 3,190 tons per hour. For the bus companies, 10% of the buses (around 600 buses) in Hong Kong are pre-euro diesel vehicles. They emitted 14% of the entire emission of Nitrogen oxide emitted by buses. If bus companies are willing to replace those vehicles with euro IV or euro V vehicles, it will help the environment a lot. At the same time, power companies can introduce renewable energy to generate electricity. Buses and power plants are the main sources of air pollution in Hong Kong. They have the responsibility to clean Hong Kong’s air.

9. Do you have any other views on the Review?

Answer: We think that beside the 19 items proposed by the government, some other methods can be adopted at the same time. They are:

  • mandatory retirement of old polluting diesel vehicles  (over 70,000 of them)
  • the mandatory installation of fine particulates agglomerators on our local coal power plants to cut the emissions of asthma causing RSP
  • for the marine air pollution :  the removal of duty on ULSF for all commercial ships and ferries using Hong Kong’s waters, and the adoption of Emission Control Areas for international shipping encompassing Hong Kong’s waters and as soon as possible the whole PRD
  • and the control and reduction of road traffic in the city centres as highlighted in recent European studies showing that only traffic reduction through ERP can improve air quality on the roadside, as proven now in the UK, Sweden, Germany, Italy, and in Asia: Singapore, Japan, and very soon Indonesia.

We trust that the government will consider our suggestions, and we hope that measures based on them will be adopted as soon as possible.