Response to AQO Review Public view Collection Form
The Government has launched a three-month consultation to solicit public views on the findings of the review of Air Quality Objectives since July 2019. A website of the public consultation (https://www.aqoreview.hk) has set up for people submitting their views on or before 11 October.
Clean Air Network has studied the Public View collection form. There are some doubts about the words used in the form. It is worth to be discussed and be aware of before submitting it:
(Suggested answers are highlighted in RED from our perspective)
Problem 1: False premises
The question posted by EPD/ENB in the view collection form falsely assumes a continuous improvement of air quality in all aspects, it is just a matter of fact for you to “discover”
However the level of ozone hits 20-year high and EPD is doing nothing on the situation:
Ozone level 1998: 35 ug/m3 –> Ozone level 2019: 48 ug/m3
(Increased by 37%!)
According to the Air Quality Objectives Review Survey conducted by the Hong Kong Public Opinion Research Institute, 52% of interviewee unsatisfied or very unsatisfied with the current air quality in Hong Kong
Problem 2: Can we still waiting for 10 more years?
The WHO Air Quality Guidelines Global Updates was released in 2005. Only after 9 years in 2014 did the government tighten the HK Air Quality Objectives. Only NO2 reached WHOAQGs in 2014.
5 years later in 2019, only the AQOs for PM2.5 and SO2 is tightened slightly, not even close to WHOAQG level. No change for PM10 and ozone. How many years have the Hongkongers to wait until we can have WHOAQGs as HKAQOs?
The only way we can achieve better air is to have more stringent air quality standard. HKAQOs should be the policy driver for better air in HK
According to the Air Quality Objectives Review Survey conducted by the Hong Kong Public Opinion Research Institute, 54% of interviewee unsatisfied or very unsatisfied with the failure of tightening up HKAQOs to WHOAQGs
Problem 3: Devil in details
Answers to Question 3 is designed in a way that the government is assuming no one will object to the tightening of SO2 and PM2.5 – but they are missing important information for people to answer the question – they will relax the no. of allowable exceedances for PM2.5 up to 35 times!
People can agree with the principle to tighten AQOs for PM2.5 and SO2 yet disagree with the way and scope of tightening. But the view collection form seems to nudge in a way to discourage such opinions.
Essentially what the government suggesting in the proposal is allowing PM2.5 24-hr level can exceed proposed AQO for 35 days in a year for every single monitoring station in HK, without tightening the AQOs for PM10 and ozone!
There is no single piece of evidence reviewing the health impact of allowing prima facie breaching of AQO up to 35 days in a year.
According to the Air Quality Objectives Review Survey conducted by the Hong Kong Public Opinion Research Institute, 59% of interviewee against or very against government proposal to only tighten PM2.5 and SO2.
From the same survey, 73% of interviewee against or very against (50%) government proposal to relax allowable exceedances for PM2.5 up to 35 times
Problem 4: Underrepresentation
To conduct one more review to tighten up PM10 and ozone and not to wait until 2024. According to the Air Pollution Control Ordinance Part II Section 7A(3), AQO review must be carried out at least once every five years. That means the law does not exclude the possibility of carrying out AQO review more than once in every five years when necessary
The formation of the working group of AQO Review should be more inclusive, including patient groups, health groups, cycling groups or community groups which live near the pollution sources. Not just “stakeholders” from business sectors please.
The overriding principle of AQO review: the highest priority for public health – that means the government should set up a timetable for HKAQOs achieving WHOAQGs no later than 2030