Globally, urban air pollution has become the leading environmental health risk. In Hong Kong, the air pollution is threatening the health of the population. With over 1,800 premature deaths caused by air pollution in one year alone (2017), and many more hospital bed days and doctor visits, air pollution is clearly a serious threat to public health causing severe damage to lungs, heart and blood vessels. The most vulnerable are the children, the elderly, patients of chronic respiratory and circulatory disease, and the socially deprived. A high quality of life is expected in an affluent city like Hong Kong, in particular, air that is safe to breathe.
It is to the benefit of all citizens of Hong Kong if the city sustains its leadership in the PRD and the wider region on the issue of clean air. Hong Kong is equipped with the knowledge and experience in controlling air pollution. With a growing focus on health and quality of life, a strong vision from the Government for clean air is a priority for the public.
What we have achieved and what is still inadequate
1) The HKSAR Government set out A Clean Air Plan for Hong Kong in 2013, which mapped out the air quality management strategy with time-bound targets, control measures, and action items until 2020, that were needed to achieve clean air.
2) As a result, over the last few years (2013-17), Hong Kong’s air quality at ambient and roadside level has improved by 30% due to the various emission control measures, including subsidy scheme to phase out diesel commercial vehicles, mandating ocean going vessel to fuel switch at berth, etc.
3) However, public health is still not adequately protected. Roadside air pollution (Nitrogen Dioxide [NO2] and Respirable Suspended Particulates [RSP or PM10]) still present major health threats in Hong Kong. The ground-level ozone is also alarming. According to Hedley Environmental Index, there were over 1,800 premature deaths and over HKD20 billion economic loss caused by air pollution, in 2017 alone.
4) Under the Environment Bureau’s projection, Hong Kong will have a steady improvement of air quality at ambient and roadside level until 2020, due to the ongoing implementation of various emission control measures.
5) There are signals that the Government should pay attention to. At roadside, the level of pollution reduction started to diminish after 2016. During 2017-18, the actual roadside pollution reduction trend was not on par with the Government’s projected trajectory.
6) Even if Hong Kong reaches the target as set out in the Clean Air Plan, by 2020, the NO2 and RSP levels will still fall short of World Health Organization’s recommended safe level by 77% and 59% respectively. This represents a strong public health threat in Hong Kong.
7) In summary, the air quality has improved in recent years. However, the improvement is not adequate to protect public health. In order to further improve the air quality, new commitment from the Government is needed. We are aware that the AQOs Review is in progress and there are over 60 policy suggestions made by the AQOs Review Working Group. It is unimaginable to see no new blueprint from the Government to clean air beyond 2020.
8) A delay in new commitment from the Government will result in further decline of public confidence in the quality of life in Hong Kong. The health impact of air pollution is a key concern for the general public, the expatriate community and multinational companies.
Based on the context, we set out below the recommendations for the 2018 Chief Executive Policy Address;
Key Recommendation 1: Government to set a timeline to clean air
9) CAN urges the Environment Bureau to provide a timetable for Hong Kong’s ambient and roadside air quality to comply with the World Health Organization (WHO)’s standard. For reference, over 30 cities, including London and Singapore, have pledged to achieve WHO Air Quality Guidelines (AQG) and halve the number of air pollution related deaths by 2030.
10) CAN urges the Environment Bureau to provide a timetable for Hong Kong’s Air Quality Objectives (AQOs) to be tightened to WHOAQG, i.e. WHO’s most stringent level. One of the positive impact would be the resolution of the loophole under Environmental Impact Assessment Ordinance (EIAO). Under EIAO, AQOs are considered when granting permits for designated projects. Currently, HKAQO is not aligned with WHOAQG. Projects failing to comply with WHOAQG safety standards, but meeting the HKAQO, are still granted permits. In other words, projects are legally allowed to emit an unsafe (i.e. not WHOAQG) level of air pollution that threatens the health and lives of individuals.
Key Recommendation 2: Upgrading commercial vehicles
11) Currently, over 90% of roadside air pollution are emitted by commercial vehicles. Emission from franchised buses is one of the most significant sources of air pollution.
12) CAN urges the Environment Bureau to show determination to reduce emission from commercial vehicles by providing time-bound final and interim targets, for Hong Kong’s franchised bus fleet to be transformed to electric (or other zero direct emission technology).
13) Since its establishment in 2009, the Steering Committee on the Promotion of Electric Vehicles, chaired by the Financial Secretary, has established the Pilot Green Transport Fund to test out green transport technologies; and the additional government subsidy to purchase 36 electric buses and related charging facilities for trial. However, the impact is minimal – up until 2017, there was less than 1% of Euro VI and electric franchised buses in operation in Hong Kong.
14) For reference, in Shenzhen, all buses were converted to electric in 2017. Political support is considered a key factor. In other cities, the political support is demonstrated by time bound policy commitment. For instance, London will set all buses to be zero-emission by 2037 and all taxis to be zero-emission by 2033.
15) Similar issues are encountered by cities in the process of transforming commercial vehicles to electric or zero emission. These issues include technology adaptation, travelling range, air conditioning, charging facilities, financial resources, etc. With the policy support from the leadership of the Government, these barriers would not be insurmountable.
Key Recommendation 3: Enhancing Low Emission Zones
16) Since 2015, the Government has set up franchised bus Low Emission Zones (LEZs) in three sections of streets in Causeway Bay, Central and Mong Kok, in which franchised bus companies are required to deploy low emission buses (i.e. buses meeting Euro IV or more stringent emission standards) to improve roadside air quality. After two years of implementation, the level of roadside air pollution including particulate matters and nitrogen dioxide at roadside within the streets had decreased.
17) There are other districts and areas in Hong Kong that face high level of roadside air pollution and high population density. The health risk due to roadside air pollution for the dense population at these areas should not be underestimated. The introduction of LEZs to these areas would further reduce the health risk on general public due to road transport pollution.
18) CAN urges the Environment Bureau to extend the LEZs to cover areas with high level of roadside air pollution and high population density, such as Sham Shui Po, Tsuen Wan, Kwun Tong, etc.
19) To improve roadside air quality, the emission standard of LEZs should be further tightened – allowing only Euro VI or Electric buses to operate; and extend the regulation to other types of commercial vehicles.
Key Recommendation 4: Publicizing data for public to better monitor effectiveness of the emission control program for LPG vehicles
20) An effective inspection and maintenance programme is a core part of a comprehensive vehicle emission control strategy. According to Environment Protection Department, catalytic converters (CATs) installed on LPG taxis or minibuses last only for about 18 months due to the high mileage of these commercial vehicles. If the CATs are not replaced after their performance start to deteriorate, emission (including nitrogen oxides, carbon monoxide and volatile organic compounds) will increase by at least ten times.
21) In 2013, the Environmental Protection Department provided a one-off subsidy replacement scheme, to support LPG vehicle owners to replace CATs. The program was completed in March 2014 (more than 18 months by now).
22) Currently, EPD uses a remote sensing program to identify high-emitting vehicles. An emission test notice would be submitted to the vehicle owners. These high-emitting vehicles must have their vehicles tested on a loaded dynometer at Designated Vehicle Emission Testing Centre. Failure to comply with the requirement will lead to cancellation of the vehicle license.
23) Given the level of roadside NOx remains at a dangerously high level, CAN urges the EPD to publicize the (i) number of emission test notice issued; and (ii) the level of NOx emitted from LPG vehicles measured by remote sensing regularly on a 6-months basis, to determine whether the current program sufficiently control emission from LPG vehicles.
Key Recommendation 5: Strengthening effort to manage transport demand to ease traffic congestion
24) There are various negative impacts on air pollution and public health due to traffic congestion. In generally, lengthened commuting journeys on the traffic road increase passengers and pedestrians exposure to roadside air pollution.
25) Over the last forty years, Hong Kong’s urban and transport development strategy has focused mainly on building large scale housing and transport infrastructure projects which conflict with the pedestrian scale.
26) The outcome is reflected in the continuous expansion of vehicular fleet. In a study report published in 2014, the Transport Advisory Committee (TAC) described Hong Kong’s vehicle fleet size has been growing at an alarming rate. According to the report, the number of vehicles increased by 30% and the average car journey speed in urban areas dropped by about 11% from 2003 to 2013.
27) The Environment Bureau has further acknowledged the problem of vehicular growth in its Climate Ready Plan in 2016, especially the private cars. ‘The annual private vehicle growth rate from 2010 to 2015 has surged to about 5% and this is clearly unsustainable by any measure in terms of land requirements, supporting infrastructure, car parking facilities, added traffic and the consequential environmental and climate impacts.’
28) The former Secretary for Transport and Housing (during 2012-2017), Prof. Anthony Cheung, has described the phenomenon where continuous expansion of vehicular fleet outpaces the growth of population and road space as an “urban epidemic” in his recent publication. To tackle traffic congestion, he concludes it is simply impossible to build more roads to catch up with the increase in vehicular demand.
29) In the report published in 2014, the TAC has also provided a range of short, medium, and long-term measures for the Government’s consideration. In 2015, the Transport and Housing Bureau responded by ‘principally agreeing with the recommendations’, and would focus on 3 areas of improvement to ease traffic congestion – enhancing public transport service to reduce reliance on private vehicles; managing use of road space; enhancing education and publicity to promote the severity of traffic congestion.
30) Since 2015, the Transport and Housing Bureau has made various effort as below – completed the Public Transport Strategic Study and adopted certain measures to enhance public transport services; has commenced but not completed the study of Electronic Road Pricing Pilot Scheme in Central District and its adjacent areas; has strengthened the enforcement against congestion related offences; has attempted but failed to increase the penalty for illegal parking.
31) Despite the various efforts, the traffic congestion problem has remained largely unresolved. The worry is that the continuous growth of vehicles and traffic congestion would further worsen air pollution at roadside and offset the improvement of air quality made by various emission control measures, as detailed earlier.
32) CAN urges the leadership of the Government to acknowledge a paradigm shift is needed to put people in a higher priority of urban and transport planning, over cars, in order to reduce unnecessary reliance on vehicular traffic.
33) CAN urges the Transport and Housing Bureau to pro-actively seek transport demand management solution to ease traffic congestion, instead of providing unlimited supply of road space for vehicular traffic.
34) To manage transport demand, specifically, CAN urges the Transport and Housing Bureau to set up a time-bound target for reducing the number and vehicle kilometers travelled by road vehicles; and strengthen the measures to discourage use of mechanized vehicles including the use of financial tools, such as increasing First Registration Tax of vehicles and implementing the Electronic Road Pricing Pilot Scheme.
Key Recommendation 6: Strengthening effort to minimize ship-induced air pollution
35) Hong Kong became the first port in Asia to regulate the emission of toxic air pollutants from ships. The Air Pollution Control (Ocean Going Vessels) (Fuel at Berth) Regulation, in effective at July 2015, requires ocean-going vessels (OGVs) to switch to clean marine fuel with sulphur content not exceeding 0.5 per cent while at berth.
36) At berthing locations, it is estimated that the measure would reduce ship-induced sulphur dioxide (SO2) and particulate (PM10) emissions by over 70 percent. It equals to a reduction by 12 percent and 6 percent of total SO2 and PM10 emission in Hong Kong respectively.
37) According to the International Maritime Office, from 1 January 2020, the limit for sulphur in fuel oil used on board ships operating outside designated emission control areas will be reduced to 0.5% m/m (mass by mass).
38) It means that, Hong Kong’s sulphur limit at berth will be leveled with the rest of the world. As the fore-runner in Asia in controlling shipping emissions, Hong Kong might consider a more aggressive benchmark in order to further minimize the negative health impacts due to shipping emissions.
39) With thousands of population reside and work close to one of the most busiest container ports and shipping routes in the world, Hong Kong should continue to tighten control of shipping emissions in order to better protect public health.
40) To maximize health gain, CAN urges the HKSAR Government to collaborate with PRD region to set up a Emission Control Area in PRD waters, including Hong Kong waters, with a limit on sulphur content in marine fuel at 0.1%.
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