Comment on the Report entitled "Relative Significance of Local vs Regional Sources: Hong Kong's Air Pollution"
• The Government is determined to combat the air pollution problem and has placed air quality improvement on top of our agenda.
• The Report entitled "Relative Significance of Local vs Regional Sources: Hong Kong's Air Pollution" ("the Report") noted that, in terms of mass concentration, regional sources from the Pearl River Delta Economic Zone account for approximately 60% of the pollution level in the HKSAR in annual average terms but that this percentage would rise to 70% in wintertime.
• Such finding is consistent with the findings of the Study of Air Quality in the Pearl River Delta Region published by the Environmental Protection Department (EPD) in 2002. The findings of the Report is also consistent with EPD's monitoring data which indicates that air pollution levels were much higher in winter than the summer time. For example, there were a total of 55 days in January and only 9 days in June with roadside air pollution index exceeding 100 between 1999 and 2006. The average concentrations of RSP measured by the general stations for the same period were 71 microgrammes per cubic metre in January and only 31 microgrammes per cubic metre in June. Therefore, to effectively reduce the high air pollution days, we must also work in collaboration with Guangdong to reduce the regional emissions.
• We will continue to explore practicable and effective measures to improve our air quality. We will also work closely with the Guangdong to effectively reduce emissions from the regional sources.
• The Report has called for action to target at emission sources including power generation, land transportation and marine transportation. These recommendations are consistent with the comprehensive package of measures adopted by the Government to reduce air pollutant emissions from local sources. This package of measures have yield concrete results. The total amount of nitrogen oxides (NOx), respirable suspended particulates (RSP) and volatile organic compounds (VOC) generated in Hong Kong in 2005 were reduced by 15%, 36% and 26% respectively compared to 1997. Only sulphur dioxide (SO2) has seen an increase in the last few years owing to the increase in emissions from power plants. We have imposed emission caps on power companies since 2005 and will progressively tighten the caps.
• We welcome any researches and studies which will help further our understanding of the challenges and solutions for improving air quality.
Specific Comments on the Recommendations of the Report *
[Standards Influence Regulation of Emissions: We appreciate that the HKSAR Government has already launched an 18-month review but immediate adoption of the WHO guidelines would galvanize a comprehensive plan to reverse the public health crisis Hong Kong faces today.]
• As clearly pointed out by the World Health Organisation (WHO) that the actual air quality standards set in each country will vary according to country-specific approaches in balancing the risks to health, technological feasibility, and other socio-economic considerations. WHO thus advises that individual governments should consider their own local circumstances carefully before adopting the WHO guidelines directly as legal standards.
• In light of WHO's new air quality guidelines published in October 2006, the Government will commission a comprehensive study on Hong Kong's AQOs, to be followed by public engagement. We will formulate comprehensive, progressive and practicable targets as well as an air quality management strategy for the medium and long term, with a view to tightening air quality control. Meanwhile, the Government will continue to implement measures to control our local emissions and work with the Guangdong government to improve regional air quality.
[Energy Efficiency: To achieve energy efficiency gains, the HKSAR government will need to take a range of actions including recalibrating the Schemes of Control to reward efficiency.]
• The Government has been taking proactive measures in promoting energy conservation and energy efficiency, both within and outside Government by -
(a) having reduced the Government's energy consumption by 5.6% between 2003/04 to 2005/06. This is equivalent to an electricity saving of about 120 GWh and a reduction of carbon dioxide emission of about 84,000 tonnes. The Government has further pledged that all Government office buildings should achieve a 1.5% reduction in electricity consumption starting from January 2006. Based on preliminary data, the electricity consumption of major Government office buildings has reduced by 3.2% in January to August 2006, compared to the same period in 2005;
(b) amending internal regulations to require bureaux and departments to take into account environmental considerations when procuring goods and services, and setting "green" specifications for procurement and public works contracts;
(c) promoting energy conservation in the community by introducing new legislation for a mandatory energy-efficiency labelling scheme to help consumers to choose energy-efficient household appliances, and urging the private sector to set office temperature at 25.5oC;
(d) setting the target of meeting 1-2% of Hong Kong's electricity supply by renewable energy by 2012 despite Hong Kong's geographical constraints (e.g., scarcity of flat land with steady wind). The two power companies have committed to setting up pilot commercial-scale wind turbines. Hongkong Electric Company's wind turbine is now up and running on Lamma Island. We further propose to provide the highest rate of return for renewable energy infrastructure in the post-2008 Scheme of Control; and
(e) launching the Action Blue Sky Campaign in July 2006 to mobilise the public as well as the business sector to take action at both the personal and corporate level to help improve air quality. The Government has set an example by signing the Clean Air Charter drawn up by the business sector.
[Lowering Emissions from Power Generation: Once the power plants in Hong Kong have been retrofitted with FGD in the coming few years, further substantial emissions reduction gains may only be achieved through changing the fuel mix, such as to use more natural gas.]
• The Government has developed a comprehensive policy on controlling emissions from power generation.
• The policy is not to approve any new coal-fired generation units and to require power plants to maximise the use of gas.
• We have imposed emission caps on power companies to ensure the lowest possible emission of SO2, NOx and RSP from power plants.
• The Government has requested power companies to install desulphurisation and de-NOx facilities to reduce SO2 and NOx emissions. Both companies have completed the EIA process for the retrofitting projects.
• We continue to urge power companies to accelerate the schedule of emissions reduction projects, increase the use of ultra-low sulphur coal and natural gas for power generation, and progressively tighten the caps on their total emissions to meet the 2010 reduction targets.
• For the environmental regulation of power companies beyond 2008, we propose to link their permitted rate of return on all fixed assets to their achievement of the emission caps in their licences.
• Power companies are required to adopt Best Practicable Means (BPM) in pollution control.
[Vehicular: Get pre-Euro, Euro I and Euro II vehicles off the road – consider (i) introducing a phase-out scheme; and (ii) complementing the phase-out with traffic management methods (e.g. road charging, restrict entry into low emissions zones).]
• From 1 April 2007, the Government will offer a grant to encourage vehicle owners to early replace pre-Euro and Euro I diesel commercial vehicles with Euro IV vehicles. If all pre-Euro and Euro I diesel commercial vehicles are replaced by Euro IV models, the vehicular emissions of RSP and NOx will be reduced by 74% and 38% respectively. Te territory-wide emissions of RSP and NOx will be reduced by 18% and 10% respectively. Such an emission reduction will bring marked improvement to roadside air quality.
[Make Biodiesel Available]
• To facilitate the use of biodiesel in Hong Kong, we are working with the oil companies on the diesel specifications and additional parameters needed to ensure its use will be fully compatible with in-service old diesels vehicles.
[Lower First Registration Charge for Low-emission Vehicles and Charge a Higher Annual Licence Fee for High-emission Vehicles]
• From 1 April 2007, the Government will offer a 30% concession of first registration tax not exceeding $50,000 to promote the use of environment friendly private cars.
[Expand Rail Infrastructure and Coordinate Rail and Bus Feeder Services Better; and Manage Density and Traffic Flow to Reduce "Street Canyon Effect"]
• 90% of the population's daily travel (i.e. over 11 million passenger trips per day) is by public transport.
• Railways carry 36% of passengers every day (i.e. over 4 million passenger trips every day), making them the largest public transport carrier in Hong Kong.
• To further reduce reliance on road-based transport, we are continuing to press ahead with the construction and planning of a number of major railway projects, including the Lok Ma Chau Spur Line, the Kowloon Southern Link, the West Island Line and the Shatin to Central Link.
• Franchised buses carry 35% of the passenger trips every day (i.e. about 3.9 million passenger trips every day). The Government requires the franchised bus companies to take a number of initiatives to reduce vehicle emissions. These include deployment of environment friendly buses on busy corridors, installation of emission reduction devices, rationalisation of bus routes and stops and the introduction of bus-bus interchange schemes to reduce bus trips.
• As a result of the bus rationalisation programmes, over 2,700 bus trips in Central were reduced from 1999 to 2005. In addition, about 1,700 bus stoppings per peak hour were reduced in Central during the same period through rationalisation of bus stops. The total number of franchised buses has decreased from about 6,200 in end 2000 to about 5,900 in end 2005. These measures have helped reduce roadside emission, particularly along busy corridors.
• At mid 2006, around 64% of the franchised buses are with engines of Euro II or above emission standards. All buses with Pre-Euro and Euro I engines (about 36% of the bus fleet) have been retrofitted with catalytic converters or continuous regenerating traps.
[Marine:
– Ships to slow down in harbour – the HKSAR Government can start with its own fleet;
– Fuel switching to lower sulphur fuels for ships – the HKSAR Government can require its own fleet to use cleaner gas oil; making gas oil available locally will also enable others to do so;
– Target land-based emissions at port – e.g. container stackers use ULSD.
– Switch to shore-side power for ships;
– Work with ship-owners to lobby internationally through the InternationalMaritime Organisation for cleaner bunker fuel (1% distillate); and
– Collaborate with Shenzhen and Guangdong to operate 'green port' policies.]
• In Hong Kong, the marine sector emits relatively small proportions of total local emissions - 7%, 5% and 18% of particulate matters, sulphur dioxide, and nitrogen oxides respectively in 2005.
• All Government ships and vessels are using ultra sulphur diesel which has a sulphur content not exceeding 0.005%.
• Annex VI to the International Convention for the Prevention of Pollution from Ships (MARPOL 73/78) came into effect on 19 May 2005. The Annex lays down universally applicable rules on emissions from ships, capping the sulphur content of fuels for ships as well as controlling and monitoring their NOx emissions.
• To implement in Hong Kong the provisions of Annex VI to the International Convention for the Prevention of Pollution from Ships, the Marine Department is actively exploring the making of the Merchant Shipping (Prevention of Air Pollution) Regulation, in order to reduce pollution caused by emissions from ships to the atmospheric environment in accordance with Convention requirements.
• The proposal requiring ships to consume only electric power from shore after docking is still under discussion and is being examined by the International Maritime Organization. Notwithstanding this, we have proposed that the new cruise terminal should be equipped with onshore power facilities.
Environmental Protection Department
21 March 2007
