October 2023

Air Policy Group (1)
Environmental Protection Department
33/F, Revenue Tower
5 Gloucester Road
Wan Chai, Hong Kong

Dear Sir/Madam,
Green Power’s Response to 2025 Air Quality Objectives (AQOs) Review – Public Consultation

1. Green Power, as a local charitable green group, would like to respond to the above-captioned consultation document launched by Environment Bureau, HKSAR Government in July 2023.

2. “Taking into consideration the target of broadly attaining Hong Kong’s prevailing AQOs by 2020 and the statutory requirement to review the AQOs at least once every 5 years”, the air quality improvement in 2025 and the scope for tightening the AQOs has been assessed in the current review (p.18).

3. We opine that the AQOs have to be updated with protection of public health as the key consideration. Unlike drinking water, which is treated up to a safe level before being consumed in Hong Kong, air is directly breathed in by almost all members of public untreated. That means any contamination of the air imposes a direct impact, in short and long term, on the health of all Hong Kong people.

Approach for the Review of Hong Kong’s Air Quality Objectives

4. Although the progressive approach of the Review “To progressively improve our air quality through the implementation of various emission reduction measures and setting of interim targets, with a view to meeting the ultimate targets of the WHO AQGs as our fi¬nal goal.” (p.3) is understandable, the context of consultation document indicates that AQOs should reflect the practicality of available improvement measures. Such approach may distract and mislead the public that “achievable AQOs” are equivalent to internationally recognized health-protecting ones. The elderly, children and patients suffering from respiratory diseases are especially vulnerable to this misconception.

5. “AQOs refer to the short-term and long-term concentration targets of the 7 major air pollutants prescribed in Section 7A and Schedule 5 of the Air Pollution Control Ordinance (APCO) (Cap. 311)”(p.6). The document states explicitly that the AQOs have the following statutory functions (p.9):

• a benchmark for consideration of designated projects under the Environmental Impact Assessment Ordinance (Cap. 499);

• a key factor to be considered when deciding whether a licence should be issued to a specifi¬ed process under the APCO.

6. That means AQOs are a set of statutory standards for law enforcement which are not a purely health-oriented standard set to inform the public the genuine and basic air quality to safeguard their health.

Exclusive Health-oriented Air Quality Standards/Targets

7. Although WHO suggests “…… various governments to, having regard to their local circumstances, gradually improve their air quality through setting their air quality standards at the interim targets (ITs) and advancing progressively towards the ultimate targets of the WHO AQGs, with a view to protecting public health”(p.7), promulgation of “health-oriented air quality standards/targets” to inform the public the air quality requirement to safeguard their health, i.e. the ultimate targets of the WHO AQGs, is not excluded.

8. Under APCO (Cap 311), AQOs “ …… should be achieved and maintained in order to (a) promote the conservation and (b) promote best use of air in the zone in the public interest.” (Section 7A (2)) and “The Authority shall aim to achieve the relevant air quality objectives as soon as is reasonably practicable and thereafter to maintain the quality so achieved.” (Section 8 (2)).

9. The Ordinance requires the authority to achieve and maintain the AQOs, but not formulate AQOs which must be promptly achievable. To our understanding, practicality should be considered in enforcement of the Ordinance but not the establishment of AQOs. More importantly, the Ordinance states that AQOs should be for the conservation and best use of air in the public interest. Improving public health and reduction of mortality due to air pollution should accord a higher priority in the context of public interest.

10. Green Power urges the Government to adopt new AQOs after the current review practice which disseminate a scientific, updated and health-oriented standard of air quality to the public, in view that the practicality of achieving the new AQOs and the willingness of the public to pay for achieving such AQOs will not alter the objective scientific correlation between air pollutant levels and corresponding health impacts. A readily achievable AQO may still exceed the due health standard.

11. If the Administration decides to keep the nomenclature of “Air Quality Objectives” for legislative purposes, Green Power considers that the ultimate targets of the WHO AQGs should be properly promulgated as they objectively inform the public the genuine and basic air quality required to safeguard their health.

Views on Proposed AQOs Amendments

12. Green Power appreciates that air pollutants including SO2, PM10, PM2.5, CO and Pb have been largely reduced since 2013 with government’s efforts in implementing the emission control measures. However, O3 and NO2 levels remain outstanding that continue to threaten public’s health (p.9).

13. According to the air quality assessment results for 2025, we appreciated that improvement in air quality can bring about HK$33 billion and HK$246 million health and economic bene¬fit respectively to Hong Kong, compared with 2015 baseline data (p.29).

14. The review proposes tightening of the 24-hour AQO for PM2.5 to the IT-2 level (50µg/m3) while increasing the number of allowable exceedances to 35 times.

15. “Between 2011 and 2017, the ambient air quality monitoring network recorded 17 exceedances against the prevailing 24-hour AQO for PM2.5, but 30 exceedances against the proposed new AQO (IT-2).” (p.26). However, “according to the 2025 air quality modelling results, the highest number of exceedances of the 24-hour concentrations of PM2.5 in the north-western part of Hong Kong against the IT-2 concentration level is 33.” (p.25). Under the IT-2 level for PM2.5, the number of exceedance increases from recorded 30 times (2011 to 2017) to predicted 33 times (in 2025).

16. We opine that such allowable exceedance number, that is equivalent to one-tenth days of the year, will jeopardise the benefits of tightening AQO for PM2.5 in view of protecting public health.

Combating Ozone Pollution

17. As tropospheric ozone level in Hong Kong is predicted to increase and cannot meet AQO, we concur the proposed measures for VOC-containing products in short term (p.21). However, we are disappointed that no further proactive actions or promotions are proposed in local and/or regional context to reduce the emission of VOCs.

Electrification of Heavy Vehicles

18. In Hong Kong’s situation, the current development of electric heavy vehicles (including light buses) lags behind that of private cars. Although the One-for-one Scheme encourages switch of fossil-fueled private cars to electric ones to deter the growth of private car fleet and corresponding pollutant emission, emission of heavy vehicles still constitutes a major portion. Therefore, the pace to curb the pollutant emission of other heavy vehicles should be accelerate with input of research resources pinpointing the unique local requirements for these vehicles that oversea cities may not deal with.

19. At the same time, the backup hardware and software required to the electrification of heavy vehicles (e.g. storage of hydrogen, charging services, repair and maintenance) should also be considered during R&D stage to shorten the time of popularization once the technology becomes practical to local situation.

Green Marine Local Transport

20. Promoting green transport network and adopting green features in urban areas, new towns and new development areas may be restricted by existing settings in some cases. In addition to promote local vessels to use electricity from the power grid while at berth (Annex 3, A16), effective and low/zero emission mass transport via marine mode should be explored after assessing its transport and energy efficiency, contribution to territorial emission and negative impacts on marine ecology, especially to and from urban areas and new towns.

Local Electricity Generation

21. As a major emission source, emission limit of local power plants should be considered and reviewed to complement with other measures, such as shift of fuel mix for electricity generation, promotion of renewable energy sources of various scale, electrification of transport tools, promotion of energy efficiency and saving in buildings, etc.

Yours faithfully,

CHENG Luk-ki
Director, Green Power

Yours faithfully,

CHENG Luk-ki
Director, Green Power