Policy Statement & Submission




The view expressed by the Chamber four years ago, and repeated again in 1995, on the need for Government to take quicker and more effective action on improving air quality in Hong Kong continues to be of relevance today. Taken in aggregate, Government clean air strategy has been a commendable effort. Measures taken to control air emissions from factories and power plants, and regulations introduced to reduce the high sulphur content of diesel fuel and to require petrol vehicles registered after 1992 to use unleaded petrol and be fitted with catalytic converters have been successful in reducing some serious sources of air pollutant emissions. However, whatever the gains in air quality resulted from foregoing measures were soon eroded by two fast growing sources of air pollution - construction dust and vehicle emissions.

In tackling the construction dust problem, government had recently introduced new regulations. The greatest challenge now faced in meeting the Government stated air quality objectives lies with the control of vehicle emissions. As Hong Kong GDP continues to grow so does the number of private and commercial vehicles. This has in turn resulted in rising levels of air pollution. Government own figures for 1995 indicate that annual average pollutant concentrations in urban areas such as Mongkok, Kwun Tong, Tsuen Wan, and Shamshuipo, where close to 1.5 million people live, continue to exceed objectives. This already worrying situation is likely to deteriorate further as Hong Kong population increases and with it, the pressure on the territory transport network.

Health Implications

In 1995, six out of the eight permanent monitoring stations in Hong Kong exceeded the Government stated air quality objectives in one form or another, due largely to the high atmospheric concentration of fine particles emitted by diesel vehicle engines. These particles, referred to as Respirable Suspended Particulates (RSP), are of a health concern because they easily lodge in the lungs giving rise to the potential for reduced lung function, increased cancer risk and respiratory illness, and in extreme cases, premature deaths.

The elderly and children are the most vulnerable to the effects of air pollution. According to a recent report in a leading English language newspaper, deaths from respiratory diseases have increased by 20 percent since 1991. Because children respiratory systems are still developing and because they breathe 50 percent more air per kilogram of body weight than adults, they are more susceptible than healthy adults to air pollution. Breathing fine particles is also especially detrimental to children and adults with pre-existing breathing, lung and heart problems.

The health and environmental ramifications of poor air quality pose a long-term threat to Hong Kong economic well-being. Direct costs associated with work absenteeism, increased medical treatment and hospital admissions and premature deaths stemming from breathing unhealthy air, whilst indirect costs of potential loss of business due to companies' relocating, and tourists avoiding Hong Kong because of pollution should weigh heavily in any decision taken by Government when analysing the benefits and costs of curbing emissions.

Vehicle Emissions

According to Government figures, there are now about 480,000 vehicles in Hong Kong, with diesel vehicles accounting for about 60% of the overall distance travelled. Although some progress had been made with controlling emissions from some type of vehicles through the introduction of unleaded petrol and catalytic converters, there is still the matter of diesel vehicles. Heavy vehicles, including container lorries and large buses are an important part of the problem. In addition, there are some 80,000 light vehicles such as goods vans, mini-buses and taxis that continue to use diesel fuel. It should be noted that diesel vehicles are the main source of two air pollutants affecting Hong Kong urban air quality: RSP and nitrogen oxides, both of which pose similar hazards to humans.

The motor trade, in particular taxi and mini bus operators, was understandably concerned about Government earlier proposal to promote the use of unleaded petrol as an alternative to diesel because of livelihood considerations and worries that such a switch would increase inflation. However, if Government were to introduce incentives for switching to cleaner fuels and engines, as with its approach in introducing unleaded petrol, this would provide some encouragement for commercial vehicle operators to switch. For heavy vehicles, government must now begin to evaluate alternatives such as gaseous fuel and assess how such a fuel switch could be made financially attractive to operators.

On a more localised, but no less objectionable level, harmful emissions include those from cooking oil especially by restaurants, dry cleaning processes, and paint fumes.

The Way Forward

The improvement of Hong Kong air quality is necessarily a multifaceted exercise involving Government, the public and business. It is clear that Government must exercise leadership to prevent a further worsening of the problem, but it must be supported by the public and business community.

In the short term, the best solution appears to be the use of cleaner fuels and the introduction of more efficient engines. The Government latest initiative to explore the use of compressed and liquefied gases such as liquefied petroleum gas (LPG), liquefied natural gas (LNG) and compressed natural gas (CNG) as alternative fuels is laudable. These are well proven technologies which contribute to lower vehicle emissions and are common in large cities such as Tokyo and Sydney, where problems of implementation have been overcome. The switch from diesel to gas should however not preclude Government from considering other options for the introduction of less polluting fuels or technology. In addition, a serious assessment must be made of options for electric trolley buses along certain routes. Immediate action should also be taken to tackle the matter of cheaper but highly polluting fuel from the mainland which is being brought illegally into Hong Kong and largely consumed by commercial vehicle operators.

It is recognised that cost is frequently a major stumbling block to the introduction of such initiatives. However, if Government were to adopt a similar approach to the introduction of unleaded petrol and catalytic converters, namely, through legislation and incentive programmes, which are considered to be vital in the initial transitory period, the switch to cleaner fuels and technology would stand a good chance of success. Meanwhile, it is imperative that proper maintenance of old-styled and less efficient engines and vigilant enforcement of emission standards be applied.

To date, Government has done a commendable job regarding the provision of mass transit facilities, but it must now rethink its transport policy if air quality and other environmental objectives are to be realised. The way forward lies with railroad travel for the vast majority of the population and a shift away from reliance on road vehicles. It is to Government credit that the existing rail systems such as the Tramway, the Mass Transit Railway, the Light Rail Transit and the Kowloon Canton Railway, already carries a great proportion of Hong Kong population and is to be expanded through the Western Rail project and MTR extensions. While applauding these moves, it is important to recognise the need to go even further if we are to seriously address air pollution. This needs further support and investment as Hong Kong population continues to grow. The Chamber wishes to re-iterate the point made in its submission on the TDSR for Government to take a pre-emptive and pro-active approach in planning for Hong Kong transport needs rather than coping with problems as they arise.

Radical as it may sound, the Government should aim at zero local emission vehicles to largely supplant those powered by internal combustion engines. As the lesson of such places as Los Angeles, California suggest, even with cleaner internal combustion vehicles, it is difficult to clean up the atmosphere if there are too many vehicles on the road. To complement rail networks, electric trolley buses could be introduced into city centres or tramlines extended to complete the picture on public transportation. Proven electric technology now also exists for scooters, cars, shuttle buses and light vans which matches the performance, autonomy (the distance that can be covered between stops for re-powering) and reliability of conventionally powered vehicles. As the technology is already available, Government can provide much-needed leadership in making this a reality.

At the same time, it is recognised that as Hong Kong economic catchment widens into Guangdong, there is the need for the Special Administrative Region Government to take into account trans-border issues when formulating environment, energy and transport policies. In this vein, the Government could conduct studies to determine the extent of local air pollution being caused by contributions from neighbouring areas and measures to resolve the problem.

Conclusion and recommendations

It is recognised that air pollution is a complex and, for some, a contentious issue. Unlike other pollution problems such as water quality, the impact of breathing unhealthy air may not be readily and immediately apparent and few options exist to avoid pervasive air pollution short of leaving Hong Kong. Yet, despite apparently convincing statistics, as with evidence about cigarette smoking in the 1970 and 1980s, it appears difficult to persuade people that a real problem exists and that long term damage is being done to virtually all of us. Perhaps most significant of all, the short-term cost of switching to cleaner fuels is relatively high. All these add up to unwillingness on the part of business and an apathetic attitude on the part of the general public to play a helpful role in contributing actively to a lowering of air pollution.

Yet none of this means that airborne pollutants and greenhouse gas output cannot be curbed. Slowly the idea that emissions from petrol and diesel vehicles are harmful to health and the environment (local, regional and global) is beginning to be appreciated by business and the individual. As the Government Environmental Protection Department points out in its 10th year anniversary report, Hong Kong air quality objectives are achievable - but a reduction in the toxic emissions requires a tremendous change in consumer attitudes.

In the time that it takes for a stronger sense of responsibility to permeate through the community, Government should assume a leading role to halt further deterioration in air quality. To do so, it is suggested that the following measures, together with those mentioned previously in this paper, be considered for implementation:

Adopt an interdepartmental approach in government:- To tackle the single largest source of Hong Kong air pollution - vehicle emissions - and in the longer term, to establish an integrated approach to addressing Hong Kong transport needs, it is essential for government policy branches such as Finance, Transport, Planning Environment and Lands, and Economic Services work much more closely together to bring about the required changes in regulatory and technical guidelines. This can be achieved by the formation of a cross-departmental Working Group comprising senior officials headed by the Chief Secretary. The mandate of this Working Group should be the development of a truly Comprehensive Transport-Environment Policy including such matters as financing of rail systems, innovative surface electrified transport (trams, trolley buses) and alternative fuels for large vehicles.

Step up enforcement measures:- Existing emission controls for diesels are clearly inadequate and need to be further tightened to bring about compliance with existing legislation. Unless laws are backed by effective policing schemes and tougher fines, polluters will continue to pollute with a sense of impunity.

Monitor air quality standards through medical research:- The present practice by Government to conduct reviews on a sporadic and ad hoc basis should instead be changed to regular and ongoing medical studies that would permit more accurate and immediate assessment of the effects of pollution levels in Hong Kong. Refinements could be incorporated over time to yield higher quality data and to mirror changing circumstances.

Refine data collection methodology:- Besides maintaining existing monitoring stations on rooftops, Government should also increase the number of permanent ground level sites, the compelling reason being that human activity is largely conducted at this level.

Pre-empt potential resistance to the switch from diesel to cleaner fuels: As suggested elsewhere in this paper, Government should draw from its previous experience of proposing a Diesel to Petrol switch if its initiative to encourage the use of alternative fuels such as compressed gases and electricity is to be successful. Anxieties of affected parties should be addressed pro-actively and satisfactorily so that sufficient support can be gathered. Those who have been selected to take part in any pilot scheme should be reassured that costs incurred in the process would eventually be distributed among the community.

Develop a strategy for large diesel vehicles: One complaint with respect to the proposed Diesel to Petrol switch was that it unfairly targetted light vehicles while ignoring the pollutant contribution of larger ones. As it moves forward with new proposals for alternative fuels for light diesels, government needs to be able to show that it is concurrently assessing options for heavy diesels and that specific proposals on these will be developed soon after the proposals for light diesels.

Implicit to the foregoing recommendations is the recognition that most of Hong Kong air pollution problem is at present caused locally. However, it should be noted that, increasingly, part of this problem is derived from across the border. To guarantee clean air for Hong Kong in the longer term, it is therefore necessary to work with authorities in Shenzhen and cities beyond in devising schemes to bring about cleaner air in these locales. The cleaner Hong Kong vehicles are at the time of such discussions, the more Hong Kong will be able to push for changes elsewhere.

27 May 1997