Policy Statement & Submission

Mr Edward Yau, JP
Secretary for the Environment
Environmental Bureau
46/F, Revenue Tower
5 Gloucester Road, Wanchai
Hong Kong


Dear Edward,

The Chamber is a strong supporter of the HKSAR Government's commitment to the Asia-Pacific Economic Cooperation Leaders' Declaration on Climate Change, Energy Security and Clean Development. Accordingly, we welcome the mandatory implementation of the Building Energy Codes (BECs) as proposed in the recent Policy Address and outlined in the above consultation paper.

Although Hong Kong's contribution to greenhouse gas emissions is comparatively small, as a cosmopolitan city we have a part to play in supporting the global effort to combat climate change. With regard to our built environment, the Chamber agrees that the time has come to make energy efficiency requirements mandatory by giving them statutory status.

We believe the implementation of mandatory BECs should be guided by two principles. Firstly, with Hong Kong now a member of the C40 Cities Climate Leadership Group, the HKSAR should endeavour to show leadership by adopting global best practices. Secondly, since efficiency is the prime concern, practicality should be emphasized in introducing the scheme, so as to achieve concrete results quickly.

Enclosed please find a paper detailing our specific response to the consultation paper. I hope you will find the Chamber views useful.

Thank you.

With warm regards




Alex Fong
CEO

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Mandatory Implementation of the Building Energy Codes
Response to the Consultation Paper
Hong Kong General Chamber of Commerce
March 2008

General comments

1. The Chamber supports the HKSAR government's commitment to the Asia-Pacific Economic Cooperation Leaders' Declaration on Climate Change, Energy Security and Clean Development (the Sydney Declaration). Although Hong Kong's contribution to greenhouse gas emissions is comparatively small, as a cosmopolitan city we have a part to play in supporting the global effort to combat climate change.

2. Hong Kong being a high-density urban city, the energy efficiency of the built environment plays a critical part in our campaign towards sustainability. The consultation paper on mandatory implementation of the Building Energy Codes (BECs) is therefore very timely.

3. The Chamber has long been a staunch supporter of voluntary energy efficiency schemes, whether they apply to consumer appliances (such as the energy efficiency labeling scheme), or to “green buildings” (such as the Building Environmental Assessment Method scheme developed by the Business Environment Council). With the experience from the voluntary schemes and the heightened expectation of Hong Kong's sustainable development, we agree that the time has come to make the energy efficiency requirements mandatory by giving them statutory status.

4. We believe the implementation of mandatory BECs should be guided by two principles. Firstly, with Hong Kong now a member of the C40 Cities Climate Leadership Group, the HKSAR should endeavour to show leadership by adopting global best practices. Secondly, since efficiency is the prime concern, practicality should be emphasized in introducing the scheme, so as to achieve concrete results quickly.

5. These two principles will guide our response to the specific questions in the consultation paper, as below. As a general chamber, our response is necessarily general and non-technical, and we trust the government will engage closely with relevant professional bodies (e.g. the BEAM Council locally, and the World Green Building Council globally) in working out the implementation details.

Specific response

Do you agree that Hong Kong should pursue the mandatory implementation of the BECs?

6. Yes, the HKGCC agrees that Hong Kong should adopt mandatory implementation of the BECs.

What broad categories of buildings should be covered?

7. We agree that the types of building listed in Annex C of the consultation paper should be covered in the mandatory implementation of the BECs (i.e. commercial buildings and communal areas of residential and industrial buildings).
8. However, we note that Annex C does not cover buildings of the public sector. It is difficult to understand the reason why buildings for public purposes such as schools, hospitals or police stations should be excluded. It would appear fairer, and more in line with the principle of best practices, that the same standard should also apply to buildings in the public sector.

Are there any specific types of functional use within the selected categories that should be exempted from the mandatory scheme, and if so, who are they?

9. It is understandable that for practicality consideration, the BEC requirement may have to be sector-specific; in some instances they may have to be implemented in phases while in others exemptions may be required. We have no strong views other than that an outcome-based approach should be adopted, and would defer to the building industry and the government to work out the best way of achieving concrete results.

Do you consider that existing buildings should also be required to improve their energy efficiency performance?

10. Again, if best practices were the guide, the answer must be yes. Due to historical reasons, the BEC may not be applicable to all existing buildings, but there should be a combination of voluntary incentives and technology facilitation to prepare for the eventual mandatory implementation for all suitable buildings.

If your answer to Question 4 is in the affirmative, which of the following options do you consider as most appropriate –
 Requiring compliance with the BECs after a reasonable transitional period; or
 Requiring compliance with the BECs only when there are major refurbishment works, such as when the works involve replacement of major components of the types of installations covered by the BECs or when the coverage of the retro-fitting works exceeds a certain percentage of the building's gross floor area; or
 Mandating conduct of energy audits and display of the audit results.
 Any other options?

11. We prefer the second option, i.e. requiring compliance when there are major refurbishment works involving replacement of major components of the types of installations covered by the BECs or when the coverage of the retro-fitting works exceeds a certain percentage of the building's gross floor area. This is a reasonable option to adopt considering the practicality principle.

As a general direction, whether we should –
 Adopt the recently updated BECs for the HKEERSB as the mandatory standards; or
 Incorporate a regular review system to uplift the standards with reference to the prevailing international standards as far as possible; or
 Introduce a tiered arrangement, i.e. with the BECs issued by the EMSD as the minimum standards applicable to all covered buildings, and a higher set of standards be introduced to give recognition to buildings that achieve better energy efficiency to encourage superior environmental performance.

12. In our view, a tiered arrangement is appropriate, as it accords with both the practicality principle and encourages aspirations for best practices.