| 12.   
                Pollution transcends boundaries – this is especially     
                true of air pollution in the Greater Pearl River Delta.      
                According to the Environmental Protection Department, 80%     
                of     
                Hong Kong    
                ’s air pollution is contributed by emissions from the PRD.      
                Controlling air pollution in the PRD is a matter of     
                common interest for both jurisdictions.    
                    
                 
                13.   Thanks     
                to the Regional Air Quality Monitoring Network developed under     
                the Regional Air Quality Management Plan by the HKSAR and     
                Guangdong governments, we now know much more about regional     
                emissions in the PRD, whether they are from energy (power     
                generation), industry and transport, marine or aviation sources.      
                However, even if the controls on emissions are fully     
                implemented, given that the economic development of the PRD is     
                proceeding at a scale never before seen, we may only be playing     
                a catching-up game, with no assurance that the environmental     
                quality of the PRD would improve.      
                With the year 2010 rapidly approaching, there is an     
                urgent need to re-assess the long-term environmental strategy     
                collectively of 
                Hong Kong    
                and the PRD, and to develop cross-jurisdictional solutions for     
                the long term sustainability of Greater PRD region post-2010.      
                
                    
                 
                14.   
                A comprehensive cross-border solution will not be easy.      
                Critical to this will be the establishment of a transparent regulatory infrastructure and its 
                effective enforcement.      
                In     
                addition, we would like to make a few suggestions in this paper,     
                as follows.    
                    
                 15.     
                First, and more immediately, the HKSAR and 
                    
                Guangdong    
                    
                governments should further develop the emission trading scheme.      
                Emissions trading helps attain     
                any given emission target efficiently, but in itself does not     
                lead to reduced emissions. Hence it is important to implement     
                emissions trading as part of under a “cap and trade” regime     
                in which the “caps” (i.e. the allowable total amount of     
                emission) are periodically lowered and then trading     
                takes place to allocate the reduced total among those     
                in the trading scheme.      
                We note that the HKSAR government has recently introduced     
                a Bill establishing caps and facilitating emissions trading.      
                We welcome this introduction of market-based instruments     
                to     
                Hong Kong    
                ’s regulatory “toolkit”. Given     
                that the Mainland has already introduced emission trading in a     
                number of provinces since 2003, we do not see the need for     
                extensive pilot-testing.      
                The possibility of extending emission trading regime to     
                cover also carbon emissions should be explored, and potential     
                synergies with the Clean Development Mechanism examined.      
                Having     
                said that, target setting must be based on sound science 
                and cost-benefits analysis, taking account of the region’s 
                capability 
                of emission reduction as well as the need for economic development. 
                (8)
                
                 16.     
                Secondly, and as a matter of priority, emissions controls     
                should be instituted on coal-fired power plants that do not have     
                it already, throughout the whole region.      
                More directly, the governments of both sides could work     
                together to find a mutually acceptable way to establish a     
                moratorium on building any new coal-fired factories in the PRD     
                noting that this has been in place in Hong Kong since 1997.     
                (9)
                
                 17.     
                Thirdly, the business sectors of Hong Kong and     
                    
                Guangdong    
                    
                must be properly engaged in the pollution abatement.      
                Already factories in the PRD are feeling the pressure of     
                tightening of emission regulations; some were banished by the     
                Guangdong Government and unfortunately quite a few of these     
                factories are Hong Kong-owned.      
                The $93 million “cleaner production” programme     
                announced in the Policy Address and to be implemented by the     
                Hong Kong Productivity Council is a welcome scheme that will     
                help factories adopt clean technologies.  The     
                Chamber fully supports this scheme and would be happy to     
                contribute to its management and promotion.      
                As the environmental and economic objectives of the Hong     
                Kong and     
                    
                Guangdong    
                    
                governments are increasingly aligned, there is an opportunity to     
                develop sustainable solutions to benefit both sides, for     
                instance, by extending the cleaner production programme and     
                projects like the Chamber’s Clean Air Charter more extensively     
                across the border.      
                The idea of an “environmental compact” for Greater     
                PRD investors can also be explored.      
                Although it is the private sector which will be signing     
                charters or undertaking clean production programmes, government     
                promotion would be essential if this were to become an effective     
                campaign across the border. 
                (10)
                
                 18.     
                For the private sector, there is also the opportunity to     
                “turn the table” on pollution abatement: to find new     
                opportunities amidst the challenges.      
                Although the Mainland itself has developed rather     
                advanced technological capabilities in environmental 
                protection, 
                Hong Kong
                businesses still have a role in bringing foreign capital and 
                technologies to help contribute to sustainable development of 
                the country. (11)
                
                 19.     
                As one foresees more environmental regulations, the     
                compliance regime needs to be strengthened, whether for     
                regulating the emission trading schemes, enforcing new measures     
                on emission reduction, or implementing future policies on     
                closure, relocation or subsidies.      
                To that end, a data set on stack emission, both in     
                Guangdong and in Hong Kong, should be compiled and shared by     
                both sides, to enable total emission loading and total effects     
                to be understood and hence the appropriate trading and     
                regulatory regime designed.     
                (12)
                
                 20.     
                Finally, riding on the success of CEPA, the Mainland and     
                Hong Kong    
                should consider developing a “CEnPA” – Closer     
                Environmental Partnership Arrangement.      
                This can be used to facilitate sustainable development     
                and environmental improvement in both jurisdictions.      
                Under the Arrangement, both sides may put forward     
                “requests” and “offers” on environmental actions such as     
                cleaner fuel, cooperation on trade in waste, development of     
                water resources, aid for industry, and of course, emission     
                reduction.  A  CEnPA framework would  
                also be a useful platform to test out innovative policy ideas  
                such as a regional fund to cover pollution abatement in the PRD  
                funded    
                by an energy tax or emission surcharge.     
                Many possibilities may be considered; the key is to use    
                the unique “One Country, Two Systems” set-up to engender    
                creative policy solutions that benefit both sides.    
                (13)
                
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