Policy Statement & Submission

3 December 2009


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


Dear Edward,

Air Quality Objectives Review - Public Consultation

Thank you very much for speaking at our EcoSmart Series of Sustainability Forums explaining in details the proposed new Air Quality Objectives (AQOs) and discussing with our members on various related issues.

Competitiveness at Stake

It is the long held view of the Hong Kong General Chamber of Commerce that Hong Kong should tackle the air quality issue as a matter of urgency. We are glad to see that some of the 43 proposals made in our submission “Restoring Blue Skies: Review of the Policy Agenda on Air Pollution” (April 2008) have been adopted. Going forward, the Chamber maintains its calls for more aggressive local actions in Hong Kong and greater cooperation with the Pearl River Delta to improve air quality. Setting appropriate targets and conducting regular reviews are crucial parts of the package of solutions.

The Chamber agrees that the new AQOs should be set with a view to protect public health. But from a business sector's point of view, poor air quality is also damaging Hong Kong's overall competitiveness. As a service economy and an international financial centre, it is essential for Hong Kong to attract and retain talents, but poor air quality has been weakening our ability to do so. Our reputation as a city with high quality of life also suffers. The need to address the issue is all the more pressing in view of the competitive environment.

Benchmarking WHO Targets

It is necessary for Hong Kong to review its AQOs, not the least because the existing ones have been in place for a considerable length of time. It has been a while since the World Health Organisation (WHO) released a new set of Air Quality Guidelines (AQGs) in October 2006 and we are glad to note that the Government has finally agreed to benchmark the WHO's latest AQGs in setting our own AQOs.

It is well known that there are different opinions on whether the most stringent WHO targets should be adopted. In the consultation document, it is proposed that the WHO's ultimate AQCs are adopted as our AQOs for three pollutants, and the lower “Interim Targets” (ITs) for four others. The Chamber is supportive of a staged approach for updating the AQOs. We can understand that in the case of some PM emissions, Hong Kong is very much under the influence of regional pollution, and it is unrealistic to set the ultimate WHO guidelines as short term targets.

Clear Timetable Needed

Though stakeholders may understand the practicable reasons for not setting the highest possible targets across the board, concerns remain about the prospect of reaching an eventual regional solution to the air quality issue. We would urge that the Government should reach specific regional cooperation agreement in addressing the issue as soon as possible. A clear timetable for actions committed by the Hong and Guangdong authorities respectively – which reflects a clear delineation of responsibilities for both sides – should be drawn up. With such a timetable and list of committed actions in place, stakeholders will be able to identify if any gaps exist and begin to discuss how such gaps should closed, and by whom. The regional air quality issue is so pressing that drawing up a timetable of actions together with the Guangdong authorities should be of the highest priority for the Government.

Locally, some of the solutions for reducing emissions require long term investments. Businesses therefore expect a clear timetable from the Government for achieving the new AQOs and implementing the proposed emissions control measures in full, so that they may plan for their investments and other required changes to their operations. It should be highlighted that better planning of investment over the long term may reduce the cost of adopting new technologies and solutions, which will in turn help obtain buy-in from stakeholders for those solutions.

Forging Consensus on Big Picture

The Chamber recognises that concerted actions are required from businesses and consumers to implement the proposed measures for achieving the air quality targets. You have emphasized that the 19 proposed measures should be considered as a package, instead of picking and choosing among them, in order to realize their full impact. We support that the 19 measures should be pursued as a total package, and would urge that the Government continues to engage the entire community proactively to secure buy-in. We believe that it is important to focusing on forging consensus at this stage on the broad principles and overall objectives for adopting the package of measures. While we agree to your aim of sending a message of “no free lunch” to the public, we are of the view that details like the costs and incidence of implementing the measures can be tackled in due course on the basis of active engagement with stakeholders. We should not be bogged down by the implementation details at this stage and lose sight of the big picture.


Leadership

To implement the proposed emission control measures effectively, it requires strong leadership across the political spectrum: the Administration, legislators, major political parties and community leaders at the district level. There exist doubts on whether the Environment Bureau would be able to drive the policy package effectively, as many such measures are outside the Bureau's purview. One count has it that 12 of the 19 emissions control measures are the responsibilities of the Transport and Housing Bureau. If such doubts are to be allayed, the Administration has to display greater collective leadership.

On the other hand, the Chamber would like to echo your calls for commitment from major political parties with regard to the implementation of some important measures – such as rationalization of bus routes, introducing low emissions zones and car-free zones – which will require buy-in from local communities. We are glad to see initial indications of cross-party efforts on coordinating discussions at District Councils on bus route rationalization.

As mentioned in our response to the Policy Address this year, improving the quality of our air cannot, even for one minute, be off the top of list of things that need immediate attention. The Chamber will continue to facilitate the business sector's participation in the discussion of air quality issues. Thank you very much.

With best regards,




Alex Fong
CEO


c.c. Air Policy Group, Environmental Protection Department