To:
The Chairman and Members of the Advisory Council on the Environment
From: Prof. A Hedley, Dr. S McGhee, Dr. C M Wong (Department of Community Medicine, School of Public Health, HKU); Prof. T W Wong (Department of Community and Family Medicine, CUHK); Dr.. A Lau, Dr. B Barron, Dr. J Fung , Dr. S C Kot, Mr. S Ng (Institute for the Environment, HKUST); Ms. C Loh, Ms. K Uebergang, Ms. M Weldon, Mr. M Van Rafelghem (Civic Exchange). Date:
September 18, 2006
Re:
Comments on A Proposal for Reviewing the Air Quality Objectives and developing a long term Air Quality Strategy
Dear Members, In reviewing the document (ACE Paper 14/2006) we have identified several points of concern. We also feel that government needs to provide a clear answer to several crucial questions before it proceeds with the Air Quality Objectives (AQOs) revision process. We also wish to note that our concerns go beyond the explicit statements made in the text to include implied approaches on the part of government to the dilemma posed by the potential costs of such a revision. In addition, while we appreciate that government’s submission cannot be fully comprehensive at this early stage, we are struck by omission of several key points and worry that this suggests government’s lack of concern about them.
1. We begin by posing two fundamental questions to government, since it is difficult for us to see how discussion can proceed without clear answers to each. a. We ask government to clearly state the purpose of AQOs. •
Are these designed as indicators of the risk to public health from prevailing levels of pollution?
•
If so, what justification would there be for setting Hong Kong’s levels less stringently than what the best information available (i.e., the 2006 WHO guidelines) indicates are the minimum needed to protect health?
•
If not, then what is the purpose?
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Comments on: A Proposal for Reviewing the Air Quality Objectives and developing a long term Air Quality Strategy
This is vital, since the way the government reports them today and the way the public and news media seem to interpret them is that they are intended to serve as indicators of how safe our air is in a given place and time. The Government document notes that WHO Working Group “thus advises that individual governments should consider their own local circumstances carefully when using the WHO air quality guidelines.” As presented in the submission, the Hong Kong government appears to interpret this statement as applying to both the Air Quality Guidelines (AQGs) and Air Quality Management Strategies. In our view this would be wrong. The guidelines are based on estimated impacts on human health. Such impacts do not vary substantially from one place to another. What varies far more is the ability and willingness of different governments to attain healthy ambient air quality through locally designed and implemented air management strategies. This distinction is fundamental: in our view it is not the AQOs themselves, but rather the management strategies and interim targets that should vary according to ‘local circumstances.’ If government acknowledges that the levels of the AQOs should be set to protect human health (and set on the basis of the best available information) then we can see no justification for Hong Kong taking several years to review the AQOs. Rather we should simply adopt those of the WHO. We also feel that evidence is sufficient at this point to warrant inclusion of not only tighter limits on PM10 but also inclusion of ones based on PM2.5 (along with the necessary monitoring to support it). b. We ask government to clarify how the AQOs are used within the EIA process to influence the project approval/non approval process, as well as, the final project design for projects allowed to proceed. We appreciate that to the extent that Hong Kong’s AQOs do have implications for Environmental Impact Assessments (EIAs), and ultimately for the approval and final design of major projects, more stringent limits could have substantial repercussions on the economy and steps need to be taken to keep such effects within acceptable limits. In light of this, we recommend that government set interim targets for ambient air quality to be used with regard to assessing (within the EIA process) the acceptability of a project’s impact on air quality.
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Comments on: A Proposal for Reviewing the Air Quality Objectives and developing a long term Air Quality Strategy
However such interim targets should be clearly identified as such and have a limited specified period of applicability (e.g. 5 years). Over time the interim targets should be gradually tightened until they match the AQOs based on health protection. Most basically, neither interim targets nor the AQOs themselves should be used to, in effect, become a license pollute. This can happen when a project negatively affects air quality, but not much so as to cause a breech in lax AQOs.
2. We are concerned government is trying to lower expectations with regard to our ability to attain a healthy ambient air quality. The government submission (Item 23) states. “the new WHO AQGs cannot be met at present even at Tap Mun, our background air quality monitoring station. It implies that even if the emissions in Hong Kong were to be eliminated completely, the new WHO AQGs still will not be met. The achievement of the new WHO AQGs will thus require comprehensive and possibly very drastic measures to be taken not only in Hong Kong but also in the mainland over the long term.” As continued in item 24 the HK government notes, “the finalization of a set of revised AQOs and the implement plans for their achievement in the long term would be possible only with a thorough public engagement process supported by detailed information on the options and implications, financial implications in particular.” Item 24 then goes on to identify in broad terms the types of measures that would be required. Item 24 ends with a listing of four steps in government’s proposed ‘comprehensive study’. With regard to Items 23 and 24, once again, we draw a distinction between targets that protect human health and interim ones that might be employed to reflect practical near term limitations on government’s ability or willingness to undertake measures sufficient to attain healthy levels of air quality. We find it important that in citing the Tap Mun example, government in effect is acknowledging that nowhere in Hong Kong is the air safe according to the WHO measures. While correcting this rather dire situation will be difficult, we stress that it is not acceptable for government to imply that it might not try to attain an air quality (via our AQOs) that protects health (i.e., ones matching those of the WHO). This is not to say that there cannot be interim targets. However, as noted, these should be explicitly acknowledged to be temporary.
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Comments on: A Proposal for Reviewing the Air Quality Objectives and developing a long term Air Quality Strategy
3. We are struck by several omissions in the government’s document: a. No mention is made of the substantial role played by Hong Kong finance, management and product purchase in Guangdong’s manufacturing sector, which is a major source of our poor air quality; and, b. The failure in the submission to acknowledge that allowing unhealthy levels of air pollution to continue imposes substantial economic and financial costs on society (i.e., there are costs incurred in doing too little). The fact that Hong Kong-based firms own, operate and manage, and product source from tens of thousands of manufacturing establishments just across the border in Guangdong offers considerable potential leverage and opportunities. This does not suggest that it will be easy to work out appropriately designed measures in Hong Kong to get more serious commitment from Hong Kong factory owners, operators, and buyers in their actions in Guangdong. Rather, we note how little has been done so far in this area to point out that when faced with a difficult challenge it is imperative to think in new ways, rather than continue to conduct “business as usual”. Air pollution at levels prevailing in Hong Kong and the rest of the PRD cause sickness. For the more serious cases of pollution-related illness medical treatment is called for. In addition, individuals affected by pollution-related symptoms have lower productively at work, and children tend to perform less well in school. Statistically, we all face the prospect of shortened expected life spans. Overall, we face a pervasive reduction in the quality of life. Thus, we face direct financial costs in the form of health care, and productivity losses, as well, as broader economic costs in terms of a lower quality of life and reduced life expectancy. Indeed, as noted widely in public discussions of our air pollution, such reductions in the quality of life are a reason for some persons (who are mobile in their domicile and work place) to leave the territory for locations where their own and their children’s health are not so much under perceived treat. For further discussion please contact Ms. Christine Loh at Civic Exchange cloh@civicexchange.org, Civic Exchange, Room 701 Hoseinee House, 69 Wyndham Street, Central, Hong Kong
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