In partnership with Clean Air Network.
Hong Kong’s some 7.5 million residents are all too familiar with the thick blanket of haze that occasionally covers the city, choking both its skyline and residents. One non-governmental organisation has taken aim at the government’s air pollution policies, which it says fail to prioritise the public’s health and curb toxic emissions.
Clean Air Network started in 2009 with the aim of educating the public about the health impacts of air pollution and mobilising public support for cleaner air in Hong Kong. Their work focuses on enhancing the public’s understanding of air pollution by collecting data from monitoring stations while lobbying the government to implement green policies.
In July, the Environment Bureau launched a three-month public consultation on a review of the Air Quality Objectives (AQO), where the government proposed increasing the number of times daily particle pollutants — known as PM2.5 — limits can be exceeded from nine to 35 per year.
Of the standards set for five major air pollutants, only one — nitrogen dioxide — complied with the World Health Organisation’s (WHO) guidelines. These standards also dictate that 24-hour fine particulate matter (PM2.5) exceedances be limited to 25.
AQOs, which set a concentration limit for hazardous air pollutants, are reviewed at least every five years, with the latest review lasting from mid-2016 to last December. If the proposal goes through this year, the relaxed measures could be implemented as soon as next year and last for at least two years.
”What are PM2.5 and PM10? Why are they hazardous? – Click to view“
PM with particles less than 10 and 2.5 microns refers to solid and liquid atmospheric particulates that penetrate deep into the lungs. These particles can cause a range of health problems including impaired respiratory function, chronic bronchitis, exacerbation of asthma, and adverse effects on the cardiovascular system upon entering the blood.
PM2.5 is classified by the WHO’s International Agency for Research on Cancer as a group one cancer-causing carcinogen, which it said caused around 223,000 deaths from air pollution-induced lung cancer in 2010.
The Environmental Protection Department (EPD) has justified raising the threshold using an air quality projection for 2025, which predicts the highest number of daily PM2.5 exceedances in a north-western part of Hong Kong will be 33 times.
But Clean Air Network has blasted the proposal as unambitious and a “short cut.” It said the threshold had been raised simply to ensure all targets are met, instead of taking steps to control emissions, such as promoting electric vehicle use — which, if effective, would decrease the number of times pollutants exceed concentration limits over time and lead to stricter AQOs.
“This is something we think is unjust,” Patrick Fung, CEO of the organisation, told HKFP. “They are too conservative in projecting the level of air pollution or air quality by 2025. The result is that the AQO will be tightened relatively less because… AQO is by law a gatekeeper for designated projects under the EIAO [Environmental Impact Assessment Ordinance].
“Therefore, infrastructure projects that cannot meet AQO [requirements], are not approved under EIAO.”
”What is the EIAO and how does it relate the AQO? – Click to view“
The EIAO was enacted in 1998 with the aim of minimising the environmental damage of designated projects which, by law, require government-approved permits to begin construction. If a project’s emissions are likely to breach AQOs, then its proponent must reduce that projection until it falls within that limit.
His concerns come amid a number of so-called white elephant projects including a controversial plan to build a metropolis on reclaimed land — Lantau Tomorrow Vision — from 2025, which was estimated to cost HK$624 billion in its first phase.
‘Taking public health seriously’
At the core of the problem is the government’s failure to prioritise public health, said Loong Tsz-wai, Senior Community Relations Manager of Clean Air Network.
“They do not take public health seriously,” he explained. “We need to have a good standard, a stringent enough standard because ultimately, setting up AQO is for protecting public health. But the problem in Hong Kong is we do not set up a stringent enough AQO. We set up a lenient AQO because we want to have the score passed — we want to have the AQO passed, but not to attain the betterment of public health.”
A 2011 study from the University of Hong Kong (HKU) found that when analysing the EPD’s air pollutant data from 2005 to 2010, the government’s AQO — during a delayed review from 2007 — could not lead to sustained air quality improvement and provide protection to public health.
“The research team showed that these additional allowable exceedances will predictably allow the annual concentrations of pollutants to rise to even higher levels than the original selected WHO limits,” it read. “These have important implications for maternal and child health, children’s lung growth and development, the prevention of heart disease, strokes, pneumonia, chronic bronchitis and many other health problems which may lead to premature deaths.”
“These bad health outcomes will be directly related to non-compliance with the WHO guidelines and the government’s permissive approach to allowing additional exceedances of already lax limits,” it added.
HKU researchers concluded that if the government complied with WHO air quality guidelines it could avoid 1,860 avoidable deaths, 92,745 hospital bed-days, and 5.2 million doctor visits, saving the community about HK$20 billion.
Based on the results of an air quality assessment for 2025, a spokesperson for the EPD defended the measures as beneficial to the public’s health.
“In accordance with the principles and guidelines promulgated by the World Health Organisation, the government commits to progressively improve air quality for [the] protection of public health,” they said. “Based on the assessment of the air quality health experts, the air quality improvement in 2025 will result in substantial health gain. It can reduce about 1,850 premature deaths, 1,530 cases of hospital admissions and 262,580 cases of clinic visits as compared to 2015.”
‘No option B’
Clean Air Network has urged the EPD to release data on the health risk assessments of alternative options for the public to consider besides the one provided by the AQO proposal.
“The information is incomplete so the result is there is no option B for the public to support under the public consultation section,” Fung said. “So, the only option the government provides is [this]. If concerned citizens want to have a more ambitiously tightened objection, we have no information to understand what levels it could be or what kind of additional benefit to the health or economy could be.”
Clean Air Network has since asked the government to release scientific data on the health impact of relaxing the PM2.5 measures, while conducting risk assessments of alternative scenarios to inform the public of what is best for their health.
‘Not legally binding’
Additionally, the EPD has cited the European Union and the United Kingdom as allowing 35 exceedances as a 24-hour PM10 standard — a comparison which Fung said was misleading.
“When we look at the nature of the monitoring station system in Hong Kong and London, London has more roadside stations and the data will be part of the decision-making process to determine the 35 [number of exceedances]. However, in Hong Kong, we use only the general monitoring station which is 10 metres tall… which is not reflecting the level of air quality,” he explained.
The EPD spokesperson rebuffed the criticism, saying that the reference to air quality policies in those countries was appropriate and in line with established scientific practice.
“Due to different urban forms, many air quality monitoring stations in Europe and the United Kingdom located at lower levels in fact are sited far away from major traffic,” they said. “Under the established principles, they are ambient stations serving the same function as the ambient stations in Hong Kong. Indeed, Europe and London, as well as many overseas cities are reporting air quality of both ambient and roadside air quality stations, same practice as Hong Kong.”
But Fung also took issue with what he said was the public’s powerlessness to hold the government to account in the event it fails to abide by AQOs by, for example, imposing penalties on those responsible.
“We can’t sue them or put any kind of pressure to push them to do it because AQO itself is not legally binding,” he said.
“The issue of AQO is … not like the situation in the UK or the countries under the EU. When the government fails to achieve [its] own AQO there are some legal consequences in that country,” Tsz added.
“For instance, in London, in Frankfurt, in Berlin, when they fail to achieve an AQO, the EU court will fine that country for exceeding the AQO. Whereas, in Hong Kong, we [can’t] fine the government or [fire] the Secretary for the Environment.”
‘We want to be included’
In June, Clean Air Network and the AQO Review Concern Group commissioned the Hong Kong Public Opinion Research Institute to conduct a phone survey, asking the public to voice their concerns about the AQO review.
The survey of residents aged 18 or above, with 574 respondents and a 58 per cent response rate, showed that 73 per cent of interviewees were unsatisfied with the government’s air quality proposals. Fifty-two per cent said they were unsatisfied with the city’s current air quality, while 23 per cent said they were satisfied.
Fung added that he feared the concerns voiced would not be taken seriously by the government because the public consultation was conducted outside of the AQO review period.
“The APCO is in effect in the first January of 2014 and it mandates a review every five years. So the review period should have ended on December 31 2018,” he said. “Right now we are in August 2019 and we are still working on the public consultation, which means that the public consultation is not considered a part of the AQO review process.”
“How come the public consultation period is not considered part of the formal AQO review process? That should have been completed at the end of December last year. So we’re out of the review process already,” he added. “So our guess is that whatever we voice out might not be channelled in any kind of adjustment the government would do.”
“We want to be included in the formal process of review defined under the Air Pollution Control Ordinance.”
The EPD spokesperson responded saying that the review period only involves the scientific work conducted by experts and specialists, after which the findings will be presented to the public for scrutiny.
“Upon completion of the public consultation, the government will consider all the views collected and consult the ACE [Advisory Council on the Environment] and the LegCo… and, if [adjustments are approved], how the AQOs should be revised,” they said.
