Submission in Response to the Public Consultation on the 2024 Policy Address

Executive Summary

Clean Air Network (“CAN”) is the only air issue focused non-governmental organisation in Hong Kong. We believe that clean air is fundamental to the overall well-being of the community. Our vision is to achieve clean air for all in Hong Kong.

Over the past decade, Hong Kong has made significant progress in enhancing ambient and roadside air quality. Still, in 2022, the city only achieved 75% of the Air Quality Objectives (AQOs), with significant gaps in nitrogen dioxide and ozone levels. Air pollution is linked to health issues including cancers, heart attacks and strokes, posing higher risk to vulnerable groups such as the elderly and individuals with pre-existing health conditions and impacting children’s health even after they grow up. With shifting public health risks and demographic changes, it is imperative that we continue to strengthen the clean-air efforts.

Specifically on indoor air quality (IAQ), the lack of systematic and sufficient management across places in Hong Kong contributes to the above-mentioned health issues. Recent research finds that volatile organic compounds (VOCs) have become the main inhalation cancer risk among ambient pollutants in Hong Kong and VOCs are commonly found indoors. Poor IAQ also means higher risk of communicable diseases transmitted via air. With a high number of ageing buildings in the city, IAQ management is becoming even more important.

We urge the Government to take a proactive approach to addressing emerging threats in order to further enhance public health.

We believe the Policy Address should outline the Government’s plans to achieve clean air for all in Hong Kong in the following areas:

1. Overall Approach to Air Quality

a) Continuing to Tackle Air Pollution Issues to Enhance Public Health: Addressing air quality issues holistically with the involvement of all relevant bureaux and departments as well as experts from all disciplines based on the Clean Air Plan 2035

2. Strengthening Measures to Address Ambient and Roadside Air Quality

a) Tightening the Air Quality Objectives: Ensuring the continuous tightening of AQOs, aligning with WHO’s most stringent standards

b) Promoting New Energy Vehicles: Enhancing the adoption of new energy vehicles across all categories and ensuring comprehensive infrastructure support

c) Formulating an Action Plan for Regional Ozone: Based on the study of ozone formation in the Greater Bay Area, developing and implementing effective strategies

d) Providing details of the Electric Ferries Pilot Scheme: Providing a clear timeline and details on the progress

3. Addressing Indoor Air Quality

a) Tackling IAQ with the Involvement of All Relevant Bureaux and Departments: Formulating objectives and work plans involving various bureaux and departments

b) Legislating for IAQ: Amending the Air Pollution Control Ordinance to include IAQ objectives, prioritise stringent standards for vulnerable groups, and conduct regular reviews

c) Developing Support for Pre-Schools and Hospitals: Creating guidelines for these vulnerable groups

d) Setting an Example for Data Transparency: Implementing continuous monitoring and reporting of IAQ data

e) Expanding the IAQ Certification Scheme: Including premises without mechanical ventilation and air conditioning systems

Full Recommendations

1. Overall Approach to Air Quality: Continuing to Tackle Air Pollution to Enhance Public Health

1.1 Despite improvement in recent years, Hong Kong ambient and roadside air quality is still worse than other major cities. In 2022, Hong Kong only achieved 75% of our AQOs, leaving significant gaps in meeting the target nitrogen dioxide [1] and ozone [2] levels. The level of nitrogen dioxide at the roadside is 530% above World Health Organization’s most stringent standard. [3]

1.2 It is indisputable that air quality and public health are closely connected. Air pollution is intrinsically linked to various health issues, including cancers, respiratory infections, heart attacks, strokes, allergies, asthma, and dementia. With lung cancer being the leading cause of cancer deaths in Hong Kong, the situation is particularly dire for vulnerable groups such as children, the elderly, individuals with pre-existing conditions, and low-income communities. Furthermore, air pollution undermines the productivity and attractiveness of Hong Kong as a tourism, business and international financial hub. The expected increase in the number of climate-induced extreme events will likely exacerbate air pollution, posing further public health challenges.

1.3 Besides these concerns, air pollution during childhood can have a lasting impact and increase the risk of disease later in life. It is crucial to protect children from the harmful effects of air pollution before the preschool period.

1.4 With an ageing population in Hong Kong, continuous control of air pollution is required, or the public health gains due to past efforts will soon be offset by demographic shifts.

1.5 In order to attract and retain talent, strengthen Hong Kong’s role as an international financial centre, care for the elderly, foster a caring and inclusive community, and to achieve the vision of “healthy living”, ‘’low-carbon transformation” and “world class” set out in the Clean Air Plan 2035, CAN calls upon the Government to reassess the approach to tackling air quality comprehensively to include ambient, roadside and indoor air quality.

1.6 We recommend the Government continue to tackle air pollution with an inter-departmental approach:

Based on the Clean Air Plan 2035, it is suggested that continuous effort be made to address air quality issue holistically with the collaboration of all relevant bureaux and departments, and include local and regional experts from air science, health, transport, development, etc, during policy review and development, along the six key areas, namely Green Transport, Liveable Environment, Comprehensive Emissions Reduction, Clean Energy and Scientific Management and Regional Collaboration.

2. Strengthening Measures to Address Ambient and Roadside Air Quality

2.1 Overall, we urge the Government to continue tightening of the Hong Kong’s Air Quality Objectives (“AQO”) until they are levelled with the World Health Organization’s most stringent standards, ensure new energy infrastructure to support the adoption of new energy vehicles, formulate action plans to control ozone at ambient level, and provide details about the pilot scheme on electric ferries.

a) Tightening the Air Quality Objectives

• The Air Pollution Control Ordinance requires the Government to review the AQOs, the standards for various air pollutants in Hong Kong, at least once every five years. However, the current review mechanism does not guarantee the tightening of the standards. Without stricter AQOs, there is a lack of robust policy drivers to significantly improve air quality over time.
• In order for the long-term goal of levelling Hong Kong’s air quality with the World Health Organization’s most stringent standard can be achieved as soon as possible, during the current and future reviews of the Air Quality Objectives, we recommend the Government take proactive approach to ensure tightening of the target for each pollutant by at least one level under the guidelines of the World Health Organization each time.

b) Promotion of the Adoption of New Energy Vehicles

• Despite general improvements in ambient and roadside air quality over the last decade, roadside nitrogen dioxide and ambient ozone levels remain high. For nitrogen dioxide, which is commonly emitted through the tailpipes of road vehicles, the Government plans to introduce 700 electric buses (around 12% of all buses [4] ) and 3,000 electric taxis (around 17% of all taxis) by 2027 [5]. However, the uptake rate remains very low. We recommend the Government take comprehensive approaches to enhance the adoption of new energy trucks, lorries, non-franchised buses, and public light buses.
• As part of the comprehensive strategy to improve air quality, it is recommended that the Government expand the trials of new energy vehicles to encompass all types of student service vehicles, with a view to mandating the use of new energy vehicles for student service vehicles in a feasible time frame.
• The Government planned for the release in the first half of 2024 of a citywide green transformation roadmap and timetable for public buses and taxis [6], but such a roadmap has still not been made available. The Government should release the roadmap as soon as possible.
• In the 2022 Policy Address, the Chief Executive announced trials of new generation electric taxis, as well as hydrogen fuel cell electric double‑deckers and heavy vehicles, to be completed by 2025 [7]. The Government has also started a trial of electric public light buses in March 2024 [8]. We recommend the Government provide updates about the trials and release data from the trials, and include school buses, coaches and medium and heavy goods vehicles in the trials. The Government should also further promote the coverage of charging stations for electric vehicles.
• For hydrogen vehicles, we welcome the release of the Strategy of Hydrogen Development in Hong Kong in June 2024. We understand that hydrogen buses are now allowed in tunnels [9]. We recommend the Electrical and Mechanical Services Department provide updates on its work on the potential new Gas Safety (Hydrogen) Regulations, Cap. 51H to govern the use of hydrogen as a fuel [10].

c) Formulating an Action Plan based on the Completed Study on Regional Ozone

• For ozone, the HKSAR and Guangdong Governments initiated a three-year study to identify the causes of ozone formation in the Greater Bay Area and develop strategies to reduce regional ozone levels [11]. We recommend the Government formulate and release a roadmap and action plans to control ozone pollution, which surged to a 20-year record high in 2023.

d) Providing Details of the Pilot Scheme for Electric Ferries

• In 2021, the Government announced a pilot scheme for electric ferries that would start in 2023 [12]. We request that the Government provide details of the scheme, including the timeline of the scheme, the progress and expenditure so far. We also request information on the progress of building charging facilities at the berthing locations.

3. Addressing Indoor Air Quality

3.1 Policy discussions in Hong Kong over the past decade have so far focused on ambient and roadside air quality, however, IAQ is as important. Most people spend the majority of their time indoors. Recent scientific findings indicate that VOCs have surpassed diesel particulate matter (PM) as the primary inhalation cancer risk among ambient pollutants in Hong Kong [13]. It is generally believed that most ambient VOCs come from indoor environments. The Government should take note that the inhalation cancer risk profile has shifted from ambient to indoor pollution sources.

3.2 In response to COVID-19, the Government has committed to strengthening the capacity to combat communicable diseases. As most communicable diseases are transmitted via air as the medium, it is important to strengthen air quality control especially indoor places where vulnerable communities stay, with high density of occupants or prolonged period of stay.

3.3 With more ageing buildings in Hong Kong, the worsening indoor environment, including the under-managed indoor air quality, would continue to threaten the health and well-being of the occupants. It is particularly important to ensure good IAQ among places where the vulnerable communities spend a lot of time in, including the nurseries, child care centres, elderly homes, etc.

3.4 Specifically, we recommend the Government formulate a comprehensive roadmap to manage IAQ. The roadmap should cover the following areas:

a) Tackling IAQ with an Inter-Departmental Approach

• Since IAQ policy would involve the contribution of experts at various bureaux and departments, particularly those responsible for and specialise in the environment (Environment and Ecology Bureau (EEB) and Environmental Protection Department (EPD)), health (Department of Health), buildings (Architectural Services Department and Development Bureau), engineering (Electrical and Mechanical Services Department).
• We recommend the Government formulate the objectives and work plan for the Inter-Departmental IAQ Management Group [14].

b) Legislating for IAQ

• The Air Pollution Control Ordinance, Cap. 311 should be amended to include IAQ objectives in the long run, with more stringent standards prioritised for places where vulnerable groups stay.
• Since a one-off revision of the IAQ objectives in the voluntary IAQ Certification Scheme in 2019 [15], the EPD has not updated the objectives.
• We recommend a regular review of the indoor air quality objectives, similar to the Air Quality Objectives review for ambient air quality, provided by the Air Pollution Control Ordinance.
• Specifically, the IAQ objectives in the IAQ Certification Scheme do not currently include one for PM2.5 [16], although the WHO has pointed out that there is no convincing evidence of a difference in its hazardous nature from indoor sources as compared with those from outdoors sources. We recommend the inclusion of PM2.5 in the IAQ objectives.
• Several jurisdictions around the world have adopted mandatory regulations and policies for indoor air quality management. For example, South Korea has legislated on IAQ since 1998. South Korean legislation mandates IAQ monitoring in public spaces and more stringent IAQ standards for vulnerable groups such as children and the elderly [17], as well as the use of air purifiers in schools [18].

c) Developing Support for Pre-Schools and Hospitals

• The Government’s Indoor Air Quality Management Group should also develop guidelines for pre-schools, hospitals and clinics, in addition to the existing guidance notes for schools and elderly homes [19].

d) Setting an Example for Data Transparency

• In its Clean Air Plan 2035, the Government stated that it would apply micro-sensors to monitor indoor air quality [20]. We believe the Environment and Ecology Bureau should continue to collect and release IAQ data on an ongoing basis for the public to understand the level of risk across the city.
• Also, we recommend all Government buildings implement continuous monitoring and reporting of IAQ data to demonstrate good practices.

e) Expanding the IAQ Certification Scheme

• Currently, the IAQ Certification Scheme only applies to premises with a mechanical ventilation and air conditioning (MVAC) system and excludes places with only window-type or split-type air conditioners [21], which means that many places, including schools and elderly homes, are not eligible.
• With growing interest among various sectors to enhance IAQ management, the EPD should expand the IAQ Certification Scheme to allow schools and elderly homes to participate.

September 2024

Civil Service Bureau
Education Bureau
EEB
Food and Health Bureau
Transport and Housing Bureau
Architectural Services Department
Buildings Department
Customs and Excise Department
Department of Health
Electrical and Mechanical Services Department
EPD (the Chairman)
Fire Services Department
Food and Environmental Hygiene Department
Government Property Agency
Housing Department
Labour Department
Marine Department
Social Welfare Department
Transport Department [22]

[1] Elevated levels of nitrogen dioxide can cause damage to the human respiratory tract and increase a person’s vulnerability to, and the severity of, respiratory infections and asthma. Long-term exposure to high levels of nitrogen dioxide can cause chronic lung disease.
[2] Breathing ground-level ozone can trigger a variety of health problems including chest pain, coughing, throat irritation, and congestion. It can worsen bronchitis, emphysema, and asthma. Ozone also can reduce lung function and inflame the lining of the lungs. Repeated exposure may permanently scar lung tissue.
[3] According to the statistics of the Environmental Protection Department on roadside air quality in Hong Kong in 2023.
[4] “Hong Kong: The Facts,” Government of the Hong Kong Special Administrative Region, accessed 2 September 2024, https://www.gov.hk/en/about/abouthk/factsheets/docs/transport.pdf.
[5] “The Chief Executive’s 2022 Policy Address,” Chief Executive, accessed 2 September 2024, https://www.policyaddress.gov.hk/2022/public/pdf/policy/policy-full_en.pdf.
[6] Ibid
[7] The Chief Executive’s 2022 Policy Address,” Chief Executive, accessed 2 September 2024, https://www.policyaddress.gov.hk/2022/public/pdf/policy/policy-full_en.pdf.
[8] “LCQ11: Promoting green transformation of public land transport,” Government of the Hong Kong Special Administrative Region, accessed 2 September 2024, https://www.info.gov.hk/gia/general/202406/19/P2024061900193.htm.
[9] “Hydrogen bus makes maiden cross-harbour trip,” Radio Television Hong Kong, 14 July 2024, https://news.rthk.hk/rthk/en/component/k2/1761546-20240714.htm.
[10] “Consultation Paper: Proposed Amendments to the Gas Safety Ordinance (Cap. 51),” Electrical and Mechanical Services Department, accessed 2 September 2024, https://www.emsd.gov.hk/filemanager/en/content_1519/GSO_consult_2024_1.pdf.
[11] See note 2 above.
[12] “Govt preparing for electric ferries,” Government of the Hong Kong Special Administrative Region, accessed 2 September 2024, https://www.news.gov.hk/eng/2021/07/20210707/20210707_155908_673.html.
[13] Wong et al., “Characterization of toxic air pollutants in Hong Kong, China: Two-decadal trends and health risk assessments,” Atmospheric Environment, 314, https://doi.org/10.1016/j.atmosenv.2023.120129.
[14] The list of bureaux and departments in the Inter-Departmental IAQ Management Group can be found in the Appendix I.
[15] “Background,” Environmental Protection Department, accessed 24 July 2024, https://www.iaq.gov.hk/en/iaq-certification-scheme-background/.
[16] “Update of the IAQ Objectives,” Environmental Protection Department, accessed 20 August 2024, https://www.iaq.gov.hk/wp-content/uploads/2021/04/annex-summary-of-old-and-new-iaqos_eng_v2.pdf.
[17] Articles 12 and 5(2), Indoor Air Quality Control Act, Statutes of the Republic of Korea, accessed 29 August 2024, https://elaw.klri.re.kr/eng_mobile/viewer.do?hseq=63632&type=part&key=39.
[18] Article 4-3, School Health Act” ECOLEX, accessed 30 August 2024, https://www.ecolex.org/details/legislation/school-health-act-lex-faoc219769/.
[19] “Guidance Notes for the Management of IAQ in Schools and Elderly Homes,” Environmental Protection Department, accessed 2 September 2024, https://www.iaq.gov.hk/en/resources-guidance-notes-for-the-management-of-iaq-in-schools-and-elderly-homes/.
[20] “Clean Air Plan for Hong Kong 2035,” Environment Bureau, et al., accessed 2 September 2024, https://www.eeb.gov.hk/sites/default/files/pdf/Clean_Air_Plan_2035_eng.pdf.
[21] “Applicability,” Environmental Protection Department, accessed 24 July 2024, https://www.iaq.gov.hk/en/iaq-certification-scheme-background/.
[22] “Guidance Notes for the Management of Indoor Air Quality in Offices and Public Places,” Indoor Air Quality Management Group, accessed 29 August 2024, https://www.iaq.gov.hk/wp-content/uploads/2021/04/gn_officeandpublicplace_eng-2019.pdf.