As the Hong Kong government prepares to confirm new Air Quality Objectives (AQOs), Blue Skies China has joined the AQO Review Coalition (AQORC), a group of now 17 organisations established in July 2018 and including environmental groups, medical organisations, Legislative Council members and lawyers.
The AQO Review Coalition was formed by Hong Kong NGO Clean Air Network to address the Hong Kong government’s AQO review for the 2020-2025 period. Under Hong Kong’s Air Pollution Control Ordinance (Cap. 311), the Secretary for the Environment is required to review the AQOs at least once in every five years and submit a report of the review to the Advisory Council on the Environment.
According to the AQORC, the proposals for 2020-205 only “tinker with” Hong Kong’s air quality objectives.
“Should the recommendations in EPD’s Report be approved, in the coming five years, Hong Kong’s AQO will continue to significantly fall short of the safety standards established by WHO. In other words, even the air quality complies with the EPD’s recommended AQO, Hong Kong citizens’ health will continuously be affected by air pollution, even after this 2nd AQO review.” says the coalition.
Specifically, members of the coalition will lobby the Legislative Council Panel on Environmental Affairs on Monday 25 March, urging the government to reduce the number of “free pass” exceedence days the government plans to give itself under tightened air quality proposals.
According to a position paper by the coalition, under the government proposals to increase the number of allowable exceedances of PM2.5 limits from 9 to 35, “the population in Hong Kong would be exposed to an additional 24% health risks every year.”
The government’s latest proposals are:
- the 24-hour AQO for SO2 be tightened from Interim Target-1 (IT-1) level (125μg/m3 ) of the WHO AQGs to Interim Target-2 (IT-2) level (50μg/m3 ) with the current number of exceedance allowed (three) remains unchanged and;
- the annual AQO for PM2.5 be tightened from IT-1 (35μg/m3 ) to IT-2 (25μg/m3 ); and its 24-hr AQO from IT-1 (75μg/m3 ) to IT-2 (50μg/m3 ) with the number of exceedances allowed increased from the current nine to 35.
The government does not include recommendations on tightening standards of other air pollutants. In addition, the government has admitted to flying blind with respect to emissions data from the Greater Bay Area, claiming there is no official projection for the region, despite so-called cooperation with the Guangdong government on emissions control in the region. “Since official projection beyond 2020 is not available, there is no basis for us to make arbitrary assumptions beyond the latest official projection available at the moment.”
The government has claimed a number of pollution exceedances is allowed under WHO guidelines. However, those WHO guidelines only suggest exceedances of pollution targets for cases of “extreme weather” and other situations out of the government’s control: for example heatwaves and drought causing hill fires. It is unclear how “light winds”, happening 35 times a year, can count as “extreme weather” in giving the government a free pass against its own air pollution targets. The guidelines also call for a comprehensive emissions inventory which, as reported by us, is something lacking in Hong Kong and the Greater Bay Area.
Blue Skies China is honoured to join the coalition and join the fight against air pollution in Hong Kong.
The full text of the coalition’s March 2019 petition to government is below:
- The government proposes to greatly increase the number of exceedances from PM2.5 from 9 times to 35 times a year. According to a research by Prof. Hedley from the School of Public Health at the University of Hong Kong, population in Hong Kong would be exposed to an additional 24% health risks every year, if the government were allowed to increase the number of exceedances while tightening the concentration limit of Air Quality Objectives (AQO) of a particular pollutant at the same time.
- The AQO Review Coalition opposes to the government proposal to relax the number of exceedances to 35 times a year for PM2.5. The reason for setting up such number is that the government assumes the level of PM2.5 would exceed the proposed AQO for 33 times in 2025 according to their own estimation. The proposal simply ignores the importance of protecting citizens’ health.
- The government should estimate and release all relevant health risk data to the public related to the exceedance proposal. The public ought to know which scenario will pose a more serious health threat to society – whether an AQO with a higher concentration limit, but with fewer number of exceedances “allowed”, or an AQO with a lower concentration limit, but with much more number of exceedances “allowed”, would be considered a more “worse” AQO that impedes public health.
- More importantly, the government proposal of increasing exceedances would set a very bad precedence – what is the meaning of reviewing AQOs then, if the standard could be allowed to exceed virtually endless times? If “extreme weather” can be the reason to a greatly increased exceedances “allowed” from 9 times to 35 times, what other reasons do we have to stop the next phase of review from further increasing exceedances “allowed” to, say, 300 times?
- According to the Air Pollution Control Ordinance (APCO) (Cap. 311) Section 7A, the Secretary for the Environment should review AQO in a way to conserve air quality and promote public interest. How can a proposal with increasing pollution allowed fulfill APCO major objective to “abate, prohibit and control pollution of the atmosphere”?
- If the emission reduction policy proposed by the government remains effective, the number of times a particular pollutant exceeds AQO should be reduced accordingly. It should be expected that the number of exceedance “allowed” will be decreased after 5 years’ time for each review period. To keep the number of exceedance “constant”, or even increasing the number by whatever means, should not be justified from a public health point of view.
- Levels of PM10 and ozone, the two pollutants with AQOs remained unchanged in the government proposal, would be increased by 5.7% and 18% in 2025 respectively, compared to the levels in 2018. The government should tighten the AQOs for the two pollutants and show the willingness to combat air pollution. It is a shame for the government to argue that AQO is not the policy driver for introducing and implementing more radical emission reduction measures.
- According to the Hedley Index published by HKU School of Public Health, there were 10,106 premature deaths caused by air pollution in Hong Kong in the past 5 years. The air quality in Hong Kong never fulfils the World Health Organization Air Quality Guidelines (WHOAQGs) and seriously impedes citizens’ health. The AQO Review Coalition urges the government to tighten AQO to WHO AQGs as soon as possible to ensure public health in the city.
The coalition requests:
- Withdraw the proposal to increase exceedances to 35 times a year for PM2.5
- Tighten AQOs for PM10 and ozone
- Tighten AQOs to WHO AQGs as soon as possible
 Lai, H. K., Wong, C. M., McGhee, S., & Hedley, A. J. (2011). Assessment of the health impacts and economic burden arising from proposed New Air quality objectives in a high pollution environment. The Open Epidemiology Journal.
 Summarized from Clean Air Plan for Hong Kong 2013-2017 Progress Report and the paper of AQO Review Working Group Air Science & Health Sub-group for the 6th meeting