With regards to the documents released by the government administration on “Work Plan of the Review of Air Quality Objectives” on 30th Mar 2016, Clean Air Network is concerned with the following areas:
1) WHO Interim Target is inadequate to protect public health
In order to safeguard public health, Clean Air Network has urged that the HK AQOs reach the World Health Organization’s (WHO) most stringent Air Quality Guidelines (AQG) levels. For instance, the current AQO for 24-hr SO2 level (125µg/m3) is too loose as most of the time the level does not exceed 20µg/m3.
According to WHO, Interim Targets do not provide adequate protection for public health when compared with the AQG levels. Thus, the EPD needs to set time targets with milestones for achieving the AQOs.
Achieving Interim Targets only but failing to achieve WHO AQG levels would result in a 2.5-5% increase in short-term mortality rate and 15% in long-term mortality rate (for particulate matters).
2) Frequency of review
According to the Work Plan, the amendment bill would be introduced to the LegCo by Mid 2019 if the AQOs are to be tightened. Clean Air Network urges the government to conduct AQO review in a higher frequency. An interim review should be conducted in 2017 in order to ensure that the progress is on track.
3) Working Group
Clean Air Network welcomes the formation of Working Groups comprising different stakeholders including air scientists and NGOs. And CAN emphasizes that such Working Groups should become a core part of the review mechanism, i.e. be formed in every review. The formation and engagement process should be open and transparent.
The Working Group should conduct health impact tracking studies for cost-benefit analysis of various policy measures. And ideally, the Working Group should look into specific key air pollutant concentrations according to changes in pollution trend, i.e. tightening of the AQOs be conducted in piecemeal for each pollutant so that the review can react and respond to the new situation more quickly.
According to the documents, the Working Group will look into control measures for “other lesser air pollution sources”, such as aviation and volatile organic compounds emission sources. CAN believes the Working Group should also look into major air pollution sources, such as roadside and ship emissions, and suggest feasible transportation planning policies that can reduce traffic demand and improve air quality in HK.