Oct 08 petition re air pollution

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    Greenpeace has an online petition re HK air quality objectives – to collect public opinion before 30 November 2008:

    Hong Kong has commissioned consultancy company Ove Arup to investigate how the city’s Air Quality Objectives should be changed and to collect public opinion on this issue before November 30. There’s no time to waste. Please sign up below to add your voice to those who are calling on the Hong Kong government to start grading air quality with the same standards that the World Health Organisation uses and to draw up a plan with a firm timetable that will ensure that Hong Kong people can start breathing clean and safe air.

    Take Action: Get the truth about the air you breathe


    I’ve received this standard reply from govt:

    Dear Sir/Madam

    The Environmental Protection Department has commissioned in mid 2007 an 18-month comprehensive study to review Hong Kong’s Air Quality Objectives (AQO) and develop a long-term air quality management strategy.

    The study has examined the latest findings on review of air quality standards by the World Health Organisation, the European Union and the United States. It will also consider factors including protection of public health, cost effectiveness, society’s expectation, maturity of the technologies needed, the need to work with the Mainland as well as impacts on other policy areas such as energy, transportation, industrial development, urban planning and conservation for devising a new set of AQO and a long-term air quality management strategy and measures for Hong Kong.

    The Government intends to announce the preliminary recommendations in early 2009, to be followed by a comprehensive public engagement exercise, to work out a long-term air quality management strategy within 2009.

    Thank you for your concern about the environment.

    K.W. CHENG


    I wasn’t impressed by the standard response; emailed govt:

    Thanks for the reply.

    Makes no mention of whether public opinion is indeed being gathered – and of whether the views I emailed will be taken into account.

    Do people in Hong Kong matter?

    – or to what extent are health issues over-ruled by cost-effectiveness, transport, industry, and urban planning?

    Received this reply, which far better:

    Dear Dr Martin Williams,

    Thank you for your email of 16.10.2008.  Yes, public’s opinion is being
    gathered. Their opinion including yours would be duly considered in
    devising the new Air Quality Objectives for Hong Kong as well as the
    strategy for the achievement of the new Air Quality Objectives. To ensure
    transparency in the course of the study, this department held two public
    forums in December 2007 and January 2008, respectively.  You may wish to
     for details.    We are also planning to stage another public forum
    probably this coming December to report on the study progress and solicit
    views from the public on some preliminary  findings.   Please watch out for
    the advertisement in the newspapers or visit the EPD homepage nearer the
    time for details.  After completion of the study, we plan to launch a
    thorough public engagement process to seek public’s view on the findings
    and recommendations of the study so as to finalize the new  Air Quality
    Objectives and the required long-term strategy on air quality management
    within 2009.

    On your second question, you may be interested to know that protecting
    public health and minimizing the impact of air pollution is the major
    consideration in drawing up the new Air Quality Objectives.  On this
    premise, the review will be undertaken with reference to World Health
    Organisation Air Quality Guidelines and the latest scientific evidence on
    the adverse health effects of air pollution in determining the new Air
    Quality Objectives.

    ( C. Y. MAK )
    for Director of Environmental Protection



    I sent the above email to Professor Anthony Hedley, of Dept. of Community Medicine, HK University. He wasn’t impressed: noted that Donald Tsang has pre-empted the Ove Arup report, and any conclusions by advisory panel.

    – prompted me to remember that the SCM Post lately had item inc Hong Kong maybe to adopt something akin to the least stringent WHO air quality targets, which are more for Third World countries – not for anywhere that calls itself a "World City".


    Just received from Professor Hedley – a letter he sent HK Standard, in response to enquiry re government and the apparently bogus public consultation:

    In my opinion the Hong Kong Government’s Environmental Protection Department (EPD) response is purpose-designed as a serious deception which is about to be perpetrated on the Hong Kong public.  For example the Interim Target – 1 level for 24 hour particulates is 150 µg/m3.  However this level is so lax that it is already well above the maximum level observed on 99% of the days of the year.  So the government will be able to say that it has achieved the Interim Target -1 on all but 3 days in the year without having made any difference to daily pollutant levels.


    Although I doubt we would agree to it they could have set the 24 hour IT-1 for Hong Kong at the 99th percentile for, say, 2006 which would be 135 µg/m3.  That at least would have been a notional tightening of the air quality regulations.  As things stand there is scope for developers to actually push pollution levels upwards so that the upper quantiles of the pollution profile approach 150 µg/m3 rather than 135 µg/m3.


    The proposed IT-1 level of the targets actually stipulates a higher level of average annual particulates, at 70 µg/m3 than the present outdated Air Quality Objective of 55 µg.  It is not clear whether they will actually also adopt the IT-1 annual figure of 70 as well as the 24 hour figure of 150.  If they do then this will be a serious retrograde step.  The point is however that they should be selecting an effective 24 hour level together with an appropriate annual standard.  There is good evidence from analyses, considered by the WHO when they set the guidelines, that these are two indivisible measures and not separate issues when it comes to considering public health goals.


    It is now very clear that from Minister Edward Yau’s latest pronouncements about the cost of pollution controls, repeated by his new undersecretary Kitty Poon on RTHK Backchat today, that it is government official policy to trade off the health of children (for example in terms of lung growth and development and future health related quality of life and their life expectancy) against the marginal costs incurred by manufacturers to clean up their business.


    Our Air Quality Objectives Concern Group (AQOCG), coordinated by Civic Exchange, has repeatedly emphasized that the price being paid for goods manufactured in the Pearl River Delta does not reflect their true cost.  The real cost to the community includes the burden of ill health, health care costs and lost productivity due to illness and premature death.  One of the worst outcomes of course is damage to the health of growing children.


    The low level IT-1 targets were intended for poor countries, with low capacity to tackle air quality problems, as an “entry level” approach to environmental management.  They are not there so that rich regions like Hong Kong can procrastinate over urgent environmental health matters.


    The EPD claims that other socioeconomically advanced countries and regions have not yet adopted the WHO guidelines.  However none of these countries have anything like the levels of pollution being experienced by Hong Kong and the PRD.  In addition, as pointed out by Dr Alexis Lau on RTHK Radio 3 Backchat today, these countries are actively working on this, in an evidence-based approach, and will predictably adopt more stringent regulatory measures in the near future.  There is now serious doubt that Hong Kong will do this on any kind of appropriate time scale.  The fact that the government has made this announcement in advance of the report from the review they implemented, conducted by Ove Arup at a cost of $6 million, means that the whole process of a supposedly evidence based review has been corrupted.  How many of the independent overseas advisors to Arup would agree with the selection of IT-1 as the next step in environmental management?  Was the Advisory Panel to the Environment Bureau, for this project, consulted before this announcement was made?


    The EPD has repeatedly and consistently rebutted or ignored our reports on the attributable (that is avoidable) illness and premature deaths from pollution and the on-going burden of costs to the whole community.  There is no mention of the word health in any of the recent pronouncements by Secretary Edward Yau or Undersecretary Kitty Poon.  Of course when challenged they readily concur that this is a health issue, but when making leading statements to the media they argue that this is a cost issue.  This direction in the government’s agenda is undoubtedly coming from the very top and as a result the Environment Bureau is not a credible independent evidence-based decision making body. 


    There is no one in government with relevant background, qualifications and experience in environmental health who has the authority and opportunity to speak to these issues and counter the biased and misleading statements made on the current status of air quality and the potential solutions to it.  To my knowledge no Secretary for Health nor Director of Health has ever made any statement about air pollution and its health effects.  The Department of Health is not involved in any way in deliberations about air quality and safety or the prevention of cardiovascular and respiratory illness which results from it.  So, in this respect environmental health management and regulation is completely rudderless and will only be determined by the narrow and mistaken viewpoints of the senior management (CE, CS and FS) on the costs of a clean up, rather than the external costs to population health.


    The environmental health lobby led by agencies such as Civic Exchange, other NGOs and the Universities have made a considerable impact on the evidence base, public awareness and advocacy in general.  However the government is digging in and will railroad through cosmetic measures despite the demonstrable need for urgent radical action.


    We have debating all these issues for a great many years, but the people of Hong Kong will be breathing dirty air for many more years to come.



    Professor AJ Hedley MD

    Department of Community Medicine

    School of Public Health

    The University of Hong Kong


    Just sent to EPD:

    Is the Ove Arup survey valid, or have decisions already been taken re HK air quality objectives?

    – Donald Tsang indicated something re this.

    Do we, in our self-proclaimed World City, look set to have Third World air quality objectives – WHO standards aimed at being first rung on ladder for developing nations wishing to try for some improvements to dire situations?

    I’m sure much is frustrating for you guys in EPD – surely joined in hopes of making Hong Kong – and the world – a better place, but instead hard to do much apart from monitor the filth.

    filthy air filter

    I’m attaching a shot of an air filter, which I’ve just taken out of filter machine in my 3-year old son’s bedroom.

    Bought the machine in hope of reducing adverse impact of particulates on his growing lungs; maybe a couple of years ago.

    Other than extremely rare cases when very very high pollution in daytime, this filter has been used only at night, in room with closed door. Chiefly from autumn to spring, when air quality here worst.

    We live on Cheung Chau – so not so affected by street level pollution; more the regional pollution – south China, with HK contributions.

    This filter was white to start with; I’ve put a piece of white paper on top.

    The grey stuff, then, is from particulates (there’s another filter in front, takes out much of larger dust): just gives some indication of the crap that people here breathe day in, day out. And if like this on Cheung Chau, what is the situation in the city?

    You – in EPD – know all this of course; surely used to seeing filthy filters, inc all the hideous soot gathered in monitoring stations.

    There was great fuss made over melamine – horrible problem, but rather small impact; SARS got monster coverage but killed relatively few, yet air pollution seems mostly a minor issue.


    This reply from EPD:

    Thanks again  for your email of 24.10.2008.  The decisions of what Hong

    Kong ‘s new air quality objectives have not been made yet. As I have

    mentioned to you before that after completion of the study, we plan to

    launch a thorough public engagement process to seek public’s view on the

    findings and recommendations of the study.  We will consider thoroughly the

    views of  the community before finalizing the new air quality objectives of

    Hong Kong within 2009.

    Thanks again for your keen interest to clean air and hope to see you in our

    coming public forum.[.quote]


    Just sent this to Ove Arup, consultant looking at public opinion re HK’s new air quality objectives; you too can comment, by email to: [email protected]

    I wish to comment on Hong Kong’s moves towards new air quality objectives.

    Firstly, it is woeful that we have such antiquated air quality objectives; good that the objectives are to be revised.

    Then, as a "World City", Hong Kong has an obligation to have Air Quality Objectives that meet the best science based evidence, and put people’s health first.

    This means adopting the WHO’s most stringent guidelines.

    Sadly, this is not to say that we will then promptly achieve the objectives, but we will know the goals.

    Further, the objectives should be subject to regular (annual?) review, again based on the best international science.

    It may seem startling to aim for high standards – why not just shilly shally, set "Objectives" that suit our filthy air, and so are readily achieved, never mind the health of local people?

    But, as a "World City" we should aspire to the best.

    – also, sadly, in Hong Kong we have become accustomed to having a polluted environment. Local children surely think it’s normal that for much of the year the sun doesn’t set on the horizon, but fades into smog. Plus, our beaches too often fail to make the A grade; several seem stuck in dire condition.

    So, I doubt many people will be startled that there is a gulf between our air quality and our objectives – but at least we will all be aiming for air of a standard befitting a "World City" (once dubbed the "Pearl of the Orient" – a grubby pearl these days).

    While to adopt less stringent standards, to aim low: that would be shameful for our "World CIty", showing political expediency – and lack of political courage – trumping the importance of human health.

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