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The Hong Kong Environment: A Green Challenge for the Community - Second Review of the 1989 White Paper on Pollution in Hong Kong

Mr A G Cooper
Government Secretariat
Planning Environment & Lands Branch
Murray Building
Garden Road
Hong Kong

8 April 1994

Dear Mr Cooper

THE HONG KONG ENVIRONMENT: A GREEN CHALLENGE FOR THE COMMUNITY - SECOND REVIEW OF THE 1989 WHITE PAPER ON POLLUTION IN HONG SONG

We have had the opportunity to consider the above Paper published by your department in November 1993. I include below our comments on the Paper for your consideration.

We would appreciate the opportunity to meet you to discuss our environmental concerns further. We found our meeting with your department in November 1992 most useful and would welcome the opportunity to continue our dialogue.

Our brief comments on the Paper are as follows:

1 GENERAL

When we met you in 1992 we expressed our concern that Hong Kong needed an environmental policy. At that point a good deal of work had been done on pollution, following the 1989 White Paper, but there was no comprehensive statement on broader issues of conservation and the environment. We expressed the hope that the opportunity might be taken to produce a Green Paper on environmental policy to guide the territory over the years ahead.

We were therefore somewhat disappointed that no such Green Paper was published, but instead a Second Review of the 1989 White Paper on Pollution. We felt, and still feel, that most of what can be done on the basis of that White Paper has been done - this is shown by the comprehensive review of progress against the White Paper's targets in Annex A of the Second Review. Yet there are a host of environmental problems in Hong Kong that remain to be addressed.

Nonetheless, we read the Second Review with interest, and note that in substance it is a discussion of broad environmental policy. While we regret that it is not actually a Green Paper, we appreciate the comprehensive treatment of environmental issues that the Second Review comprises. We found it generally a good articulation of the principles that should guide Hong Kong's environmental policy.

Following this, we feel that the need is now to translate this general statement of principles into specific action that will improve Hong Kong's environment. Some specific points follow.

2 SPECIFIC POINTS

2.1 Institutional structure

As we stated in our meeting with you, we are concerned that the current departmental structure - with Environment lumped together in one branch with Planning and Lands - does not give a sufficiently high profile to environmental policy. There is a danger that where planning and land use objectives conflict with environmental objectives the former will prevail. We are not persuaded by the argument that having the three functions within one branch assists coordination. Some other countries, Britain for example, have a separate department of the environment. We consider that there should be a separate Environment Branch in Hong Kong.

We also have some concern at the proliferation of advisory committees. An Environmental Efficiency Committee and an Environmental Programme Committee appear to have been added to the original EPCOM (now ACE) and the ECC. We believe that if advice is required, more independent advice can be obtained from the various green groups, from legislators and from political and community groups. We have concern at the continuation' let alone proliferation, of advisory groups appointed by the executive in Hong Kong's increasingly democratic environment.

2.2 Policy issues

While generally we found the Second Review comprehensive, there were some points that appeared neglected, or which could have been treated more fully.

The economic case for good environmental practice could be put more strongly. The Paper dwells on the cost of environmental measures, and on the possible trade off between economic growth and environmental quality. These problems are well treated in the Paper, but they are not the whole picture. A sound environment can yield definite economic benefits. Tourists, a major source of Hong Kong's earnings, are increasingly deterred by pollution and attracted by unspoilt scenery and cultural sites. Customers for Hong Kong's products are increasingly concerned as to the environmental effect of the product's manufacture. Hong Kong has to continue to attract investors and executives from overseas, and money alone is not enough: a healthy environment for them and their children is increasingly important. There is also scope for Hong Kong to utilise its relatively advanced understanding of environmental protection in the China market. There are economic carrots as well as sticks to encourage environmental good behaviour.

Effective deterrents. The sticks themselves must also be more effective. We would like to see heavier fines for environmental offences by business, particularly persistent offences, as some companies regard the light fines that are currently payable simply as a cost of doing business. We would also like to see on-the-spot fines for smoking vehicles, possibly administered by the police on a similar basis to traffic fines.

Conversion of agricultural land. We do not feel that enough attention was devoted in the Paper to the problem of the containerisation of the New Territories, and the uncontrolled conversion of agricultural land in the islands. Urgent action in needed on this issue.

2.3 Other issues

Sick buildings. Although we are not aware of any comprehensive study of the subject we suspect that sick buildings, and buildings with asbestos and other undesirable materials, are at least as great a problem in Hong Kong as they are in many developed countries, possibly a greater problem. This is an issue, not discussed in the Paper, that should be examined.

Waste separation. The Paper discusses waste separation, but neglects to mention that - certain major companies apart - institutionalised waste separation in the territory is quite limited. It would be a simple matter for bottle banks and other waste separation facilities to be installed in residential blocks, but this has not been done. Such separation as is performed is done after the event by the waste collectors themselves and by elderly people. We believe that it would be very simple, and would have a major educative effect on the population, for waste separation facilities to be introduced in residential blocks. An example could be set by government quarters and Housing Authority estates.

Vehicle emissions. The Paper expresses a preference for petrol rather than diesel vehicles. However we understand that in fact a well-maintained diesel engine emits no worse pollution than a petrol engine, and has the benefit of being more efficient. The problem lies in maintenance and the type of diesel engine used. We recommend above that on the spot fines be considered as a deterrent to poor vehicle maintenance. We also recommend that the oil companies be encouraged to switch to low sulphur fuels, as they have done for example in the Scandinavian countries. Finally, the Government should adjust the taxation of vehicle fuels so as to encourage the use of those that are less polluting.

Use of hardwoods. An example should be set by government and Housing Authority estates in exploring substitutes for hardwood floorings. Preference should be given to contractors with environmentally friendly techniques.

I hope that the above comments are helpful. We would like to meet with you to discuss our environmental concerns further. Finally, we would like to note again our appreciation of the effort that has gone into the Second Review - which we believe, despite its name, may serve as a guide to environmental policy in Hong Kong over the coming years.

Yours sincerely

Dr. Patrick Shiu
Chairman