Re: A Proposal to Ban Idling Vehicles with Running Engines
5 February 2008
Environmental Protection Department
Mobile Source Control Group
Room 4518, 45/F Revenue Tower
5 Gloucester Road
Wanchai
Hong Kong
Dear Sir,
Re: A Proposal to Ban Idling Vehicles with Running Engines
We are writing to submit our views on the above consultation paper.
Overall, we are supportive of the paper, and welcome the Government's initiative. Although idling engines make only a small contribution to the territory's total pollution, they cause particular aggravation in sensitive areas, such as outside schools and shops, residential blocks and tourist sites. Switching off one's engine while stationary is a basic courtesy to others; enforcement would foster not only environmental awareness but also community spirit.
We are not in favour of exemptions, except where these can be very clearly delineated as in the case of emergency services, since exemptions tend to dilute the message and are difficult to police. Thus we believe the ban on engine idling should apply everywhere and at all times (except to emergency services, etc.), without any three-minute grace period. We also think that the ban should extend to idling during passenger boarding and loading/unloading, i.e. we disagree with the proposed exemption in 6.2(a). This practice is generally unnecessary as far as the comfort of those involved goes, and actually forces the passengers/loaders to inhale intense concentrations of pollutants in the process. In addition to traffic wardens and EPD staff, the police should also have authority and responsibility to enforce the ban, as they presently do other traffic violations (point 6.5).
The ban on engine idling will necessitate changes in behaviour. In hot weather, tourists will have to refrain from boarding their coaches early and drivers will have to get out of their cars and into any available shade. Invalids who cannot tolerate outside temperatures will have to plan their journeys so that any stops would be within reach of air-conditioned premises such as shopping malls. More thought should be given to how to encourage and facilitate the necessary behavioural changes. For example, some consideration should be given to identifying coach designs that allow natural ventilation - many modern coaches have no windows.
Our responses to the specific consultation questions are attached.
We would also encourage the EPD to work more vigorously to tackle vehicular pollution in other ways. Efforts should be made to introduce LPG cars, and to move the old and high-polluting elements of the fleet finally off the roads. Given the intense use of vehicles on Hong Kong's roads, as cited in the paper, and given the canyon effect of high buildings by the roadside, much greater effort is needed in Hong Kong than in overseas cities before a tolerable living environment can be achieved. We look forward to the Government's further efforts in this respect.
I hope that our views are helpful.
Yours sincerely,
George W H Cautherley
Vice-Chairman
Question (1) Do you agree that a statutory ban to require switching off the engines of idling vehicles should be introduced in principle? [Section 5.1]
Yes
Question (2) In addition to diesel vehicles, do you agree that the ban, if introduced, should also cover petrol and LPG vehicles? [Section 5.2]
Yes.
Question (3) Do you agree that certain types of vehicles be exempted from the ban for operational reasons? If so, which types of vehicles should be exempted? [Section 5.3]
No exemptions.
Question (4) Do you agree that the ban should be made territory-wide or applied only to some selected areas or hours during which the air is most polluted? If you are in favour of the latter approach, what would be the criteria for selecting the areas or hours of exemption? [Section 5.4]
Territory-wide, 24 hours.
Question (5) Do you accept allowing no grace period for drivers to leave their engines idle for a while after stopping? If not, what should be the appropriate grace period?
[Section 5.5]
No grace period.
Question (6) We would welcome views on the proposed implementation framework set out in sections 6.1-6.2 above. [Sections 6.1-6.2]
We generally agree with the proposed framework, except that we do not think that there should be exemption for boarding/alighting (6.2(a)). We are not convinced that security vehicles need exemption either, and recommend closer consideration of the rationale for this ((e)). We accept the need to allow running engines for ancillary purposes, but recommend that this area be subject to closer scrutiny in the future, i.e. when the existing policy has been in force for a while and experience has been gained ((f)). Likewise, we accept ((g)), the need for disciplinary forces, etc., to keep their engines running during operational exercises, but recommend further scrutiny of this area in future. We would also hope that when operational needs permit they would switch off their engines whenever possible as a courtesy to the community. We also wonder if vehicles engaged in a parade etc. ((h)) really need to have their engines on when stationary, particularly since by definition these vehicles will be surrounded by crowds and their emissions will cause maximum aggravation. Why can these vehicles not simply restart their engines when the parade starts moving again?
Question (7) Do you agree that the Government may exempt a particular area or a particular period of time from the statutory ban? If yes, what should be the criteria for considering such an exemption? [Section 6.3]
Yes, there should be provision for the Government to grant limited exemptions, but we wonder what grounds there could be for subjecting citizens to otherwise unnecessary pollution. We recommend that exemptions be granted only sparingly and only for very limited periods and extents.
Question (8) Do you agree that the ban should be effective throughout the year or waived during summer to allow drivers to keep the air-conditioning running for the comfort of drivers and passengers? [Section 6.4]
Throughout the year. The comfort of drivers and passengers, who will in any case enjoy air-conditioning when the vehicle starts, has to balanced against the health of passersby who would have to inhale their emissions.
Question (9) Do you accept that the violation be made a contravention (a minor infraction, with a fixed penalty of $320 as the only punishment)? [Section 6.5]
Yes, the penalty should be mild, at least in the initial period of the ban. In the longer run, further consideration should be given to applying more severe penalties for engine idling in confined spaces, such as carparks without external ventilation, since this practice can lead to build-up of carbon monoxide and be highly dangerous. In this latter regard, we would draw attention to the fact that a common method of suicide is to sit in one's car in the garage with the engine running. There was also the unfortunate case in Afghanistan following the 1979Russian invasion where a Russian military column was forced to halt in a tunnel and because engines were not switched off a large number of soldiers in the column died.
Question (10) Do you accept that the ban be implemented by fixed penalty system rather than summons? The former legislative scheme is to afford an opportunity for the driver to discharge his liability to contravention (or liability to conviction for that offence, if the violation is made a criminal offence) by payment of fixed penalty. [Section 6.5]
Yes.
Question (11) Do you accept pitching the level of fine at the same level as illegal parking, i.e. $320? If not, what should be the appropriate level? [Section 6.5]
Yes.
Reproduction of this paper is permitted with proper attribution to the Hong Kong Democratic Foundation