Feedback on the Consultation Paper

EMAHK submited our feedback on the Consultation Paper (the paper) “Hong Kong’s Climate Change Strategy and Action Plan” on Dec 10, 2010

1.      This submission constitutes the opinion of the Association and the feedback from the speakers and the audience at the Public Forum jointly organized by the EMAHK and the MSc. Environmental Management Programme of the University of Hong Kong on 20th November 2010.  There were over 40 members of the Association attending this Forum, including academics, environmental consultants, environmental managers, environmental engineers, governmental officers, businessmen and current postgraduate students from the University of Hong Kong, Hong Kong Polytechnic University and Hong Kong Baptist University.

2.      The feedback in this paper will be grouped into foursections:

a.       An overview (i.e., executive summary);

b.      Comments on the questions raised in the paper;

c.       Comments outside of the scope of the paper

d.      Suggestions from the EMAHK and

An Overview

3.      The EMAHK welcomes the consultation.  It is a good step towards engaging the Public on the issue of climate change, and the likely responsibility of Hong Kong to act on this particular subject.

4.      The facts and figures produced in the paper are very much in line with the current situation.  However, EMAHK believes that there is a severe shortage of absolute figures.  We believe it is much more suitable to express total emissions figures in terms of emissions targets (e.g., tonnes of CO2 or GHG per annual).  The Government can be a lot more generous in sharing such data with the Public while she should conduct more detailed scientific studies to accurately determine the inventory of our CO2, GHG and energy budget across various potential sources.

5.      The EMAHK believes that the scope of the paper is much narrower than desired.  The paper correctly identified emissions from power generation as the main source of emissions in Hong Kong, and went on to propose a change in the composition of power generation by source of power.  It did not fully address the issue of vehicular emissions, aviation and shipping emissions, nor did it address the opportunity to reduce power consumption.  Education, while briefly mentioned, was not given sufficient focus in the paper.  The issue of both solid waste and wastewater treatments was again insufficiently covered.

6.      We believe that using 2020 as a benchmark year is insufficient.  The international community, led by UNFCCC, generally request for targets beyond 2020 and up to 2050.

7.      The issue of climate change does not go away in the year 2020.  In fact, setting a target for 2050 should entail and facilitate longer term planning. We must have both mid- and long-term goals for GHG reduction in Hong Kong, given that the Government shall take a leading role and always anticipate to asking “What is next?” and planning ahead with a view to achieving sustainable development and balanced growth of our economy.

8.      There was little mention on how the goals in the paper are to be achieved. For example, how certain sources of energy can be obtained?  Where will the nuclear mentioned in the paper come from?  How it is going to affect Public finance and cost of energy?  If substantially reducing the use of coal, what shall we do with the existing coal-based power plants (which are newly installed with advance and expansive scrubbing system to remove sulfur)?  How much will Hong Kong pay to attain the limited goals as detailed in the paper?

Feedback to consultation questions:

9. Question (1) Do you notice more extreme weather in Hong Kong, such as more hot days and heavier rainfall? Do you think climate change is affecting us?

Yes, it is sensed that the weather of Hong Kong is getting hotter in recent years and the figures provided from the consultation document also proved that.

Climate change could be one of the factors caused such weather and we also believed other factors such as urban heat island effect also lead to extreme weather, particularly high temperature in the urban area.

It is no doubt that all extreme weather would affect us in different ways, thus properly addressing all root causes is essential

  1. Question (2) In the light of international and national developments, do you agree that Hong Kong should adopt a carbon intensity target to guide our futures actions to control GHG emissions?

EMAHK agrees that a target to be set but using carbon intensity with relative measure based on GDP is insufficient. Hong Kong should alternatively consider a target of emission per capita as well.

11. Question (3) Do you agree that the community should conserve energy and use greener transport to reduce local GHG emissions? What do you think you could do as an individual or as a business enterprise?

Yes. It is essential to conserve energy and reduce GHG emission at source. Bus is the major source of GHG emission from vehicles in Hong Kong, changing to ERUO 5 engine should be set as immediate target. Consideration in using other cleaner fuel like LPG and electricity should also be given and promoted.

EMAHK is a group of individuals that believe we could do something, like provide our professional opinions to help to shape a better environment.  We also would like to make the environmental management to be a more reachable subject and transfer knowledge to general public, thus every individual can do their part.

12. Question (4) Will you agree to the proposed strategy of reducing use of coal and increasing use of natural gas and non-fossil fuels in meeting local electricity demand? Do you think the proposed fuel mix is appropriate for Hong Kong in 2020, with regard to such considerations as better environment, availability, reliability and cost?

In response to the aggressive proposal of increasing the nuclear energy from 23% 50% in 2020 ,  the EMAHK supports the use of nuclear power only as an interim solution before clean energy can be economically used. However, even so, we need the Government to inform the Public on the source of such energy, the cost to Hong Kong, and most importantly, to give assurance on the safety aspect of the building and operation of nuclear power plants.  In addition, there should have a complete evaluation of the carbon footprint including the building of nuclear power plant, mining and handling the nuclear waste.

It is clear that Hong Kong lacks its own control on energy source if we start to import nuclear energy. However, in the proposal there is only 3-4% in RE. Grid storage for power generated by windfarms must become a high priority in our action plan.

With a drastic proposal to reduce coal to <10% ,  our further question is how to handle the current infrastructure? Many of the coal fire generation plants in Hong Kong are rather new. Will they be replaced and if so, who would bear the cost of such premature asset disposal

It is reasonable to expect that prices of oil, gas and coal will continue to rise; when uranium ore comes scarce and demand are increasing ( China, Russia, India are all increasing the number of nuclear plants in 10-20 years time).

The paper correctly identified emissions from power generation as the main source of emissions in Hong Kong, and went on to propose a change in the composition of power generation by source of power.  Without a rigorous evaluation on the carbon footprint of substitution, it may or may not yield the climate change result as expected.  Apart from that, the paper has not fully address the issue of vehicular emissions, aviation and shipping emissions, nor did it address the opportunity to reduce power consumption. For this area, we have more comment in other sections.

13. Question (5) To build Hong Kong as a green city, do you agree to the proposed target to reduce the carbon intensity of Hong Kong by 50 – 60 % by 2020?

If the reduction target is solely relative measure based on GDP, EMAHK does not think it is sufficient. Since the emission could be offset by increase of GDP. We believe Hong Kong should support international studies, which suggested implementing the goal of achieving a maximum emission at 450ppmv of Carbon Dioxide by 2050. Hong Kong should alternatively consider a target of emissions per capita as well.

We believe that using 2020 as benchmark year is insufficient. The international community, led by UNFCCC, generally request for targets beyond 2025 and up to 2050. The issue of climate change is not likely to be solved by 2020. In fact, setting a target for 2050 should entail and facilitate longer term planning.

14. Question (6) Do you support the Government’s proposed direction and action agenda in achieving the proposed carbon intensity reduction target?

As comment in other section, Hong Kong should alternatively consider a target of emissions per capita.

EMAHK believes that the scope of the paper is much narrower than desired. The paper correctly identified emissions from power generation as the main source of emissions in Hong Kong, and went on to propose a change in the composition of power generation by source of power.  It did not fully address the issue of vehicular emissions, aviation and shipping emissions, nor did it address the opportunity to reduce power consumption. Education, while briefly mentioned, was not given sufficient focus in the paper. The issue of waste treatment was again insufficiently covered. Thus EMAHK has the following comments and suggestions:

Buildings Electricity Conservation – There is hardly any mention on how Hong Kong can carry on with its present style of living with reduced resources. As a matter of fact, the use of excessive electricity due to design of buildings, neon display, road illumination can be mitigated through rules, regulations and codes. In other countries such as Australia, building codes have been established and energy use of buildings is graded. We strongly believe that Hong Kong should follow this path.  Create building codes and reward owners of energy efficient buildings. This can be done through proper legislation or administrative practices. Reduction of rates for energy efficient buildings and increasing rates for energy inefficient buildings should be considered.  Administrative measures and education are needed to drive the reduction of resources use. In California, USA, power charges vary according to usage. The bigger power user is charged on peak rates all the time. In Australia, civilians can sell the power generated through their solar cells to the grid, thereby reducing their electricity charges. These are good examples we can learn from developed countries. In terms of education, we must communicate frequently to the Public in schools and other communication channels on the need to reduce.

Development of clean energy in Hong Kong – the key resource for clean energy development in Hong Kong is wind and solar. It follows that we must make the best use of these sources of energy. There are issues with power generated by windfarms and solar power facilities. Much of these relate to the intermittency of power generated, causing instability of electrical frequency that will damage power grids. Building grid storages in Hong Kong may solve the problem. Recent scientific development is very optimistic towards building viable grid storage infrastructure. Grid storage can also serve to regulate electricity generation at peak demand periods.

Road side pollution – after the successful campaign to replace pre-Euro diesel engines, there is no clear effort on the part of the government to further enhance the scheme, at least not in this paper.  We advocate the immediate adoption of EURO V emissions standard heavy vehicles, and at the same time, we should ban import of non-environmentally friendly cars and reward the use of electrical vehicles

Use of biofuel – use of biofuel has been discussed in the paper and is presented as a viable alternative to coal and gas power plants. We are of the opinion that a 10/90 fuel mixture would not help a lot in terms of emissions reduction. The sustainability of biofuel is also in question. In fact we believe mass production at economic prices of biofuel will have to precede any claim that biofuel for power generation may attribute to reducing emissions.

Taxes and incentives – these are tools that the Government can use to motivate clean air operators and penalize polluters. We firmly believe this is a sure way of achieving reduced emissions.

Solid waste treatment – modern ultra-high incineration facilities can reduce waste volume by roughly 90%, and generate power at the same time. This has to be part of Hong Kong’s action plan towards climate change.   Instead of building mega size incineration plants, the Government may also consider building smaller district treatment plants. We must learn from Japan, Taiwan and the Northern Europe in their success in instituting such facilities in there.

Greenify Hong Kong – Another main resource of Hong Kong is its country side. The built area of Hong Kong is only a fraction of its own volume. The planting of high efficiency oxygen producing plants would be a good way to beautify Hong Kong’s country side and reduce Hong Kong’s carbon foot-print.  It is recommended that a large scale tree planting movement should be implemented. Also, we should study experience and legislation of nearby countries and China on statutory green zone requirement when granting land for buildings

Transparency – New policies would generally face skepticism and opposition. This is an instituted element of any open society. In achieving social agreement on emissions reduction, the Government needs to be open about the difficulties it is facing. A case in point is that under the Control Scheme for electricity companies, early disposal of assets will cause burden on the part of the Government as compensation may be needed. We support the government’s clear and thorough sharing of its problems so to ensure the Public is on the same page. To begin with, the Environmental Protection Department should share the consultancy report that it mentioned so many times in the paper.   If the EPD were willing to disclose the consultancy report, we would support the extension of this consultation for another three months.

Who bears the costs? A substantial number of our members were born after the 80’s. They expressed a clear question in their minds in that with an aging population, they will be the group of people who would have to bear the consequences of bad decision making at this time. It is reasonable to expect that prices of oil, gas and coal will continue to rise; when uranium ore comes scarce their price would definitely come up too. Every power generation facility will have its used by date and needs to be renewed. It would be our responsibility to think for those in the younger generation so that we leave behind a sustainable society

15. Question (7)  Do you agree that we should strengthen regional co-operation in the Pearl River Delta Region in moving along the low carbon pathway, and aspire to become one of the greenest cities in China?

EMAHK agrees that there should be stronger regional co-operation in PRD region. Being closely connected geographically and socially, the emission in PRD influence Hong Kong greatly.

It is known that HK government set up pilot project with Guangdong Provincial for emission trading for thermal power plants. This is an encouraging step.

We believe this kind of project should extend to business sector to enhance cooperation other than institutional level.

16. Question (8) Do you think that as an individual, you know enough about climate change? Are you prepared to make changes to your lifestyle to help combat climate change? If so, how do you think you can contribute?

The answer is depends on the standard of “enough”.  We have knowledge in climate change and the research of climate change is keep going. There is need to continuous update our knowledge on the issue.

EMAHK would like to take the role in communicating climate change issue with general public and make it a more understandable topic for all.

We are planning to provide lectures to secondary and primary students, our future generations, on environmental management which included climate change.

17. Question (9) How do you think climate change will impact the vulnerable areas as identified in this consultation paper? What are your views on the proposed framework of adaptation options?

EMAHK believes climate change would have negative impacts on those areas.

Besides the five Adaptation Options and Measures mentioned in consultation paper, more effort should be put in reduction at source, such increase energy efficiency of buildings. Reduction is through education, which again should become part of Hong Kong’s emissions reduction action plan.

Comments Outside the Scope of This Paper

18.  Use of nuclear power – the EMAHK supports the use of nuclear power as an interim solution before clean energy can be economically used and viable.  However, even so, we need the Government to inform the Public on the source of such energy, the cost to Hong Kong, and most importantly, to give assurance on the safety aspect of the building and operation of nuclear power plants.

19.  As nuclear power plants are designed to run and provide a base loading of the energy demand, the peak surge of energy consumption shall be met by other means such as natural gas or coal based power plants.  It is a well-known fact that the effectiveness of wind power highly depends on season, wind direction and speed etc. and thus the energy supply from wind power may not be reliable.  If using a mixed energy mode, how the Government can ensure the reliable, consistent and continuous energy supply to Hong Kong people (please see also Clause 22).

20.  Use of biofuel – use of biofuel has been discussed in the paper and is presented as a viable alternative to coal and gas power plants.  We are of the opinion that a 10/90 fuel mixture would not help a lot in terms of emissions reduction.  The sustainability of biofuel is also in question.  In fact we believe mass production at economic prices of biofuel will have to precede any claim that biofuel for power generation may attribute to reducing emissions and overall global carbon footprint.  Nonetheless, the transformation of used industrial and cooking oils into fuel oil is highly encouraged as it acts as one stone for reducing waste oils and the use of fossil fuel.

21.   What about the current infrastructure? Some of the coal fire generation plants in Hong Kong are rather new with newly installed device to remove sulfur.  Will they be replaced and if so, who would bear the cost of such premature asset disposal?

22.  Development of clean energy in Hong Kong – the key resource for clean energy development in Hong Kong is wind and solar.  It follows that we must make the best use of these sources of energy.  There are issues with power generated by windfarms and solar power facilities.  Much of these relate to the intermittency of power generated, causing instability of electrical frequency that will damage power grids.  EMAHK recommends that this problem can be resolved by building grid storages in Hong Kong.  Recent scientific development is very optimistic towards building viable grid storage infrastructure.  Grid storage can also serve to regulate electricity generation at peak demand periods.

23.  It is apparently economically viable for village houses to install solar system to generate hot water and limited amount of electricity.  To promote such low carbon energy utilization, EMAHK recommends that the Government should consider the model of Australian Government to provide economic incentive such as tax redeemption for village people who install such green energy device(s) in their house.

24.  Thinking outside the box, another main resource of Hong Kong is its country side.  The built area of Hong Kong is only a fraction of its own area.  The planting of high efficiency carbon synthesizing plants would be a good way to beautify Hong Kong’s country side and reduce Hong Kong’s carbon foot-print, should carbon trading come into play.  Please be noted that China Government also treated tree plantation as one of the strategies to reduce its carbon footprints and promote environmental awareness.  EMAHK highly advocates that the HKSAR Government should set a more aggressive target in reforestation within and outside country parks, and most importantly establish more effective and preventive measures to reduce local hill fires.

25.  Road side pollution – after the successful campaign to replace pre-Euro diesel engines, there is no clear effort on the part of the Government to further enhance the scheme, apart from encouraging the use of electric vehicles.   The issue of emissions from existing heavy vehicles was not clearly addressed in this paper.

26.  Solid waste treatment – modern ultra-high incineration facilities can reduce waste volume by roughly 90%, and generate power at the same time.  EMAHK views that this has to be part of Hong Kong’s action plan towards climate change.

27.  Reduction – there is hardly any mention on how Hong Kong can carry on with its present style of living with reduced resources.  As a matter of fact, the use of excessive electricity due to design of buildings, neon display, road illumination can be mitigated through rules, regulations and codes. In other countries such as Australia, building codes have been established and energy efficiency of buildings is graded.  We strongly believe that Hong Kong should follow this path.  In terms of excessive lighting, there needs to be controlling rules and regulations.

28.  Education – we opine that emissions reduction is not only the work of the Government.  It should be the collective effort of all sectors.  The key to mobilizing the society at large to support emissions reduction is through education, which again should become part of Hong Kong’s emissions reduction action plan.  Also, we shall engage more young people to start thinking of their future as they will suffer more from the impacts of climate change.   They should be one of the key stakeholders involving in the decision making on how we should respond and adapt to climate change.

29.  Taxes and incentives – these are tools that the Government can use to motivate clean air operators and penalize polluters.  We firmly believe this is an important way of achieving reduced emissions.

30.  Who bears the costs? A substantial number of our members were born after the 80’s.  They expressed a clear question in their minds in that with an aging population, they will be the group of people who would have to bear the consequences of bad decision making at this time.  It is reasonable to expect that prices of oil, gas and coal will continue to rise; when uranium ore comes scarce their price would definitely come up too. Every power generation facility will have its used by date and needs to be renewed.  As such costs of energy will only go higher unless we start investing in power generation that is of much higher cost efficiency.

Our Suggestions

31.  Extend the reach of emissions target to 2050. We believe Hong Kong should support international studies, which suggested implementing the goal of achieving a maximum emission at 450 ppmv of Carbon Dioxide by 2050.  In so doing, using emissions intensity, a relative measure based on GDP, is insufficient.  Hong Kong should alternatively consider a target of emissions per capita (e.g., tones CO2 per capita per year) as well.

32.  Invest heavily in the research of clean and renewable energy in the context of Hong Kong. It is clear that Hong Kong lacks its own control on energy source if we start to import nuclear energy.  Grid storage for power generated by windfarms must become a high priority in our action plan.

33.  Create building codes and reward owners of energy efficient buildings. The impending legislation on Building Energy Efficiency is a correct step towards this direction.  We believe a reward system such as reduction of Government Rate for energy efficient buildings and increasing Government Rate for energy inefficient buildings should be considered.

34.  Greenify Hong Kong further. As mentioned in Clause 22, it is recommended that a large scale tree planting movement should be implemented.  Also, we should study experience and legislation of nearby countries and China on statutory green zone requirement when granting land for buildings.  It is of foremost important for the HKSAR Government to implement more effective and preventive measures via legislation and enforcement to stop local hill fires which killed thousands of trees each year.

35.  Reduction, prevent wasteful use of energy. Administrative measures and education are needed to drive the reduction of resources use.  In California, USA, power charges vary according to usage.  The bigger power user is charged on peak rates all the time.  In Australia, civilians can sell the power generated through their solar cells to the grid, thereby reducing their electricity charges.  These are good examples we can learn from developed countries.  In terms of education, we must communicate frequently to the Public in schools and other communication channels on the need to reduce energy consumption and enhance energy efficiency.

36.  Road-side emissions reduction. We advocate the immediate adoption of EURO V emissions standard for heavy vehicles, and at the same time, we should ban import of non-environmentally friendly cars and reward the use of electrical or hybrid vehicles.

37.  Introduce ultra high temperature incineration to deal with solid wastes, the advantage of which has been mentioned in Clause 24.  Instead of building mega size incineration plants, the Government may also consider building smaller district treatment plants.  We must learn from Japan, Taiwan, Germany and the Northern Europe in their success in instituting such facilities in there.

38.  Transparency. New policies would generally face skepticism and opposition.  This is an instituted element of any open society.  In achieving social agreement on emissions reduction, the Government needs to be open about the difficulties it is facing.  A case in point is that under the Control Scheme for electricity companies, early disposal of assets will cause burden on the part of the Government as compensation may be needed.  We support the government’s clear and thorough sharing of its problems so as to ensure that the Public is on the same page.  To begin with, the Environmental Protection Department should share the consultancy report that it mentioned so many times in the paper, but such an important report is currently sadly unavailable to the public.

39.  Some believe that we need to extend the deadline of this consultation.  We are of the opinion that this consultation has probably come too late.  If fact, we believe the EPD should gather the responses of this consultation and publish them within 2-3 months, and continue to consult the Public when specific policies are being contemplated.

For further information, please contact the following:

Sui Lau, General Secretary at secretary@emahk.org or Equeen Leung, Vice President Policy Research at vp_policyresearch@emahk.org