Climate Blog
2024-09-11
Submission to the HKSAR Government's 2024 Policy Address Public Consultation
Introduction:
CarbonCare InnoLab (CCIL) hereby submits its recommendations for the Hong Kong Special Administrative Region Government's 2024 Policy Address public consultation. Our submission focuses on seven key areas of climate policy: climate governance, renewable energy, resource management, climate adaptation, green finance, youth engagement, and just transition. In light of the escalating climate crisis and the urgency to limit global warming to 1.5 degrees Celsius, CCIL urges the government to swiftly realign and comply with the Paris Agreement goals. We advocate for accelerated and expanded climate action to avert more severe climate disasters.
To: The Honourable John Lee Ka-chiu, GBM, SBS, PDSM, PMSM
Chief Executive of the Hong Kong Special Administrative Region
Dear Sir,
On behalf of CarbonCare InnoLab (CCIL), I am writing to submit our recommendations for the 2024 Policy Address public consultation. Given the unprecedented challenges that climate change poses to Hong Kong, we urge the government to take bold and decisive action to safeguard our city's future and the well-being of our citizens.
CCIL, established in 2014, is a non-governmental environmental organization dedicated to fostering low-carbon lifestyles in local communities, with a particular focus on supporting Hong Kong's youth in climate action. Through innovative approaches and community engagement, CCIL aims to enhance society's capacity to address the climate crisis.
Our SolarCare Programme has installed nearly 5,000 solar photovoltaic panels at 31 local non-profit social service organizations, demonstrating the benefits of the feed-in tariff scheme across Hong Kong. This initiative not only promotes climate education but also supports social services, serving as a model for solar energy support of local community services. Additionally, CCIL published the "Paris Watch Hong Kong Climate Action Report," which compares Hong Kong's carbon reduction performance with that of other cities in the region, advocating for more ambitious climate action targets and accelerated implementation.
CCIL's recommendations are grounded in the latest climate science research and our decade-long experience in fostering community engagement and climate action locally. We firmly believe that Hong Kong has the potential to become a regional leader in implementing climate mitigation, adaptation, and resilience measures.
In light of the escalating climate crisis, evidenced by record-breaking heatwaves and extreme weather events both globally and locally, CCIL urges the government to prioritize climate action in the upcoming Policy Address, in adherence to and compliance with the Paris Agreement. Our recommendations span several key areas, including climate governance, renewable energy, resource management, climate adaptation, green finance, youth engagement, and just transition, with a particular focus on protecting the most vulnerable communities from the impacts of climate change.
CarbonCare InnoLab (CCIL) hereby submits the following recommendations:
Global and local climate trends are deeply concerning. The World Meteorological Organization (WMO) has confirmed 2023 as the warmest year on record. This warming trend is expected to continue, with the European Union and the U.S. National Oceanic and Atmospheric Administration (NOAA) predicting that 2024 may surpass 2023 as the hottest year on record. Notably, the first eight months of 2024 have each set new temperature records.
According to the United Nations Framework Convention on Climate Change (UNFCCC) analysis of Nationally Determined Contributions (NDCs), current climate commitments are projected to lead to a global temperature rise of 2.4-2.6°C. This forecast significantly exceeds the Paris Agreement's 1.5°C target, potentially resulting in more severe climate disasters. The Intergovernmental Panel on Climate Change (IPCC)'s Sixth Assessment Report warns that, at the current rate, there is a high likelihood of reaching 1.5°C between 2030 and 2035. The WMO further indicates that the probability of exceeding 1.5°C before 2027 is over 50%.
Climate change is not only causing extreme heat but also leading to super typhoons, unprecedented rainstorms, floods, and droughts worldwide. These extreme weather events have resulted in loss of life, food crises, infrastructure damage, and biodiversity loss, causing severe economic damage. Munich Re reports that global disasters led to economic losses of $120 billion last year, while the Potsdam Institute for Climate Impact Research projects annual climate-related economic losses of $38 trillion by 2049 under various warming scenarios.
The impacts of climate change are increasingly evident in Hong Kong. Last year was one of the warmest on record, with 54 very hot days, 56 hot nights, and 4 extremely hot days, ranking first, second, and fifth highest on record, respectively. This year, the Hong Kong Observatory issued 14 consecutive days of very hot weather warnings up to the end of July. Beyond extreme heat, heavy rainfall has also caused significant damage. In early September last year, Typhoon Haikui triggered unprecedented torrential rainfall, leading to the longest Black Rainstorm Warning on record, lasting 16 hours and 35 minutes. A record-breaking 158.1mm of rain fell within one hour, resulting in numerous landslides, 60 flooding incidents, at least two deaths, and over 140 injuries. The Insurance Authority reported claims totalling HK$1.9 billion from the September typhoon and rainstorm events.
Vulnerable communities are often the disproportionately affected by extreme weather. A recent CCIL study with the Kwai Chung Subdivided Flat Residents Association found that residents of subdivided flats, rooftop houses, industrial buildings, and social housing experienced perceived temperatures about 6°C higher than measured indoor temperatures, reaching "extreme caution" levels. This indicates that local climate adaptation plans are inadequate for vulnerable groups, including subdivided flat residents, during extreme weather events like heatwaves.
Outdoor workers and the elderly are also highly susceptible to extreme heat. A survey of outdoor cleaners revealed that most respondents had experienced heat-related illness symptoms and felt that the Guidelines on Prevention of Heat Stroke at Work were insufficient to protect their health. During the June heatwave this year, an average of over 1,800 daily emergency calls were received from elderly persons using personal emergency link services, more than 15% above normal levels. A University of Hong Kong study on 18 extreme heat events between 2014-2023 estimated over 1,600 heat-related deaths. These figures highlight the challenges posed by extreme weather to various vulnerable groups in our society.
In light of the aforementioned challenges, CarbonCare InnoLab (CCIL) presents the following recommendations for the 2024 Policy Address:
1. Climate Governance
Overview: The Hong Kong Climate Action Plan 2050, updated by the government in 2021, sets a carbon neutrality target for 2050, positioning Hong Kong as one of Asia's leading cities in this regard. This commitment is commendable. However, CCIL is concerned about the concrete plans and timelines for implementing these recommendations to comply with the Paris Agreement goals and accelerate the achievement of various carbon neutrality targets.
Recommendations:
1.1 Enhance 2030 and 2035 carbon reduction targets in compliance with the Paris Agreement:
Hong Kong's current 2030 target aims to reduce emissions by 26-36% compared to 2005 levels, falling short of the Paris Agreement's 45% reduction goal. CCIL recommends that the government, following the suggestions in the "Paris Watch Hong Kong Climate Action Report," elevate the 2030 carbon reduction target to align with the Paris Agreement. Additionally, the government should consider advanced countries’ initiatives and increase the 2035 carbon reduction target from 50% to 60%.
1.2 Establish five-year interim targets and update the Climate Action Plan:
CCIL urges the HKSAR government to promptly initiate the fifth-year review of the Hong Kong Climate Action Plan 2050. This review should include a progress report and set more ambitious medium and long-term goals. The current targets of 7.5-10% renewable energy by 2035 and 15% by 2050 are conservative compared to other leading cities. CCIL recommends establishing five-year interim targets and enhancing both medium and long-term goals within the plan. This approach would strengthen government accountability in climate mitigation and adaptation measures, demonstrating a heightened climate ambition.
2. Renewable Energy
Overview: Hong Kong's renewable energy still constitutes a very small portion of the local energy mix. According to the Electrical and Mechanical Services Department, in 2021, it accounted for only 0.6% of total electricity consumption and 1.0% of total energy use. This is far from the local renewable energy targets of 7.5-10% by 2035 and 15% by 2050. During last November's mid-term review of the Scheme of Control Agreements, the government again shelved two crucial offshore wind power projects: CLP's project near the Ninepin Group and HK Electric's project southwest of Lamma Island. This raises concerns about the feasibility of achieving the local renewable energy targets set in the Hong Kong Climate Action Plan 2050.
The government has made some progress in promoting other local renewable energy projects. Benefiting from the Feed-in Tariff Scheme implemented since 2018, the local solar PV installation capacity has increased significantly from less than 1 MW to 380 MW in 2023. Regarding the floating solar power systems on reservoirs, which CCIL has long advocated for, the Water Supplies Department has installed small-scale systems in three reservoirs since it was proposed in the 2017 Policy Address, generating a total of 360,000 kWh annually, which is only sufficient to power the reservoir operations. This year's Budget proposed a " Pilot Scheme on Building-Integrated Photovoltaics," planning to apply a Building-Integrated Photovoltaic system to the Electrical and Mechanical Services Department Headquarters building this year. However, overall, these projects are still too few and too slow, falling far short of the ambition required by the Paris Agreement and the Hong Kong Climate Action Plan 2050.
Recommendations:
2.1 Relaunch the two offshore wind power projects: CCIL urges the government to reconsider these projects promptly, prioritizing Hong Kong's long-term sustainable development over short-term financial considerations. We believe that direct financial support for these projects could change public perception of large-scale infrastructure and accelerate Hong Kong's renewable energy transition.
2.2 Floating solar PV systems on reservoirs: CCIL welcomes the Water Supplies Department's plan to add a 5 MW generation capacity to Plover Cove Reservoir by 2026. We recommend the government accelerate and expand investment, installing large-scale systems in more reservoirs across Hong Kong to allow citizens to benefit from solar power.
2.3 Building-Integrated Photovoltaics systems: CCIL suggests the government include Building-Integrated Photovoltaics systems in the Feed-in Tariff Scheme, require a certain proportion of Building-Integrated Photovoltaics systems in new building projects, and recommend the Buildings Department streamline the approval process to increase developers' incentives to install these systems.
2.4 Continue the Feed-in Tariff Scheme to attract solar PV investment: While the Feed-in Tariff Scheme has shown significant results since its implementation, it has not yet substantially increased the proportion of renewable energy. CCIL recommends continuing the scheme and offering more competitive Feed-in Tariff rates to attract more solar PV investment until local renewable energy proportions increase significantly.
2.5 Hydrogen fuel development: The government announced the "The Strategy of Hydrogen Development in Hong Kong" in June, promoting hydrogen energy development through regulations, standards, and market approaches. CCIL believes that hydrogen fuel production should be driven by renewable energy (green hydrogen) rather than the current main method using natural gas (grey hydrogen). The government should provide a roadmap and timeline for Hong Kong's production and import of green hydrogen.
3. Resource Management
3.1 Waste Management and Circular Economy:
Waste management is a crucial component of the Hong Kong Climate Action Plan 2050. CCIL expresses deep disappointment at the government's failure to implement the Municipal Solid Waste Charging Scheme. However, the government should not abandon any possibilities to promote a circular economy. This includes evaluating the effectiveness of current district-level waste recycling initiatives such as the Green@Community scheme and three-colour recycling bins, improving waste recycling processes, and reconsidering the implementation date of the Municipal Solid Waste Charging Scheme. Outdoor cleaning workers and low-income individuals are key stakeholders in waste recycling. Before implementing related policies, their participation must be ensured and their well-being protected. CCIL believes that neither waste-to-energy nor seeking landfill sites in mainland China are options for a circular economy. Source reduction and resource reuse remain the only viable directions for waste management.
3.2 Reassess Waste-to-Energy Projects:
CCIL believes that waste-to-energy is not an effective method of resource utilization. Developing waste-to-energy without a comprehensive waste recycling system will only lead to increased dependence on this technology, failing to achieve a true circular economy and wasting efforts towards this goal. CCIL recommends the government reassess these projects.
3.3 Carbon Auditing:
Carbon auditing is a crucial tool for measuring an organization's carbon footprint and monitoring carbon reduction efforts. CCIL recommends the government lead by example by implementing mandatory carbon audits for government procurement, establishing relevant agreements and codes of practice. Moreover, all government departments should publish their carbon footprints annually to allow public monitoring of their carbon reduction performance. CCIL also suggests the government support listed companies, SMEs, and other organizations in conducting carbon audits. The government must regularly update relevant carbon audit guidelines to meet recent requirements for Scope 3 emissions auditing. With the government's recent promotion of the Mega Events economy, and given the global attention on the carbon footprints of mega events (e.g., Singapore's Formula 1 race publishing a carbon audit report), CCIL recommends the government follow international practices by supporting event organizers in conducting and publishing carbon audits to encourage carbon footprint reduction.
4. Climate Adaptation
Overview:
The current Hong Kong Climate Action Plan 2050 focuses on climate adaptation of infrastructure, such as flood prevention, storm surge protection, and landslide control. While all these are important, community engagement in climate adaptation is lacking. CCIL is particularly concerned about the climate adaptation needs of vulnerable groups, including subdivided flat residents, outdoor workers, and the elderly. The government's 2023 Policy Address proposal to establish a task force to address subdivided flats and recommend minimum standards presents an opportunity to improve climate adaptation for these residents. Regarding outdoor workers, while the Labour Department has updated its "Guidelines on Prevention of Heat Stroke at Work" and heat stress warnings, surveys by concerned groups indicate that these measures still fail to adequately protect workers' health.
Recommendations:
4.1 Strengthen Community-based Climate Action:
CCIL recommends that the Hong Kong Climate Action Plan 2050 should include a reassessment of climate adaptation and disaster preparedness measures and goals. It should create an environment conducive to community group collaboration, developing local adaptation and disaster prevention plans through community dialogue, with a focus on protecting vulnerable groups from climate change impacts. The plan should include public education on community climate adaptation and involve citizens in disaster preparedness, especially in establishing community support, early warning systems, and shelters for vulnerable groups.
4.2 Subdivided Flat Residents:
CCIL urges the government to expand housing standards to incorporate climate adaptation and resilience measures for subdivided flats and other transitional housing. Climate adaptation requirements should be included in the project implementation guidelines for NGO-supported transitional housing projects. CCIL also recommends comprehensive heat-related health assessments for subdivided flat residents, introducing community resources for extreme heat, developing climate-resilient building codes, providing targeted education on extreme heat, and regularly monitoring the effectiveness of these measures. Adaptation measures should include improving insulation and ventilation, installing energy-efficient cooling systems, increasing green facilities, and providing extreme heat subsidies to support vulnerable groups.
4.3 Outdoor Workers:
CCIL supports recommendations from concerned groups that employers should more proactively provide heat prevention equipment and measures, and review the workload of outdoor cleaning workers. They suggest authorities introduce district-level heat stress indices and an upgraded heat warning mechanism. The guidelines should include a mechanism for employers to notify employees, clarify that basic rest periods remain unchanged, and ultimately legislate the enforcement of these guidelines. Including these guidelines in tender documents and making paid heat stress leave and heat allowances criteria for selecting outsourced contractors would help eliminate heat-related risks for employees.
4.4 Flood and Storm Surge Warnings:
CCIL recommends expanding the current flood warning system from the Northern District to all districts in Hong Kong, enhancing warnings for flood and storm surge hotspots. The Drainage Services Department should intensify inspections of flood prevention measures in each district during the rainy season to ensure facilities are not left unused.
4.5 Comprehensive Climate Disaster Warning System:
CCIL suggests the government develop a comprehensive climate disaster warning system that integrates all different climate disasters and departmental response plans into a single early warning mechanism, addressing the needs of specific districts and communities.
4.6 Adherence to International Disaster Prevention Framework:
CCIL recommends that the government adhere to the Sendai Framework for Disaster Risk Reduction, adopted by the UN Office for Disaster Risk Reduction in 2015. The government should develop local disaster prevention and reduction policy documents, transparently demonstrating to the public its goals and methods for preventing climate disasters, and enhance public participation.
5. Climate Budget and Green Finance
5.1 Climate Budget:
In the 2021 Policy Address, the government committed to investing HK$240 billion in climate initiatives over the next 15-20 years. However, details of this budget have not been disclosed in the past three years. CCIL urges the government to publish these details as soon as possible and to track and audit the expenditure to evaluate the effectiveness of climate actions.
5.2 Utilization of Green Bond Funds:
The Financial Secretary has stated that Hong Kong is a leading green finance centre in Asia. Last year, Hong Kong issued over US$50 billion in green bonds, accounting for more than one-third of the Asian market. However, funds from both government and privately issued green bonds have not accelerated local renewable energy development, nor have they disclosed their contribution to overall local carbon emission reduction. CCIL recommends that the government allocate a certain proportion of government green bond funds for developing local renewable energy and disclose the contribution to overall local carbon emission reduction in annual reports.
5.3 Develop a Comprehensive Green Finance Strategy:
In March this year, CCIL and Greenpeace published an "Evaluation on Hong Kong Green Finance Policy" report, identifying three major gaps in Hong Kong's green finance, with performance lagging behind cities like Singapore and Tokyo. CCIL urges the government to develop a comprehensive development strategy, including setting specific quantitative targets, roadmaps, and timelines; strengthening the assessment of climate risks to the financial system; establishing rigorous audit processes and third-party audits; legislating against greenwashing practices. In the long term, climate factors should be incorporated into local financial policies to achieve the vision of becoming Asia's leading green finance market.
6. Youth Participation
6.1 Expanding Youth Engagement Opportunities:
CCIL recommends that the government continue to promote youth participation in climate action, create a favourable environment to support youth involvement in climate decision-making, and invite youth from various sectors to jointly implement relevant climate measures.
7. Just Transition
7.1 Achieving a Just Transition for the Whole Society:
CCIL urges the government to consider the recommendations in the "Hong Kong Just Transition Report." Key areas for strengthening climate resilience across society, especially for vulnerable groups, include maintaining physical and mental health; stabilizing living costs; ensuring access to information; improving transportation; adjusting work environments and arrangements; promoting green lifestyles.
CCIL also recommends promoting a just transition for the whole society, including through community dialogue and people-centred policies to ensure fairness and justice in climate mitigation and adaptation measures. CCIL calls for multi-stakeholder dialogues to reassess climate policies and financial allocations, ensuring that frontline communities, not just businesses and academic institutions, can participate equitably.
Conclusion
CCIL recommends that the government should strive to achieve a vision of just transition, net-zero emissions, and climate resilience. CCIL urges the government to prioritize the severity of climate change and decisively implement policies to protect citizens' physical and mental health. Our submission represents the voices of citizens concerned about climate change, and we hope these suggestions can provide a strategic, society-wide direction for the 2024 Policy Address.
Sincerely,
CarbonCare InnoLab