HK government's pet projects based on flawed assumptions
The recent judicial review of the Hong Kong-Zhuhai-Macau bridge project has highlighted a policy snarl-up, which surpasses even this government's uncanny talent for getting into a tangle.
It calls into question not only the assumptions underpinning the bridge project, but also the economic arguments advanced by the government to justify its other pet infrastructure projects, including the proposed third runway for Hong Kong International Airport.
Things began to go wrong for the government when Tung Chung resident Chu Yee-wah applied for a judicial review of the Hong Kong- Zhuhai-Macau bridge, saying the government's environmental impact assessment of the project failed to meet its own standards for gauging the likely effect on local pollution levels.
The judge agreed and overturned the project approvals granted by the Environmental Protection Department. The government has appealed and a decision is expected towards the end of this month.
But even if the appeal court upholds the original approvals, Chu's challenge exposed major shortcomings in the government's procedures to assess and approve infrastructure projects.
Usually an environmental impact assessment provides a baseline scenario based on recorded data to show what air quality would be like if the project did not go ahead. Then it gives a projection of local air quality with the project in place (and any other projects that are planned) so the public can get an idea of the likely effects.
But the assessment for the bridge project neglected to include this background scenario. It simply asserted that air quality in 2031 with the bridge in place will meet the government's objectives.
There are several big problems with this approach. As the judge in the initial review hearing pointed out, it treats the environment as a bucket into which pollutants can be poured until it is full.
The assessment says nothing about the amount of pollution the bridge and its traffic will actually add to the local atmosphere, which makes it impossible to gauge the environmental cost of the project. That defeats the purpose of the study in the first place.
There are other problems, too. For one thing, there are grave doubts about the use of the government's model for projecting future air quality. In effect it is a black box. The output is only as good as the data put in, and that is questionable.
According to David Renton, an environmental lawyer with legal firm Baker Botts, the model says air quality will meet the government's objectives largely because it assumes pollution levels will fall in line with government policies. Unfortunately, there is no assurance this will happen.
There are flaws, too, with the government's air quality objectives, which dictate acceptable levels for different pollutants. These were fixed in 1987 and have not been changed since, despite an increasing body of evidence that they have been set well above concentrations damaging to human health. That's especially worrying for inhabitants of Tung Chung, where as the charts (above) show, atmospheric levels of toxic pollutants commonly exceed levels that the World Health Organisation say should not be passed on more than one day in 100.
And despite what the government says, it is likely that air quality around Tung Chung will deteriorate. Although the environmental impact assessment for the bridge project predicted that local pollution levels will meet the government's present standards in 2031, the assessment did not factor in plans to build a third runway at Chek Lap Kok, which will also add heavily to pollution in the area.
What this indicates is that in making its economic arguments for new infrastructure projects, the government has neglected to factor in environmental costs. In particular, it has failed to account for the future health costs caused by the air quality deterioration they will cause.
Given that the government's economic forecasts for its projects already look stretched, this is a major omission. Add in the environmental and health costs, and it is highly doubtful whether Hong Kong's prized infrastructure projects will bring the city any net economic benefits at all.