Response to Public Engagement on the Electronic Road Pricing Pilot Scheme in Central and its Adjacent Areas

Response to Public Engagement on the Electronic Road Pricing Pilot Scheme in Central and its Adjacent Areas Friends of the Earth (Hong Kong) March 2016

Traffic Congestion and Air Pollution Air pollution in Hong Kong is one of the most prolonged environmental issues facing the city. The two major issues are street-level pollution and the regional smog problem. Vehicular emission is the main source of street-level pollution and the level of air pollutants at roadside monitoring stations has consistently exceeded the Air Quality Objectives (AQO) set down by the Environmental Protection Department (EPD) 1. According to the EPD Air Quality in Hong Kong 2014 Statistical Summary, non-compliance with both 1-hour AQO (200µg/m 3 with allowance of exceedance for 18 occasions) and annual AQO (40µg/m 3 ) for NO 2 were recorded at all three roadside monitoring stations (Causeway Bay, Central and Mong Kok) (Table 1 and 2) 2. Table 1: No. of Exceedance of Short Term Limits of Air Quality Objectives in 2014 Source: EPD (2014) Air Quality in Hong Kong 2014 Table 2: Monthly and Annual Averages of Air Pollutants in 2014 Source: EPD (2014) Air Quality in Hong Kong 2014 1 Air Quality in Hong Kong 2014, Air Science Group, EPD: http://www.aqhi.gov.hk/api_history/english/report/files/aqr2014e_final.pdf 2 Air Quality in Hong Kong 2014 Statistical Summary, Air Science Group, EPD: http://www.aqhi.gov.hk/api_history/english/report/files/aqr2014%20summary_en0707.pdf

Air pollution is a major environmental risk associated with various health problems, such as nose and throat irritation, shortness of breath, coughing, and chest tightness. People suffering from asthma or chronic respiratory diseases are more susceptible to air pollutants. Studies conducted by the Department of Health revealed that high pollution incidents are positively correlated to hospital admissions and premature deaths 3. According to the Hedley Environmental Index 2015, air pollution in Hong Kong resulted in 2196 premature deaths, 3.5 million doctor visits and a total economic cost of around HK$ 27.4 billion 4. Traffic congestion is one of the many factors contributing to roadside air pollution. A study conducted by Transport Advisory Committee (TAC) in 2014 revealed that there are five major causes of road traffic congestion including limited scope for more road transport infrastructure; excessive number of vehicles; competing use of road space; management and enforcement issues; and road works 5. There is a significant continuous growth of vehicle fleet in Hong Kong (about 3.4% per annum). Specifically, private cars are the key contributor, which account for 70% of the total number of vehicles in Hong Kong and takes up about 40-70% of the total traffic flow of the major roads in Hong Kong. Electronic Road Pricing Pilot Scheme In light of worsening traffic conditions and poor roadside air quality, the Transport Department and the Transport and Housing Bureau released the public engagement document for Electronic Road Pricing (ERP) Pilot Scheme in Central and its Adjacent Areas 6. ERP is a traffic management tool designed to rationalise vehicle flow in areas and periods of severe traffic congestion using a user pays principle where motorists are charged when they use designated roads during specified times. This is not a new concept as the Government has conducted 3 studies on ERP in 1985, 2001 and 2009 respectively. While studies have shown that ERP is feasible and beneficial for the city, the ERP was not adopted due to privacy concerns and the lack of community consensus. 3 The Health Effects of Air Pollution, Department of Health: http://www.chp.gov.hk/en/content/9/460/3557.html 4 Hedley Environmental Index, School of Public Health, The University of Hong Kong: http://hedleyindex.sph.hku.hk/ 5 Report on Study of Road Traffic Congestion in Hong Kong, Transport Advisory Committee, 2014: http://www.thb.gov.hk/eng/boards/transport/land/full_eng_c_cover.pdf 6 Public Engagement Electronic Road Pricing (ERP) Pilot Scheme in Central and its Adjacent Areas" : http://www.erphk.hk/en/home/index.html

ERP aims to discourage the use of private cars, the least efficient passenger carriers, in areas suffering from severe congestion during peak hours. Conversely, it provides the financial incentive for motorists to switch to effective public transport. With the pilot implementation of ERP in Central, it is expected to enhance traffic efficiency, air quality, liveability and connectivity. Q1. Do you have any views on how the boundary of the Central District ERP Pilot Scheme should be drawn up, and what are your reasons? The Central District ERP boundary should be drawn out based on the localised level of traffic congestion. According to the study of road traffic congestion in Hong Kong 2014, the average car journey speed on Hong Kong Island is the lowest, with a recorded traffic speed of around 20 km/h (Figure 1). Major roads and primary routes should be covered in the scheme. These would obviously include Connaught Road, Cleverly Street, Hillier Street, Chater Road, Des Voeux Road, Queen s Road and more, as these road sections in Central bear the worst road traffic congestion, with recorded traffic speed as low as 10 km/h 7. Figure 1: Car journey speeds during the morning peak hours on weekdays Source: Transport Advisory Committee (2014) Report on Study of Road Traffic Congestion in Hong Kong Beyond incentivising motorists to take public transports, the boundary should be drawn in a fair manner such that it would not disrupt motorists whose origins and destinations are not in Central or its adjacent areas. Roads (i.e. Rumsey Street Flyover) leading into the future Central-Wan Chai Bypass should not be drawn into the boundary (Figure 2). 7 Report on Study of Road Traffic Congestion in Hong Kong, Transport Advisory Committee, 2014: http://www.thb.gov.hk/eng/boards/transport/land/full_eng_c_cover.pdf

Figure 2: Central-Wan Chai bypass and island eastern corridor link Source: AECOM, Contract No. HY/2009/18 Central-Wan Chai Bypass Central Interchange Q2. Do you think some neighbouring areas of Central, say some parts of Admiralty or Sheung Wan, should be covered in the Central District ERP Pilot Scheme? If so, which area(s)? The purpose of ERP is to alleviate traffic congestion within Hong Kong s central business district. Admiralty should be included into the scheme as well if the traffic flow fulfil the criteria, as it is part of the central business district and can sometimes be considered to be a part of Central. Furthermore, traffic congestion during peak hours typically extends past the Central district. Therefore, neighbouring areas with heavy traffic flow should also be covered in the pilot scheme. As per our previous concern with the ERP boundary, the boundary should only cover motorists whose origins and destinations are within Central and other covered areas. Q3. Do you prefer an area-based or cordon-based charging mechanism for the Central District ERP Pilot Scheme? Why?

A cordon-based charging method is closer to the objective of ERP. Since vehicles are charged every time they cross a charging point, it reflects the user pays principle. Although an area-based charging method is much simpler to implement and easier to understand, it is unable to address congestions at specific periods of time, direction and/or locations. A cordon-based charging method provides more flexibility in setting up ERP in Hong Kong. The use of multiple charging points allow the possibility of changing the charging level depending on the time of day, location and travel direction. As vehicles are charged every time they cross a charging point, charging points can also be set up such that the cost can reflect the distance a vehicle travels along the congested road. Q4. Do you agree that ERP charges for the Central District ERP Pilot Scheme should be imposed throughout the hours in a day when the traffic flow is high in the charging area? ERP charging level should vary accordingly with the traffic flow to ensure a good balance. The charge should be sufficiently high such that it will accomplish the objective alleviating localised traffic congestion without deterring all motorists from utilising the road. A variable rate will encourage people to reschedule their travelling time to non-peak hours, or if not possible, to take public transportation instead. According to the daily and hourly variations of traffic flow of Central and its adjacent areas as stated in the consultation document, the peak traffic hours are from 7:00am to 8:00pm during weekdays (Monday to Friday) and 8:00am to 8:00pm during Saturdays. We suggest setting the charging period based on the level of congestion, and the charging rate should be adjusted based on regular monitoring result. Q5. Do you agree that Sundays and public holidays should be excluded from the ERP charges for the Central District ERP Pilot Scheme? Do you have any other views on the charging period? As mentioned above, exclusions should only be made based on the level of traffic congestion. A systematic plan must be created in order to ensure that traffic congestion is managed on all days. For example, the Singapore ERP scheme varies according to location, time of passing and vehicle type. The scheme levies charges on weekdays, including Saturday, except for public holidays. This exception has been made knowing that congestion on public holidays is relatively

low 8. In Stockholm, Sweden, there is no charge levied on Saturdays, Sundays, public holidays or the day before public holiday due to low levels of congestion 9. According to the daily variations of traffic flow of Central and its adjacent areas as stated in the consultation document, the traffic flow on Sunday is significantly lower than the daily average in a week 10. It should be kept in mind that increased exclusions lead to increased inefficiency in the ERP system. Hence, exclusions of all kind should be controlled and reduced as much as possible. In Central, traffic congestion is high on most days except Sundays. We suggest only excluding Sundays and public holidays in the pilot scheme. Q6. Which charging approach do you prefer for the Central District ERP Pilot Scheme a unified charge for all vehicles, differential charges based on vehicle sizes (i.e. larger vehicles to be charged more), or differential charges based on a vehicle s carrying capacity (i.e. vehicles with higher carrying capacities to be charged at lower levels)? In London and Gothenburg, a unified charge imposed for all vehicles, and there is no distinction made based on size or carrying capacity. 11 This method is easier to handle and implement as there are lesser factors to deal with and control. In Singapore, differential charges based on vehicle size were implemented so that the larger vehicles will be charged more. We suggest linking the charging rate to the emission, such that more-polluting vehicles will pay more. However, vehicles with zero tailpipe emission should not be exempted either. Although electric vehicles (EVs) do not contribute to emissions directly in-situ, they do contribute to traffic congestion, leading to increased emissions from other vehicles. Hence, exemptions should not be made for EVs, rather a discount may be offered to them. To facilitate the implementation, the Government should review the first registration tax and annual license fee in view of the emission level. 8 ERP in Singapore what s been learnt from five years of operation? http://www.lta.gov.sg/ltaacademy/doc/erp%20in%20singapore%20-%205%20years.pdf 9 The Stockholm congestion charges: an overview, Centre for Transport Studies: http://www.transportportal.se/swopec/cts2014-7.pdf 10 Public Engagement Electronic Road Pricing (ERP) Pilot Scheme in Central and its Adjacent Areas" : http://www.erphk.hk/en/home/index.html 11 The Stockholm congestion charges: an overview, Centre for Transport Studies: http://www.transportportal.se/swopec/cts2014-7.pdf

Q.7 Do you have any suggestion on the range of ERP charge which you believe could induce motorists to adjust their travel behaviour when (a) ERP charge is levied on a per day basis; or (b) ERP charge is levied on a per pass basis (charging at each and every charging point)? Motorists who need to make repeated trips during the day (taxis, goods vehicles, etc.) would certainly prefer a flat per-day charge. A per-day charge however will be less efficient in reducing traffic congestion, as motorists are incentivise to make multiple trips in a day after getting charged the first time. A per-pass charge is more effective and fits into the purpose of user pays principle. A per-pass charge can also be adjusted based on the time of use to maximise its deterrent effect during periods of severe congestion. It should be ensured that several cordoned areas are set up, such that the same vehicle passing through the mid points for a second time are also charged. Such a set up allows for charging that reflects on the distance a vehicle travels along roads in the charging area. Q.8 Do you support providing exemption/concession to vehicles other than emergency vehicles for the Central District ERP Pilot Scheme? If so, what are the type(s) of vehicles and why do you choose them? Since all vehicles utilising the roads with the charging area contribute to road traffic congestion, it is only fair that all vehicle users to pay the congestion charge under the "user pays" principle. The higher the numbers of exemptions are, the less effective a charging scheme would be. Even in other countries with successful charging schemes, exemptions are kept to a minimum. All potential exemption needs to be evaluated against the basic principles of equity, efficiency and public acceptability. We suggest following Singapore case to reflect the "user pays" principle where only emergency vehicles are exempted. Q9. DSRC technology requires the installation of an IVU in each vehicle entering the charging area for ERP payment, while ANPR technology captures the licence number plate of a vehicle every time when it enters / leaves / circulates in the charging area. On the whole, would you say that ANPR or DSRC is a more preferable technology for the Central District ERP Pilot Scheme?

Automatic Number Plate Recognition (ANPR) technology is more convenient to motorist as it does not require installing the in-vehicle unit (IVU). However, it has various shortcomings, including the intrusion of personal privacy, higher error rate, and consumption of substantial resources like the need for manual identification of license plate numbers and high operational costs. Conversely, DSRC (Dedicated Short Range Communications) technology requires the installation of IVU with stored-value card for instantaneous payment. Vehicles passing under gantries will get money deducted automatically 12. The Singapore ERP scheme which uses DSRC has shown high effectiveness. After the first year of implementation, average car speed increased by 26%. With demographic data similar to Singapore, we support the introduction of DSRC, especially since it could be incorporated with tunnel tolls and parking charges. Though the initial setup costs may be high, better protection of personal privacy, ease of manual input and broader scope of usage would definitely benefit the project in the long run. Q10. Do you have any concern over the protection of privacy in the Central District ERP Pilot Scheme? What are your concern(s) and how do you think it / they could be addressed? There are concerns over the protection of personal privacy in the implementation of ERP scheme, specifically the collection of personal data. To ensure compliance with the Personal Data (Privacy) Ordinance (Cap. 486), we recommend the adoption of DSRC technology 13. Only vehicles that are unable to pay the ERP charge or are in violation of traffic rules would have their license plate number captured. If such image being recorded, we suggest limiting the data storage to a reasonably defined time so as to safeguard the privacy. Q11. What indicators do you think we should use to evaluate the effectiveness of the Central District ERP Pilot Scheme? The following three indicators could be introduced in evaluating the effectiveness of the ERP Pilot Scheme: 1) Number of Cars 2) Average Car Speed 3) Pollutant Concentration 12 Land Transport Authority: nt/ltaweb/en/roads-and-motoring/managing-traffic-and-congestion/in-vehicle-unit-iu.html 13 Personal Data (Privacy) Ordinance: http://www.legislation.gov.hk/blis_pdf.nsf/4f0db701c6c25d4a4825755c00352e35/b4df8b4125c4214d482575ef000ec 5FF/$FILE/CAP_486_e_b5.pdf

The ERP schemes in Singapore, London and Gothenburg all showed an effective initial reduction of traffic volume by 16%, 16% and 15% respectively while traffic speed also increased by 26%, 27% and 20% respectively. Considering that enhancing air quality is another objective for implementing a pilot ERP in Central, we suggest using roadside air pollutant concentration as the third quantitative indicator of the scheme s effectiveness. Major vehicular- pollutants include NO 2, NO X, SO 2 and RSP. The Government should adopt multi-pronged approaches to alleviate the air pollution problem in Hong Kong so as to comply with the AQOs. Q12. Do you agree that the charging level should be reviewed regularly and adjusted where necessary in order to maintain the effectiveness of the Central District ERP Pilot Scheme? Continuous monitoring and evaluation is important to check whether the objective is achieved. Therefore, the charging level needs to be reviewed and adjusted regularly to ensure the effectiveness of the scheme. Singapore s ERP charging rate is regularly reviewed to ensure that the fee has a sufficient deterrent effect on traffic congestion without severely impacting local businesses and operations. Q13. Do you have any suggestions on measures which could complement the implementation of the Central District ERP Pilot Scheme? The road traffic conditions in Hong Kong have been worsening in recent years. Hong Kong, as an international metropolis, has been striving to maintain and enhance our competitiveness and sustainability. Deteriorating road traffic congestion is adversely affecting the connectivity, livability, air quality as well as the economy of Hong Kong. Mobility and air quality are two closely related attributes influencing the quality of living and attractiveness of a city. The Government should develop both short-term and long-term measures to alleviate road traffic congestion so as to sustain our city s competitiveness. Currently, the Government adopts a three-pronged approach to tackle road traffic congestion, including (a) improving transport infrastructure; (b) expanding and improving public transport system; and (c) managing road use. Particularly, the TAC conducted a study on road traffic

congestion in 2014, which provided 12 key recommendations as stated in Appendix 1 of the consultation document. The ERP pilot scheme, one of the TAC recommendations, is considered as an effective approach to alleviate traffic congestion in areas where the scheme is implemented. However, the problem cannot be solved with just a couple of initiatives, it is necessary to consider a full implementation of concerted measures. Public Transport Network: To cope with congestion and roadside emission, the Government has implemented several measures such as phasing out Pre-Euro IV diesel commercial vehicles, strengthening emission control for petrol and LPG vehicles, tax incentives for cleaner private vehicles, etc. However these measures do not address the root of the problem, which is the congestion of major roads by private vehicles. A study conducted by TAC in 2014 identified private vehicles as the largest contributor to the traffic mix on all listed tunnels and most major roads 14. Private vehicles are the least efficient passenger carriers. The Government should strengthen the public transportation network as the preferred choice in Hong Kong. In addition, we support the reorganisation of bus routes, adoption of electric public vehicles, and increasing the number of charging stations so as to reduce roadside emission. Low-emission Zones: The three roadside air quality monitoring stations showed that Central, Causeway Bay and Mong Kok were recorded non-compliant short-term and annual roadside NO 2 concentration in 2014. FoE welcomes the Government to set up low-emission zones (LEZs) at the busy roads in Causeway Bay, Central and Mong Kok. We encourage the Government to expand the restriction scope from franchised buses to all vehicle types. Pedestrianisation: Since 2000, the Transport Department has implemented three types of pedestrian schemes (Full-time Pedestrian Street, Part-time Pedestrian Street and Traffic Calming Street) in several areas including Causeway Bay, Central, Wan Chai, Mong Kok, Tsim Sha Tsui, Jordan, Sham Shui Po, Stanley and Shek Wu Hui 15. Pedestrianisation offers various benefits, such as reducing noise and air pollution, enhancing pedestrian safety, promoting walking as a healthful alternative, facilitating social, cultural and tourism activities etc. The 14 Air Quality in Hong Kong 2014, Air Science Group, EPD: http://www.aqhi.gov.hk/api_history/english/report/files/aqr2014e_final.pdf 15 Transport Department: http://www.td.gov.hk/en/transport_in_hong_kong/pedestrianisation/pedestrianisation/

Government should enhance pedestrian networks linkage to public transportation, so as to promote walking as a viable transport mode in the urban planning. Cycling-friendly City: Beyond addressing private vehicles, FoE recommends the Government to encourage more cycling within the city as an alternative mode of transport. In addition to being pollution-free, cycling promotes healthier lifestyles and social connectivity among Hong Kong citizens. It should be stressed that cycling is more than just a healthy recreational activity that happens to be carbon-free. It should also be a practical alternative mode of transport for people. Government has to demonstrate that Hong Kong is bicycle-friendly through its urban planning policies such as having proper bike lane and parking facilities integration into the building code to enhance safety and convenience for cyclists. The Government should develop more bike routes in Hong Kong particularly on Kowloon and Hong Kong Island, along the entire Harbour-front. Hong Kong s bike routes should be completely connected, allowing cyclists to get around the city with just a bicycle.