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Hong Kong Moves to Tackle Deadly Ship Smog Fouling City’s Skies – Bloomberg

Dear KS Wong

we fully support your intentions  to attempt to resolve  the pollution mess left by the last inept administration of Donald Tsang which failed in its duty of care to

the Environment and to the people of Hong Kong.

We know Veronica Booth at Civic Exchange did a lot of work on the marine pollution problem.

The information below may be of interest to you.

It’s high time we had an Emissions Control Area for ships and designated Clean Air Zones (Euro 4 up/ hybrid / electric only) for roadside areas like Nathan Rd, Causeway Bay and Central.

Years ago we suggested bus routes terminating outside these areas with only hybrid shuttle buses plying the main thoroughfare routes – of course that was before we realised Donald Tsang’s brother ran Citybus and First Bus.

Kind regards,

James Middleton


From: []
Sent: Monday, June 27, 2011 17:54
To: James Middleton
Subject: E(11/1515) : Port Strategy – A new dawn

Dear Mr Middleton,

Thank you for your messages of 23 and 26 June.   The consolidated reply of EPD and the Marine Department (MD) is as follows.

1. What is the actual fuel sulphur cap here?
Ans. According to Regulation 29(1) of the Merchant Shipping (Prevention of Air Pollution) Regulation, the sulphur content of any fuel oil used on board ships in Hong Kong is not to exceed 4.5% m/m.

2.  How is this enforced for incoming vessels which refueled elsewhere?
Ans. According to Regulations 33(4) and 34 of the Merchant Shipping (Prevention of Air Pollution) Regulation, all incoming ships of 400 gross tonnage or above and engaged in international voyage shall carry Bunker Delivery Notes (BDN) with the associated representative sample of the fuel on board.  The BDN and the representative sample are subject to inspection by Government Surveyors.

3.  What samples are taken to ensure the ships are conforming to “grey smoke emissions instead of black smoke”?
Ans. MD is currently using Ringelmann Chart for the identification of black smoke.  If a ship emits smoke of or darker than Shade 2 for continuous 3 minutes, the emission is regarded as black smoke.

4.  Since these Charter member shipping lines have opted to switch to ULSD only at berth and not whilst sailing within Hong Kong waters what has Government done to seek their compliance whilst underway rather than just at berth?
Ans. The Fair Winds Charter signatories have committed themselves to switching their vessels to 0.5% sulphur fuel when at berth.  While sailing underway within HK waters, these vessels must meet the sulphur limit requirement stipulated under MARPOL Annex VI.  As mentioned, since China has not designated its waters (including that of Hong Kong) as an Emission Control Area, there is no vehicle for Hong Kong to “require” operators to use fuels of more stringent specifications.

5.  What is the sulphur content of bunker fuel supplied for refueling in Hong Kong?
Ans. It must be below 4.5% and is usually in the range of 3.5% – 4.0%.  You may contact the local suppliers in the attached document for details or access the MD’s website on the link provided for that document. <>

6.  Hong Kong is supposed to be an independent territory for 50 years from 1997 is it not?  We make our own laws do we not ?  The EPD intends to designate Low Emission Zones for traffic on Nathan Road, Causeway Bay and Central so that only Euro 5 diesels / hybrids will be allowed to enter those areas.  I see no difference with doing the same for HK waters – either meet the relevant standards or do not enter our waters or be fined if you do.
Using “China did not do it” is a lame duck reply more worthy of Donald Tsang than a body supposed to be looking after the air quality here , in this 50 year independent SAR.
Ans.  Under MARPOL Annex VI, there are general requirements on the sulphur content of any fuel oil used on board ships.  There is also a mechanism for member states of the International Maritime Organization (IMO) to apply for designating its waters as an Emission Control Area (ECA), within which the requirements are more stringent than the general requirements.  This mechanism is not mandated for all member States to designate its waters, in whole or in part, as an ECA.  As a matter of fact, Hong Kong is an associate member of IMO, not a full member (member state) and thus cannot file an application for ECA designation by Hong Kong itself.

Best regards,
Tony YT Lee

From: [ 27 August, 2012 11:14 To: James Middleton Cc:; EPD HKG
Subject: E(12/2120) IN BRIEF (Page 2)|HongKong Business|
Dear Mr Middleton,

Thank you for your message.  Ships operating in the North America Emission Control Area (ECA) must use fuel containing not more than 1% sulphur.  This would help reduce the ship emissions in the ECA, but not in our local waters.

2.        Oil companies in HK normally supply bunker fuels with a sulphur content not more than 2.8%, better than the 3.5% limit stipulated in MARPOL Annex VI.  We are not in a position to speak on behalf of oil companies as to whether they would supply bunker fuels of even much lower sulphur content.

Best regards,
Tony Y T Lee


“James Middleton” <>

24/08/2012 06:24

To <>, “EPD HKG” <>
Subject E(12/2120) IN BRIEF (Page 2)|HongKong Business|

Dear EPD
Does HK offer low sulphur bunker fuel  in a like manner ?
If not, why not ?

Kind regards,
James Middleton
Sinopec plans low-sulfur fuel for ships

China Petroleum & Chemical Corp, the country’s largest fuel supplier, plans to supply low-sulfur shipping fuel at Chinese ports as ships sailing to the US and Canada are required to burn the cleaner fuel.

Sinopec, as China Petroleum is known, is arranging barges, tanks and pipelines to supply shipping fuel, or bunker, containing 1 percent sulfur, Zhou Yiqing, the vice manager of the bunker department at Sinopec Fuel Oil Sales Co, said in an interview by telephone. The company will start with “big” ports, he said, without elaborating.

Ships sailing in US and Canadian waters are required to use bunker fuel with a maximum sulfur content of 1 percent starting this month under air-pollution standards set out by the North American Emission Control Area. Vessels outside the controlled areas can use bunker with a maximum sulfur content of 3.5 percent.

Hong Kong Moves to Tackle Deadly Ship Smog Fouling City’s Skies

By Natasha Khan & Ben RichardsonNov 23, 2012 8:19 PM GMT+0800

Hong Kong will force oceangoing ships to burn cleaner fuel while at berth, bringing relief to residents facing a third straight year of near-record pollution.

The city also said it would phase out polluting trucks and buses and clamp down on smoky vehicles, according to a government release today which detailed an emissions reduction plan to 2020.

Forcing ships to switch to the more expensive, cleaner fuel may reduce the smog that causes more than 3,000 premature deaths a year in Hong Kong, where the world’s highest rents, shortages of schools and the filthiest air of any global financial hub are deterring skilled workers. Vessels can now burn oil containing 3,500 times the sulfur as auto diesel sold in the city.

Soot from burning marine fuel accounted for 31 percent of respirable particles in Hong Kong’s air in 2008, according to the city’s government.

The decision to replace the current voluntary program that international shipping companies say rewards polluters was part of a raft of measures Hong Kong and the neighboring Chinese province of Guangdong endorsed to meet 2015 air emission targets.

To contact the reporters on this story: Natasha Khan in Hong Kong at; Ben Richardson in Hong Kong at

To contact the editor responsible for this story: Jason Gale at

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