From: James Middleton [mailto:dynamco@netvigator.com]
Sent: Friday, September 30, 2011 16:12
To: ‘franchise-renewal@td.gov.hk‘
Subject: Bus Franchise Requirements
Transport Department
1 The time for submissions needs to be extended to allow further studies and submissions and you have not provided copies of current Franchise documents for evaluation.
2 The document you provided permits the bus companies to continue using Euro 1 and Euro II through Euro V vehicles whereas existing Franchise documents already require that any replacement vehicles must be of Best Available Current Technology which is Euro V (soon to be Euro VI). Any new deal means the companies should comply with BACT rather than outdated polluting current buses.
3 Transport department should not be making unilateral decisions that would impinge on other departments’ responsibilities namely, Air Quality.
4 Roadside pollution in Hong Kong is already diabolical and rates next to the worst performing 3rd world countries in the emissions of lethal PM2.5. which comes from the combustion of fossil fuels. The Central roadside PM2.5 levels are nine times higher than Vancouver and double those of Singapore. Mongkok and Causeway Bay are worse.
5 There seems to be no incentive to allow the bus companies to bring in hybrid buses which would be best suited here given the topography and hills.
6 There should be a date set and made known to all that certain areas will be designated Low emissions Zones where only Euro V or later or hybrid / electric buses will be allowed to operate. Setting this into Law will make the bus companies comply accordingly.
7. Transport Department personnel and their children have to breathe the same pollutants as the public and they should realise that health and environment come first and the profits of the bus business tycoons last.
James Middleton
Chairman