2024-09-16

HKGBC’s Response to 2024 Policy Address Public Consultation

Hong Kong Green Building Council (HKGBC) has always been supportive to the Policy Address Public Consultation and submitted our following suggestions which aim to enhance the promotion of green building developments and reinforce the efforts of striving towards achieving carbon neutrality in Hong Kong:

1. Mainstreaming adoption of green building practices through BEAM Plus and relevant certification schemes

For the ESG reporting required by HKEX, inclusion of green building adoption on property portfolio (e.g. attainment of BEAM Plus certification) in the ESG reports will definitely be helpful to support green building developments and hence strive towards achieving carbon neutrality in Hong Kong. As a pre-requisite for seeking Gross Floor Area (GFA) concessions, new building projects are required to register for the BEAM Plus rating scheme. The BEAM Plus assessments have encouraged the building industry to utilise green building technologies. We see that the efforts should also be extended to the 42,000 plus existing buildings in Hong Kong. This is a new growth area that are well supported by innovation and technology developments, particularly in implementing retrofitting and retro-commissioning in line with the carbon neutrality roadmap of our Climate Action Plan.

We suggest the Government to take the lead by requiring the 8,000 plus existing government buildings and facilities as well as public housing to obtain BEAM Plus Existing Buildings (EB) and Interiors (BI) certification so as to set examples for the public and private sectors to follow. The first possible step is to revise the existing Government circular on green government buildings so as to urge all existing government buildings to gradually apply for BEAM Plus certification. Besides, it may be advantageous for the Government to demonstrate its decisiveness by indicating the current resources spent and/or committed in achieving relevant certification as well as conducting retrofitting and retro-commissioning works for existing government buildings.

Besides, the Council has published the "Climate Change Framework for Built Environment" and relevant Guidebooks as well as launching the "Zero-Carbon-Ready" and “Net-Zero-Energy” Building Certification Schemes. These initiatives encourage the industry to adopt systematic and benchmark-driven approaches to reduce energy consumption, and provide the industry with clear standards to enhance energy performance, benchmark testing standards and increase tenant engagement, while also contribute to the establishment of milestones for green finance. We recommend the Government to take the lead by encouraging all government departments as well as their Carbon Neutrality (CN) partners from public and private sectors to adopt our Framework and Guidebooks in enhancing their operational performance, and obtain certification for government buildings and public housing where appropriate through the above Schemes.


2. Exporting green building certification professional services and expertise by creating job opportunities

Another new growth area is to promote the BEAM Plus certification scheme to buildings outside Hong Kong. As a first step, we have already published the BEAM Plus EB Global Version and are in the process of preparing for launching the BEAM Plus New Buildings (NB) Global Version. This will facilitate the escalation of BEAM Plus from a localised to an international green building certification scheme. We have signed MOU with some 13 property developers, property management companies and state-owned enterprises who have kindly agreed to explore applying our BEAM Plus Global Versions to their building projects in the Mainland and overseas. This will also support the export of our professional services and expertise, and create job opportunities in providing BEAM Plus certification to other regions/countries, such as the Greater Bay Area, Belt and Road countries, etc. 

We have launched a series of promotion activities since the publication of BEAM Plus EB Global Version earlier this year. To facilitate the effective promotion of BEAM Plus to the international arena, it is suggested that the Government should consider setting up appropriate funding scheme to offer financial incentives and support, such as subsidising application fees, etc. to attract more applications from building projects outside Hong Kong, in particular those by local property developers investing in overseas projects.


3. Enhancing legislative requirements and promoting carbon credit trading

Since building-related activities in Hong Kong account for around 90% of total electricity consumption and 60% of total carbon emissions, we echo the Government's focus on demand side of energy by promoting energy conservation technologies and improving energy efficiency as one of the key strategies towards achieving the net-zero target. We support the proposed amendments to the Buildings Energy Efficiency Ordinance (BEEO) and recommend to expand its scope to cover more building types, in particular those with high energy consumption such as data centers, etc. As the BEEO is currently applicable to 13 types of prescribed buildings but the mandatory requirement to conduct energy audit is only restricted to commercial buildings and the portion of composite buildings that is for commercial use, consideration should be given to extend the energy audit requirement to all building types covered and to be covered by the BEEO, with the eventual objective to cover all existing buildings in Hong Kong. Besides, the interval of energy audit should be shortened from the current requirement of ten years to five years or even shorter in future. Mandatory implementation of energy management opportunities identified from these energy audits should also be considered for inclusion into the legislation where practicable. In terms of mandatory disclosure of information in energy audit reports, we suggest disclosing more energy-related information so as to enhance market transparency and encourage participation in energy-saving retrofitting and retro-commissioning.

If standards or criteria can be developed to turn energy savings into carbon credits, it can provide monetary incentives for retrofitting projects. The carbon credits represent the extra energy savings compared with the baseline scenario (i.e. energy reduction targets stipulated in the Climate Action Plan). Facilities management companies can produce technical proposals to their clients and play a major role in obtaining financial support for the retrofitting projects. The carbon credits generated can be put to the voluntary market or purchased by the Government to offset its carbon emissions. It is recommended that the Government should provide the initial investment for setting up the necessary platform to facilitate carbon credit trading.


4. Carbon reduction for existing buildings with the support of green financing

The Council is pleased to see the Government's continued development of green and sustainable finance, promotion of green technology, and commitment to establishing Hong Kong as an international hub for green finance. Collaboration between green buildings and green finance is crucial for driving decarbonisation in the built environment. The Council has published the “Retrofitting Guidebook” to promote and facilitate the industry in implementing retrofitting for better operational performance in energy efficiency for their building stocks. Retrofitting would involve capital expenditure which is one of the major barriers for building owners. It is envisaged that green finance will be able to provide support to the industry for retrofitting and hence improving the performance of their buildings. We would like to suggest the Government to consider setting up extra funding support in this respect and exploring the provision of green loans as key incentives for existing buildings to go green.

Our BEAM Plus and Zero-Carbon-Ready building certification schemes have been included in HKMA's Hong Kong Taxonomy for Sustainable Finance published earlier this year. By adopting the said certification, stakeholders can set energy performance benchmarks, establish carbon neutrality goals, and justify projects for green financing. It is necessary to develop suitable operational guidelines for the said Taxonomy, the Council will actively collaborate with the Government, HKMA and the industry in this respect with a view to accelerating the decarbonisation process in the entire built environment of Hong Kong.