- The Consumer Council (CC) welcomes the opportunity to give views on the "Draft Comprehensive Plan to Tackle Road Traffic Noise in Hong Kong" (Draft Comprehensive Plan) for consideration of the Environmental Protection Department (EPD).
- This submission sets out CC's views on the measure proposed in the Draft Comprehensive Plan about disclosure of noise information in sales brochure, which have direct relevance to consumers/homebuyers.
- In tendering its views, CC embarks from the perspective of consumer interests, and considers that certain guiding principles have to be observed in the proposed measure:
- Right to know - every member of the public has the right to know the noise levels in their living environment;
- Consumer empowerment - disclosure of noise information enhances consumers to make informed decision;
- Accuracy - homebuyers should be assured about what they are told; and
- Transparency - noise information should be communicated in everyday language that can be easily understood by a layman.
Right to know
- Since the purchase of a home may be the largest investment in the lifetime of an average consumer, a legitimate expectation of prospective homebuyers is that they will have adequate information and assistance they need to make their purchase decision. Property developers should provide the necessary information. CC supports requiring disclosure of noise information in sales brochure to satisfy prospective homebuyers' right to know.
- Ideally, CC considers that this disclosure requirement should be extended to benefit existing homeowners or tenants. EPD may wish to explore ways such as encouraging property management companies to display current noise information in their developments for information of homeowners or tenants so that they can take steps to minimize their noise exposure if necessary.
Informed choice
- CC considers the disclosure of noise information in sales brochure important in informing and forewarning prospective homebuyers about the expected level of noise affecting the relevant properties. This then enables them to assess the impact of noise in making decisions, such as whether or not to purchase the property or provide for additional funds to take certain mitigation steps once they take up occupation.
Independent assessor
- Trust can only be established if people have confidence in the truth of what they are being told. It is therefore essential that when providing noise information in brochure, every effort should be made by property developers to ensure its accuracy. It is equally important that noise information should be based on data gathered and/or collated by an independent body. Ideally, uniform standard should be adopted by the property developers when disclosing noise data.
Understandable information
- CC is of the view that if any noise information is considered important to homebuyers, it must be accurate as well as comprehensible.
- Noise level has commonly been described in terms of decibels in a single figure which aggregates and averages out the various noise components. This means that the information given to the public may not relate closely to a person's actual concerns.
- It is important that the details should not be buried in an average day noise data nor should information on what happens at sensitive times (at night) be hidden by the use of weightings.
Aircraft noise
- CC understands that the proposed disclosure measure is meant to apply only to traffic noise information but not aircraft noise information. However, it is generally accepted that the noise levels generated by aircraft activities also have great adverse impact on the quality of life. EPD may wish to consider incorporating this aspect into the noise disclosure requirement.
Impact on development planning
- The requirement to disclose noise information is beneficial in that property developers may therefore be more discriminating when siting and planning. More importantly, this may encourage property developers to seriously examine noise control measures such as using building construction components and configurations to provide sufficient sound insulation. This will help to reduce noise exposure in future residential developments.
Providing guidance to consumers
- Whilst it is important to enhance transparency by providing noise information in sales brochure to prospective homebuyers, the purpose may not be served if they have little idea of what the noise level will be like. Ideally this requirement should be supplemented by consumer education. For example, at environmental resource centres or public libraries, EPD may consider making available sound tracks so that interested consumers may have an idea of the noise levels. Brochures describing the sound levels can be produced to help readers comprehend and make comparisons. Advice should also be given as to where further assistance / details can be sought. This can help consumers differentiate and assess the impact of different noise levels on them.
