Reply To: China waste incinerators pose wide-ranging threats



We are a group of non-governmental organisations and individuals who care about China’s environmental protection and social wellbeing. In this letter we would like to express our heartfelt concern regarding the investment and construction arrangements of the Beijing Nangong Municipal Solid Waste Incinerator, and would like to seek an opportunity to develop a frank dialogue with your bank.

according to our information, there are widespread problems associated with the use of waste incineration technology in China. Some aspects of environmental hygiene facilities in Beijing, which Germany has helped construct, are also worthy of re-examination. If these already existing problems are not addressed, resolved, or taken seriously by the responsible parties, the implementation of the Nangong Waste Incinerator project could harm the public interest of Beijing residents. It would also contradict your bank’s investment principles and harm the international reputation of the German government and companies.

In China municipal solid waste incineration is already an environmental pollution source that cannot be ignored. First, it is commonly known that the burning of waste will produce and emit dioxin-type pollutants. The Chinese government’s “People’s Republic of China National Implementation Plan for the Stockholm Convention on Persistent Organic Pollutants” lists municipal solid waste incineration as an emissions source whose control must be prioritised.[3] In 2009 academics from the China Urban Construction Design & Research Institute published an article stating that in 2007 the estimated airborne dioxin emissions from municipal solid waste incineration (there were less than 70 incinerators in operation in that year) in China was 157.93g TEQ (toxicity equivalent), which was a big increase on the 2004 figure of 125.8g TEQ. For comparison, in 1994 airborne dioxin emissions from municipal solid waste incineration in Germany were only 30g TEQ. It is estimated that this figure has been below 0.5g TEQ since the beginning of the 21st Century (around 70 municipal solid waste incinerators are running in Germany now). [4]In the same year, scholars from the Chinese Academy of Sciences published the results of their research into the airborne dioxin emissions from 19 municipal solid waste incinerators in China. According to their results, 13 incinerators did not meet the EU standard of 0.1ng TEQ/m3. Three incinerators even exceeded the Chinese national standard of 1ng TEQ/m3.[5] In addition, whilst investigating the environmental quality of soil around a waste incinerator in Shanghai’s Jiading District, researchers from the Shanghai Academy of Public Measurement discovered that dioxin levels were markedly higher than the surrounding area. Based on this, they made the following conclusion: waste incinerators are a source of dioxins in the Shanghai area’s land.[6]

Apart from dioxins, China’s waste incinerators also emit a large amount of the heavy metal mercury. According to a 2011 article by academics from the South China University of Technology, mercury emissions from municipal solid waste incineration account for 21% of total man-made mercury emissions in the Pearl River Delta, second only to emissions from coal-burning (28%).[7] In other case studies, Chinese academics have discovered that airborne emissions from municipal solid waste incinerators have resulted in sharp increases in the mercury content of surrounding land and flora.[8]

Why do waste incineration facilities that can be operated relatively safely in some European countries and Japan “fail to acclimatise” when they reach China? Apart from the complicated mix of Chinese waste (high moisture content, low burning value, large quantity of hazardous waste products), the low standard of engineering technology and a lack of investment in pollution control, we believe that the main reason is that government departments are seriously lacking supervision and control over waste incinerators.

According to a 2011 article by scholars from the China Urban Construction Design & Research Institute, apart from a minority of cities including Shanghai and Guangzhou, the majority of fly ash from Chinese municipal solid waste incinerators is not handled safely.[9] Faced with this situation, it cannot be denied that there has been negligence from supervisory departments. The media has also reported cases of waste incinerators operating in breach of standards. For example: fly ash from the Macau Waste Incinerator was improperly dumped, ash residue from the Shenzhen Nanshan Waste Incinerator flowed into a black brick yard, and leachate from the Shenzhen Nanshan and Laohukeng waste incinerators was dumped directly into the sea without treatment. A programme televised by Shenzhen TV revealed that in May 2011 an incinerator operated by the Herrel Group in Sichuan was fined 50,000 Renminbi by the Chengdu City Environmental Protection Bureau for failing to adhere to regulations concerning the reporting of fly ash production, transportation and handling. However, in July the Herrel Group and the Environmental Protection Bureau “agreed to mediate” and the fine would not be enforced. We can say that these incidents have resulted from a lack of government supervision and control.

In addition, some important supervision and control information concerning the operation of incinerators is frequently not publicly disclosed in a timely manner, and monitoring data are not completely trustworthy. From February to April of this year the environmental non-governmental organisation Wuhu Ecology Centre applied to China’s 31 provinces, cities, and autonomous regions’ environmental protection bureaus and the Ministry of Environmental Protection for the release of a list naming companies that emit large quantities of dioxins (waste incinerators count as major emission source companies). However, only six provinces and cities’ environmental protection bureaus responded meaningfully.[10] As to the monitoring data concerning waste incinerator emissions of harmful pollutants (dioxins, heavy metals, polycyclic aromatic hydrocarbon, PM2.5), it is extremely rare for environmental protection departments to voluntarily release this information or to do so in response to an information disclosure request application. Some scholars have emphasised that most data in scientific research articles concerning legal dioxin emissions from waste incinerators is based on measurements taken under the most favourable conditions.[11] As a result, it is questionable whether or not these data can represent the normal operating situation of waste incinerators in China.

Because waste incineration in China has already resulted in significant amounts of pollution, and due to insufficient supervision and control and a lack of transparency, waste incineration projects in many urban and rural locations face increasingly strong opposition from local residents. Some opposition activities have even evolved into serious street protests, involving urban residents in cities including Beijing, Shanghai, Wuhan and Nanjing, and residents from towns or villages in locations including Likeng Village in Guangzhou’s Taihe Township, Pingwang Township in Jiangsu’s Wujiang, and Huangtutang Village in Wuxi’s Donggang Township. It can be said that waste incinerators cannot avoid causing anxiety to local residents wherever they are planned.