Just submitted this to government, as response to plan for waste incinerator, especially the preferred option of building an artificial island for this by Shek Kwu Chau:
Hong Kong Outdoors, Cheung Chau, 17 March 2011
To Ms Anissa Wong, Director of Environmental Protection
` Comments on the proposed IWMF Agreement No. CE 29/2008 (EP)
The Hong Kong Government has given two options for the planned waste incinerator: ash lagoons at Tsang Tsui, Tuen Mun; and an artificial island to be constructed off southwest Shek Kwu Chau. We are told the latter is the preferred choice, and a public consultation began last month.
This public consultation is too short: the issues merit further discussions by Hong Kong people. Yes, landfills will fill up soon, yet the government’s policies have contributed to this, making Hong Kong one of the world’s most throwaway societies. Any sense of urgency must be countered by the fact the “preferred” option cannot become operational until 2018 at the earliest.
The choice of Shek Kwu Chau is not appear justified on any scientific basis, and is environmentally unacceptable.
Shek Kwu Chau Selection Contradicts Government Plans
The selection of Shek Kwu Chau (really, waters to the southwest, where an artificial island will be constructed) is in direct contradiction to the intent of the government’s Southwest New Territories Development Strategy Review. This recommended that south Lantau and nearby islands be protected for nature conservation and leisure tourism. Shek Kwu Chau was designated as a potential conservation area.
Badly Biased Environmental Impact Assessment
Reading the environmental impact assessment, it is clearly biased towards making Shek Kwu Chau appear environmentally acceptable as a site for the incinerator. Note, for instance, different approaches taken to “assessing” Sai Kung islands and Lamma sites, and Shek Kwu Chau: with the former, factors are covered that reject these sites; yet though similar factors can apply to Shek Kwu Chau, they are barely mentioned, and the EIA highlights supposed factors in favour of Shek Kwu Chau.
This would appear to result from an overarching political imperative, and the EIA consultants seeking to do their paymasters’ bidding.
Among factors that make Shek Kwu Chau unacceptable:
An artificial island with no infrastructure does not seem a sensible choice for locating a complicated, substantial industrial complex. Plus, Shek Kwu Chau is exposed to the elements, including tropical storms and typhoons.
Even before building the incinerator, massive funding will be required for constructing the artificial island together with necessary infrastructure.
Building the island will take time, additional to the time needed for constructing the actual incinerator. The incinerator cannot become operational until 2018 at the earliest. Hence, it may not be available until after existing landfills are full. And, there may be pressure to rush the project, reducing efficiency and increasing pollution once it does begin operating.
Potential air pollution
Especially given the location, it is unlikely to incinerator will operate at anything approaching the efficiency possible with waste incinerators, which are complex, with potential for releasing a range of toxic chemicals that have been proven to cause cancer and other illnesses. For instance, dioxins are readily created by incineration, particularly if there is inadequate waste sorting and drying. Physical constraints will make it difficult or impossible to make subsequent improvements.
Pollutants will not only affect the immediate vicinity, including Cheung Chau and south Lantau, but will also spread across east and north Lantau, and reach other areas of Hong Kong including Kowloon and Tuen Mun.
Shek Kwu Chau has remarkable biodiversity. One species and one sub-species of snake – Hollinrake’s Racer and Jade Vine Snake – have been found nowhere else on earth. Shek Kwu Chau is one of only three islands in the world, all near Lantau, that are home to Bogadek's legless lizard. Around two-thirds of Hong Kong’s species have been recorded: an astonishing diversity for such a tiny island. Plus, Shek Kwu Chau is one of few local breeding sites for Hong Kong’s most magnificent resident bird of prey, White-bellied Sea-Eagle.
Marine biodiversity is high around Shek Kwu Chau. The waters to the southwest of the island are the best fishing ground near Cheung Chau. Some 15 species of hard coral have been found.
This is one of three key sites in Hong Kong for Black Finless Porpoise, a marine mammal that is globally Vulnerable to extinction. This fact alone should make Shek Kwu Chau an unacceptable location for the incinerator.
Reclaiming around 16 hectares of land, plus breakwaters and berthing area will cause significant, irreparable and unacceptable destruction and damage to the marine environment.
As the Southwest New Territories Development Strategy acknowledges, Shek Kwu Chau is located in an area of islands and coastline with great scenic value, including south Lantau, the Soko Islands, and Cheung Chau.
The EIA cited scenic value as an important reason for rejecting potential sites in Sai Kung islands and on Lamma. Shek Kwu Chau should also be rejected because of the landscape value.
Tourism – particularly involving people from urban areas in Hong Kong, as well as overseas visitors – is very important for nearby Cheung Chau and south Lantau. Indeed, for Hong Kong city people visits to these areas give them a chance to escape the “concrete jungle”, and enjoy greenery, scenery, and fresher air.
Activities include hiking, swimming, eating seafood, and enjoying the scenery. Shek Kwu Chau is an important island for these visitors, readily visible from many places – and the waters here are already popular for leisure boats, with potential for increased visits to appreciate the unspoiled coastlines. This situation is similar to the Sai Kung islands – and yet the EIA used leisure activities as a reason for rejecting the Sai Kung islands as a potential site, but not Shek Kwu Chau.
There is potential for increased tourism to waters around Shek Kwu Chau.
However, it is absurd to suggest (as some proponents have done) that an incinerator island by Shek Kwu Chau No one visiting Cheung Chau or south Lantau is intent on seeing an industrial complex with giant chimney belching fumes.
As the EIA makes clear, the site at Tsang Tsui ash lagoons is far better than Shek Kwu Chau on environmental grounds. If an incinerator were to be built here, there would be far less constraints on land area than at Shek Kwu Chau, and it would be possible to also use money “saved” (by not constructing an island) to maximise incinerator efficiency – such as using burning at temperatures of 1350C and above, rather than 850C as currently planned.
Also, Green Island Cement has an alternative proposal, which would appear to have several benefits: far lower cost – partly as industrial land with infrastructure is already available; tried and proven in Hong Kong; higher capacity; trial operations yielded waste emissions substantially lower than government standards – for instance, dioxin levels 99 percent lower than the BMP standard.
The government should also consider transforming existing Refuse Transfer Stations into Waste Processing Centres (including incinerators). The merits of this alternative is that i) we do not add any dirty facility to any district; ii) we are proposing improving the RTSs; iii) we avoid double-handling of wastes; iv) each district (LegCo district) solves their own problems and bears the same responsibility; v) if the incinerator can generate electricity, it can be provided free to all government facilities in the district directly.
Plus, should proponents of the Shek Kwu Chau site really believe it will benefit tourism: build it at Disneyland. Here, there is land available, transport will be easier, and Disneyland needs more attractions. [No, this is not a serious proposal; yet it helps highlight the absurd nature of plans for “Incinerator Island” by Shek Kwu Chau.]
Woefully Inadequate Public Consultation
To date, public consultation has been woefully inadequate. Even the information on the EPD website has been barely updated. A meeting on Cheung Chau involved EPD officials and AECOM consultants talking, hearing a multitude of complaints and questions, but giving no substantial answers: nor have answers been conveyed to participants.
The government has produced propaganda videos, only in Chinese – even though English is an official language in Hong Kong, and this issue affects everyone in Hong Kong. At least one shows a pretty girl happily talking about the situation in Japan, in a manner recalling a beauty products company promotion.
Further discussions, and genuine public consultations are needed. An alternative to constructing an artificial island with incinerator by Shek Kwu Chau must be found.
Dr Martin Williams
Hong Kong Outdoors