Plan for incinerator island by Shek Kwu Chau environmentally unacceptable

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:

Location

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.

Cost

Even before building the incinerator, massive funding will be required for constructing the artificial island together with necessary infrastructure.

Timing

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.

Terrestrial biodiversity

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

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.

Scenic value

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 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.

Better Alternatives

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.

Yours sincerely,

Dr Martin Williams

Hong Kong Outdoors

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[quote]Dear Sir / Madam

Environmental Impact Assessment (EIA) Ordinance, Cap. 499
Application for Approval of EIA Report
Development of the Integrated Waste Management Facilities Phase 1

       This is to acknowledge receipt of your e-mail dated 18 March 2011.

       Our officers will proceed in accordance with the EIA Ordinance. The decision on the application will be placed in our EIAO Register Office located at 27/F, Southorn Centre, 130 Hennessy Road, Wanchai, Hong Kong and on our website (http://www.epd.gov.hk/eia).

Regards,
Sunny LAM
for Director of Environmental Protection[/quote]

Hardly makes me think the govt will pay much attention to submissions; certainly barely mentioned in EIA sub-committee meeting of Advisory Council on the Environment.

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Summary of Why No “Incinerator Island” by Shek Kwu Chau?

為什麼石鼓洲不可有“焚化爐“簡要
 

It’s the slowest, most environmentally destructive and most expensive option.

這是最慢,最破壞環境性和最昂貴的選擇。
 

Will cause permanent destruction of and damage to best fishing ground near Cheung Chau

會造成長洲附近捕魚環境的永久性破壞和損害
 

Location is not suited to a large-scale, complicated industrial process: this will be among the world’s largest waste incinerators, needs extreme care to ensure that emissions are not harmful to health, including causing cancers

石鼓洲位置不適合大規模、複雜的工業過程:這將是世界上最大的垃圾焚燒爐,需要格外小心,以確保排放不危害人體健康,包括導致癌症
 

If toxic emissions are released, will spread across surrounding area, including over Lantau and to Kowloon and Tuen Mun

如果有毒物質排放出來,將擴散到週邊地區,包括在大嶼山及九龍及屯門
 

The artificial island and incinerator will form an eyesore in one of the most beautiful areas in HK.

人工島和焚化爐,將對美麗的香港地區造成一個礙眼的阻礙。
 

Damage to tourism on Cheung Chau, and along south Lantau. Especially to recreational boating.

損害旅遊業對長洲,大嶼山南沿岸;尤其是對娛樂、划船等活動。
 

Contradicts government plan to designate this area for conservation and leisure tourism.

工程違反了政府指定在離島區僻作自然保育和休閒旅遊的規劃。
 

Shek Kwu Chau has fascinating land wildlife, including white-bellied sea-eagle, a unique snake species, rare lizard, high butterfly diversity. All could suffer from air pollution; disturbance may stop the eagles nesting.

石鼓洲是野生動物的生活及棲息地,包括白腹海雕,以及獨特的蛇種,稀有蜥蜴,蝴蝶品種多樣性。空氣污染將影響所有生物;工程也可能會干擾白腹海雕築巢。

 

Will kill globally endangered porpoises [rare, and cute]

More marine life will be killed

會趕絕了全球瀕危的江豚 [罕見且可愛的動物]
更多的海洋生物會被殺死
 

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If you're interested in this issue, you may also like to see - and maybe "Like" (as if joining) a Facebook page:
石鼓洲並非一個合適處理垃圾的地點 Shek Kwu Chau wrong place for burning Hong Kong lap sap

Martin Williams's picture

Edited version of this letter from me appeared in today's South China Morning Post:

I read with interest the recent article and editorial on Hong Kong's environmental impact assessment, including the editorial noting that some green activists joke that EIA reports are "invincible".
 
These were especially timely given I am involved in opposing plans for building an artificial island together with mega waste incinerator beside southwest Shek Kwu Chau, in the otherwise unspoiled waters along southern Lantau.
 
I considered the EIA report on possible sites for waste incinerators was strongly biased towards making the Shek Kwu Chau site appear a viable choice for an incinerator, and deficient concerning potential pollution, as well as impacts on scenery, biodiversity, and Hong Kong people's quality of life.
 
So when I attended a public session of an Advisory Council on the Environment sub-committee meeting on the report, I looked forward to hearing some strong criticisms, with ACE members pointing out the report’s many shortcomings. Instead, there was little of substance; and to my mind, the sub-committee functioned largely as a rubber stamp for the report.
 
Also striking to me: though the meeting included government officials and consultants, together with ACE members, it appeared not one person present was an expert in waste incineration. Indeed, after a little research within Hong Kong and on the internet, I felt better informed than most people who spoke.
 
In this case, then, the EIA process was particularly deficient. Not only was the government both proposing and judging a project that would cause environmental damage, but the EIA was discussed by a government-appointed body, with ACE chair Paul Lam Kwan-sing admitting (in the Post article) that members lack certain expertise.
 
The government subsequently withdrew the EIA report, after a judicial review found serious issues with the EIA for the Hong Kong - Zhuhai - Macau Bridge. This suggests that though ACE passed the report, the government lacks confidence in it.
 
Clearly, a better system is needed. Not just a bureaucratic mechanism: I believe there is a case for leadership coupled with true dialogue with Hong Kong people; both are sorely lacking at present.
 
The choice of Shek Kwu Chau for Incinerator Island has surely arisen not through vision, but through the government fumbling for a strategy, with a series of consultations, reports and committee meetings that have failed to tackle the root causes of Hong Kong's waste problem or find forward-looking solutions.

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I have had request from EPD that I withdraw my objection to the dredging and reclamation work planned for beside Shek Kwu Chau; or did I have further comments.

I sent further comments:

LUI Ping-hon

Environmental Protection Department

 

Dear Lui Ping-hon:

Thank you for your responses to my objection to the Dredging and Reclamation to the South-Western Coast of Shek Kwu Chau for the IWMF – Phase 1.

I do not wish to withdraw my objection – far from it; and I indeed have some further comments:

George Orwell, author of 1984 (in which, say, the Ministry of Truth is in charge of misinformation and falsifying history), might appreciate this project.

·      The project is led by the Environmental Protection Department, yet will involve significant environmental destruction;

·      The EPD is the project proponent, funds the consultations, and judges information on the project;

·      I sent an objection to the Lands Dept covering the reclamation, and received a response from EPD covering the entire Incinerator Island project (reclamation, incinerator and all);

·      The project supposedly involves waste management, yet waste mis-management would seem more likely – with environmental damage, potentially useful waste burned, no incentives for waste reduction, reuse and recycling (indeed, incinerators are “hungry”, needing waste to burn)’;

·      There are a host of contradictions in available info: the incinerator should be away from public view and yet can be beautiful (!!!), the chimney fumes will be clean, and yet too dirty to site the incinerator in the heart of the city;

·      The project is being driven forward with no information on costs, and very little re alternatives;

·      There are “consultations”, yet it seems there is no real interest in listening to public views – indeed, instead of any real response or engagement, people and organisations objecting to the reclamation have received requests to withdraw these objections;

·      Though the issues connected with the project are wide-ranging, there are attempts to show this is a very localised project;

·      The Pui O meeting on 25 November is in a far-flung location: ideal for minimising participation by wider Hong Kong public, or any media attention. [Likewise the newly added meeting on 28 Nov]

So, to your response to my objection, dated 4 October; a few remarks:

No New Information

There was nothing new in the information; I had read project info, attended talks, had a little discussion – after which, I objected.

Hence, why would you think that by rehashing information I would withdraw my objection?

EIA for Incinerator to Follow Permission for Reclamation

It remains ridiculous, in my view, to seen the go ahead for reclamation project, for a project that supposedly does not yet have the go ahead itself. Without the incinerator by Shek Kwu Chau, there is no need for the reclamation.

IWMF to Not Affect South Lantau Tourism

You twisted my words here, and did nothing to show that the IWMF plan does not contradict government strategy including south Lantau and nearby islands, including Shek Kwu Chau.

I did not just write of south Lantau tourism, but tourism for the area; this includes potential for boating tourism – much as in Sai Kung area, say: of interest to Cheung Chau fishermen, and could be timely given the coming ban on bottom trawling here. No one will be so keen on boat trip past Incinerator Island, the place porpoises once roamed!

Even your statement re south Lantau tourism not being affected is open to question. Why do you say this? What of cafes etc at places such as Cheung Sha, with clientele including people arriving by junk from HK Island: surely their customers can instead favour places with more natural coastal landscapes.

You will have noticed EIA getting muddled here. Says Sai Kung islands not suitable site, as can be seen from country parks; Lamma old quarry not good as visible from Sok Kwu Wan restaurants. Yet this highly biased EIA somehow fails to mention She Kwu Chau Incinerator Island will be visible from Lantau country parks, south Lantau restaurants, and surely Cheung Chau restaurants – which will lie in path of the chimney fumes on many a summer evening, when these restaurants are extremely popular.

High Aesthetic Standards for Incinerator

Look, I know you tell us this; but really – it’s more nonsense, an incinerator is clearly utterly unsuited to an area of outstanding natural beauty like this.

EPD has produced images of art deco style incinerators, that may suit industrial areas that are highly visible, or might even fit into urban areas; but nothing suitable for Shek Kwu Chau Incinerator Island. Green paint and a few blades of grass and bushes won’t make it lovely; there’s a 150-m chimney, for goodness sake! Plus mini container ships arriving, unloading and departing: this will be an industrial site.

IWMF to Become Tourism Attraction(!)

Nonsense! No tourists will be interested in this. We laugh at this idea on Cheung Chau; which on weekends already attracts many thousands of tourists. And behind the laughter, there’s surely the feeling the EPD is being insulting here, including to Cheung Chau.

You might attract school tours, some visitors with working involvement in incinerators (Elvis Au told ACE people many of them had been to incinerators in Japan, yet surely not on their family holidays?!), but nothing that will make this incinerator beneficial for tourism in this area.

-       and if it will be so great, try placing it where many more can visit, like by the new government offices. See how enthusiastic the Tourism Commission and Tourism Board are about this.

Indeed, this incinerator will be so clean, so beautiful, so beneficial, and needs a central location – so Central, by govt offices, indeed the best place for it.

Onwards, to more of the response:

Acceptable to Kill Endangered Porpoises

I paraphrase here, of course.

The waters to southwest of Shek Kwu Chau are very important for Finless Porpoise, particularly in winter.

The porpoise is globally Vulnerable to extinction. Hence, any department with responsibility towards the environment would call a halt to the project on this basis alone.

Yet there are attempts to obscure the importance of the area to this porpoise, to downplay or strive to ignore it being Vulnerable to extinction, and Hong Kong holding a potentially significant population, and this being one of few large animals remaining in Hong Kong. The EIA’s main map shows the porpoise range looking extensive; somehow managed to exclude important area east of Shek O.

Yet saying it’s okay to devastate this area for Incinerator Island is a little akin to saying that just because you move widely around Hong Kong, you won’t be affected if someone demolishes your bedroom and maybe another room or two.

I noted there is no science behind the mitigation measures; indeed you fail to come up with anything to contradict this regarding the porpoise.

To protect an endangered species, you protect its habitat. As you work in environmental protection, you should know this. Sadly, seems EPD has forgotten about protecting environment in this case; and it of course doesn’t help our environment and biodiversity that AFCD does not seem too interested in conservation.

Anyway, those mitigation measures seem pathetic. Draw some lines on a map, for a marine reserve that might be established sometime… Maybe sink a few boats, and dump in some fish fry – and hope for the best.

And this will be “acceptable”?? Bah!

Note this too: if porpoise population falls, as Chinese white dolphin numbers have lately dropped, maybe as result of factors including reclamation work and extra marine traffic –you will not be able to do anything worthwhile to reverse the decline. You will not be able to unmake Incinerator Island.

Precautionary principle, then: safeguard the known porpoise areas.

Incinerator Emissions to be “Clean”(?!)

This too is just another assertion from EIA etc.

There is scant information on how the air quality data was calculated; seems it is all based on best-case scenarios. 

Spreading Facilities Around

Not sure if this is in your response; but I’ve seen argument that southwest Hong Kong deserves an incinerator as part of evenly distributing facilities.

Well, who thought of this? It should come with a sign reading Warning: Idiots at Work!

For there is no real cause for spreading facilities around like this. Otherwise, might plan for a new football stadium for Lai Chi Wo, a landfill for Central, a major public library for Tung Lung Chau…

There might, however, be justification in having waste facilities biased towards where waste is actually created. So mainly in urban areas (as Japan’s incinerators, which you kindly showed to various people and highlight in a video). This might well be worth considering, including for anaerobic digesters; could boost awareness of waste – not just sending off to some remote place for burning.

 

Well, I’ve made some further comments, as you requested. Yet I don’t expect any worthwhile responses: after all, seems EPD is fully set on track for Incinerator Island, plus incinerator for Tsang Tsui, and who knows how many incinerators in future.

There surely are alternatives, even if hard to arrange, and needing significant change in philosophy. Needs complex mix, rather than just taking waste to sea and setting it on fire: anaerobic digesters (large and small), deposits on whatever items are possible so they are returned, more recycling and encouragement for it, maybe some incineration (by Green Island Cement) and so forth.

But such an approach would be harder than the Let’s Build a Bonfire, Someplace Most Hongkongers Don’t Know and Can’t See approach.

I know EPD is working on several approaches; but so far not much impact, and seem to be given only minor effort/attention compared to incinerator.

In summary: this project is not powered by science and commonsense – far from it! – but by politics.

Best regards,

Dr Martin Williams

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Attn:     Secretary for the Environment
        Mr. Edward Yau Tang-wah

Re:        Meetings organised by the EPD on 25 November 2011 at Pui O Public School, Lantau, and on 28 Nov on Cheung Chau, regarding the  dredging and reclamation to the South-western coast of         Shek Kwu Chau for the Integrated Waste management Facilities Phase 1

Dear Mr. Yau:

My name is Martin Williams, a conservationist living on Cheung Chau.
I met you, briefly, a couple of years ago, as you opened a Geopark centre on Kat O. I was impressed at your readily talking with villagers; and you told me that you needed public support for environmental protection.

Sounded good that you need public support; seemed heartfelt. And yet, now the government is forging full steam ahead with the wrong-headed plans to build Mega-Incinerator Island beside Shek Kwu Chau.

There are so many severe issues with this project, it is hard to know where to begin or which to cite here:
- Will kill finless porpoises, a species globally Vulnerable to extinction (never mind the EIA says whatever deaths etc happen will be "acceptable");
- WIll severely impact other marine life, and affect the rich, unique biodiversity of Shek Kwu Chau;
- Will create a monstrosity in an Area of Outstanding Natural Beauty. An area the government has earlier designated for leisure tourism and conservation;
- WIll increase air pollution in relatively clean area of Hong Kong;
- Will be immensely expensive, perhaps by far the world's costliest mega-incinerator;
- Will fail to solve Hong Kong's waste problems - this is not "integrated", and Hong Kong will be putting most of its waste efforts into one bonfire (or later two bonfires, then three - and how many more do you envisage?);
- Will provide minimal job opportunities; and as for boosting tourism - well, here on Cheung Chau, we laugh at the idea.

The project is an utter disgrace.

You know there are alternatives; yet it would appear you are allowing politics - not science or commonsense - to drive the Mega-Incinerator Island scheme.

Here, you do not deserve any support whatsoever; your job is environmental protection, not environmental destruction.
I believe you should you seek more modern, more holistic, more enlightened alternatives, with scientific backing.

Though you talked cheerily enough with Kat O villagers, it has seemed that lately you have stayed well out of the limelight regarding the incinerators issue. Perhaps in part as you are a changed man since two years ago; can't be easy in your role, with political pressures, and CE Donald Tsang apparently so enamoured with projects involving concrete.
Yet I write in hope that within you there is still a man who wants to work on positive projects for Hong Kong. We certainly need this!

Anyway, I hope there is time for a change of course. Though I'm not optimistic.

Best regards,

Dr Martin Williams

Founder, Hong Kong Outdoors
 

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Ms Anissa Wong
Director of Environmental Protection

Dear Ms Wong:

I write with comments on the Environmental Impact Assessment on plans for the mega-incinerator ("IWMF") and artificial island to be constructed beside Shek Kwu Chau.

Writing with a heavy heart; as I believe it is no use making comments.
And you are heading a project that involves not environmental protection, but significant environmental destruction.
It seems you do not care about Hong Kong's environment; deeply sad given your role.

Overall, the EIA is lacklustre. Yet no one seems surprised at this, perhaps low standard EIAs are the norm here - and after all, the EPD is project proponent, employs the consultant, then has final say regarding the EIA, so why shouldn't the consultant write a report just as you require, fully expecting it will be simply rubber stamped.

And for the record: I have worked on EIAs, including for the World Bank and the Asian Development Bank, and I strived to make them a better standard than I see in this case.

Perhaps that's enough said.
After all, the EIA comments period ends on 17 December, yet the EIA sub-committee of ACE has already given the green light to the project: which to me helps make a mockery of the EIA process.
There was further farce, of course, in the EIA already having appeared for comments, then being withdrawn, and now reappearing - with other work perhaps proceeding according to schedule.

So, for the record, to the EIA itself; and I hope you have response I made when EIA originally appeared:

Overall, sadly biased in favour of making Shek Kwu Chau and Tsang Tsui appear suitable sites for an incinerator. Tsang Tsui indeed has features making it suitable in several ways. Not so Shek Kwu Chau; yet the EIA rejects sites such as Sai Kung islands and Lamma quarry for reasons that could be equally applied to Shek Kwu Chau (visible from country park, visible from restaurants).
Likely impact on Indo-Pacific finless porpoise is downplayed; main report obscures the fact this is a key area for this locally rare species, and fails to mention it is classed as Vulnerable to extinction by the IUCN.

Further remarks, already sent to EPD in objection to the reclamation and dredging project:

·      The project supposedly involves waste management, yet waste mis-management would seem more likely – with environmental damage, potentially useful waste burned, no incentives for waste reduction, reuse and recycling (indeed, incinerators are “hungry”, needing waste to burn)’;

·      There are a host of contradictions in available info: the incinerator should be away from public view and yet can be beautiful (!!!), the chimney fumes will be clean, and yet too dirty to site the incinerator in the heart of the city;

·      The project is being driven forward with no information on costs, and very little re alternatives - perhaps ALL of which would be far less costly, and far more "integrated";

·      There are “consultations”, yet it seems there is no real interest in listening to public views – indeed, instead of any real response or engagement, people and organisations objecting to the reclamation have received requests to withdraw these objections;

·      Though the issues connected with the project are wide-ranging, there are attempts to show this is a very localised project: convenient for govt if can show opponents are just a bunch of NIMBY folk.

IWMF to Not Affect South Lantau Tourism

The IWMF clearly contradicts government strategy to earmark south Lantau and nearby islands, including Shek Kwu Chau, for leisure tourism and conservation.

As well as S Lantau tourism, there is potential for boating tourism – much as in Sai Kung area, say: of interest to Cheung Chau fishermen, and could be timely given the coming ban on bottom trawling here. No one will be so keen on boat trip past Incinerator Island, the place porpoises once roamed!

Notice EIA getting muddled here. Says Sai Kung islands not suitable site, as can be seen from country parks; Lamma old quarry not good as visible from Sok Kwu Wan restaurants. Yet this highly biased EIA somehow fails to mention She Kwu Chau Incinerator Island will be visible from Lantau country parks, south Lantau restaurants, and surely Cheung Chau restaurants – which will lie in path of the chimney fumes on many a summer evening, when these restaurants are extremely popular.

High Aesthetic Standards for Incinerator

An incinerator is clearly utterly unsuited to an area of outstanding natural beauty like this.

- anyone saying otherwise should push for incinerator in heart of city, such as right outside your office. There's still space at Tamar.
EPD has produced images of art deco style incinerators, that may suit industrial areas that are highly visible, or might even fit into urban areas; but nothing suitable for Shek Kwu Chau Incinerator Island. Green paint and a few blades of grass and bushes won’t make it lovely; there’s a 150-m chimney, for goodness sake! Plus mini container ships arriving, unloading and departing: this will be an industrial site.

IWMF to Become Tourism Attraction(!)

Nonsense! No tourists will be interested in this. We laugh at this idea on Cheung Chau; which on weekends already attracts many thousands of tourists. And behind the laughter, there’s surely the feeling the EPD is being insulting here, including to Cheung Chau.

Might attract school tours, some visitors with working involvement in incinerators (Elvis Au told ACE people many of them had been to incinerators in Japan, yet surely not on their family holidays?!), but nothing that will make this incinerator beneficial for tourism in this area.

-       and, again, if it will be so great, try placing it where many more can visit, like by the new government offices. See how enthusiastic the Tourism Commission and Tourism Board are about this.

Acceptable to Kill Endangered Porpoises

I paraphrase here, of course.

The waters to southwest of Shek Kwu Chau are very important for Indo-Pacific Finless Porpoise, particularly in winter.

The porpoise is globally Vulnerable to extinction. Hence, any department with responsibility towards the environment would call a halt to the project on this basis alone.

Yet there are attempts to obscure the importance of the area to this porpoise, to downplay or strive to ignore it being Vulnerable to extinction, and Hong Kong holding a potentially significant population, and this being one of few large animals remaining in Hong Kong. The EIA’s main map shows the porpoise range looking extensive; somehow managed to exclude important area east of Shek O.

Yet saying it’s okay to devastate this area for Incinerator Island is a little akin to saying that just because you move widely around Hong Kong, you won’t be affected if someone demolishes your bedroom and maybe another room or two.

I noted there is no science behind the mitigation measures; indeed you fail to come up with anything to contradict this regarding the porpoise.

To protect an endangered species, you protect its habitat. As you work in environmental protection, you should know this. Sadly, seems EPD has forgotten about protecting environment in this case; and it of course doesn’t help our environment and biodiversity that AFCD does not seem too interested in conservation.

Anyway, those mitigation measures seem pathetic. Draw some lines on a map, for a marine reserve that might be established sometime… Maybe sink a few boats, and dump in some fish fry – and hope for the best.

And this will be “acceptable”??

Note this too: if porpoise population falls, as Chinese white dolphin numbers have lately dropped, maybe as result of factors including reclamation work and extra marine traffic –you will not be able to do anything worthwhile to reverse the decline. You will not be able to unmake Incinerator Island.

Precautionary principle, then: safeguard the known porpoise areas.

Incinerator Emissions to be “Clean”(?!)

This too is just another assertion from EIA etc.

There is scant information on how the air quality data was calculated; seems it is all based on best-case scenarios.

Also, nothing to suggest calculations are based on actual Hong Kong waste being burned. No pilot projects conducted; the only pilot waste incineration scheme I know of was by Green Island Cement, which has been mysteriously disallowed from tendering for Hong Kong waste solution.
Spreading Facilities Around

I’ve seen argument that southwest Hong Kong deserves an incinerator as part of evenly distributing facilities.

There is no real cause for spreading facilities around like this. Otherwise, might plan for a new football stadium for Lai Chi Wo, a landfill for Central, a major public library for Tung Lung Chau…

There might, however, be justification in having waste facilities biased towards where waste is actually created. So mainly in urban areas (as Japan’s incinerators, which you kindly showed to various people and highlight in a video). This might well be worth considering, including for anaerobic digesters; could boost awareness of waste – not just sending off to some remote place for burning.

 

There surely are alternatives, even if hard to arrange, and needing significant change in philosophy. Needs complex mix, rather than just taking waste to sea and setting it on fire: anaerobic digesters (large and small), deposits on whatever items are possible so they are returned, more recycling and encouragement for it, maybe some incineration (by Green Island Cement) and so forth.

But such an approach would be harder than the Let’s Build a Bonfire, Someplace Most Hongkongers Don’t Know and Can’t See approach.

In summary: this project is not powered by science and commonsense – far from it! – but by politics.

Yours sincerely,

Dr Martin Williams

Director

Hong Kong Outdoors
 

Martin Williams's picture

article appeared in S China Morning Post:


 
Hong Kong people seem to be put off by incinerators because of their impression of such technology from the past - smoke-belching incinerator chimneys of the 1980s.
Today's incineration technology has in fact advanced considerably, so only very low levels of dioxins and other pollutants are emitted. Instead, we should fear the plant's destructive impact and wasteful capability if it is built as currently proposed by the Environmental Protection Department.
The environmental impact assessment report of the proposal to build an incinerator near Shek Kwu Chau has been resubmitted to the Advisory Council on the Environment for approval. The council is now scrutinising it, after one of its subcommittees endorsed it earlier this month.
Consideration of the incinerator plan was delayed by a legal challenge to the quality of the environmental report for a proposed bridge to Zhuhai and Macau. In that case, the Court of Appeal ruled that bridge works could proceed, but said the director of environmental protection should have the professional knowledge to ensure that the environmental impact of projects are kept to a minimum to safeguard public health.
The spirit of requiring an environmental impact assessment to be conducted is to allow the project proponent to apply the best practical means (including best technologies) to first avoid potential impact on the environment, and then to minimise any impact that is unavoidable.
As a member of the advisory council's subcommittee that evaluated the incinerator reports, I registered my disagreement. I could see there was no major change in the resubmitted report to the questionable choice of the site for the proposed incinerator, nor proper consideration of the latest technologies being used elsewhere. Where is the mention of local corporations that want our garbage or their trials showing low emission levels? Is this due diligence by the director, who is supposed to be the department's final gatekeeper?
In the proposal, the incinerator will perform basic sorting out of incoming waste, and the furnace will burn high-value resources, such as plastic, paper, metal and even food waste, to produce a little electricity. Will revenue from that electricity even cover the daily operating costs?
It appears that, once again, the department is attempting to hard-sell its questionable decision to locate the incinerator off Shek Kwu Chau.
The following questions are worthy of discussion.
First, the department has said the location of the incinerator off the island would not directly damage the land ecology of the island. Officials are right, but can it avoid permanent damage to the marine environment, or indirect damage to Shek Kwu Chau?
Second, the building of the incinerator off Shek Kwu Chau by 2018, rather than at Tuen Mun, the government's second choice, will take two more years to complete. So what is the logic behind a choice that means over two million more tonnes of waste going into our landfills, not to mention the extra billions of dollars of taxpayers' money that will be spent on the permanent destruction of the marine environment, on account of the reclamation?
Finally, the council's subcommittee was asked to approve the environmental impact assessment reports for both options - Shek Kwu Chau and Tuen Mun - even though the government plans now to build only one incinerator. What is the motive behind that? Could it be that the department wants to avoid the hassle of getting approval for a second incinerator to cope with more garbage?
Without more waste-avoidance measures like charging for disposal, a landfill ban, producer responsibility schemes and community-wide education, then even a 3,000-tonne incinerator plant won't be able to cope with the garbage generated by our wasteful lifestyles.
Edwin Lau Che-feng is director of general affairs at Friends of the Earth (HK) and a member of the Advisory Council on the Environment

 

Martin Williams's picture

Letter in today's S China Morning Post:

I agree with Craig Colbran's letter ("Incinerator is a bad way to burn money", December 30).
The Environmental Protection Department does almost nothing for the taxpaying public. My name for it has been, for some years, the Environmental Polluting Department and I think the title fits.
I recently wrote to the department to express my opposition to the plan to build an incinerator at Shek Kwu Chau.
I first visited the island in 1968 to see the superintendent of the Society for the Aid and Rehabilitation of Drug Abusers' (Sarda), drug rehabilitation centre.
We agreed that what was most suitable was to develop the island for recreational use and for tourists, but that the Sarda centre would have to be relocated.
Building an incinerator at Shek Kwu Chau would be irresponsible. It would lead to the destruction of an asset of great natural beauty. I gather that the estimated cost of the project would be far more than the cost of building the same facility at the Tsang Tsui ash lagoons in Tuen Mun. I have walked in the area where these lagoons are located and feel that if Hong Kong must have this type of incinerator, then Tsang Tsui would be a far better location and, as I understand it from the limited information available, a lot cheaper.
I visited a modern incinerator on the outskirts of Tokyo, only a few kilometres from Tokyo Disneyland, and was most impressed by its layout and the cleanliness. Hong Kong should consider adopting a similar design, although we would have to adopt a better system of separation of rubbish.
The rigorous system in operation throughout Japan is something that the Hong Kong government should introduce. In this regard the Environmental Protection Department can take a leading role.
Several years ago, I noted the clean way in which rubbish was separated in Japan for collection. I felt it was the only country in the world with what I would call gift-wrapped garbage.
I believe that achieving something similar when it comes to waste separation in the SAR is more important than building a super-incinerator.
Shek Kwu Chau is a pearl in the chain of precious islands to the south of Lantau. It must be saved from senseless and wanton destruction.
Gordon Andreassend, Tai Kok Tsui

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Two letters published in South China Morning Post.

7 June 2012

Ash from incinerator is hazardous

I refer to the letter by Wolfgang Ehmann ("Residual waste cannot be eliminated", May 23). Since 2007, through these columns, your correspondent has promoted the use of incineration.

In a submission to a Legco panel in March, Mr Ehmann, on behalf of the German Chamber of Commerce, said: "In 2007 our office led a delegation of senior [Environmental Protection Department] staff and stakeholders to Germany to attend the Waste to Energy Trade Fair and visit waste to energy plants in Hamburg and Frankfurt." So he is doing his job to promote German incineration technology and point out the lack of local legislation to mandate recycling.

Germany, thanks to at-source recycling legislation, has a 70per cent recycling rate, so it now imports waste from around the world to keep its incinerators operational.

What he and the outgoing environment minister sidestep is that incineration thermally converts waste and leaves 23 per cent bottom ash and 6 per cent fly ash by weight, which are hazardous waste, with no landfills left here to take the ash. That means building mega islands to receive the ash.

Last month, a company called Solena Fuels was in town. It uses plasma gasification of waste to produce biofuel for jets and boats, bio-naphtha and biodiesel. Its partners are 15 world airlines and Maersk. There are no ash or emissions from a plasma plant, just a molten slag that can be used as road aggregate.

Incineration and its airborne/soil pollutants have long been associated with dioxins.

The only incinerator of the size proposed here is in Detroit, Michigan, in the US. According to one report, it has cost the city an estimated US$1.2 billion, and has caused increased pollution levels. It says that "asthma death rates in Detroit are two times that for the state".

Meanwhile the Environmental Protection Department did not mention in a recent environmental impact assessment that three incinerators are planned in Shenzhen from 2015 (burning 6,300 tonnes of waste a day), with predominant northerly winds blowing into Hong Kong.

James Middleton, chairman, Clear the Air

and, today:

Incinerator plan is a disgrace

I refer to James Middleton's letter ("Ash from incinerator is hazardous", June 7), citing hazards associated with incinerators, and wish to point out that the use of such facilities to get rid of waste is basically the same as dumping this waste into our oceans.

Burnt waste is turned into gases; they stay with us and are then dissolved into rain clouds, and then the rain falls into our oceans. Most incinerators are located to allow emissions to discharge into the sea to reduce the impact to us land-dwellers.

Modern incinerators, such as the integrated waste management facilities being proposed in Hong Kong, merely ensure that emissions are odourless and invisible to the naked eye. However, no greenhouse gas will be captured, which will affect global warming. The Environmental Protection Department and minister Edward Yau Tang-wah, who are promoting these waste facilities, are a disgrace for not protecting our environment.

Nigel Lam, Kowloon Tong