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There was further farce, of course, in the EIA already having appeared for comments, then being withdrawn, and now reappearing – with other work perhaps proceeding according to schedule.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.
Dr Martin Williams
Hong Kong Outdoors