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- 9 November 2004 at 11:37 am #6856
(idea from Keen, posted here at his request):
Is Government paying millions to have waste tyres create pollution and fire hazards?
I would like to hear comments on the use of waste tyres to form artificial reefs for recreational fishing and water sports.
We live in a high tension city and also have a rapidly ageing population. Recreational fishing, outdoor activities including water sports are getting more and more popular. We also have many waste tyres which I know can be, and have been, reused to form biofilters that serve as artificial reefs to attract fish along our coast. Could this be a Sustainable Tourism product? If so, can we ask EPD to consider the option of reusing HK’s waste tyres?
I am prompted to pose the question first of all due to my interest in Sustainable Tourism, and also because of an incident reported in the local magazines “NEXT”.
Apparently, over the past 16 months, EDP paid HK$4million to a private company operated by a university professor to turn 4,000 tons of HK’s waste tyres into marketable products so as not to over burden existing landfills. Up to the end of Sept, the company managed only to process about 8% of the lot. The remaining waste tyres were stockpiling in Yuen Long breeding mosquitoes and generally posing other health and fire hazards. This is a time when Dengue fever was deemed a chronic public health problem in the district.
After the matter was exposed by the magazine, the company proceeded to dump the waste tyres indiscriminately in various government lands in Yuen Long, some of which were grounded or turned into scraps. The problem is therefore accentuated by the spread and especially near residential areas. The larger dumpsites are some 30m x 20m and 2m high, such as one near Tin Sam Village on Castle Peak Road. That dump caught fire on 23 Oct which was not fully extinguished, emitting toxic gas for some 10 days.
According to the news report, EPD is renewing or extending the contract to the same company subsequently. One may question:
• Why is such a disposal technology and unproven product adopted by EPD?
• Who gave the company right to dump the waste tyre scraps in various government lands?
• What remedial actions have Government taken to rectify the problem?
• Is the $4million public money well-spent on this project, or could it be better spent on creating more artificial coral reefs and benefiting sustainable-tourism?
• Has the Government (EPD) considered other ways of disposing future waste tyres still being delivered to the company?
The question remain, can we not make use of waste tyres to form artificial reefs at some quiet beautiful bays that can be used for water sports and recreational fishing.
from another email from Keen:
I understand that ARs base on waste tyres have been used and proven
successful at Hoi Ha Marine Park and the AFCD has plans to use the same
to mitigate damaged seabed a various locations. If there is adequate
interest from the HK Forum, I intend to get someone to study the present
waste tyres issue.19 November 2004 at 10:54 am #7581
After Charlie Frew emailed Keen, with some reservations about tyres for artificial reefs, Keen obtained this info from an engineer friend:
“16th November 2004
RE: MERITS OF TYRE ARTIFICIAL REEFS (ARS)
I shall address each of the five issues raised concerning the tyre artificial reefs as follows:
1. Would toxins leach out from tyres?
Many scientific studies have been carried out in the past ten years to determine whether tyre AR will contaminate the seawater.
The following is a list of references we have at hand confirming that tyres are safe to use for ARs:-
(a) The US National Artificial Reef Plan (Stone, 1995) includes tyres as a reef construction material, noting that no toxic effects attributable to leaching or decomposition have been demonstrated.
(b) National Artificial Reef Plan. NOAA Tech. Memorandum NFMS OF-6, US Dept. of Comm., Wash, D.C, Nov. 70; Stone, R.B., 1995.
(c) A review of waste tyre utilization in the marine environment; Chemistry and Ecology 10: 205-216; Collins, K.J, A.C. Jensen and S. Albert, 1995. …. No adverse impacts demonstrated.
(d) Bio-accumulation studies of tyre artificial reef biota. Paper presented to the Third International Ocean Pollution Symposium, Harbor Branch Oceanographic Institution, Florida April 1997. Chemistry and Ecology; Collins, K.J, W. Figley, and E. Spanier, (in press).
(e) Acceptable use of waste materials. In European Artificial Reef Research, Proceedings of the 1st EARRN conference, Ancona, Italy, Southampton Oceanography Centre, 1996, pp 377-390; Collins, K.J., and Jensen, A.C., 1997.
(f) Scrap tyres for marine construction: environmental impact. In Recycling and Reuse of Used Tyres; p-p. 149-162. ed. By R.K. Dhir, M.C. Limbachiyya, and K.A. Paine. Thomas Telford London; Collins, K.J., Jensen, A.C., Mallinson, J.J., Mudge, S.M., Russel, A., and Smith, I.P. 2001.
(g) Epifauna of tyre reefs in Israel have been studied in detail. No significant excess levels of contaminants (for a range of heavy metals) were found (Collins et al in press.)
For, Hong Kong, in AFCD’s first tyre AR contract for Hoi Ha Wan and Yan Chau Tong Marine Parks in 1997, laboratory tests were carried out to detect possible toxins leaching from the waste tyre samples. None were detected. Since then, AFCD has deployed tyre ARs extensively in Marine Parks at Yan Chau Tong, Ho Ha Wan and Sa Chau- Long Ku Chau, and at the Airport Marine exclusion Zone, Kit-O Marine Research Center, the Long Harbour PFA and the Outer Port Shelter PFA.
2. Would tyres break loose from ARs
The tyre reef project in Florida is a well-documented failure which highlights the importance of using special design to cater for the corrosive environment in the sea. Even today, many countries still use steel fasteners to bond tyres together to form Tyre ARs. These steel fasteners corrode quickly in seawater and the tyres eventually break loose spilling tyres along the coasts.
In Hong Kong, the tyre reef designs were selected after an international tender and uses non-metallic fasteners in a patented construction. In the past 7 years, these tyre ARs have withstood many typhoons, impacts of huge trawler booms and fish dynamites without disintegration. These reefs are regularly checked and some of them have been dragged along the sea floor, far from original positions, and still retain their structural integrity.
3. Can tyre ARs act as anti-trawling devices?
In the last two years, AFCD has successfully deployed anti-trawling ARs specially designed to withstand Hong Kong’s most powerful trawlers. Moreover, these special anti-trawling ARs are able to rest on the silty seabed without sinking.
In short, with careful design and construction, mechanical strength and anti-trawling properties can be built into tyres ARs, or ARs of other selected materials.
4. Are tyre ARs productive?
Through extensive studies since 1997, AFCD has tried out many different types of artificial reefs using concrete, rocks, boats, tyres and special synthetic materials with various AR designs.
AFCD found that rock pile ARs and concrete ARs are both too heavy and prone to sink into Hong Kong’s muddy seabed.
AFCD also found that, the ship hulls are relatively empty and not very productive for its huge mass. Fish tend to aggregate in the small pilot cabins where the structures are more complex. However, when tyre ARs are deployed in these hulls as those in Long Harbour PFA and Outer Shelter PFA, the productivity of the boat ARs increases by several order of magnitude. The most obvious observations were that there were more fish in the tyre AR than the pilot cabin of the same boat.
AFCD also found that elevated tyre ARs of sufficiently large sizes are comparable to their most prolific ARs with bio-filters.
5. Do ARs pull fish away from rocky shores without adding to the total biomass?
HK’s shorelines have been damaged by extensive land reclamations over the last four decades and this trend shows no sign of stopping. Some recent examples include the reclamations in Victoria harbour, the west Kowloon reclamation, the reclamation for the Disney Theme Park at Yam O and the Lamma Island Power Station reclamation. Clearly an extensive portion of HK’s natural marine habitats is continuously been destroyed. The deployment of ARs even at the proposed rate of 200 ARs per year for the whole of Hong Kong, can only partially replace these lost habitats. To put it in anyway, where would those fish go now that their natural habitats at Victoria Harbour (or west Kowloon) are destroyed?
Similarly, away from shore line, most of the hard bottom substrates in HK’s inshore seabed are destroyed by the intensive use of bottom-scrapping trawler nets in the past three decades. Again ARs must be deployed to replace the lost habitats for the marine lives.
Therefore the question of ARs pulling fish away without adding to the total biomass is really not applicable to HK’s badly damaged marine landscape.
Henry”19 November 2004 at 10:56 am #7582
email correspondence continued, with this from Charlie Frew:
Many thanks for forwarding me the response from your engineering colleague. Whilst I agree with some of the responses I still fear that a lot more work needs to be carried out into the deployment of xx tyres as ARs.
Yes Hong Kong’s seafloor is in a state of oblivion, no thanks to trawlers – but carpeting the bottom with tyres may not necessarily be much better.
We have not had a direct hit with a serious typhoon in many years, the big one is yet to come, dynamiting has more or less been stamped out from Mirs Bay (HK side at least) and Anti trawling devices are usually ships/ or derelict dolphins – much heavier obstructions. Tyre nodules are purely fish habitats. So none of these impacts have really been tested on tyre ARs in Hong Kong.
We should also look at the fisheries management of the Tyre ARs – currently licenses are given out to indigenous fishermen who are free to fish in and around ARs. Are we not pulling in fish stocks to a centralised location for them to be fished quicker? I strongly believe that more work needs to be done by AFCD into this issue and further research into natural habitat verses ARs. West Kowloon and Victoria Harbour are not particularly good examples…..as these are beyond any form of short/long term remedial action. The east coast of Hong Kong is where we should be looking.
Maybe using some of the tyres is an obvious solution and yes AFCD should continue to monitor the ARs and draw comparisons. I really think they have done some tremendous work so far.
I for one would like to see more ARs in Port Shelter, esp since they are due to bring in the trawling ban. Sink some tyre ARs in certain locales and we will have a very productive region.
But I am just throwing caution to the wind as the number of tyres that need disposing off could make the seafloor of HK look like a scene from NT; but in our case it is out of sight-out of mind.
CF”26 November 2004 at 11:15 am #7583Quote:Dear Charlie,
I discussed the issues you raised with my marine engineering friend again. He has kindly provided further views in respond specifically to them. He is a proponent of wider deployment of Anti-trawling Artificial Reefs along our coastline, as a means to restore our damaged seabed and depleted fish stock, to prevent further damage by illegal trawling, as well as reuse of our waste tyres as sustainable disposal solution. What is perplexing to us is why is this option not adopted by EPD to dispose of our waste tyres stockpile, and why is AFCD not charged with enriching our in fish stock through Anti-trawling ARs. However, it is also important to know that Waste-tyres AR is by itself a sustainable solution, hence these exchanges. My other enquiries reveal that AFCD is only charged with creating the ARs in Marine Parks and Fishery Protection Areas, as well as the methodology of creating the ARs; anywhere else is the responsibility of Lands Department, and the Marine Department would have a say from the navigation point of view. I don’t see the Lands Department initiating a sustainable solution for the seabed. Hence it would appear to me that the responsibility should fall on the Environmental Department which has to dispose of the waste tyres. EPD has apparently been adopting wrong methods of disposal. We are eager that EPD is motivated to initiate the use a more sustainable solution such as Anti-trawling ARs to dispose of our stockpiling waste tyres, and for the other departments, Lands, AFCD and Marine to co-operate.
and from engineering friend:Quote:Re: Anti-Trawler Tyre Artificial Reefs
Apparently, some old issues have not been settled and some new ones are raised. Hopefully the new information below will help: –
1. “Structural Integrity of the tyre ARs is still untested. …. No direct hit by serious typhoon
yet”. Back in 1997, AFCD were equally cautious when they set out to choose an appropriate
tyre AR design. AFCD subjected the test tyre AR to the “flip tests” which simulated the
worse possible conditions where a severe typhoon would tumble the tyre ARs along the
seabed. These were very severe tests because the tyre AR was tested on land where its
weight is 4 times that in water, and therefore experienced 4 times the stresses actually
encountered in the sea. If the tyre AR passed the tests on land, it would have no problem
in the sea during typhoon conditions.
The chosen tyre AR design performed well during the test. All tyres were intact and the
whole AR structure maintained its shape. Thereafter, questions of structural integrity of
the chosen tyre AR design never arose again.
In fact, these tyre ARs have proven themselves over the years. Since their first
deployment in 1998, Hong Kong was hit by no fewer than 11 typhoons rated 8 or above.
Maggie rated 9, hit Hong Kong in June 1999 followed in September 1999 by York, rated 10. York, the most severe typhoon in the last twenty years lashed HK for over 11 hours
with wind speed up to 234 km/hour, the highest recorded wind speed in HK. Subsequent
dive surveys by AFCD showed that the deployed tyre ARs retained their structural
integrity and, no repair or maintenance work was required.
Two “Tyre nodules are (traditionally used as) fish habitats.” … They have not been tested as
Since AFCD began their AR Programs in 1995, HK’s AR technologies have evolved
rapidly from small pyramidal tyre nodules or sunken boats, to very sophisticated, high
profile structures designed to suit specific tasks and sites. The latest and most successful
anti-trawling ARs are such specialized structures, incorporating tyres or bio-filters,
sufficiently heavy and robust to resist the impacts of the largest trawlers in HK, and yet
light enough not to sink into HK’s muddy seabed.
Some of these third generation anti-trawler ARs standing 7 m above the sea floors, can be
found in the two marine parks in Hoi Ha Wan and Yan Chau Tong as well as the Long
Harbour Fishery Protection Area. From the shrill complaints AFCD receives since their
deployment and the large number of damaged trawler nets found on these anti-trawler
ARs, there is no doubt that these ARs are extremely effective.
Regular dive surveys by AFCD have also confirmed that these ARs provide excellent
feeding grounds, spawning sites and protective habitats for a wide variety of fishes,
including commercially valuable reef fishes.
3. “Anti-trawlers are usually ships/or derelict dolphins … much heavier obstructions”
Traditionally, ships or derelict dolphins were deployed as anti-trawlers. But derelict
dolphins from dismantled bridges or piers are not readily available and very expensive to
deploy due to their massive weight; while de-commissioned ships are expensive to buy,
clean out and prepare for deployment to avoid polluting the sea.
Furthermore, with the high prices of scrap steel in recent years, any mass over and above
the necessary weight (such as the over sized steel ships) to stop illegal trawlers is
redundant and a waste of resources. The modern anti-trawler ARs are designed to provide
just enough mass to stop the illegal trawlers and yet do not sink into the muddy seabed in
HK, unlike the massive dolphins.
HK’s experiences also showed that ships and derelict dolphins were not as productive as
purpose built anti-trawler ARs. They need additional enhancement ARs to raise their
productivity. So from an overall cost benefit point of view, purpose built anti-trawler
ARs are much better proposition than decommissioned ship, dolphin, or other dismantled
4. “The number of tyres that need disposing off could make the sea floor in HK look like a
scene from NT.” Some simple calculations may clarify the situation.
According to AFCD’s latest AR design with anti-trawling properties, one 8-9 m high tyre
anti-trawling AR will take about 4,000 tyres, to give the AR sufficient size, weight and
structural complexity. Just to put a protective ring of anti-trawler ARs around one marine
park (e.g. Tong Ping Chau) would require over 300 of these ARs. That comes to 1.2
Let’s consider the Outer Port Shelter Fishery Protection Area. To put a protective ring
around this area would require over 600 of these anti-trawler ARs. That comes to 2.4
Experiences also show that some trawlers attracted by the increased fish stock inside the
protected area, would lift their nets over the anti-trawler boundaries to fish inside. So
randomly dispersed AR deployments inside these zones are also necessary. Again, let’s
take the Outer Port Shelter FPA as an example. At a deployment rate of 1% of the sea
floor area, a further 1,800 ARs are needed. That adds up to 7.2 million tyres, or six years
supply of HK’s discarded tyre.
5. Does AR promote fish production or merely pull in fish stock from the nearby rocky
shores? …. The “natural habitat versus ARs” issue
AFCD’s own surveys and studies showed that the deployed ARs supported larger (sizewise)
and more commercially valuable reef fishes than the natural rocky shores in HK.
On the other hand, there were very few fish in HK’s muddy seabed.
Native species such as John’s Snapper, Painted Sweetlip and Long-tooth Grouper which
had disappeared in HK waters since the late 1950’s, have reappeared in and around the
ARs and in significant numbers. More interestingly, several commercially important fish
have used the ARs as spawning sites. These included the Blacktip Crevalle, Purple
Amberjack, Mangrove Snapper, Painted Sweetlips, Japanese Seabass, Black Seabream
and Goldlined Seabream.
These are usually reef fishes which prefer waters deeper than six meters (i.e. away from
the rocky shores) where HK’s natural hard-bottom substrates are already destroyed by
intensive trawl fishing in the past. Therefore, AFCD’s studies strongly suggest that the
deployed ARs do increase the overall fish stock within the HK waters rather than merely
pulling the fish away from HK’s rocky shores or muddy seabed.
6. “By deploying anti-trawler ARs, are we not pulling in fish stock to centralized locations
for them to be caught quicker?”
In 2000, AFCD commissioned a study to examine the impacts of various policy
approaches on HK’s fish stocks. The study concludes “the greatest improvement in (HK’s)
fishery (would be) achieved by the elimination of trawling”. Failing that, the simple
exclusion of trawlers in the various marine parks and Fishery Protection Areas (FPAs)
would be better than doing nothing. In addition, further improvements can be achieved by
deploying ARs in these protected zones even if we cannot exclude the indigenous
fishermen using gill nets and lines from these sites.
Therefore, the answer is very clear. HK’s fish stock will benefit much more if anti-trawler
ARs are deployed to keep out the trawlers in these protected areas.
Ideally, we should ban all form of fishing inside the existing 2 PFAs, the 4 marine parks,
the D’Aguilar Marine Reserve and the Airport Marine Exclusion Zone. But political
reality dictates that we have to move one step at a time if we hope to make steady
headway in helping our marine environment.
7. There are still some doubts. Why don’t we wait until there are conclusive scientific proofs
before taking the plunge?
It is important to realize that HK’s hard bottom substrates at 6 meters and deeper were
virtually eliminated by indiscriminate trawling in the past. The anti-trawler ARs deployed
in water deeper than 10 meters (to allow for a minimum draft of 5 m Chart Datum) in the
PFAs and marine parks are simply an attempt to partially restore this portion of this
marine ecology. HK cannot afford the luxury to sit back and do nothing.
8. West Kowloon and Victoria Harbour are not particularly good examples … these are
beyond any form of short/long term remedial action.
A practical approach would be to require land reclamation projects to contribute 1%, of
the project costs to a “Marine Mitigation Fund” to be used to partially restore the damage
marine ecology. The mitigation effort can be carried out in HK’s marine parks, marine
reserve, the Airport Marine Exclusion Zone and the PFAs. “Carpeting the (sea) bottom”
with ARs is not practical and has never been considered.29 November 2004 at 11:03 am #7584Anonymous
I really like the responses from your colleague and it is certainly food for thought.
However there are still some Grey Areas…but we could exchange emails ad infinitum on whether AFCD’s Flip Test results are really worth their weight in reality.
But the underlying objective of tyre AR’s is to provide fisheries habitat and some form of anti trawl device.
Unless we have enforced fisheries management and scientific deployment then disposing of xx million tyres into HK’s territorial waters is a simple excuse for dumping at sea. What’s next abandoned containers?
AFCD and EPD have to prove to themselves that they can enact a fisheries policy because as it now stands we have no commercial fishery and rubber tyres won’t change in that in neither short term nor long term.
For me its:
1. Phase out dumping of sludge and reclamation material at sea.
2. Deploy selected AR’s
3. Enforce Fisheries
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