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Super-Incinerator: LIM’s Letter of Objection to the EIA

i Dec 14th No Comments by

Also available as a google doc here

14 December 2011

Dear Sirs,

Agreement Number CE 29/2008(EP)
Engineering Investigation and Environmental Studies for Integrated Waste Management Facilities (EIA)

Living Islands Movement (LIM) wishes to comment on and object to the captioned EIA in the following areas:

    Waste Management Strategy

We deplore the lack of progress in Municipal Solid Waste reduction at source, separation for recycling and reuse (the so-called “3Rs”) since the Policy Framework paper was published in 2005. As the EIA admits in paragraph, ‘Over the past years, the quantity of MSW generated in Hong Kong has been on an increasing trend’.

Clearly Hong Kong has a serious problem. We are notorious for our wasteful practices and for lack of public awareness or civic pride in our surroundings. Hence we see widespread littering of the countryside (often by government contractors), beaches and BBQ pits piled high with garbage at certain festivals, and large scale marine pollution impacting our coastlines.

Excessive packaging and the lack of manufacturer take-back programmes are among the reasons that Hong Kong has the highest per capita waste output in the World, estimated at about 1.36 tons per annum.

We are concerned that proposals to introduce waste charging in isolation will be counterproductive and lead to more illegal dumping (similar to the effect of construction waste charging).

We question the relevance of EPD’s figure for MSW recovery of 52%. It appears to relate to waste that is exported, in whatever form. Our everyday experience is that nothing like this amount is recovered from household waste at least, so perhaps it represents the “easy pickings” from large scale commercial sources.

The current provisioning around Hong Kong of some coloured recycling bins, limited to only three undifferentiated categories of waste, is wholly inadequate and there are serious doubts about whether much of even this is ever actually recycled.

LIM considers that the first priority must be to halt and reverse this malign trend of ever-increasing waste production. It is vital both to change attitudes by investing in public education and to provide the means and facilities for intensive engagement in modern waste reduction, separation and recycling practices. This requires a major effort on the part of government, backed up by appropriate legislation.

We think that the budget for the incinerator (however much that actually is) would be far better spent in this way. Further, there is a great opportunity to create thousands of jobs in the waste collection and recycling business in both public and private sectors. 

LIM’s position is that controversial and expensive large-scale incineration should only be considered, if absolutely necessary, once a comprehensive 3Rs regime has been implemented territory-wide.

    Incineration Technologies and Pollution


In the event that incineration becomes part of the waste disposal strategy, we believe more research is needed into the technology and style of individual operations. In general, we would favour smaller scale, dispersed operations using the latest (almost) pollution free technologies.

For now however, there are three reasons why we seriously question the apparently conservative but costly choice of the moving grate technology, on this large scale and in this remote location:

First, we note that the residue of incineration to be sent to landfill is stated in the EIA to be 30% of the input amount (see para 6b.4.1.55), of which one sixth will be highly toxic fly ash, requiring pre-treatment and cementation. (Specialist commentators estimate the likely output waste at 50% or more.)

Not only will this output waste be difficult to dispose of, posing a long term environmental hazard from mass leaching, it will also need to be transported back to the WENT landfill, thus more than negating the claimed marginal reduction of transportation distances. (By the same token, we question the wisdom of installing a 300 tpd mechanical waste separator at the remote location of Shek Kwu Chau, since the salvaged materials will need to be transported back to the urban areas).

Also, this reduction ratio is a very poor return for the amount of the investment and the amount of environmental damage caused.

Second, we also note that monitoring of the incinerator’s dioxin output will only take place on an “intermittent” basis (clarified by EPD’s testimony to the ACE sub-committee on 5 December 2011 to mean a sample of air coming from the incinerator stack taken quarterly ie once every 3 months for the first 12 months of operation, thereafter once every 6 months).

Given the controversy and extent of scientific and public fears surrounding the cumulative effects of dioxins in the environment and on humans, we consider this proposed ‘intermittent’ testing to be wholly inadequate and somewhat irresponsible. Further, there are no plans to monitor the recently identified threat from tiny PM1 and PM 2.5 particles.

Third, we understand that a recent study indicates that there is a possibility of smog forming from particles emitted by the smoke stack of the incinerator drifting over to the Airport and Tung Chung Town causing visibility problems for aircraft operations.

This is in addition to the air pollution that will likely be caused at Cheung Chau for the 25% of the year that the wind is blowing in that direction.

Other technologies have been dismissed by the EIA, apparently based on paper-based research dating back to 2002. Yet technology and thinking is moving on rapidly. The plasma gasification technology for example is gaining traction, while a number of countries are now moving away from old-style incineration altogether.

Whilst not attached to any particular technology, LIM has taken a special interest in plasma gasification which in the last year or so has received regulatory approval for significant quantities of urban MSW processing in North America and Europe.

The attached paper, prepared for LIM after consultation with Tetronics/APP of the UK, sets out how plasma gasification technology avoids the environmental downsides of the proposed incinerator (with no toxic emissions and no output waste sent to landfill) and enables a more modular and localized approach to Hong Kong’s waste problem, with greater energy conversion efficiencies enabling profitable operation even when not at full capacity.


A seemingly non-polluting and economical solution has also been proposed by Green Island Cement, yet the company has been led to believe that it is not going to be seriously considered, based on a cursory experiment conducted a few years ago that was hampered because the company was not permitted by EPD to take delivery of sufficient MSW to burn!


By the time the proposed incinerator comes into operation, further advances in alternative waste management technologies will make EPD’s current determination to replicate the conventional mass-burn incinerators of Singapore and Macau look all the more outmoded and foolish.
LIM believes that more time and effort should be given to developing innovative and flexible solutions, using the latest advances in technology, in partnership where appropriate with the private and academic sector. Hong Kong needs and deserves state-of-the-art waste management methods and technologies.

    Comparative Advantages of the Sites


Even if large-scale, geographically concentrated incineration were to be the only option available, we strongly disagree that it should be located in this part of the Islands District, for a range of economic, environmental and social reasons.

Overall, the EIA clearly points to Shek Kwu Chau as being the least appropriate location of the sites reviewed, on almost all conceivable criteria:

It requires large scale reclamation of an untouched marine environment, compared with the alternative site, an already formed site in a degraded industrial area at the aptly named Tsang Tsui Ash Lagoons (TTAL).

It requires extensive dredging to install a submarine cable to South Lantau coast for electricity transmission, which will cause irreversible environmental damage, compared with the minimal distance from TTAL to the adjacent Black Point Power Station.

It requires the creation of a special desalination plant. TTAL by contrast can be linked to the mains water supply.

Habitats of various species, particularly Finless Porpoises, White-bellied Sea Eagles and several types of coral will be adversely impacted. The EIA states that Shek Kwu Chau has a delicate eco-system with natural habitats for unique wildlife and marine life. The effectiveness of “mitigation measures” is highly uncertain. There are no such ecological issues at TTAL.

EPD envisages a need for one further IWMF of the capacity of 3000 tonnes of MSW per day (see its Legislative Council Brief of January 2011, file ref EP86/03/175A, para 12.) Because EPD is committing to limit the Shek Kwu Chau footprint, the obvious place to build such a further incinerator is TTAL.

TTAL has the site capacity for both incinerators. If it is to be the site of an incinerator in any event, TTAL should be the site of the first incinerator, because the environmental downsides of building there are so much less.

Permanent loss of 31 hectares of fishery and 15.9 hectares of fish spawning grounds is expected. There are no fisheries at TTAL.

Transportation distance by sea for waste is claimed to be slightly less, but this depends on the chosen starting point and ignores the existing transport networks that currently deliver by various routes to WENT. The effect of greatly increased barge traffic in sea lanes near Cheung Chau and South Lantau is not assessed.

We are particularly concerned about the potential for damaging spillages. TTAL is close to WENT so onward remission of output waste will involve minimal transportation, in contrast to Shek Kwu Chau where the total transportation of input and output waste will be nearly double that for TTAL.

Visual impacts are “moderate/substantial” particularly along the South Lantau Coast, affecting residents and visitors using the beaches and hills for recreational activities. The effect on property values and businesses catering to recreational and tourist activities are not assessed. That the site is very close to the main Macau Ferry route, via a narrow neck of the Adamasta Channel, is a further issue.

The lead time to commissioning (now 2019) is at least two years longer than the alternative. This is inconsistent with EPD’s stated urgent need.

Of course, the costs of construction at Shek Kwu Chau will be very significantly higher than that of the alternative site, although the EPD have so far declined to produce comparative costs.

In addition to all these disadvantages, LIM considers that it is highly inappropriate from a good planning perspective to site an industrial facility of this type in this area. The South Lantau Coast and Offshore Islands district is the last unspoilt area on the West side of the SAR, and the government’s own strategic development plans have long stated that it will be reserved for conservation and recreation.

    Decision Making Process


As described above, it is clear from the EIA that on all objective criteria Shek Kwu Chau should be the least preferred site, yet EPD choose to ignore these facts and instead base their decision on other grounds, none of which stand up to rational analysis.

We refute the four reasons given by EPD for selecting Shek Kwu Chau as follows:

EPD claims that the NE prevailing wind direction is a unique advantage to Shek Kwu Chau, yet this is exactly the same situation for the other site. Further, when the wind is in the opposite direction (for 25% of the year) it will blow pollution directly over Cheung Chau with a population of 25,000 persons, and a very popular local tourist destination. At TTAL, there is no such risk. This is therefore a misleading and irrelevant claim.

EPD claims that siting the incinerator at Shek Kwu Chau will lead to a “better spatial distribution of such facilities”. We find this statement utterly incomprehensible. Sound economics and good planning practice should seek to optimise efficiency and synergies by siting close to the sources of waste and/or adjacent to complementary activities, i.e. in industrial zones.

There seems to be a misplaced notion that it is only “fair” to extend the waste footprint of Hong Kong to all points of the compass. To accept this idea would set a dangerous precedent for justifying widespread environmental destruction on this “beggar my neighbour” basis.

EPD claims that the carbon emissions from transporting waste to Shek Kwu Chau will be less than to the other site. This is based on the assumption that road transport will still be needed for sending waste to the alternative site, when a new jetty could easily be built.

It also overlooks the cumulative transport requirements of sending the incinerator’s output waste to landfill which make TTAL the more convenient site by a large margin. Therefore this is another misleading and incorrect reason.


EPD claims that the IWMF at Shek Kwu Chau will be a tourist attraction creating a few hundred jobs. Clearly this is not a unique advantage to this site as it would be true wherever such a facility is built.


Further, it ignores the potential negative impact on tourism in South Lantau and Cheung Chau arising from industrialisation. For example, how are the fishermen of Cheung Chau supposed to engage in eco-tourism (as proposed by EPD in reporting to the ACE sub-committee on 5 December, referencing its successful uptake by the fishing communities of Sai Kung) when their boats cannot go near the incinerator without risk of dioxin ingestion? Again, this is an irrelevant and misleading justification.

The real reason, as stated by EPD to objectors at the public meeting held in Pui O on 25 November, is that EPD perceives Tuen Mun as already having enough pollution. This is why EPD now maintains the polluting effect of this incinerator should go where the air is clearer – to a pristine stretch of coast designated a conservation area suitable for eco-tourism and leisure activities.

We also suspect that the narrowing down of the proposed incinerator sites to just two for in-depth assessment was premature. We have already raised the Green Island Cement proposal.

In addition, the EIA mentions another possible site next to the Power Station on Lamma Island (Hei Ma Wan), an already degraded area and a logical location for a waste-to-energy facility. Yet this site was apparently rejected based on the incorrect statement that there would be visual impact to residents of Hong Kong Island, when in fact it will be hidden from view since it is on the West Side of Lamma Island.

LIM is of the view that further investigation is warranted into these two alternative locations before a final decision is taken. We also consider that a legal challenge of the decision to select Shek Kwu Chau could well succeed since it is not based on reasonable criteria. EPD’s statutory duty is to minimise the impact of such projects on the environment and this decision is not in our view compatible with that duty.

    Government Process


The EPD has apparently decided that it wants to site the incinerator at Shek Kwu Chau without having produced any comparative cost calculations. It is suspected that the actual cost of the Shek Kwu Chau option will be HK$12-13 billion, or 4x the cost of the alternative locations. We find this an extraordinary lapse in good government and irresponsible to the taxpayers.

The decisions both to build a large-scale incinerator and to site it at Shek Kwu Chau have very serious implications for the whole of Hong Kong. There are many different stakeholders including residents and visitors from all over the territory who come for a range of recreational activities such as hiking, cycling and water sports.

The impact on South Lantau tourism and property values has not been factored in. Many have genuine fears about dioxins and toxic waste that is cumulative in the human body as well as marine and animal life. There is also an impression that government wants to hide Hong Kong’s waste problem in a supposedly remote location instead of dealing with the root causes and facilitating the public to adopt modern environmentally friendly practices.

In conclusion, LIM believes this EIA should be rejected until the many issues raised above have been fully investigated and resolved. At the very least we demand a full public consultation on waste management strategy for territory.

Yours faithfully,

Louise D Preston
Living Islands Movement




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