Super Incinerator – A very important opportunity to voice your opinions

i Mar 7th No Comments by

Dear Members and Friends

The Legislators are listening!

Your voice is being heard and is making a difference. Now you have another chance to express your views on the proposed landfill extensions and the building of the Super Incinerator near Shek Kwu Chau. The next meeting of the Panel on Environmental Affairs will be open to the public, and is therefore a great opportunity to tell them your opinions regarding the EPD proposals.

If you wish to speak at the meeting, you must submit your request ASAP to speak and/or make a submission on Saturday 22 March. Details can be found at
The reply slip on the website is for organizations. Here is a reply slip for individuals.

The entire process is at a very critical stage with respect to the future of Hong Kong’s Waste management plans that will affect HK people for many decades. Below is a brief update to help with your submission to the Government, though the key message in this email is “Book your place to make a submission on Saturday 22 March”.

You can submit your written statement after you register your speaking place and during the presentation you will not be asked any questions. Each participant will have just 3 minutes to speak.

We will send a list of possible items to raise along with the LIM submission in a couple of days.

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We will be following the direction of our letter that was sent to the Panel on Environmental Affairs for their meeting held on 24 February.

A short summary and important dates:

  • Thanks to all who sent in letters to the EA Panel. During the meeting on 24 February, it was clear that those letters had been received as some of the legislators were referring to the 6 questions. The result of the meeting was the setting up of the Public Hearing on Saturday 22 March
  • March “Fact Finding” tour to Europe by EPD and some Legislators
  • 17 March – applications to speak on 22 March close and you need to have your written submission in by this date.
  • 22 March – Public Hearing at Government building
  • Public Works Subcommittee on 16 April
  • Finance Committee in May (possible dates are 2nd, 16th and 30th May)

It is worth noting that with or without the support of the EA Panel or the Public Works Committee the Secretary for the Environment can legally go directly to the Finance Committee to request funding for the Landfill Extensions and the building of the Super Incinerator near Shek Kwu Chau.

LIM urges you to continue to make your voice heard, so please submit your request ASAP to speak and/or make a submission on Sat 22 March

LIM Committee

Send a Letter to EA Panel

i Feb 22nd No Comments by

Dear LIM Members and Friends

RE: Urging you to write an email to express your concerns about the Mega Incinerator ASAP (especially before Monday morning).

You may not have heard that the Panel on Environmental Affairs will be meeting on Monday (24 Feb) at 2:30 to consider approving the building of the Mega Incinerator near Shek Kwu Chau.

Details of the meeting can be found at and the public can attend by booking a seat in the public gallery via 3919 3399.

The LIM committee has written to all members of the panel asking them to challenge and reject the proposal rather than give it the official endorsement needed to make progress. (View our letter)

Below are listed “Six Key Questions On Waste Management In Hong Kong” taken from the letter.

You might also like to write a letter to the panel members and express your concern.  The main email address is though we also have created an email template to all panel members (click on this link to create the email).  Feel free to base your response on the suggestions in our letter though of course feel free to add your own concerns as well.

The list of Panel Members can be found at  If you know any of them, give them a call and discuss your concerns.

There are 3 members on the “Panel on Environmental Affairs” who represent New Territories West (which covers the Islands District). They are:

  • Hon Albert CHAN Wai-yip (
  • Hon LEE Cheuk-yan ( 
  • Hon CHAN Han-pan (

Of course share this email with your friends and ask them to write a letter to the Panel and to the media.


The Living Islands Committee


  1. The Bureau has admitted that their statistics for recycling are false and misleading. The previous claims that 48-52% of Hong Kong’s waste is recycled have been shown to be incorrect. Waste being imported and re-exported without processing tonnage was previously added to the recycling figure but excluded from the waste generation figure. How can EPD be trusted on the Blueprint when it is based on such misleading and/or inadequate statistics? 
  2. LIM estimates that the true recycling percentage could be less than 10%. It is also clear from everyday observation that there is very little actual waste recycling in Hong Kong. The few “three-colour” recycling bins in use are mostly in obscure or difficult to get to locations, are too small and are badly designed, while the public is given no guidance on what types of plastic and paper waste can be recycled and what not to put in recycling bins.  The recycling bins are often overflowing and remain so for days on end. Why is the EPD ignoring the strong demand from the public to recycle more waste and why are they not making much greater efforts at all levels to provide this most basic waste management infrastructure?
  3. The EPD’s strategy for the destruction of waste is based on sending unsorted waste to landfill or mass-burn incineration in a remote location. There are no intermediate steps between collection and dumping or burning. If the IWMF proposal is implemented, it will effectively rule out waste separation at source, intermediate stage sorting and the development of an effective recycling industry in Hong Kong. There will be no need for any of this if it can all just be burned. Why does the Blueprint contain no plans for sorting of waste to divert it away from landfill or incineration?
  4. The large-scale incinerator will result in a net daily reduction in waste of 2,000 tonnes, while actually producing around 900 tonnes per day of highly toxic waste in the form of fly ash, which will still be sent to landfill. How can the huge economic and environmental cost of this IWMF be justified for such a small gain, which could be equally achieved through enhanced waste reduction and recycling?
  5. Moving-grate incineration only achieves a 70% reduction in the amount of waste that is burned. This is at the expense of converting some of the waste into gases that contain poisonous dioxins which are pushed into the atmosphere, and by reducing the rest to a highly toxic ash residue. The claim that this is “Modern” incineration is simply not true. Why does the Bureau continue to resist other rapidly emerging technologies in the face of the growing evidence that these technologies are gaining acceptance around the world?
  6. Why is the Bureau leading a delegation of LegCo Members to Europe to study incinerators and alternative technologies only after seeking approval for the out-dated mass-burn incinerator?  

Press Release – IWMAG Submission

i Dec 19th No Comments by

Press Release regarding the proposed rezoning of sites to assist solve Hong Kong’s Waste Management problem

Living Islands Movement (LIM) supports a new approach to solving Hong Kong’s waste management problem. Compared to the approach being taken by the Environmental Protection Department, LIM supports the Integrated Waste Management Action Group (IWMAG) initiative, which

  • aims for a dramatic increase in the amount of recovery and recycling of waste material, and a radical reduction in the amount of waste going to landfill
  • will involve the whole community in Hong Kong,
  • will be environmentally sensitive,
  • can be implemented in a relatively short timescale,
  • is economically viable,
  • can include up-to-date technology options,
  • and distributes the responsibility for waste management regionally within the SAR.

Waste Management is a problem for the entire Hong Kong community. LIM briefing meetings in December have highlighted the flaws in the Government selection of Shek Kwu Chau for constructing an artificial island on which to build a giant incinerator. The Government’s short sighted vision is to localise the problem by building a single giant incinerator to which all of the unsorted waste material in Hong Kong will be transported. This is a management style from the nineteenth century, and Hong Kong deserves better than this.

The IWMAG rezoning proposal can provide space quickly and cost effectively for constructing sorting facilities at or near existing landfill sites, with little or no damage to the existing flora or fauna in those areas. The Government proposal will irreversibly destroy an area of outstanding natural beauty in Hong Kong. LIM asks why the Government have allowed a proposal that will knowingly damage the environment beyond repair.

85% of Hong Kong’s waste comprises recoverable or recyclable materials. LIM is concerned that if the Government builds a super incinerator with a token waste-sorting facility (with planned capacity for sorting just 300 tonnes per day out of the 3,000 tonnes per day that the incineration plant is projected to handle) there will be no incentive to follow through with expanding any waste sorting facilities. It just becomes easier to burn everything rather than sort and separate anything.

The Government proposal to construct a huge-scale moving grate incinerator will create toxic emissions that will be dispersed across a wide area of Hong Kong. By expanding the recovery and recycling of waste, the need for incinerations is largely removed. Other technologies may be useful to further reduce the residual waste to a negligible issue.

LIM advocates a regional approach to alleviating the waste management problem. Existing locations should be developed to use existing infrastructure and minimise the transportation of waste over long distances.


Press Release: 19 Dec 2013 – for immediate publication



For more information, please contact:

 Michael Pratt, Vice Chairman Living Islands Movement. Mobile 9092 8481

Make a submission to support the IWMAG rezoning application

i Dec 12th No Comments by

LIM is one of the organisations who are supporting the application by “Integrated Waste Management Action Group” (IWMAG) to have “Rezoning of Sites to Facilitate the Implementation of an Integrated Waste Management Policy for Hong Kong

For details on making a submission before end of 20th Dec  visit

IWMAG consists of various NGO’s, professionals and members of the public who are knowledgeable in the issues which relate to the development and operation of a comprehensive, truly integrated waste management (IWM) system for the whole of Hong Kong.

More glass recycling on Lantau: let’s make it permanent

i Oct 28th No Comments by

Glass bins Tong FukIMG_2584

A win for recycling on Lantau.


HK Government – Blueprint for Sustainable Use of Resources 2013-2022

i May 21st No Comments by

The Environment Bureau unveiled on Mon 20 May the “Hong Kong: Blueprint for Sustainable Use of Resources 2013-2022“.

Read the Press Release via

Civil Engineering and Development Department public forum for Greening Master Plan (GMP) for Islands District

i Oct 19th No Comments by

Please find below the information regarding the CEDD Public Forum for the Greening Master Plan for Islands District on the evening of Friday 26 October 2012.

The Plan “aims to define the overall greening framework of the area
and serves as a guide for all parties involved in planning, design and
implementation of greening works.  In addition to identifying suitable
locations for planting, the GMP will establish the greening theme and
propose suitable planting species.”

Date:  Friday 26 October 2012
Time:  7.00 pm – 9.00 pm
Venue:  G/F, Central Terminal Building, Central Star Ferry Pier (Pier 8).

Participation at the community forum by residents and stakeholders is

If you intend to participate please note that the registration deadline is 22 October.

To register:

  • Phone:  2905 8666 (Ms Law is the point of contact)
  • Fax:  2832 2110
  • email:

The invitation, registration form and poster are available in downloadable PDF format through the links below:


Incinerator: FOE Says Impact Report Falls Short (SCMP)

i Dec 19th No Comments by

Burning questions on the choice of site remain unanswered

SCMP, Dec 19, 2011

By Edwin Lau Che-feng, director of general affairs at Friends of the Earth (HK) and a member of the Advisory Council on the Environment

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.




Dec 17 Deadline for Next Set of Objections to the SKC Incinerator

i Dec 17th No Comments by

The Living Islands Movement (LIM) urges opponents of the proposed super-incinerator at Shek Kwu Chau to get their letters of objection to the flawed Environmental Impact Report (EIA) in before a Saturday, December 17 deadline.

The full EIA is available at

LIM has produced a copy of a sample letter for objectors to adapt, and a paper setting various possible points of objection plus some questions. It is suggested that correspondents select two or three points from the paper that are the most pertinent to them.

It is advisable to include at least one question in your letter of objection so that government is obliged to reply.

Objections should be sent to the Environmental Protection Department (EPD).

Fax: 2174 0894

By mail to:
The EIA Ordinance Register Office
Environmental Protection Department
27/fl Southorn Centre
130 Hennessy Road
Wanchai, Hong Kong


SAMPLE LETTER ( click here to here to download the letter in MS Word or here for the Google doc version)


For the attention of the Environment Protection Department
Re: Development of the Integrated Waste Management Facilities Phase 1

I am writing to place on record my objection to, and comments on, the EIA for the Development of the Integrated Waste Management Facilities Phase 1.

This document makes it clear that incineration is the government’s main solution to Hong Kong’s waste problem. There should be a greater emphasis on reducing and recycling waste and encouraging more responsible behaviour. Incineration is the easiest, but most expensive and most harmful solution. This document should be withdrawn and replaced by a proper waste management strategy.

The EIA clearly indicates that Shek Kwu Chau is the least appropriate location of the sites reviewed, because of its remote location, distance from the sources of waste, no connection to the electricity grid, damage to eco-systems, high cost of building and longer lead time to build.

The decision to build the incinerator in this location therefore insults the common sense and intelligence of the tax payers of Hong Kong.

Furthermore, the south Lantau coast and Offshore Islands district has been reserved by the government for conservation and recreation. Why are these planning guidelines being ignored? Why is the incinerator not being built in an industrial zone?

I do not agree that the environmental impact of an incinerator on Shek Kwu Chau is “acceptable”. Irreversible damage will be caused by sea-bed dredging and the natural habitats of a number of unique species will be destroyed. People on south Lantau and Cheung Chau are also concerned about their exposure to the cumulative dioxins and other toxins that result from the transportation and incineration of waste.

The decision to site an incinerator on Shek Kwu Chau has been made without the production of any comparative cost calculations. Can you confirm that building an incinerator on Shek Kwu Chau will take two years longer and cost approximately four times as much as the alternative at Tsang Tsui Ash Lagoons? This project cannot proceed until these facts are fully disclosed, and tax payers have been widely consulted.

[please add a sentence about how the incinerator will personally affect you – eg the views from your house, your leisure pursuits, your business]

[your name]

[your address]

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