Submissions due by 23 May for rezoning application to the TPB

The supplementary information provided by IWMAG to the Town Planning Board application Y/I-SKC/1 has now been notified and is open for public comment until 23 May.

We urge you to send in letters supporting this updated submission which takes into account the original responses by both the public and the government departments. You can read the IWMAG cover letter and IWMAG supplementary information response which includes a response to each of the government department concerns.

The core of the submission still remains to provide space, via 4 locations on or near existing landfills sites around Hong Kong (that do not require reclamation), for truly Integrated Waste Management Facilities that can be designed to focus on waste sorting and recycling the majority of the Municipal Solid Waste (MSW).

The current proposal by the Environmental Protection Department (EPD) which is being presented to LegCo by the Environment Bureau (and if approved) will only be able to handle approximately 30% of HK’s MSW and does not even contain facilities suitable to sort that 30% of MSW before being incinerated.

We have prepared an email template to assist you in making a submission before 23 May to the Town Planning Board.  Feel free to modify the template and also share with your network.

Click here to open up the email template or see other options for making a submission.

Verbal Submission Notes to EA Panel on 22 Mar 2014

On Sat 22 March 2014, the Panel on Environmental Affairs held a special meeting to hear submissions from the community on the “3+1 Proposal” which is seeking funding to expand 3 landfills and build an incinerator near Shek Kwu Chau.

Below is the submission by IWMAG at this meeting (PDF Version: Verbal Submission Notes – EA Panel 2014 03 22)

You can watch a replay of the 22 Mar 2014 meeting via
The full list of submissions can be downloaded in Word (0.1Mb) or PDF (5.5Mb) format

Madam Chair,

Our written submission is Paper 24 The Group is concerned that the Administration’s proposal is inadequate, will be too-little too-late, and relies on a big incinerator which is not a solution to the waste problems.

The Administration’s plan – call it Plan A – will not work. Therefore, Plan B based on large capacity waste sorting facilities is proposed and explained in our submission. The Group cannot understand why there is no industrial scale sorting and recycling in the Blueprint. This is used extensively elsewhere in the world. A holistic approach is necessary.

Industrial scale sorting machines can handle up to 700 tpd of MSW and reduce it by 80%. 5 of these machines will handle the same amount of waste as the proposed incinerator. It is simple technology and has no significant environmental concerns. The waste is delivered to one end and a series of conveyor belts moves it through sorting stations which mechanically, or manual, remove recyclable materials. It creates jobs directly and in the recycling industry.

There is no guarantee that Governments proposals for waste sorting at source will work. Under Plan B waste must be mechanically sorted before it is dumped in the landfill. The two landfill sites at NENT and WENT are large enough to include these sorting machines, recycling facilities, and composting plants.

Govt does not have sites for their proposals in the Blueprint but they have huge landfill sites of 150 to 200 ha they are not using efficiently. These must be used for a full range of integrated waste management activities rather than just dumps for rubbish. The poor use of landfill sites results in the unnecessary need to expand them. Waste sorting and recycling plants could be operating on these sites within 3 years and they don’t require reclamation – well before the incinerator.

5 waste-sorting lines would cost between $2 to 4 billion dollars and reduce waste as much as the incinerator, but much cheaper. Implementation of sorting will reduce the need to expand the landfills – maybe no need to expand at all.

The full Plan B of 9 sorting machines would leave about one thousand two hundred tpd of material to be landfilled, or heat treated in 2 small incinerators or gasification plants – one at WENT and one at NENT landfill. The big incinerator at Shek Kwu Chau is not needed.

Waste-sorting and recycling needs to be done on an industrial scale to deal with the large amount of waste generated. It is technologically easy, cheap, is a sustainable use of resources, and creates jobs.

The administration’s proposal is outdated and should not be supported.

The Administration is proposing a Strategic Study in paragraph 9(1) of the paper. The incinerator at SKC should not be funded until after that study is completed.

Thank you.

Our submission to EA Panel – The need for Plan B

(Eng PDF version and Chi PDF version)

Submission to Legco Panel on the Environment

The Need For a “Plan B”

Integrated Waste Management Action Group

IWMAG _EA_Panel_Figure_1_Current_SituationIWMAG _EA_Panel_Figure_2_Alternative_Proposal_Plan_B
IWMAG _EA_Panel_Figure_3_IWMF
IWMAG _EA_Panel_Figure_4_IWMF_Plan_B

1. Introduction

1.1  The Integrated Waste Management Action Group (IWMAG) supports a holistic approach to address the waste issue, with a priority on implementing measures to reduce the generation of waste. IWMAG believes that communities should take responsibility locally for the waste they generate and therefore advocates a regional approach to dealing with municipal solid waste (MSW).

1.2  The Government’s current plan (Plan A) of relying on the expansion of landfills and the construction of a large incinerator at Shek Kwu Chau (SKC) has met with widespread community objections and is simply not the answer to the problem. The proposed commissioning dates are too late, the solutions do not deliver sufficient capacity to handle the total amount of projected MSW, implementation is too expensive and it does not optimize existing land resources already used for waste disposal purposes, or which are currently under-utilised.

1.3  Government has said it has no Plan B, but this should not be the case if it is to respond proactively to widespread community concerns. Any alternative approach likely to be acceptable to the community, must be quicker to implement, less expensive, more sustainable, able to address the issues in a variety of positive ways, and be adaptable to changing needs and improved technologies. The current proposal should be abandoned and a “Plan B” adopted. The attached Figures summarize an analysis of the Government’s proposal and the basis for IWMAG’s “Plan B”.

1.4  IWMAG has formally submitted this Plan B proposal to the Town Planning Board. The application is yet to be heard.

2. Problems with the Current Government Proposal

Inadequate Capacity to Deal with Current MSW tonnage

2.1 The Government plan does not seek proactively to change community attitudes towards waste generation and offers no proposals for comprehensive waste separation or recycling. Recently announced proposals for reducing the amount of MSW, organic waste treatment and recycling are inadequate, being small scale and little more than window dressing. They do not address the key issue which is how to reduce the total tonnage of municipal waste. As a result the Government plan requires major investment in the expansion of the existing landfills and the construction of a large incinerator at SKC. The current Government treatment and disposal proposals will be inadequate to meet actual MSW volumes in the required time frame.

What is Phase 2 – Another Incinerator?

The Phase 1 Government proposals will result in approximately 2,100 tonnes per day (tpd) of MSW still being dumped in landfills. How this is to be dealt with has not been explained but it would seem likely that a second incinerator will be required. Other sites have not been formally identified in Government documents, although a second incinerator is thought most likely to be located at the Tsang Tsui Ash Lagoons (TTAL) site.

2.2  The Legco briefing paper refers to the planned incinerator at SKC as Phase 1 but there is no mention of Phase 2. The Government should be required to now state clearly whether Phase 2 means a second large incinerator at the TTAL site in Tuen Mun and inform the whole community of the timetable for the Phase 2 project.

Inadequate Use of Existing Sites

2.3  The existing landfill sites are huge by world standards and, given Hong Kong’s scarce land resources, they are a massive miss-use of land, as they are only used for land fill purposes rather than for multiple functions relating to waste management. IWMAG has proposed that permitted use of these sites be broadened – for instance the sites were never considered for the location of incineration facilities – even though there is great potential for synergies with other forms of waste management and economies of scale. These sites should be considered as suitable locations for fully integrated regional waste treatment facilities and significant investment should be made by the both the public and private sectors to achieve this.

No Investment in High Capacity Waste Sorting Plant

2.4  High capacity waste sorting equipment forms a significant part of integrated approaches to waste management in other countries. Depending on the relevant circumstances, the use of high capacity waste sorting plants can reduce the amount of MSW going to landfills by up to 80%. The 80% of the material recovered is then sent for various forms of recycling and re-use. The remaining 20% is then forwarded to waste-to-energy plants for further treatment or, as a last resort, sent to landfills. This significant and flexible approach to reducing the need for landfill or incineration has not been included in the Government’s Blueprint. Waste sorting plants require manual input, and will therefore create jobs, while the recovery of recyclable materials creates additional job opportunities in the downstream recycling industries.

Taking the Soft Option

2.5  The Government proposals are based on taking the line of least resistance, the soft option, in the hope the community will not realise the long term social, economic and environmental impacts. Government fails to focus on addressing the fundamental problems, or to put forward proposals that are both comprehensive and flexible, including solutions which are capable of being achieved quickly and with community support. It is essential to adopt measures that focus on changing public attitudes, and reducing waste at source. An incinerator at SKC will not be available until 2021/22 by which time the total volume of MSW could be substantially reduced by adopting a comprehensive sorting and recycling plan coupled with active, widespread public education.

No Real Sense of Urgency

2.6  Government claims an urgent solution is needed, yet proposes to build an incinerator on a site that does not yet exist, thereby delaying the commissioning of the facility by several years. If Hong Kong does indeed need an urgent solution, then clearly the facility should be constructed as soon as possible. This indicates construction should be on land that already exists and which was identified as being suitable during the Government’s site selection process, namely the site at the TTAL. The Government’s claim for urgency has no credibility if it insists on selecting a site requiring extensive reclamation works.

3. IWMAG Alternative : “Plan B” – Separate, Recycle – Don’t Incinerate

3.1  The Government proposal does not fully address the MSW problem, is piecemeal, and in any event is not likely to be completed in time to deal adequately with the volume of MSW being generated. More practical and flexible alternatives should be urgently implemented. The envisaged expansion of the landfill sites may not then be necessary or, at the very least, such expansion could be reduced in size or delayed by adopting IWMAG’s “Plan B”.

3.2  The IWMAG proposal consists of the following main points:-
  • The prime objective is to reduce to the absolute minimum the amount of MSW that goes to landfill or for disposal through thermal treatment, so as to reduce the need to expand the landfill sites;
  • Four regional sites, none of which require reclamation, should be adopted for fully integrated waste management facilities – mainly based on waste sorting and recycling of around 700 tonnes per day (tpd). (see Figure 6);
  • All MSW should be processed through mechanical waste sorting plants before going to waste-to-energy plants or to land fill.
  • As a LAST RESORT small scale waste-to-energy plants (thermal treatment by incinerators or gasification plants) should be provided within some of these sites to reduce quantity of MSW going to landfill.

Four Regional Sites

3.3 The four sites proposed are:-

  • Site 1 : NENT Landfill site – 155ha – to include two waste sorting lines with a total capacity of 1,400 tpd, recycling plants, compositing plant and a small waste to energy plant for 600tpd.
  • Site 2 : Tseung Kwan O Area 137 – 8.9ha – formed and with sea access – to include two waste sorting lines with a total capacity of 1,400 tpd, recycling plants and composting plant.
  • Site 3 : NE Lantau – 8.9ha – formed and with sea access, part located in cavern under hills; to include two waste sorting lines with a total capacity of 1,400 tpd, recycling plant, composting plant and education centre.
  • Site 4 : WENT Landfill – 200ha formed and with sea access – to include three waste sorting lines with a total capacity of 2,100 tpd, recycling plants, composting plant and a waste-to-energy plant for 600tpd.

The mix of facilities illustrates the benefit of a regional and integrated approach where the key is flexibility such that the actual facilities on each regional site can be adjusted over time to meet changing needs, and avoid massive investment in any one particular facility.

Waste Sorting Plants

3.5 There are many examples of waste sorting plants of various sizes operating around the world. Some of these are manufactured in China. They can consist of modules for different purposes (see Figure 3). An example can be seen at while many other videos of these machines in action can be found at They are usually contained within one large warehouse-type building and they include relatively unsophisticated equipment such as conveyor belts and other machines in a production line. They create jobs on-site and off-site through downstream recycling.

3.6  An assumption has been made that waste sorting lines handling 700tpd would be appropriate, and more than one line could be located at each site to accommodate the amount of MSW that needs to be processed for that particular area. The actual number required would depend on the effectiveness of the waste reduction measures that would be implemented as part of the overall strategy. There are no specific environmental concerns arising from the use of this type of facility.

Waste to Energy Plants

3.7  Plan B does not require a large-scale incinerator for Hong Kong. After waste sorting, it is estimated that the remaining amount of MSW for treatment by thermal means would be about 1,200tpd and that could be distributed to two small plants of around 600tpd. It is proposed that one thermal treatment facility can be located as part of the totally integrated facilities at each of the NENT and WENT landfill sites. With plants of this size it would be possible to consider either modern incinerators or plasma methods of thermal treatment, as there are plasma plants with this capacity operational elsewhere in the world. Whichever is adopted would need to meet the highest environmental and safety standards.


3.8  With the change in land use zoning proposed by IWMAG, the use of the NENT and WENT landfill sites, and Area 137 in Tsueng Kwan O, the waste sorting plants could be in place and operating within a 3 year period if policy priority is given to them. This would be achievable within the 2017 deadline. Regardless of the discussion that may be on-going regarding landfill extensions or the appropriate waste-to-energy plants to install, these waste sorting facilities and re-cycling plants should be put in place as part of a sensible, well-rounded waste management strategy.

4. Strategic Review Should be Completed Before Funding Support

4.1  The inadequacies with the current proposals appear to be belatedly recognised by the Administration. In paragraph 9(l) of the Paper it is mentioned that:-

“we will embark on preparatory work this year for a strategic study on future waste management facilities. The study will look into various issues such as types, scale, technology, locality and timing of new strategic and regional facilities and services with a view to drawing up a strategic masterplan of waste management facilities for the future.”

This has also recently been announced by Secretary for the Environment, Mr. Wong Kam Shing.

4.2  IWMAG’s analysis has shown that such a masterplan is necessary and their “PLAN B” is in reality a flexible, high level “strategic masterplan” which needs to now be developed and expanded in greater detail. In view of this need now being recognised by the Bureau, it would be fundamentally wrong to give support to spending billions of dollars of taxpayer’s money for an incinerator before the masterplan has been completed.

5. Conclusion

5.1  Members are urged not to endorse the Government’s request for approval of the funding for the incinerator at SKC and the extension of the three landfill sites. These proposals are outdated, do not represent a cohesive strategy for waste management, and are not sustainable in the long term. A strategic review is necessary.

5.2  Instead the Environment Bureau should be asked to revise those parts of their current MSW Waste Plan to incorporate mechanical waste sorting facilities, major investment in recycling plants of an industrial scale, and to make best use of the existing land that is available and can be used quickly. This should be done as a matter of urgency and would be unlikely to compromise a long term masterplan, as it is a flexible approach and has significantly less need for funding.

Integrated Waste Management Action Group
March 2014

Make a presentation to the EA Panel on 22 Mar

You can make a presentation to the Panel on Environmental Affairs on 22 Mar about the Proposed Landfill Extensions and the Incinerator near Shek Kwu Chau though you need to submit your application before the end of Mon 17 March.

Thanks to the Living Islands Movement ( for preparing the following information

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.

Update on TPB Application

The response from the public to the application has resulted in 3384 comments.  We are reviewing these comments and preparing responses to the Town Planning Board (TPB).  Due to the number of comments we have applied for a 2 month extension so the tentative date for the meeting with the TPB has not yet been advised.  (It was not held on 7 Feb 2014 as listed on


On 16 January we received via the TPB comments by the concerned Government departments.  You can read those comments via IWMAG_Gov_Dep_Comments_20140116160149697

Environmental Affairs Panel Meeting 24 Feb 2014

There has been much debate in recent weeks about the Government’s plans for landfill extensions and plans to construct one or more large incinerator to tackle Hong Kong’s municipal waste problem. We are aware of a study tour to Europe planned for early March to review options in light of the widespread public opposition to both incinerators and landfill extensions.


It was a surprise therefore to read the Lai See column in the SCMP on 28 Jan 2014 that suggests Government is to seek funding for its plans even before the study tour takes place.

If correct it seems to us that the Government is treating Legco with contempt by seeking funding for projects on 24th February that could radically change as a result of a Government sponsored fact finding trip in March. Clearly the fact finding trip is a waste of public money unless the Government is genuine and is willing to change it’s plans once the facts have been found!

We would hope all Legco members are offended by such a lack of common courtesy and will reject all requests made on 24th February and insist on a full report after the fact finding trip, if possible an independent Legco report rather than one from EPD who continue to ignore the many alternative ideas proposed by concern groups and enlightened individuals.

We urge all Legco members attend the meeting on 24th and be a voice of reason by rejecting premature requests for funding.

NT Concern Group

The New Territories Concern Group was founded on the 4th May 2013. It was established with the aim of monitoring the Government’s various policies in relation to the New Territories. Learn more via

While they did not initially have a strong interest in waste management they have become active in this area. They released a “Report on Waste Management” dated 23 Nov 2013 that provides an alternative technology approach (called plasma gasification) to the technology being promoted by the HK Government. We encourage people to read the report available via


Government needs to rethink its waste management policy

An interesting summary of the waste challenges HK is facing from Howard Winn in the SCMP on Sat 4 Jan 2014

Government needs to rethink its waste management policy

We see that the forces in favour of building a large incinerator near Shek Kwu Chau are coming together for another push at getting the project approved by the Legislative Council. A South China Morning Post story recently reported that a group of academics and professionals were calling on the government to scale back landfill and get on with building the incinerator.

“We need to act now, or this will end with rubbish piling up on the streets,” said Professor Poon Chi-sun, of Polytechnic University’s civil and environmental engineering department and spokesman for the new Alliance for Promoting Sustainable Waste Management for Hong Kong. Poon says the government is right to adopt moving-grate technology – in which waste goes through a combustion chamber – in its incinerator plan, adding that the technology is used in 2,000 plants around the world.

What he doesn’t say, however, is that the number of operating incinerators and the installation of new ones is declining. In the United States, the number of moving-grate incinerators dropped from 186 in 1990 to 87 in 2010. In Japan, it fell 25 per cent between 1998 and 2005. In Europe, there is an overcapacity of incinerators because of successful recycling efforts. Not so long ago, New York City issued a tender for a waste management facility specifying that it did not want offers using traditional moving-grate technology.

Professor Irene Lo Man-chi, of the University of Science and Technology’s department of civil and environmental engineering, said the technology had been proved to be a reliable option that was safe in terms of emissions. This is a moot point, and there are peer-reviewed reports showing abnormally high death rates and incidence of cancer among people living near incinerators. We accept that modern incinerators produce less emissions but that is not to say they are safe.

One technology that is known to produce far less emissions than incineration is plasma gasification. However this is dismissed as the wrong choice by Lo, who says it wouldn’t be able to cope with Hong Kong’s volume of waste. And by way of support, she says that problems with plasma technology had led to the closure of a 10-year-old plant in Japan. She omits to say that the plant was closed because it ran out of feedstock. She also appears oblivious to the number of plasma gasification projects that are springing up all over the world.

Ever since the incinerator project was introduced, the Environment Bureau has refused to budge from its insistence that it must be built, even with the change of leadership at the bureau. It also continues with the politically expedient reasons for locating the incinerator at Shek Kwu Chau rather than at Tsang Tsui near Tuen Mun. But it is clear to many people that if any progress is to be made on this, then some aspects of the plan have to be rethought. About 42 per cent of Hong Kong’s waste that goes to landfills is food waste and is between 70 and 90 per cent water.

Clear the Air chairman James Middleton has spoken to three engineers who say it is perfectly feasible for food waste to be shredded at source using garburators and disposed of down the drain and handled by the Stonecutters water treatment plant, which is currently operating at 50 per cent capacity. This idea has been incorporated into the thinking of the New Territories Concern Group, which, after visiting various waste treatment plants, including plasma gasification projects in Europe, produced a report supporting the use of plasma technology. The group is politically significant and includes Junius Ho Kwan-yiu, who, in addition to being a former president of the Hong Kong Law Society, also has the distinction of having deposed Heung Yee Kuk chairman Lau Wong-fat as chairman of the Tuen Mun Rural Committee.

In addition to its support for disposing of food waste at source, the report suggests gasification as a more mature and appropriate technology to meet Hong Kong’s present and future waste management needs. It recommends the establishment of one or more pilot plants to determine the suitability of gasification technology for Hong Kong. This approach would give Hong Kong considerable breathing space for it to take another look at the options available rather than its current approach, which is making little progress.