Policy Comments & Advocacy

Green Power would like to draw your kind attention to our comments about the above-captioned Project Profile (PP).

1. Tuen Mun is highly prone to air pollution which ranked the top most polluting districts in terms of the number of hours with AQHI ≥7 and days with daily maximum AQHI ≥7 according to the Environmental Protection Department’s yearly average Air Quality and Health Index (AQHI) data for past nine years (2014-2022)⁽¹⁾. The air pollutant sources of the proposed Project at the operation phase including the air emissions (such as nitrogen oxides) from the incinerator stacks and the odour nuisance from the waste reception halls will unavoidably worsen the air quality of neighbouring community and the district.

2. In particular, emissions of toxic air pollutants such as dioxins, polycyclic aromatic hydrocarbons (PAHs), hydrogen chloride, mercury vapour, etc., are anticipated. A cumulative air quality impact assessment, taking consideration of all existing and planned projects in the district as well as the regional emissions within the Pearl River Delta, should be undertaken in the EIA process.

3. The concentration of toxic or carcinogenic substances at the Project site should be closely monitored at the operation phase. A contingency plan should be deployed in response to any accidental events that threaten human health.

4. The project may receive incinerator bottom ash, fly ash and flue gas cleaning residues from I·PARK1 for enhanced treatment for beneficial (Section 3.1.10). However respective details of related facilities, transportation of materials, industrial products and corresponding environmental impact assessment were not mentioned in PP. Such information and assessment should be comprehensively addressed in the EIA report.

5. The Project proponent should only adopt non-dredged method for the construction of berthing facility to minimize the adverse impacts on the water quality.

6. The waters around the Black Point next to the Project site have been identified as the “hot spot” of Chinese White Dolphin where “dolphins regularly occurred in the past” ⁽²⁾, therefore dolphins should be the ecological sensitive receivers directly influenced by the increase of marine traffic induced by the Project. However, the Project Profile does not mention the potential impacts to dolphins at all, we urge the Project proponent to conduct ecological impact assessment on marine mammals.

7. The Project site is located within the Deep Bay Water Control Zone. Therefore the Zero Discharge Policy should be strictly observed for discharge of wastewater during both the construction and operation phase.

8. The impacts of thermal pollution and antifouling agents on marine water and ecology from the cooling system of the proposed Project, if installed, should be assessed, especially on the oyster farms in Deep Bay. Cumulative pollution impacts of all operating and planned facilities in these aspects should be conducted.

9. The solid wastes generated from the proposed Project, including the construction and demolition (C&D) materials, chemical wastes, incinerator bottom ash, fly ash, etc., should be properly stored, transported, and finally disposed of at the designated facilities in accordance with the regulations.

10. Since the major sources of waste will be transported to the proposed facilities via marine access during the operation phase, any dumping at sea should be strictly forbidden during the transportation of waste with effective and prompt surveillance measures. The Real Time Tracking & Monitoring of Vessel (RTTMV) System⁽³⁾ adopted by EPD should be taken place to timely detect any irregularities.

11. In order to demonstrate the superiority of waste-to-energy technology to landfilling in combating climate change, the CO₂-equivalence of unit weight (both with typical water content and without water content) should be calculated for common ingredients of combustible municipal solid waste.

Thank you very much for your kind attention. For any inquiries, please contact the undersigned at Green Power (T: 3961 0200, F: 2314 2661, Email: info@greenpower.org.hk).