Policy Comments & Advocacy

1. Recently, an average of about 11 100 and 5200 tonnes per day (tpd) of municipal solid waste (MSW) are disposed of at landfills and recovered in Hong Kong respectively, i.e. the amount of waste generation is about 16300 tpd and the overall MSW recovery rate was 32%.

2. Regarding the development of waste-to-energy (WtE) incinerators, with the Integrated Waste Management Facilities Phase 1 (I•PARK1) under construction and the proposed Integrated Waste Management Facilities Phase 2 (I•PARK2), Hong Kong’s municipal solid waste (MSW) incineration capacity is expected to reach 9000 tpd.

3. Assume that the amount of waste generation is level off and I•PARK1 and 2 operate fully in designed capacity, incineration is capable of treating 55% of MSW. That means, without landfills or other waste disposal facilities, 45% MSW must be recovered which is also the target rate set by “Waste Blueprint for Hong Kong 2035”.

4. Under this scenario, MSW recovery need increase from 32% to 45% which was planned to achieved by MSW charging. However, the enactment of the law of MSW charging has been suspended. Without ambitious interim policy or measures to boost recovery rate, we are gravely concerned that saturation of existing landfill space will accelerate.

5. The energy generated by WtE incinerators depends on the calorific value (energy content) of MSW wastes. Plastic and paper have high calorific value but that of food waste varies considerably due to its water content and composition. Other wastes are of either low calorific value or insignificant amount.

6. In order to sustain the operation of WtE incinerators and their energy efficiency, wastes of high calorific value are needed to input, e.g. plastic and paper. We are worried that the implementation of WtE incineration will compete with local recovery sector for recyclable plastic and paper. If so, incentive of waste reduction, especially for plastic, and energy saving will be depressed under this bogus “green” energy source.

7. Therefore, we opine that incineration should be the last resort disposal measure for MSW. Treatment of MSW should follow the hierarchy of avoidance, minimization, reuse, recovery/recycle in prior to disposal, whatever landfilling or incineration.

8. In view that voluntary recycling practice is failed to halt the growth of MSW, the Administration should promptly devise action plan to enact the MSW charging. The ultimate goal of conserving the environment and securing life quality should be delivered to the public with thorough public engagement. Public opinions, views and worries should be properly discussed and addressed.

9. On the other hand, the scope of producer responsibility schemes have to be broadened to reduce wastes related to consumption and packaging such as drink boxes and plastic bottles, and raise the recovery rate of MSW.

10. We are skeptical of the need of additional incinerator(s) in view of limited location options and the government’s pledge to reduce MSW to combat climate change, save energy, curb pollution (especially microplastic) and wisely use of resources.

11. We also urge the Administration to further explain the details for implementation of WtE incinerators under the scope of “Waste Blueprint for Hong Kong 2035”, such as supply chain of fuel (i.e. MSW), its composition, electricity generated per tonne of MSW.

Thank you very much for your kind attention.