Waste Charging Consultation 31 March 2010

Response to the Consultation Document “Sustainable Waste Management, Strengthening Waste Reduction: Is Waste Charging an Option?”

Submitted to the Environmental Protection Department

Living Lamma welcomes any effort to protect the environment through measures to reduce waste and encourage recycling.

We have responded in our paper of 30th April 2010 to the EPD’s consultation on Waste Electric and Electronic Equipment. We also contributed papers dated 29th April 2009 and 30th March 2010 to the Legco Panel on Environmental Affairs on the problems of dumping and fly‐tipping.

Over the last 3 years, we have studied the problems of waste in our community, monitoring people’s behaviour and attitudes. We have carried out many clean ups, noting what type of waste is collected and where it has likely originated. We believe that the experience on Lamma is reflective of that all over the rural New Territories, and it from this perspective that we make our comments. Lamma has chronic waste problems

– the bin areas are often overflowing and untidy, and dumping and littering are commonplace. We have attached photographs at the end of this report to illustrate these problems.

As the consultation document points out, waste charging is common in other parts of the world. Often the charge is included as part of a local authority tax. Any direct “pay as you throw” scheme risks increased fly‐tipping. This, in turn, increases the costs to society for waste removal, as well as exacerbates environmental degradation, encouraging more dumping.

In order to avoid these consequences, people need to have options available to facilitate good behaviour and authorities must have the ability to act quickly and decisively against fly‐tippers. Neither of these two conditions is apparent in Hong Kong. Options for waste disposal and reduction are very limited. Recycling is underdeveloped and there have been few policy initiatives to reduce the amount of waste that is generated in Hong Kong. There is no effective action to deter dumping or littering.

Compared with Hong Kong, the difference between the facilities provided for waste disposal in most modern economies is startling. For example, in the UK, Canada, US, Australia, and many other countries, rubbish used to be handled in much the same way as it is in Hong Kong today. For the public, waste was simply something that was thrown in the bin or taken to the tip. Tips were dirty, smelly places and people spent no longer there than the time it took to dump unwanted items.

With the introduction of recycling, tips became “recycling centres”, somewhere to go not only to take unwanted but useful items, but also to pick up things cheaply or freely.

Recycling centres are now clean, well‐organised and conveniently located within communities. People are not only educated about waste reduction and recycling, but have the means to carry it out.

This compares with the facilities available in Hong Kong, where waste is still regarded as dirty, unuseful and the responsibility of someone else to pick up and take away.

The consultation paper alludes to “modern facilities” and “integrated waste management facilities.” However, in reality there is nothing integrated or modern about the way in which waste is collected or processed in rural Hong Kong. Recycle bins are not part of integrated waste collection points, but stand alone or next to the general bins. There has been no development of properly managed recycling facilities in the community, though a blueprint for community recycling was put forward for Lamma in 1995. It is common to see non‐recyclable items in the general waste bins and recyclable material in the general bins. The system often defies common sense. For example, there are no collection points for glass waste at the bin areas because of safety concerns. Yet, the current method of glass disposal is to put it in or next to the general bins or dump it along with the other litter found off all the pathways on the island.

The EPD’s proposed HK$15 billion incinerator plant off Shek Kwu Chau, which in the consultation document on waste charging is only referred to in euphemistic terms, will do nothing to instill a change in behaviour to reduce waste as it does not alter the way in which waste is perceived, collected or dealt with.1 Whether the waste is taken away and buried, or taken away and burned, will make no difference to the average person accustomed to simply throwing their waste on or near a bin. The fact that EPD hides the true nature of its waste management plan, and has a dual role as project proponent and scrutiniser, does not instill confidence that the department is serious about educating the public about waste or altering behaviour.

Add experience of recycling scheme

Answers to specific questions raised in the consultation document:

  1. Question 1: Does Hong Kong need to introduce MSW charging?

Hong Kong has a very narrow tax base. It is not inconceivable that additional charging to cover basic services, such as waste disposal, may have to be made in future. However, introducing charges without providing appropriate facilities will only lead to increased fly‐tipping.

This has been the experience since the introduction of charging for the disposal of construction waste. Cases of dumping on agricultural land have been reported to EPD. No action has been taken because of a loophole in the law, which means that no punitive measures are possible. EPD continues to congratulate itself on the success of the charging scheme, turning a blind eye to the evidence that shows mounds of construction and mixed waste blotting the landscape.

A good starting point for the charging of MSW in Hong Kong would be with government and its contractors. As Hong Kong’s largest employer, Hong Kong government is responsible for a significant proportion of waste produced. An audit of government

1 The consultation mentions the incinerator only as: “related issues”, “modern facilities”, advanced waste treatment facilities”, “appropriate waste treatment and disposal facilities” and an “integrated waste management facility.” No mention is made about the reclamation off Shek Kwu Chau or about the protests against this project.

practices (such as the use of bottled water and the delivery of school dinners in polystyrene boxes) and policy (such as the rules governing food factory licenses specifying that food must be served in disposable, but not biodegradable, packaging) to identify opportunities for waste reduction and changes in behaviour that would go a long way to setting Hong Kong off on a path to being more responsible with regard to waste.

  1. Question 2: Should Hong Kong go for a waste charging system for all sectors or a partial charging system? and
  2. Question 3: Should Hong Kong go for a Quantity‐based system, a Proxy system or a Fixed Charge system?

Until Hong Kong government demonstrates a commitment to waste reduction by instituting measures that would reduce the amount of waste entering Hong Kong, facilitate the re‐export of materials for processing and providing much improved and cleaner waste facilities, the discussion of the type of charging is premature, for reasons stated above.

  1. Question 4: Are you prepared to change your behaviour in waste disposal if an MSW charging system is introduced?

Though the system is far from perfect or convenient, on Lamma, it is possible to: compost all non‐cooked organic waste, and recycle glass, plastic, paper, plastic, small electrical items, books, clothes, toys and household items. Careful purchasing can ensure that most packaging is recyclable. Buying food on a daily basis and only serving what can be eaten while saving or freezing the rest can reduce food waste to almost zero.

Using cloth nappies removes 1‐2 tonnes of waste from landfill during the child’s young life. You can also use and recycle rechargeable batteries and Ikea lightbulbs. What behaviour should be changed if someone is being careful about the waste they produce and recycle as much as is possible in Hong Kong?

The biggest contributor to landfill, or perhaps the incinerator, would be Tetra Paks. The company is eager to recycle in Hong Kong but faces bureaucratic hurdles. Should the public be penalized for not recycling items that can be recycled elsewhere? In Canada, for example, a cash deposit is returned for Tetra Paks returned to the store.

  1. Question 5: Do you agree that the Government should introduce legislation to mandate the separation of waste at source and accordingly ban unauthorized disposal of MSW?

Tightening legislation to improve waste collection and tackle dumping and fly‐tipping would be welcomed. However, the problem seems not to be with legislation, but with enforcement.

Penalties for dumping and littering exist, but these are seldom enforced. Part of the problem is that rubbish is not simple rubbish in Hong Kong. What action is taken depends on what kind of rubbish it is and where it lies (EPD for electrical waste, FEHD for household waste, LandsD for construction waste, LCSD in the playground, DSD in the nullah – apart from the waste water from restaurants, which is back to EPD again).

Clearly people rarely think about separating their waste when they dump it. That government delineates responsibility for waste along specific lines drastically impedes efforts to clean up our neighbourhood.

The police will only enforce the law if there is a complaint from the public backed by photographic evidence identifying the perpetrator. This rarely, if ever, happens. Our attempts to ask the police to enforce the law resulted in them suggesting that we talk to FEHD. FEHD sent us to LCSD and LCSD said, “Have you tried the police?”

The dumping and littering continues, and its often government contractors who are responsible. Again, if government is serious about changing behaviour, it should first look at its own actions.

2. The Unintended Consequences of Government Policy – Dumping or the “Storage of Construction and Demolition Waste”?

On agricultural land

On someone’s doorstep

Living Lamma March 2012