Response to EPD Waste Management Consultation Paper 9 April 2012

Response to Consultation Paper:
Strengthening Waste Reduction: Is Waste Charging an Option?

Submitted to the Environmental Protection Department (EPD)

9 April 2012


Living Lamma is a registered society, which exists to clean up the environment and lobby for sensitive design of public projects on Lamma Island.

Lamma has chronic waste problems – the bin areas are often overflowing and untidy, and dumping and littering are commonplace. Waste ends up on our beaches, making them resemble landfill sites, like this:

Recycling bins exist for paper, cans and plastic, but these are often not used properly. Though on March 2nd, 2012, EPD started a pilot scheme for the recycling of food waste, glass, plastic and household electrical items, this has been poorly communicated, with the department deciding to exclude Lamma’s green groups and the public from the programme’s official launch. Lamma is just 25 minutes by ferry from Central, Hong Kong, and is designated for tourism and leisure, but its potential as one of Hong Kong’s eco-destinations is inhibited to a large part because of its waste problems.

Living Lamma has invested considerable time raising awareness about these problems, lobbying for better waste facilities, and carrying out our own clean ups. In our paper of 30th April 2010, we responded 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. In addition, we have written to Edward Yau, Secretary for the Environment, and to the Legco Panel on Environmental Affairs with concerns about EPD’s logic in building a super-incinerator off the coast of Shek Kwu Chau. Despite significant efforts, Lamma’s waste problems remain and we have yet to witness any co-coordinated and coherent strategy, or even willingness, on the part of government to tackle these issues.

In February 2010, we published a report containing over 250 photographs of unsightly areas in our community. Entitled “Stop the Mess”, the report was distributed to all relevant government departments, including EPD. We found that many of the problems occurred because of the way in which waste is handled. When we carry out clean ups, we note what type of waste is collected and where it has likely originated. We have also investigated attitudes towards waste that govern the way in which people behave. Though we can sometimes manage to get government departments to act to clean up waste, there has been no evidence of departments acting to solve Lamma’s waste problems. For members of the public who use their own private time to report problems or take part in clean ups, the experience is very frustrating. Most of the time bureaucratic jurisdiction prevents the action necessary for sustainable solutions.

The waste problems found on Lamma are common all over the rural New Territories, and it is from this perspective that we make this submission. Hong Kong’s densely populated urban areas have their own waste challenges, which are beyond the scope of our paper. We use specific examples and photographic evidence gathered from 3 years’ of campaigning for a cleaner environment to illustrate our points.

Waste Charging in Hong Kong – A Local Community Perspective

As the EPD’s consultation paper 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 in other countries, 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. 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 parts of 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.

In Hong Kong, however, waste is still generally regarded as dirty, of no use or value, and the responsibility of someone else to pick up and take away. Asia’s World City relies on scavengers – often the elderly – to pick through bins for recyclables when the market price makes such activity worthwhile. Rural areas are blighted with “Steptoe’s Yards” or littered with stockpiled materials.

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 pathways on the island.

The EPD’s proposed HK$15 billion incinerator plant off Shek Kwu Chau, which in the consultation paper on waste charging is only referred to in euphemistic terms[1], is unlikely 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. 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.

The consultation paper raises five specific questions on waste charging to which we now turn:

Answers to specific questions raised in the consultation paper:

(a) 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 if Hong Kong’s sizable budget surplus were to decline sufficiently. However, introducing charges without providing appropriate facilities, and without providing the necessary communication and education that can lead to a change in mindset, 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 such pictured here have been reported to EPD:

No action has been taken because of a loophole in the law, which means that no punitive or remedial measures are enforceable. EPD does not acknowledge the dumping, but refers to it as “the temporary storage of personal property on private land.” This allows landowners to destroy agricultural land, creating mini landfills in our communities, with the purpose of changing the zoning in future to enable property development. EPD continues to congratulate itself on the success of the charging scheme for construction waste, turning a blind eye to the evidence that shows mounds of construction and mixed waste blotting the landscape. It is deeply worrying that the consultation paper does not highlight this widely reported problem.

In other countries, the cost of remedial action to combat fly-tipping has led to some places dropping charges for waste disposal. Though the environmental degradation caused by littering and dumping is apparent in Hong Kong’s rural areas, it is not clear that society bears significant costs for its removal. It is often difficult, or impossible, for remedial action to take place because of loopholes in the law that allow dumping on private land, or because government departments argue over which, if any, department is responsible. The waste, therefore, often just left where it is thrown.

It is clear that the Environmental Protection Department is unable to protect the environment by providing sustainable solutions to the degradation caused by waste and pollution problems in Hong Kong. Environmental protection should not be the remit of a separate department, but rather should be apparent in the work of all government departments. Currently it is not.

There are numerous other examples of government action (or sometimes inaction) contributing to environmental degradation, some of which we have included in this paper. The system demonstrates that the EPD often lacks the vision, management and communication to drive the changes necessary. Hong Kong’s waste strategy lacks transparency and is unresponsive to community needs. Though the MSW Policy Framework of 2005 emphasizes waste reduction and recycling initiatives, EPD’s focus is clearly on landfill and incineration, with scant support for waste reduction and recycling measures, which are often prevented by senseless bureaucracy. This approach clearly has implications with regard to Hong Kong’s need to introduce MSW charging.

Hong Kong would benefit from the setting up of an independent body, backed by improved policy to safeguard the environment, with the authority to act against polluters. An “Independent Commission Against Pollution” would be an enforcement agency that would advise government, business, schools/universities, and individuals on ways to reduce pollution and cut waste, or issue fines and make prosecutions where necessary.

(b) Question 2: Should Hong Kong go for a waste charging system for all sectors or a partial charging system?

If charging for the disposal of MSW is to be introduced in Hong Kong, a good starting point 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 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, or the abolition of wine duty, which increased wine sales and the amount of glass going into landfill) to identify opportunities for waste reduction and necessary changes in behaviour would go a long way to setting Hong Kong off on a path to being more responsible with regard to waste.

The attitudes and behaviours that contribute to waste problems in the wider community are also apparent among government workers. The practice of “only clearing the snow in front of your own front door” (whereby people clean up one area only to dump on another) is common. We also witness irresponsible waste disposal, lack of understanding over biodegradable and non-biodegradable material, disregard for vegetation, and an inability to change established practices. Here are some examples:


When government contractors carry out work on Lamma, they invariably leave behind all sorts of rubbish. We have tried to fix this problem by carrying out clean ups and through complaints via the government 1823 hotline and directly with departments responsible. On clean ups, we routinely find construction material, lunch boxes, cigarette packets and drink’s containers – including mostly full plastic bottles of water. When we clean up and report our findings to 1823, the department responsible usually acknowledges our efforts, yet the dumping continues. We have even had the experience of reporting rubbish left behind after works had been carried out, only to find that the workmen responded by throwing the waste further down the hillside, still visible from the tourist path, but very difficult and dangerous to retrieve.

There seems to be zero oversight on the part of departments to ensure that waste generated by contractors is not dumped. It has been suggested that the problem may be that government contractors are not paid for proper waste disposal. We notice that government employees seldom appear aware or unconcerned about what happens to waste generated by public works. We are often told that it is the responsibility of the contractor.

Government outsourcing may be a significant contributing factor to Lamma’s waste problems and it is high time that departments took back responsibility for the waste they produce. For example, the Lands Department (LandsD) generates large amounts of green waste whenever trees are felled. This organic material is either left in large piles by the side of the path (creating fire risks and encouraging more dumping, as people who dump waste do not generally differentiate between biodegradable and non-biodegradable materials) or wrapped in black plastic and sent to landfill. Over 20 years ago, the Leisure and Cultural Services Department (LCSD) composted green waste was composted on Lamma, but that this stopped once LCSD outsourced the provision of plants. The person we spoke to did not know what happened to the green waste generated by LCSD works.

Lack of thought with regard to waste also occurs in joint operations. On Thursday 29th March 2012, for example, five different government departments participated in the removal of 13 bikes from the ferry pier. These were taken directly to the Waste Transfer Station where they were thrown into the trash compactor and sent to landfill.

The purpose of such clearances should be to identify and remove abandoned bicycles. There are piles of scrap metal, including old bikes, outside the Waste Transfer Station on Lamma, awaiting collection for recycling. The bikes that were destroyed were clearly still in use and some looked new. There was no opportunity for people to claim their property and bike owners who were lucky enough not to receive a notice 2 days prior to the clearance, or managed to see the notice and park elsewhere on that morning, kept their bikes and now continue to park along the ferry pier. Given Hong Kong’s landfill problems, it is astounding that new and usable property is allowed to be trashed and that the EPD was unable to prevent this from happening.

For attitudes and behaviours towards waste to change in Hong Kong, there must be leadership from government. Government practices should provide workable solutions for Hong Kong’s waste management problems at the local level, not contribute to those problems.


(c) 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, facilitating the re-export of materials for processing and providing much improved and cleaner waste facilities, the discussion of the type of charging is premature.

If a system of rewards/penalties for waste reduction and recycling is to be instituted, this should done at a district level. Thus far, there appears to have been little engagement of the local district councilors in the debate on waste. As it entails the provision of local services, district councilors should be educated and involved. They should serve as the conduit to providing sustainable solutions for the districts in which they serve.

(d) 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. Leaving packaging behind in stores can help to send the message that excess packaging is unwanted. 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. Using rechargeable batteries and certain brands of light bulbs allows those products to be recycled. And of course, using a reusable bag for your shopping eliminates the need for a plastic bag, while taking along a reusable bottle or cup means that drinks can be enjoyed without generating unnecessary waste.


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? What happens if the only reason that the waste is contributing to landfill (or is incinerated) is because Hong Kong lacks the policy support to reduce waste, or the systems to recycle items which are recycled elsewhere in the world?

For example, there is no system to recycle Tetra Paks in Hong Kong, yet most milk, juice and drink boxes use this method of packaging. 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.

Hong Kong is already 15 years into a fifty year period of “One Country, Two Systems.” So far, with regard to waste, the emphasis is on the two systems nature of the relationship with the country to which Hong Kong belongs. During the twenty year period from 1980, Hong Kong and the neighbouring cities of the Pearl River Delta (PRD) region developed faster than any other region in the world, thanks to a winning combination of investment, technology, rule of law, and global communication in Hong Kong and low priced land and labour in the PRD region.

Waste comes into Hong Kong via the importation of goods, most of which come from the Chinese mainland. Scarcity of land and the system of land ownership in Hong Kong mean that it is difficult, or impossible, to achieve the scale necessary to make recycling businesses viable. Government support for and facilitation of an exploration into the synergies and economies possible through closer Hong Kong/PRD cooperation on waste reduction and recycling should be a priority. This may provide the residents of the Greater Pearl River Delta region with the means to change their behaviour with regard to waste disposal.

(e) 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. For example, EPD handles electrical waste, the Food and Environmental Hygiene Department (FEHD) picks up household waste, the LandsD is responsible for construction waste, LCSD cleans up rubbish in playgrounds and sitting out areas under its control, and the Drainage Services Department (DSD) clears out waste deposited in its nullah, but can do nothing about the greasy, waste water that flows into it from the restaurants. That is the responsibility of the EPD.

That government delineates responsibility for waste along specific lines drastically impedes efforts to clean up our neighbourhood. Clearly people rarely think about separating their waste when they dump it. This is why it took 10 months, and persistent lobbying on the part of Living Lamma, for government to clean up this large pile of rubbish deposited on government land on the harbourfront in Yung Shue Wan:

The police will only enforce the law if there is a complaint from the public backed by photographic evidence identifying the perpetrator. For practical reasons, this rarely, if ever, happens. Living Lamma’s attempts to ask the police to enforce the law on littering resulted in them suggesting that we talk to FEHD. FEHD referred us to LCSD and LCSD sent us back to the police. Needless to say dumping and littering continue to be problems on Lamma.


Living Lamma

March 2012

Author: Jo Wilson

  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 to accommodate a large-scale incinerator, or about the protests against this project.