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Untitled - HKU Libraries - The University of Hong Kong

THE UNIVERSITY OF HONG KONG

LIBRARIES

Hong Kong Collection


Control of the Environment in Hong Kong

STAGE 1 REPORT

Prepared for The Secretary of the Environment

Hong Kong Government

\

BY ENVIRONMENTAL RESOURCES LTD AUGUST W5


Environmental

Resources Ltd

Consultants in

Environmental Management

35a Thayer Street

London W1M SLH

Telephone

01-486 8277

CONTROL OF THE ENVIRONMENT IN HONG KONG

STAGE I REPORT

Prepared for

The Secretary of the Environment

Hong Kong Government

by

ENVIRONMENTAL RESOURCES LIMITED August 1975

Directors:

Florence Fisher, BSc, (Managing) (USA)

John M. Sidwick, MIWPC

Robin Bidwell, MA, PhD • William Fisher, BA (USA)

Norman A. White, MSc. PhD (Econ), CEng f FIMechE

Associates: Professor Peter C. G. Isaac, BSc (Eng), SM, FICE, FIWE , * R. Ted Bevan, ISWM • Noel Carr, BSc, DPhil

James McLoughlin, LIM • Sandra Mason, MA • Ian Morris, BSc, PhD • Brenda Thake, BSc

Registered Office: Devonshire House, 1 Devonshire Street, London WIN 2DR Registered No. 1014622


Environmental Resources Ltd


Environmental

Resources Ltd

35a Thayer Street

London W1M 5LH

Consultants in

Telephone

Environmental Management 01-486 8277

FF/RB/HK 31st August 1975,

The Secretary for the Environment,

Colonial Secretariat,

Lower Albert Road,

Hong Kong.

Dear Sir,

Control of the Environment

We have pleasure in submitting our report on

Stage I of this project. In this report, we

outline our preliminary proposals for measures to

protect the Hong Kong environment.

A team from Environmental Resources Ltd. visited

Hong Kong on two occasions. On each of these

visits we received every assistance from the

members of the Government with whom we were in

contact. We should like to record our thanks

for this assistance and for the subsequent work

involved in compiling and forwarding relevant

information to us.

We look forward to discussing our report with you.

Yours faithfully,

Florence Fisher (Mrs)

Managing Director.

Directors: Florence Fisher, BSc, (Managing) (USA) • Robin Bidwell, MA, PhD - William Fisher, BA (USA)

John M. Sidwick, MIWPC • Norman A, White, MSc. PhD (Eeon), CEng, FI MechE

Associates: Professor Peter C. G, Isaac, BSc (Eng), SM, FICE, FIWE • R. Ted Bevan, ISWM • Noel Carr, BSc, DPhil

James McLoughUn, L1M • Sandra Mason, MA • Ian Morris, BSc, PhD • Brenda Thake, BSc

Registered Office: Devonshire House, 1 Devonshire Street, London WIN 2DR Registered No. 1014622


Environmental Resources Ltd

CONTENTS OF THE REPORT

I INTRODUCTION 1

II WATER POLLUTION AND ITS CONTROL 9

2.1 Introduction 10

2.2 Inland Waterways - The present situation 1O

2.3 The development of water quality

objectives for inland waterways 11

2.4 Facilities for the disposal of wastes

other than by discharge into inland

waters 17

2.5 Cost of improving inland waterways 21

2.6 Summary of costs 23

2.7 Recommendations for inland waterways 25

"2.8 Coastal waters - the present situation 29

2.9 The development of quality objectives

for coastal waters 30

2.10 The cost of improving the coastal waters 34

2.11 Recommendations for coastal waters 35

2.12 Costs of meeting water quality objectives 40


Environmental Resources Ltd

Page

III NOISE POLLUTION AND ITS CONTROL 53

3.1 Introduction 54

3.2 Noise from stationary sources; noise

sources and present controls 56

3.3 Recommendations for control of noise

from stationary sources 58

3.4 Motor vehicles - noise emissions and

present controls 62

3.5 Motor vehicles - methods of control

and recommendations 64

3.6 Aircraft - noise emissions and

present controls 68

3.7 Aircraft - methods of control and

recommendations 69

3.8 A programme for the reduction of noise 73


Environmental Resources Ltd

Page

IV AIR POLLUTION AND ITS CONTROL 77

4.1 Introduction 7 8

4.2 Methods for the control of sulphur

dioxide 80

4.3 Methods for the control of other

emissions from stationary sources 84

4.4 Existing legal controls 88

4.5 Proposed legal controls 90

Air pollution from mobile sources:

methods for controlling traffic fumes 92

4.7 Existing controls over mobile sources 96

4.8 Proposed controls over mobile sources 98

4.9 The development of an air pollution

control policy and programme 99

4.10 Analysis of costs and summary of

control alternatives 104


Environmental Resources Ltd

Page

V COLLECTION AND DISPOSAL OF SOLID WASTES 113

f

5.1 Introduction 114

5.2 Environmental impact associated with

solid waste collection 116

5.3 Collection •*• present controls 117

5.4 Collection - proposed control measures 12O

5.5 The environmental impact associated

with solid waste pretreatment and

disposal 123

5.6 Disposal of wastes - present controls 125

5.7 Disposal of wastes - proposed control

measures 125

5.8 Litter and the deposit of other solid

wastes 129

5.9 Controls over litter 13O

5.10 Litter - proposed control measures 132

5.11 Solid waste planning 134

5.12 Summary of alternative solutions to

solid waste problems 143


Environmental Resources Ltd

Paqe

VI THE ROLE OF PLANNING 154

6*1 Introduction 155

6.2 Existing iand use controls 158

6.3 Proposals for additional land use

planning controls 161

6.4 Co-ordination with other forms of

control 163

VII THE CONTROL AUTHORITIES 164

7.1

The need for a central control 165

7.4 authority

7.5 Proposals for the Central Unit for

Environmental Protection 174

7.6 The Central Unit for Environmental

Protection: its Development and

Functions 176

7.7 The cost of the Unit 178

7.8 Advisory Committee on Environmental

Pollution 189

7*9 A Country Parks Authority 191


Environmental Resources Ltd

Page

VIII

THE RESPONSIBILITY FOR COSTS OF POLLUTION

CONTROL 193

IX

THE REPORT SUMMARY INCLUDING A LIST OF

THE RECOMMENDATIONS 197

APPENDIX A - Review of the Environmental

Situation

Bound

separately

APPENDIX B Review of the Environmental Bound

Legislation

separately


Environmental Resources Ltd

I. INTRODUCTION

Environmental Resources Limited was asked by the

Hong Kong Government to make recommendations on the

environmental controls required for the protection

of the Hong Kong environment and on the organisations

required for their administration.

The full brief is included at the end of Section I.

It was agreed that the work should be carried out in

two stages:

^n Stage I we are required to make outline

proposals on the type and structure of the

control authorities and the control system

necessary for the protection of the

environment and to provide an indication

of the cost;

in Stage II we are required, following

agreement with the Government on the

principles to be incorporated in the

legislation to make detailed recommendations

on the authorities and the control system,

prepare drafting instructions and assist

the Government to inform the community about

the proposed protection programme.

Throughout, we were requested to take account of

the special environmental, economic, legal and

social characteristics of Hong Kong.

In this, the Stage I Report, we have reviewed the

environmental situation and the existing environmental

controls; and we have made proposals for the control

system and authority that we consider would best

ensure the protection of the Hong Kong environment.


Environmental Resources Ltd

1*2 Hong Kong's environmental problems for the main part

derive (as in most other countries) from the

following two causes:

wastes discharged into the environment have,

with a few exceptions, been largely untreated:

there has been no requirement to minimise the

impact of these wastes either by reduction at

source or by treatment;

no special account has been taken until

recently of the impact on the environment of

the discharge of waste and noise from these

developments^)

Increasing population and economic activity have

exacerbated the problem in Hong Kong. This applies

not only to existing urban areas, but also to

other areas where the need for new industrial and

residential developments makes demands on a limited

acreage of land, and creates problems for the future.

Even in recreational areas, intensity of use will, to

some extent, diminish amenity, and there is a danger of

these being reduced in size as the demand for land

for other uses grows. If present trends continue, a

point will be reached at which Hong Kong will no longer

be able to provide the balance of industrial,

agricultural and recreational facilities which permits

the present quality of life to be maintained. That, in

its train, will bring further problems. The size of

the population and its present trends are facts which

we must necessarily take into account (see Appendix A,

Section 1) • Measures to influence the growth of the

population are, however, outside the terms of our

brief, and they raise economic and political implications

on which we are not required to comment* But it is

clear that further increases in population may reduce

the effect of any proposals we may make.

Action to improve the quality of the environment

inevitably involves expense. It may also involve

changes in the siting of industry and agriculture

and methods of industrial and agricultural production.

Care must be taken to keep any disruption to a

minimum.


3. Environmental Resources Ltd

It is therefore essential that decisions should be

taken on what the priorities are for environmental

protection and improvement: to decide the extent to

which resources should be made available for

environmental protection and how these should be

used to best effect.

As consultants, we cannot make these decisions: it

is for the Government and the community to determine

where the balance lies bewteen improving the quality

of the environment and the costs and disruptions of

such improvements.

We have, however, in this report aimed to provide

sufficient information to enable these decisions to be

made and, perhaps more importantly, to prepare a

framework to enable this decision-making to become

a continuous process which will allow Hong Kong to

achieve the objective of environmental improvement

and protection.

With this objective, we have in this report:

reviewed the major forms of environmental

pollution and their causes;

indicated what further information is

required in order to determine whether action

is required to control the pollution and what

form of actions would be practical;

outlined our recommendations for the development

of a control authority, for a control programme,

and for the legislation that will be required to

implement the control programme.

1.3 In discussing the formulation of environmental

protection policy we have used a number of terms.

These are defined below:

: physical

condition of any part of the environment and

usually expressed as the amount of contaminant

in the environment that is considered to be


4 . Environmental Resources Ltd

acceptable; it may be intended that the

objective should be achieved immediately

or at some time in the future as a planned

programme of environmental improvement; the

quality objectives are usually determined by

consideration of the impact of the

contaminant on man, his property and on

nature, and by consideration of the options

for controlling the release of the

contaminant ard their costs;

physical

condition of any part of the environment

which receives contaminants, and which it

is the immediate aim of any control or

controls to attain and/or maintain;

discharge^or^emission^standards: the rate of

emission of contaminants from any particular

source which is not to be exceeded; the

standard is usually expressed in terms of

concentrations and volume permitted in a

given period but noise standards are expressed

in terms of the intensity of sound pressure

levels permitted in a given period;

: specified physical

characteristics for a product expressed in

terms of a maximum which must not be exceeded,

e.g. sulphur content of oil, noisiness of

motor vehicles under specified operating

conditions;

specifications relating to the design,

installation and/or operation of a construction,

machinery or other potential source of pollution

designed to minimise the environmental impact

at the source.


Environmental Resources Ltd

1. 4 Layout of the report

In the following four Sections, we have examined the

problems of Water Pollution (Section II), Noise

Pollution (Section III) g Air Pollution (Section IV) ,

and Pollution from solid waste and litter (Section V)

we have reviewed the existing control measures and

have made recommendations for future controls.

In Section VI we have discussed the role of land-use

planning and in Section VII we have made

recommendations for the Control Authorities. In

Section VIII we have outlined the principles

relating to the responsibility for bearing the costs

of control.

A detailed review of the socio-economic and

environmental situation and existing environmental

legislation is included in Appendix A and Appendix

B respectively; these have been bound separately.

The list of references and its recommendations are

summarised in Section IX.

For the purpose of identifying geographical areas,

we refer to Map Codes and Water Sectors. Map Codes

are based on primary planning limits and Water

Sectors on water drainage areas and the surrounding

coastal waters. The areas covered by each are shown

in Map 1.1 (on the following page) and in Map 2.1

(after P.11). A more detailed description of the

areas included is given in Appendix A, Section 1.1,

for Map Codes and Section 2.1. for Water Sectors.


HONG KONG MAP CODE AREAS

km 1 O t £ 3 4 5 6 J 6 9 V_ «-»

THE ENVIROMMFI"


6 - Environmental Resources Ltd

THE BRIEF


"7 - Environmental Resources Ltd

THE BRIEF

(as prepared by the Hong Kong Government

and outlined in Appendix A

of the letter to

Environmental Resources Limited

Reference ENV 8/05/05 (TC 3O)

dated June 19th 1974)

A. To advise on the principles to be incorporated

in a general Environmental Protection Ordinance

for Hong Kong, covering all aspects of

pollution on land and sea, in the air and

from excessive noise, having regard to:

the different approaches being applied

in UK, USA, Japan, Singapore, Australia,

Europe and elsewhere in the world where

pollution control legislation and

practice have been established;

ii.

the present state of the overall environment,

the existing pollution problems, the control

already provided for and exercised under

existing legislation and organisations, and

the possible future sources of pollution in

Hong Kong;

iii. the present state of social, economic,

agricultural and industrial development

and the future trends in Hong Kong.

B. To prepare the detailed drafting instructions

and to recommend any standards and regulations

that should be scheduled under the legislation

having regard to local conditions and

circumstances, and current state of technical

knowledge and the economic implications.


8 • Environmental Resources Ltd

C. To advise on the proper organisation required

for the enforcement of such legislation,

including the overall organisation for

monitoring and controlling all forms of

pollution, the recruitment and training of

the necessary staff*

D. To draw up the detailed strategy for the

introduction of the legislation, including

a programme for publicity, phased application

and enforcement of the legislation and the

detailed procedure for the inspection and

control of discharges and emissions as

appropriate.

E. To prepare explanatory handbooks 6n each

branch of the legislation, in layman 1 s

terms for publication.


9 - Environmental Resources Ltd

SECTION II

WATER POLLUTION AND ITS CONTROL


10. Environmental Resources Ltd

II

WATER POLLUTION AND ITS CONTROL

The present state of Hong Kong's inland and

coastal waters is discussed in Appendix A,

Section II.

In this section, we discuss the existing controls

over water pollution, outline proposals for the

development of a programme for the improvement of

water quality and make preliminary recommendations

for the legislation that would be required*

We have included estimates of the costs of

improvement»

For the purpose of the analyses, we have divided

the Territory and the surrounding coastal waters

into five sectors: A - E. The areas covered by

these sectors are shown in Map 2.1 (from Appendix A)

INLAND WATERWAYS

2.2 The Present Situation

We have noted in Appendix A, Section II, that while

the streams in the catchment areas are clean, most

of the lowland waterways are grossly polluted.

Domestic refuse impedes their flow; and effluent is

discharged into them untreated from agricultural,

domestic and industrial sources* At present, about

80 % of the fresh water BOD load (total BOD loads

(i.e. inputs of orcranic pollution) - inland and

marine - in each sector estimated for 1974 and 1984

are illustrated on Map 2.2) discharged into the

streams is from pig and poultry fanning. We

estimate that only a small proportion of the sources

of freshwater pollution are industrial. Onlv about

7% of industrial enterprises discharge into inlana

waterways: however, some of those that do (tanneries

paper manufacturers, chemical companies and a few

textile and electroplating companies) may have an

impact out of all proportion to the volume of their

discharges.


HONG KONG - CONTROL OF THE ENVIRC

HONG KONG

WATER SECTORS

A - F


Environmental Resources Ltd

The present legal controls over the pollution of

inland waters are set out in Appendix B, Sections

4.22-4.36.

Those which are designed to protect inland

watercourses in general take the form of simple

prohibitions, and are largely unenforced. There

is, of course, no point in trying to enforce legal

restraints over the pollution of waters if facilities

are not available for the proper disposal of effluents

and other wastes. For many of the wastes in Hong

Kong, particularly agricultural wastes, adequate

facilities have not yet been developed.

The provisions restricting discharges or deposits

into sewers and drains relate to solid matter,

and substances which may cause nuisance or danger

to workmen, or damage to the sewer to drain itself,

Treatment of the content of sewers varies from

primary and secondary biological treatment at the

Shek Wu Hui Pilot Plant to the simple screening

given to sewage from the heavily populated areas

of Hong Kong Island and Kowloon before discharge

usually to coastal waters.

2.3 The Development of Water Quality Objectives for

Inland Waterways

The treatment of all effluents from agricultural,

industrial and domestic sources to discharge

standards at which they would have no impact

whatsoever on the natural environment would be

prohibitively expensive.

To be practicable, any programme of treatment and

control must be geared to objectives which are more

selective. If the programme is not to be haphazard

and wasteful of the limited financial resources

available it must be:

(a)

directed to the attainment of

specified quality objectives;


Environmental Resources Ltd

(b)

implemented in accordance with a

system of priorities.

For these reasons we recommend in Section VII the

establishment of a body which can advise and assess

the Secretary for the Environment on the development

and implementation of such a programme.

The programme will involve setting quality standards

for particular uses of a river or section of a river,

and requiring treatment of effluents to achieve

.ind maintain those standards. Attention may also

be paid to raising quality standards so as to

increase amenity value. The programme cannot be

worked out in full without further examination

of the technical problems (particularly those relating

to agricultural wastes), and without detailed

examination of the circumstances in each area of the

Territory. This will be a task for the relevant

authority (see Section

It is incumbent upon us at this stage, however, to

offer sufficient information to enable the

Government to decide whether or not to adopt our

recommendations. This we do by indicating quality

standards which might be considered appropriate to

the circumstances in Hong Kong and estimating the cost,

The costs of achieving these standards are discussed

in paragraph 2.5.

(i)

_

Farming

We have listed the contaminants that are undesirable

in water used for irrigation purposes in Appendix A,

2.13.

A high quality of water is not needed for irrigation

of agricultural land, but attention must be paid to

organic wastes which might contain pathogens.


Environmental Resources Ltd

There is a danger that water into which they are

discharged might be used to irrigate crops which

will be eaten before they are adequately cleansed

and cooked* It would be impossible to ensure

that effective precautions against infection are

taken at all farms; therefore in cases where such

crops are grown, higher standards are desirable.

Close attention must also be paid to discharges

containing toxic pollutants, such as heavy metals,

for they present a danger to soil, crops and fish

of which the producer would be unaware-

In addition to the contaminants present in the

water, we understand that the presence of domestic

and agricultural solids in the waterways dam the

flow and can cause flooding to the detriment of the

crops.

(ii)

Imgroyements_to

Inland waters must not be unpleasant to sight or

smell if they are to have amenity value. They

should be free from:

(a)

(b)

(c)

effluent solids causing objectionable

deposits;

floating debris, oil, scum, etc.;

objectionable colour and odour*

Information from the Binnie Survey on the New

Territory's stream pollution, together with our own

observations, suggests that streams in the country

parks, the country park hinterlands and the

protected forests in general achieve this quality.

The chief exceptions are those in the north-east of

the New Territories, where parts of the Indus and

other streams which lie within the protected

forest area fall below this quality.


14. Environmental Resources Ltd

At present most of the lowland waters, particularly

in the north of the New Territories (PPUs 4, 5 and

6) are highly objectionable and cannot be considered

as offering any amenity value. They are used for

the disposal of agricultural solid and liquid

wastes, domestic sewage untreated or partially

treated in septic tanks, industrial effluents

usually untreated but sometimes receiving partial

treatment, and domestic refuse* They are anaerobic,

unsightly and, in effect, open sewers. These

conditions are aggravated during the dry season when

many of the watercourses contain too little or no

clean water to dilute the effluents they receive*

There can be little doubt that the removal of

solid wastes discharged into streams would significantly

improve their amenity value. To achieve this, it

would be necessary to:

prevent the dumping of domestic

refuse in streams;

prevent the deposit of poultry and

pig manure: this would require

the introduction of a collection and

disposal service, and could involve

the construction of some new access

roads;

remove solids from domestic sewage

by providing sedimentation, Irahoff

or septic tanks: removal of solids

would be a simple procedure but

some sludge disposal would be

required;

remove objectionable characteristics

(mainly solids, colouration and

odour) from industrial effluents:

there are few factories producing

wastes with high concentrations of

suspended material in the northern

New Territories, but there is the

problem of controlling illegal


15 " Environmental Resources Ltd

Unfortunately, improving the amenity value of

streams will carry the attendant risk that people,

especially children, will be tempted to bathe in

what will appear to be much improved watercourses*

The danger is that the waters will probably still

carry a high pollution load, and,in particular,

hazardous concentrations of pathogenic organisms.

(iii)

It is clear from information given to us by the

Forestry Division of the Department of Agriculture

and Fisheries, from consultants 1 reports (Ref 76),

and from our discussions in Hong Kong, that there

is an increasing demand by people in urban areas

for opportunities for recreation in the New

Territories, including the use of inland waters*

The standards laid down by the United States

Federal Water Pollution Control Administration for

"primary contact water sports", such as swimming

and diving (see Appendix A, 2.13), include the

requirement that faecal coliforms should on

average not be found in concentrations of more than

200 per 100 ml, and for 9O% of the samples, should

not exceed 400 per 1OO ml. In order to achieve

rhis, it would be necessary not only to treat all

effluents to a high standard, but also to chlorinate,

or sterilise by some other method, any in which

there are likely to be pathogenic organisms.

(iv)

Use_of_Waterways_as_Source_of_Potable_Water

In Appendix A, Section 2.13, we outline the quality

standards laid down by the Commission for the European

Communities for the purpose of abstracting supplies

of drinking water.

We have compared these with the data contained in

the Binnie Report. The comparison shows that the


Environmental Resources Ltd

quality of streams in existing catchment areas

meets the quality standards laid down for waters

which will be given the normal physical and

chemical treatment and subjected to disinfection.

Again, the one exception is the River Indus and

other streams in its locality. However, we

understand that these are pumping catchment areas

and that the water quality is closely monitored 0

This situation is illustrated on Map 2.3.

To improve the waterways to the quality standard

needed for water abstraction, it would be necessary

to:

remove toxic materials and certain

other specified substances from

industrial effluents;

treat effluents from agricultural,

domestic and industrial sources to

high standard.

The potential of streams in the North-West of the

New Territories as a water source was examined by

Binnie (ref 32).

It was estimated that this area could provide

up to 90,000 cubic metres per day. The cost of

producing potable water by desalting is about

HK$3*50 per cubic metre. This suggests that the

value o± the water lost to this use in the North-

Western area is about $80 million per year. It is

relevant to use the cost of desalting for valuing

the water catchment potential of areas, because,

in future, any major shortfall in water supply will

need to be made up by desalting unless the catchment

areas could be increased.


17. Environmental Resources Ltd

2.4 Facilities for the Disposal of Wastes, other than

by Discharge into Inland Waters

A necessary part of any programme to improve the

quality of inland waters is to provide or promote

the development of facilities for the treatment of

wastes, or for their disposal elsewhere. In Hong

Kong the problem is often one of feasibility as

well as costs. In this paragraph we outline the

nature of the problem and possible solutions,

costs are dealt with in the following Section 2.5.

(i)

Existing arrangements for the collection and disposal

of domestic sewage are outlined in Appendix A, 2.2.

It will be seen that domestic sewage from the

established urban areas is mainly discharged into

the coastal waters and not into inland waterways.

In the New Territories there is a three year

programme for the provision of aqua-privies,

although we are informed that progress is slower

than had been hoped. It is also the intention

of the Government to provide improved housing

for all families within the next ten years. As

these programmes of improvement are carried through

the pollution load of streanu from domestic sources

should be reduced

We appreciate that these progressive improvements,

the provision of aqua-privies and of septic tanks

in villages, are based on priorities which take

into account improvements in the conditions for

residents in the New Territories and the need for

improvement of the physical environment. Any scheme

for, the improvement of local waterways must be

co-ordinated with those improvements if it is to


18. Environmental Resources Ltd

have the greatest effect at the least cost.

This inevitably calls for a control authority

which can introduce its controls by stages.

(ii) Industrial Effluents

As mentioned above, a number of small enterprises

discharge industrial effluents into streams,

which restrict the uses to which the waters can

be put, and reduce amenity.

Some of these enterprises are engaged in what are

classed as "offensive trades", and will be moved

to special areas. This will have the merit of

siting them where their pollution will cause less

damage, although more could be done if they were

moved to places where special facilities for

treatment and safe disposal could be provided.

The provision of the usual biological treatment

plant for sewage can itself create problems,

for the biological process is itself in need of

protection and this increases the need for controls

over discharges to sewers. This can mean that

some industrial enterprises will have to pre-treat

their effluent or discharge it elsewhere.

Many of the enterprises in question are small,

and could not provide treatment plant without

running into grave financial difficulties. At

least for existing firms this is a factor to be

taken into account, and therefore points to the need

for a flexible system of controls, to be applied

by the exercise of discretionary powers. The draft

Trade Effluents Bill would introduce some

flexibility, but would also prescribe fixed

emission standards. The position of a stream, the

uses to which it is put or might be put, and

the contribution made to material prosperity by

the enterprise in question all vary, and it is

likely that there will be cases in which the fixed

standards would be unduly restrictive. We cannot

therefore support the proposed statutory fixed

standards for general application.


19 * Environmental Resources Lid

(iii)

Agricultural^Wastes

The principal problems of pollution from

agriculture arise out of the disposal of chicken

and pig manures. Before any controls can be

reasonably and effectively enforced, some other

method of disposal must be made available.

Progress has been made with the experimental plant

at Pat Heung for the drying of chicken manure to

convert it to a usable fertiliser. Moreover,

we have been informed that increases in the prices

of imported fertiliser have made prospects for the

recycling of chicken manure as fertiliser more

favourable. But prices will not necessarily

remain high, and this raises the question as to

whether a useful recycling programme such as this

should be left to succeed or fail according to the

vagaries of market prices. We suggest that, if the

need arises, consideration be given to the imposition

of a duty on imported fertilisers.

The disposal of pig manure presents a more serious

and less easily soluble problem. Practical advice

has already been given, particularly by

Professor Isaac. At the same time it is recognised

that the problems of collection and disposal are not

the same throughout Hong Kong and that different

solutions might be needed in different areas.

It is here more than ever clear that enforcement of

pollution control measures cannot be effective until

satisfactory disposal facilities have been provided.

Moreover, progress is unlikely to be the same

throughout the whole of Hong Kong, and even when

facilities have been provided, pollution on a

smaller scale may be expected to continue for some

time. In these circumstances the present inflexible

provisions, such as Section 4 of the Summary Offences

Ordinance,are inappropriate.


20 * Environmental Resources Ltd

Collection and removal, possibly for export as

manure, more likely for disposal at sea or on land

promises to be the most usual solution. For many

farms, access will have to be improved and

collection points constructed. It may even be

necessary to persuade farmers to move to new sites.

This could be a relatively long term process with

the control authority co-operating with the Department

of Agriculture and Fisheries to provide the changes.

In some areas the authorities may be justified in

banning pig keeping on grounds of public health or

even the prevention of nuisance. We are informed

that an amendment to the Public Health (Animals

and Birds) Ordinance is being drafted to give the

authorities such powers.

The Director of Agriculture and Fisheries has

suggested that the award of grants for improvements

in animal husbandry should be used to improve

pollution prevention and control measures. Grants

are at present awarded, through the Department of

Agriculture and Fisheries, for improvements in animal

husbandry. It has been suggested by the Director

of that Department that in the award of these grants,

more weight might be given to development of facilities

which will reduce pollution. If the farmers

themselves cannot afford to provide such facilities

and if Hong Kong wishes for strategic or political

reasons to maintain a supply of home-produced pork,

this would be a justifiable departure from the

principle that the polluter must, in the first plac^,

pay for the control of the pollution he generates.

The award of grants would then have to be part of

a programme carefully planned and supervised by the

pollution control authority and the Department of

Agriculture and Fisheries acting jointly. They would

have to take into account, not only the needs and

resources of the farmers, but also the programme of

stream improvement.


21 * Environmental Resources Ltd

2.5 Cost of Improving the Inland Waterways

In Table 2*12 (e) at the end of the section, we

have summarised the steps that we believe are

required to achieve the improvements in inland

waterways to achieve the uses discussed in

paragraph 2 0 3.

We have estimated pollution control costs for

alternative control measures. These costs are

designed to provide an indication of the costs

of implementing action programmes to meet

alternative targets for waterway use. It is

important to stress that they can be no more than

a broad guide. It will be appreciated that:

the costs will vary considerably

depending upon the quantity and

characteristics of effluent produced

by the individual source; we have

expressed all our costs in terms of

removal of specific contaminants:

the size of the treatment plant can

influence the cost of removal by at

least an order of magnitude;

industry can often find alternative

means of achieving effluent

standards other than the installation

of pollution control equipment: in

the case of toxic constituents,

there are often alternative chemicals

that may be used (for example, in the

bleaching and dyeing industry

chromates can in some cases be replaced

by hydrogen peroxide); process changes

can often be introduced to reduce BOD

and suspended solids; removal of

polluting constituents can sometimes

show a cost benefit through

reclamation or recycling;


2 2 - Environmental Resources Ltd

the collection,, transport and

disposal of sludges is an

important factor in the costing

again, the exact cost for any

source will depend upon such

variables as the means of

transport, the distances from the

disposal point, and the means of

disposal.

It should be noted that capital costs indicate the

level of initial expenditure and annual costs

include amortised capital costs and operating costs.

We have prepared estimates of the cost of improving

the state of the inland waterways by reducing the

quantity of waste discharged into them from domestic,

agricultural and industrial sources (see Tables

2.12 (a), 2.12(b), 2.12(c) and 2.12(d) at the end of

Section II).

The calculations provide an indication of the cost of

providing for uses (I) and (II);

removing solids, toxic materials, grease

and oil from effluent so as to improve the

waterways' amenity value and make them

suitable for irrigation and fish farming

we are aware that some grossly polluted

streams are already used for irrigation

purposes but this cannot be considered

to be altogether satisfactory;

providing for use (III):

reducing the BOD load by secondary

treatment to further improve the quality

and make them suitable for water catchment

(Stage III); it will be appreciated that

the extent of secondary treatment (or

tertiary treatment) will depend on the

quantity of polluting discharges in relation

to the receiving waters;


23. Environmental Resources Ltd

providing for use (IV) :

removing solids, toxic materialsi grease

and oil and chlorinating the remaining

effluent so as to make the receiving

waters suitable for water contact sports

(stage IV).

We have not included the cost of refuse removal

or the cost of removing colouration from the effluents

of dye factories.

All costs refer to existing discharges* These

calculations have been prepared for each water

sector and are shown in Tables 2.12(f), 2.12(g) and

2.12(h) .

They are summarised below:

2.6 SUMMARY OF COSTS OF IMPROVING INLAND WATER QUALITY

Use

Cost of Improvement

Capital Cost

Annual Cost

1,11: Improved amenity,

Irrigation,

Fishfarming

$m

83.2

$m

31,S

III;

Water catchment

quality

585.8

126.3

IV:

Suitable for

swimming

99.9

62.5


2 4 • Environmental Resources Ltd

Reference to the Tables indicates that for the

first of these target uses (Stages I and II) the

costs of treatment falls most heavily on the

domestic sector (annual costs of $10m) and the

pig farmers (annual costs $8m)„ We have assumed

that for the domestic sources currently discharging

their effluent into streams it will be necessary to

provide septic tanks.

If full treatment of all effluents were required/

the main cost would fall on the pig farmers. We

have calculated the cost as in the region of $100m

per year - or an added cost of about $400 per pig.

This clearly woald be too high a cost to pay and

if it were decided that there were advantages in

achieving this standard we would suggest that the

pigs in that area should be moved.

It has been suggested that Sector D (North-West

New Territories) might provide up to 90,OOQ cubic

metres (20 million gallons) of water per day if the

quality of the streams could be improved: this is

equivalent in value to about $80m per year if the

water is costed as for desalting: (extra water

may have to come from this source). We suggest

that further investigation of this source of water

could prove worthwhile; although the pig farms

could still prove a major obstacle.

A point which should be noted is that the costs

outlined in the previous section refer to the costs

°f treating pollution. It would, in certain

circumstances, be less costly in monetary terms

(though perhaps not in political terms) to move the

source of pollution/ for example, some of the pig

farms, from those areas where there would be some

value in improving the quality of the waterway.


Environmental Resources Ltd

2.7 Recommendations for Inland Waterways

Pollution control methods designed to improve the

quality of all international waterways to a high

standard would be prohibitively extended and could

not be regarded as a priority for the use of the

resources available for environmental improvement.

On the other hand, at present most of the lowland

streams are grossly polluted, are offensive in terms

of their visual appearance and their smell, and can

be considered as giving rise to economic loss where

the pollution interferes with irrigation, fish

farming, water catchment, or where it leads to

flooding following the build-up of solid waste during

the dry season.

We make the following comments:

we do not consider that for the

foreseeable future or, indeed, in

the long term, it will be either

practical or economic (in terms

of the Territories" other

priorities) to improve all the

waterways even to the lowest of

the proposed standards;

we consider that action whould be

selective and that any action

programme for improving streams

should be prepared as part of an

overall land-use programme for

the territory. In areas of high

anemity value, the streams should not

be grossly polluted; in areas where

the water may be abstracted for

irrigational use or for fish farming,

the areas should not be grossly

polluted and no oil or toxic material

should be allowed to enter the water

upstream. And, of course,

increasingly catchment areas will

require a heavy expenditure - at


26. Environmental Resources Ltd

present we understand that the

Water Department does not consider

that such improvement in the North-

West New Territories, the most

likely area, would be justified in

terms of the benefits to the water

stock.

In these circumstances, it is clear that controls

of discharges to streams would best be applied to

the various areas of the Territory at different

points in time, and with different degrees of

severity. We therefore recommend that an authority

(see Section VII) be established with discretionary

powers to control discharges to inland waters.

The Authority would, subject to policy control by

the Secretary for the Environment, have a duty to

establish quality objectives for the various

stretches of water within the Territory. The quality

objectives would be related to specified uses.

It would also have powers to control discharges to

those waters in order to attain those objectives.

The objectives would be renewed and controls varied

as improvements became technically and economically

practicable. The quality objectives and strictness

of controls would thus vary from stream to stream,

and in some areas from one part of a stream to another,

The general aim would be a progressive improvement,

but not necessarily a gradual one, for each stretch

of water. It has been noted in paragraph 2.4

that one of the greatest dangers lies in a stream

which is apparently clean, but in fact contains

pathogenic organisms. The authority's programme of

water quality improvement should be designed so as

to avoid creating this danger.

The control powers would be in the following terms:

(a)

the authority to have power to prohibit

or control all or any class of


27 • Environmental Resources Ltd

polluting discharges into inland

waters, deposits into the waters

which might pollute or obstruct

the flow of a stream, deposits

of wastes in a place from where

they might fall into any inland

waters;

(b)

the authority to have power to

grant consent to discharge liquid

(and solid) wastes into a stream,

subject to conditions which may

relate to:

(i)

(ii)

place of discharge or

deposit;

time of discharge or

deposit;

(iii) composition of discharge

or deposit;

(iv) temperature of discharge

or deposit;

(v)

(vi)

maximum quantity of any

given period;

providing monitoring

equipment or paying a

monitoring fee.

(c)

The authority to have power to require

the installation and use of plant or

equipment for the pre-discharge treatment

of any effluent.

A breach of any prohibition under (a), any consent

under (b) or any requirement under (c) would be a

criminal offence. On convicting a person/ the court

would have power to order the cessation of any

discharge (or of any practice which led to the

committing of the offence) and to order the convicted

person to pay the costs of restoring the stream to

the condition it was before the committing of the

offence.


28. Environmental Resources Ltd

We further recommend that any individual should

have a right to object to the grant of a consent,

and a right of action for breach of statutory duty

for damage caused by any act which constitutes one

of the above offences* He should have no right

of action for a discharge which is in conformity

with consent conditions. To facilitate the

enforcement of these rights, all applications,

consents and data about the actual discharges

collected by the authority should be published.

It is envisaged that the authority will at first

exercise its powers over a limited area and therefore

staff requirements would be limited in the early

stages*

An essential part of the authority f s work will be

to promote improvements in treatment and disposal

facilities in order that stricter controls can be

effectively enforced. For this purpose it may be

given power to promote/or assist/in research and

development and in establishing pilot schemes.

It will advise and co-operate with the Department of

Agriculture and Fisheries in the administration of

the grants scheme for agricultural development in

so far as grants may relate to waste treatment or

disposal.

There is at present a limited control over

discharges to sewers, exercised by the Public Works

Department (see Appendix B, Paragraph 4.35).

As that Department is responsible for the sewers and

the treatment works, this is entirely justified.

We recommend that the authority controlling

discharges to inland waters should have the

responsibility for controlling discharges to coastal

waters also (see below 2.11). The Public Works

Department discharges the contents of its sewers

or the effluent from its treatment plans almost

entirely to coastal waters, and will be subject to

that control. It follows that the department should

also have control over all trade and agricultural

effluents to its sewers. It would be unreasonable

for the cost of receiving and treating discharges

from private industrial and agricultural enterprises

to be a charge on public funds. We therefore recommend

that for these discharges the department should have

power to impose a fee.


29- Environmental Resources Ltd

COASTAL WATERS

2.8 The Present Situation

Information on the contamination of coastal waters

by pollution is summarised in Appendix A, Section II.

About 85% of Hong Kong's total effluent load

(measured as BOD) is discharged direct into the

coastal waters. Of the total estimated load of about

335 tonnes per day, 65% arises from domestic sources,

20% from industry (about 80% from the textile industry)

15% from agricultural sources (most of which is

discharged initially into inland waterways).

Almost 80% of the total pollution is discharged into

the area around Kowloon and Hong Kong Island

(Sector A as illustrated on Map 2*2).

We have estimated the distribution and source of

toxic metal loads (Appendix A, Table 2.4(d)); of the

2 tonnes discharged each day, over 90% is discharged

in Sector A and over 90% is discharged by the textile

industry.

We have also estimated that about 30-50,000 kgs of

waste lubricating oil are discharged each day: some

is tipped but a high proportion probably finds its

way into sewers and from there into the sea*

The legal powers of control over discharges to, and

deposits into, coastal waters are outlined in Appendix

B paragraphs 4.37 and 4.44.

It will be seen that the Public Health and Services

Ordinance S6 prohibits the discharge of oil or

petroleum spirit into any public sewer or drain.

There is no equivalent provision however prohibiting

discharges to watercourses or nullahs. The Merchant

Shipping Ordinance S71(a) provides that an offence is

committed if oil is discharged or escapes from a

vessel or place on land "into the waters of Hong Kong" ,

but that term does not appear to apply to inland

watercourses.


30- Environmental Resources Ltd

Controls over the discharge of oil from vessels or

places on land into the waters of Hong Kong are now

similar to those in the United Kingdom Prevention of

Oil Pollution Act 1971, except that there are no

restrictions on the transfer of oil at night, as in

S10 of the United Kingdom Act. The Dangerous Goods

Ordinance gives close control over the storage of

petroleum, but not over other oils. Recommendations

have already been made, however, for statutory

requirements relating to oil from tank farms and

terminals and to enable the Director of Marine to

require specified precautions to be taken during

tankering. It has also been suggested that the

Governor in Council be asked to use his powers to

give the Director of Marine powers to control all

ship movements in Hong Kong waters, so as to reduce

the risk of pollution accidents.

2.9 The development of water quality objectives for

coastal waters

As for inland waterways, it would be prohibitively

expensive to treat all discharges to a standard

where they had little or no impact on the marine

environment.

We review below water quality objectives for the uses

to which the marine environment is put.

i. Swimming and other_water_contact_sports

The EEC has a proposed directive on water quality

standards for bathing (see Appendix A, 2-13). The

Commission has laid down mandatory values which must

not be exceeded and guideline values which represent

a target to be achieved where possible*

Regular analysis has been carried out at ten of the

Territories gazetted beaches on Hong Kong Island.

We nave compared aata from these analyses with the

Commission for the European Community standards.

The comparison showed that most of those beaches

exceed the guideline values laid down by the Commission

for total coliform bacteria present, for between

15% and 40% of the time (based on 1974 sampling).

However, none of the readings during the


31. Environmental Resources Ltd

period January 1971 to April 1975 exceeded the

mandatory values of 10,000 coliforms per 10O ml.

Althouah a few years' results must of course be

treated with caution the available information

gives no indication that the situation is deteriorating

in fact, during the last bathing season, all the

beaches, with the exception of Repulse Bay, showed

some improvement when compared with the previous

three years.

We have been told by the Urban Services Department

that:

there is no evidence that marine pollution

has been responsible for illness or disease

amongst the swimmers;

indications are that the bathers themselves

are responsible for the relatively high

levels of faecal bacteria.

We have seen no data on the state of the water at the

New Territories gazetted beaches.

ii.

Shell Fisheries

Shell fisheries at Deep Bay form the main commercial

oyster beds of the Territory. It has been reported

that the oysters become grossly contaminated with

faecal bacteria. (See Chilvers et al f Leung et al,

Morton et al, ref 155). During the winter months

the level of contamination is relatively low but,

commencing with the onset of the rains in the

summer months, it has been shown that there is

a considerable increase in the level of pollution.

Leung et al comment that much of this rise is

attributable to the arrival of long living faecal

bacteria, presumably from the Pearl River. The

evidence suggests that faecal bacteria of local origin

shows only a marginal increase. A strain of pathoqenic

salmonella has been isolated from the water.


Environmental Resources Ltd

There has been an apparent decline in the oyster

fisheries, but it has been suggested that factors

other than marine pollution may have been responsible.

There is some suspicion that oysters are gathered,

taken ±nto the Chinese People's Republic, to be then

imported into Hong Kong. Concern that the oysters

are pollution, however, may have contributed to a fall

in demand. Agriculture and Fisheries Department has

investigated the feasibility of moving the beds to

another bay.

Although no outbreak of disease directly attributable

to oysters has been reported amongst the consumers,

it will be recognised that in cases other than a

widespread epidemic, it might be difficult to identify

the cause of a food-borne disease during summer.

There was some suggestion that the increase in the

number of cases of hepatitis in early summer 1975,

the first year that hepatitis has been notifiable,

could possibly be connected with contaminated oysters.

iii. Coastal Fisheries

All but a small part of the marine fishing takes place

at some distance from Hong Kong f s shores* We have

been unable to derive a figure for the fish caught in

coastal waters.

The Government chemist has carried out some analysis

of levels of heavy metals and arsenic in fish caught

locally. The levels found were not far from those

levels that would be expected under normal unpolluted

conditions

It has been recognised that since the incidents that

occurred in Japan of serious disease from contaminated

fish, great caution needs to be exercised where fish

that have ingesting and accumulating pollutants

such as mercury are caught and consumed. We consider

that regular checks should be carried out on fish

caught in local waters both where these fish are

being consumed by the fisherman as well as being sold

through the recognised markets.


33. Environmental Resources Ltd

iv.

Marine Fish Farms

There is a concentration of fish farms in the Aberdeen,

Sai Kung, Shau Tau Kok and Shau Kei Wan districts.

We are aware of two incidents leading to heavy

mortalities in the fish cages: arising from the Ap Lei

Chau oil incident, and from what was believed to be

effluent from a film processing factory.

We have no evidence that marine pollution generally

interferes with the rearing of the fish or leads to

any hazard associated with their consumption.

v *

assimilate waste

There are two areas of the coastal waters which are

giving rise to concern: the area around Victoria

Harbour (Sector A) and Tolo Harbour (Sector C).

We note that long-term objectives for the state of

harbour waters have been developed by PWD Civil

Engineering office and Environment Branch (Ref 2) and

we would support the proposed guidelines. We understand

that at present the dissolved oxygen level

off the West coast of the Kowloon peninsula sometimes

falls well below the proposed minimum dissolved

oxygen level of 50% saturation. However, the North-

West Kowloon effluent scheme should alleviate the

situation.

There is so far insufficient evidence on whether or

not Tolo Harbour is in danger of becoming eutrophic:

we have discussed the existing data in Appendix A,

2.9. The situation must be kept under review:

further deterioration of Tolo Harbour would result

in a serious 3oss of amenity to both residents and

visitors to Hong Kong


Environmental Resources Ltd

2.1O The cost of improving the coastal waters

We ha\7e calculated the cost of treating discharges

where the pollution is discharged to the sea:

this includes discharges direct to the sea, from

discharges to sewers and from waterways,

where these flow down to the Hong Kong coast. It

should be noted that the Indus, which carries much

of the tannery effluent, flows into mainland China,

The basis for these cost estimates is the same as

for discharges to inland waterways and are set out

at the end of this section in Tables 2.12

All calculations refer to the existing situation.

We have calculated the cost of

removing all grease, oil and toxic

materials so as to minimise the potential

hazards associated with the contamination

of coastal fisheries and fish farms;

carrying out secondary treatment of all

effluents, in addition to the removal of

grease, oil and toxic materials so as to

effectively remove the impact of

pollution on the coastal waters.

Once again, we have not calculated the cost of the

removal of colouration from effluent or refuse frora

the sea.

We calculate that the annual cost to industry of

removing all grease, oil and toxic materials would be

about $100m: this includes the cost of the final

disposal of the toxic materials. In addition, the

cost of collecting and disposing of oil from garages,

workshops, etc. will be about $lxn. Table 2.12(j)

shows which sectors of industry would bear the cost

and Table 2.12(k) which shows the total costs

including domestic and other oil load.


35 • Environmental Resources Ltd

We have also calculated the cost of effectively

removing the impact of effluent on coastal waters:

this would require the removal of grease and oil,

toxic materials and the treatment of all effluent

discharges throughout the Territory to a secondary

standard (Table 2.12(1}). We estimate the capital

expenditure requried would amount to between

$375,000,000 and 420,000,000 (depending on whether

piq effluent was treated) and the additional annual

expenditure would amount to between $800 and $900

million per year (about $20O per person or 2.5% of

the GDP).

In Section C, Tolo Harbour, we estimate that effluent

treatment designed to minimise the risk of

eutrophication (secondary treatment and nutrient

removal) would require a capital expenditure of

HK$120 million and an annual expenditure of HK$25

million for the population expected to be present

in 1984 (exclusive of the cost of Sha Tin sewage

works which should be added)*

2.11 Recommendations for coastal waters

While there is no evidence that discharges into the

marine environment are interfering with its use by

the community, the heavily concentrated pollution

loads around Victoria Harbour, the discharge of toxic

metals and oil are all causes for concern and should

be kept under review.

We recommend that the Authorities should take the

following into account when developing their programme

for environmental protection.

i. Beaches

There is at present no evidence that would suggest

that action should be taken to reduce marine pollution

because of the danger to swimmers 1 health; however,

contaminated waters do have the potential of spreading

diseases such as hepatitis, and we certainly believe

that regular monitoring should continue and that all

ga-zetted beaches should be included in the monitoring

programmes.


Environmental Resources Ltd

We suggest that the monitoring programme is devised

so as to attempt to record background levels of

contamination as well as levels caused by the

presence of swimmers. We recommend the introduction

of guidelines covering the levels of contamination

in bathing water. These would act as an early

warning system for taking action either to close

the beach, or control or move the source of pollution,

The levels established as guidelines should be set

after discussions with the relevant Government

Departments.

ii.

Shell fisheries

At present there is no clear evidence that pollution

arising from the Northern New Territories is a

major factor in the contamination of the oysters.

What evidence there is suggests the serious

contamination arises from the contamination from

Pearl River. There is no doubt, however, that the

discharges from Yuen Long and the surrounding area

contribute to a considerable quantity of faecal

bacteria from domestic and agricultural sources.

As the town of Yuen Long develops, the quantity of

contaminants is likely to increase.

We recommend further investigation into the source

of oyster contamination. Meanwhile, precautionary

measures seem justified. Such precautionary measures

are at present under consideration by the Government;

we would therefore prefer to delay making any

recommendations.

We recommend regular monitoring for pathogenic

organisms.

iii. Coastal fisheries

We understand that the University is at present

monitoring levels of heavy metals on the West Coast

in the Tsuen Wan/Tsing Yi area.


37* Environmental Resources Ltd

We recommend that this should if possible be

undertaken as a regular exercise.

We recommend that steps are taken to encourage

local industry to reduce their discharges of oil

and toxic materials.


38 * Environmental Resources Ltd

PROPOSALS FOR LEGAL CONTROLS

Much of the pollution- of coastal waters derives from

pollutants discharged into watercourses inland. To

that extent the pollution of the coastal seas and of

inland waters constitutes a single problem. Any

revision of powers to control discharges to inland

waters must, therefore, have regard to the probable

effects of discharges on coastal waters, and take

into account pollution from other sources and the

existing state of those waters. It would be a

difficult task to determine and achieve quality

objectives unless both areas were under the jurisdiction

of a single authority* The same applies to

discharges to sea by Public Works Department pipelines

At present they are qnder the sole control of that

Department. It would be logical to make a single

authority responsible for controlling all those

discharges. We recommend that its control over

discharges should apply to coastal as well as to

inland waters.

Recommendations as to the monitoring of coastal waters

have already been made above. Clearly the same

authority should be responsible.

ii.

We are informed that, apart from nightsoil and the

screenings from sewage outfalls, very little is

dumped at sea. Control within territorial waters is

exercised by the Director of Marine, and at present

there seems no need for any change.

There are no controls over the discharge of waste to

the sea beyond Hong Kong waters, but we have already

submitted advice on that matter f and the question is

soon to be brought before the Executive Council for

cons ideration.


39- Environmental Resources Ltd

If more advanced industries are established in

Hong Kong, and if controls over discharges into other

parts of the environment are so tightened that firms

seek to dispose of wastes at sea, the present law

governing sea dumping could become inadequate.

Controls would then have to be exercised over dumpings

both within and beyond territorial waters. Further

consideration will be given to this in Stage II.

iii. Oil at sea

Legislation relating to the pollution of the sea by

oil has been revised in recent years, and we understand

that steps have been taken to have the operation of

the United Kingdom Merchant Shipping (Oil Pollution)

Act 1971 and the Merchant Shipping Act 1974 extended

to Hong Kong. None of the recommendations we have to

make involve changes in methods of control or new and

substantial expenditure. They are therefore not

dealt with in this Stage 1 Report.

One proposal has been made, however, on which we would

like to comment now. It has been proposed that when

an oil spill occurs and a charge is to be brought

against the owner or master of a vessel, the master

should be required to appear before the court in

person. This, it is hoped, would prevent the vessel

from leaving the jurisdiction before the case has

been heard and the penalty enforced. We are informed

that most ships' crews have men who can take the

vessel to sea, and considering the cost involved in

delay, this would be done. We suggest that a better

method would be to grant a power to prevent the

sailing of the ship until a bond had been given by

the owner, if necessary equal to the maximum fine

which might be imposed.

The reports of the Sub-Committee on Oil Pollution (SCOOP

Reports) have given a thorough review of the present

powers and facilities for dealing with oil pollution,

and their shortcomings. These reports we have found

most helpful, and have nothing further to add in

this section of our report.


40. Environmental Resources Ltd

The control of pollution by oil from ships, tank farms

and other related shore-based installations lies with

the Director of Marine* Although we have recommended

the establishment of a single authority to have

responsibility for the control of most forms of

pollution, we feel that responsibility for controlling

the forms of oil pollution which we have referred to

is more appropriately left where it now lies. Further

consideration will be given to this in Stage II.

2,12

In the Tables included on the following pages we set

out our calculations on the cost of meeting the water

quality objectives discussed in the preceeding

paragraphs»


TABLE

2.12{a)

APPROXIMATE COSTS OF TREATING AND DISPOSING OF AGRICULTURAL WASTES

(INCLUDING SLUDGE DISPOSAL)

Pollution Control Stage

Action Required

Capital Cost Annual Cost

HK$OOO

HK$OOO

Cost per 1OOO Pigs

Comments

A. PIG WASTES

For Stage I and II

Remove solids and

dispose of by

landfill, compost

or to land.

3O.O 25.0 Assumes 1,100 tonnes of solids per

year collected from collection

point. Capital cost for collection

arrangements. Operations cost does

not allow for large proportion to

be composted.

For Staqe III

Secondary Treatment 1,5OO.O 300.0 Secondary treatment of pig effluent

would not achieve a good standard

of effluent.

For Stage IV

As for I and II

plus chlorination.

8O.O 12O,O Cost of chemicals for chlorination

is high.

B, POULTRY WASTES

Cost per

1OOO Poultry

For Stage I and II

Remove solids and

dispose of by

landfill or to land.

0.5 2.0 Assumes about 7O tonnes per year

and no extra capital costs.

HONG KONG - CONTROL OF THE ENVIRONMENT Environmental Resources Ltd


TABLE 2.12(b)

APPROXIMATE COSTS OF TREATING AND DISPOSING OF DOMESTIC SEWAGE (INCLUDING SLUDGE DISPOSAL)

PER THOUSAND OF POPULATION (ON A BASIS OF EQUIVALENT LOAD)

Pollution Control Stage

Action Required

Capital Cost Annual Cost

HK$OOO

HK$OOO

Cost per OOO Population

Comments

FOR SEWERED AREAS

For Stage I and II

Screening of

solids*

8O.O 20.0

For Stage III (a)

Secondary treatment

500.0

100.0

(b)

Nutrient removal.

525.0

105.0 For removal of N and P

For Stage IV

As for I and II

and chlorination*

1OO.O 50.0 High chemical costs for

chlorination.

FOR UNSEWERED ARFAS

All stages Septic tanks 5OO.O 100.0

HONG KONG - CONTROL OF THE ENVIRONMENT Environmental Resources Ltd


TABLE

2.12(c)

APPROXIMATE COSTS OF TREATING A.ND DISPOSING OF INDUSTRIAL EFFLUENTS

'

Stage I

Stage I & II or IV

Stage III

Manufacturing Establishment

Screen solids and oily

wastes

Cost per establishment

As for I and removal of

toxic constituents

Cost per establishment

As for II and secondary

effluent treatment

Cost per establishment

Capital

HK$OOO

Annual

HK$000

Capital

HK$OOO

Annual

HK$000

Capital

HK$000

Annual

HK$OOO

Food companies

2OO.OO

5O.O

2OO.O

5O.O

Drink companies

Textile companies

Tanning

Paper

20. 0

2OO.O

-

20.0

5.0

5O.O

-

5.0

20.0

4OO.O

2OO*O

20,0

5,0

100.0

50.0

5.0

20.0

per Kg/

day BOD

plus

I, II

4.0

per Kg/

day BOD

plus

I, II

Chemicals

15O.O

4O.O

300,0

80.0

Electroplating

2OO.O

50.0

HONG KONG - CONTROL OF THE ENVIRONMENT

Environmental Resources Ltd


TABLE

2.12(d)

SUMMARY OF ESTIMATED COSTS FOR ACHIEVING IMPROVEMENTS TO INLAND WATERWAYS

Target

COSTS BY SOURCE IN HK$OOO

Per OOO Pigs Per OOO Poultry Per OOO People

Capital Annual Capital Annual Capital Annual

Capital

Industry

Annual

For Stage I

Suitable for fish farming

irrigation and improved

amenity.

3O.O

25.0

-

2.0

80.0

20.0

See Table

For Stage III

Suitable for water

treatment: improvement

in aquatic life.

1,500.0

3OO.O

-

2.0

5OO.O

1OO.O

2O. O per 4.O per

Kg/day Kg/day

plus plus

Stage Stage

I, 11 I, II

For Stage IV

Suitable for swimming.

80.0

120,0

-

2.0

100. 0

50.0

See Table

HONG KONG - CONTROL OF THE ENVIRONMENT

Environmental Resources Ltd


TABLE 2.12 (e)

POLLUTION CONTROL MEASURES REQUIRED TO ACHIEVE IMPROVEMENTS IN INLAND WATERWAYS

Target for use of

Waterway

POLLUTION CONTROL MEASURES FOR EFFLUENT FROM MAJOR SOURCES

Domestic Sources

Agricultural Sources

Pxgs I Poultry

Industrial Sources

Comments

Waterways as an

amenity: visually

and otherwise

attractive.

Remove solids by

screening.

Prevent dumping of

refuse in waterway.

Prevent dumping of

oily wastes.

Remove solids F dry

and transport for

central processing.

Screen out solids,

Prevent dumping of

oily wastes.

While steam would be

apparently less

offensive/ it would

still be a hazard to

health.

II

Waterway for use

for controlled

irrigation and

fish farming.

As above As above As above and removal

of selected toxic

constituents.

This is a minimum

requirement„ Crops

should not be used

for perhaps 2 weeks

after watering

because of damage

from pathogens.

U1

III Waterways suitable

for water catchment

and improvement in

aquatic life.

As above.

Se condary treatment

of liquid effluents

or use of septic

tanks in unsewered

areas.

Secondary

treatment

As I

above.

As above.

Secondary treatment of

industrial effluents.

Treatment of pig

liquid effluent to

the necessary

quality might prove

impractical.

/contd...

HONG KONG - CONTROL OF THK ENVIRONMENT

Environmental Resources Ltd


TABLE

2.12{e) - continued

POLLUTION CONTROL MEASURES REQUIRED TO ACHIEVE IMPROVEMENTS IN

INLAND WATERWAYS

POLLUTION CONTROL MEASURES FOR EFFLUENT FROM MAJOR SOURCES

Target for use of

Waterways

Domestic Sources

Agricultural Sources

Pigs Poultry

Industrial Sources

Comments

IV

Waterways suitable

for swimming etc.

As (I) plus

chlorination of

effluent

As (I) plus

chlorination of

effluent

As (II)

V

Waterways capable

of supporting

varied natural

life.

Treatment of all effluents to a 1O:1O standard lagooning and

chlorination of effluents containing pathogens.

HONG KONG - CONTROL OF THE ENVIRONMENT Environmental Resources Ltd


TABLE 2.12(f)

ESTIMATED CAPITAL AND ANNUAL EXPENDITURE REQUIRED TO ACHIEVE STAGE I AND II WATER QUALITY FOR

INLAND WATERWAYS (i) - HK$ ! OOO

»

Source

Cap

A

Ann

Cap

B

Ann

Cap

C

Ann

Cap

D

Ann

Cap

E

Ann

F

Cap

Ann

Total

Cap

Ann

% of

Annual

cost borne

by

polluters

Pigs

-

2062

1719

346

289

5186

4322

1430

1192

516

430

9540

7952

24.9

Poultry

554

2214

85

341

1097

4389

305

1220

54

217

2095

8381

26.3

Domestic (ii)

Industrial

-

12820

1^560

2580

3675

4828

7OO

966

180

14035

24OO

2807

610

9207

1500

1841

380

7838

3700

1568

950

48728

22860

9762

5795

30.6

18.2

Total

-

-

29996

10188

5960

1775

22718

12128

12442

4633

12108

3164

83223

3189O

1OO.O

% of cost by

water sector

«.

-

36.0

32.0

7.2

5.6

27.3

38.0

15.0

14.5

14.5

9.9

100.0

100.0

Notes: (i) Suitable for amenity purposes , fish farming and irrigation: removal of solids and other

objectionable or toxic constituents.

(ii) Assumes nightsoil is still collected and dumped at sea or deposited on land equivalent to 1974

population of 268,000. A considerable amount of domestic sullage is also disposed of on land.

Therefore population in terms of treatment and disposal cost is considerably less than 4,17O,OOO.

HONG KONG - CONTROi, OF THE ENVIRONMENT

Environmental Resources Ltd


TABLE

2.12{g)

ESTIMATED CAPITAL AND ANNUAL EXPENDITURE REQUIRED TO ACHIEVE STAGE III WATER QUALITY FOR

INLAND WATERWAYS (i) - HK$ f OOO

Source

Cap

A

Ann

Cap

B

Ann

Cap

C

Ann

Cap

D

Ann

Cap

E

Ann

Cap

F

Ann

Cap

Total

Ann

% of

Annual

cost borne

by

polluters

Pigs

Poultry

Domestic (ii)

Industrial

~

-

-

-

-

-

-

-

103115

554

14575

39460

20623

2214

2914

8655

17310

85

4828

1OOO

3462

341

966

236

259298

1097

14035

6160

t

51860

4389

2807

1362

71520

305

9207

4660

14304

1220

1841

1012

25773

54

7838

4940

5155

217

1568

1198

477016

2095

50483

56220

95404

8381

10096

12463

75.5

6.6

8.0

9.9

Total

-

-

157704

34406

23223

5005

280590

60418

85692

18377

38605

8137

585814

126344

100.0

% of cost by

water sector

27.1

4. O

47.8

14.6

6.5

1OO.O

Notes: (i) Water could be classed as relatively clean and suitable for catchment purpose* Removal of

solids, grease and oil, toxic materials and treatment of all discharges to a high standard.

(ii) Assume nightsoil is still collected and dumped at sea or deposited on land equivalent to 1974

population of 268, OOO. A considerable amount of domestic sullage is also disposed of on land.

Therefore population in terms of treatment and disposal cost is considerably less than 4,170,000.

HONG KONG - CONTROL OF THE ENVIRONMENT

Environmental Resources Ltd


TABLE

2.12(h)

ESTIMATED CAPITAL AND ANNUAL EXPENDITURE REQUIRED TO ACHIEVE STAGE IV WATER QUALITY FOR

INLAND WATERWAYS (i) - HK$'OOO

*

A

B

C

D

E

F

Total

Cap

Ann

Cap

Ann

Cap

Ann

Cap

Ann

Cap

Ann

Cap

Ann

Cap

Ann

Pigs

Poultry

Domestic (ii)

Industrial

-

-

-

~ _

-

5499

554

12903

14560

8249

2214

2705

3675

923

85

4828

700

1385

341

966

180

13829

1097

14035

2400

20744

4389

2807

610

3814

305

9207

1500

5722

305

9207

1500

1375

54

7838

37OO

2062

54

7838

950

25440

2095

49484

22860

38162

8381

10143

5795

>£*

UD

*

Total

-

.

34189

17099

6536

2871

31361

28550

14826

9163

12967

4797

99879

62481

Notes: (i) Suitable for swimming. Removal of solids, grease and oil, toxic constituents and chlorination of

agricultural and domestic waters.

(ii) Assumes nightsoil is still collected and dumped at sea or deposited on land equivalent to 1974

population of 268, OOO. A considerable amount of domestic sullage is also disposed of on land.

Therefore population in terms of treatment and disposal cost is considerably less than 4,170,000.

HONG KONG - CONTROL OF THE ENVIRONMENT

Environmental Resources Ltd


50.

TABLE 2.12(j)

BREAKDOWN OF ANNUAL COSTS OF REMOVING GREASE, OIL AND

TOXIC METALS FROM INDUSTRIAL EFFLUENTS

Annual Cost

Million HK$

Food and Drink

19.9

19

Textiles

44. 3

43

Tanning

1.1

1

Paper

0.1

O(-f)

Chemicals

21.6

21

Electroplating

16.9

16

Total 103.9 100

Environmental Resources Ltd


TABLE 2.12(k)

ESTIMATED CAPITAL AND ANNUAL EXPENDITURE REQUIRED TO REMOVE GREASE, OIL AND TOXIC

CONSTITUENTS FROM MARINE ENVIRONMENT (iii) - HK$'OOO

*

Source

Cap

A

Ann

Cap

B(i)

Ann

Cap

C

Ann

Cap

D

Ann

Cap

E

Ann

Cap

F

Ann

Cap

Total

Ann

Pigs

«

-

-

-

-

-

-

-

-

-

_

-

~

-

Poultry

-

-

.

-

-

-

-

-

-

-

-

-.

-

-

Domestic

4485

897

50

10

65

13

50

10

50

10

300

60

5000

1OOO

Industrial

343100

86815

9460

2395

6120

1555

15280

3880

9920

2505

26340

6760

410220

103910

Total

347585

87712

9510

2405

6185

1568

15330

3890

9970

2515

2664O

6820

415220

104910

Notes: (i) Sewered discharges from Shek Wu Hui in Sector B are excluded as these enter the Indus system and

are carried into China,

(ii) Assumes nightsoil is still collected and dumped at sea or deposited on land equivalent to 1974

population of 268/OOO. A considerable amount of domestic sullage is also disposed of on land.

Therefore population in terms of treatment and disposal cost is considerably less than 4,170,000,

(111) Removal of these contaminants from marine and inland waterway discharges.

HONG KONG - CONTROL OF THE ENVIRONMENT

Environmental Resources Ltd


TABLE 2.12(1)

ESTIMATED CAPITAL AND ANNUAL EXPENDITURE REQUIRED TO REMOVE ALL OIL AND TOXICS FROM MARINE

ENVIRONMENT (iii-) AND PERFORM SECONDARY TREATMENT OF ALL MARINE AND INLAND WATERWAY OUTFALLS

HK$ 'OOO

A

B (i)

C

D

E

F

Total

Cap

Ann

Cap

Ann

Cap

Ann

Cap

Ann

Cap

Ann

Cap

Ann

Cap

Ann

Pigs

38676

7735

103115

20623

17310

3462

259298

51860

71520

14304

25773

5155

515692

103139

Poultry

45

182

554

2214

85

341

1097

4389

305

1220

54

217

2140

8563

Domestic (ii)

Additional Cost(iv)

Industrial

1744957

-

1566940

348991

-

331583

18141

-

15100

3627

-

3055

25701

1047

24100

5141

208

5147

21323

-

49840

4265

~

10792

18232

-

40100

3646

-

8541

115846

-

62320

23170

-

12484

1944200

1945247

1758400

388840

389048

371602

Cn

Total

3350618

688491

136910

29519

67196

14091

331558

71306

130157

27711

203993

41026

4220432

872144

Alternative

Total (iv)

68243

14299

4221479

872352

Notes:

(i) Sewered discharges from Shek Wu Hui in Sector B are excluded as these enter the Indus system and are

carried into China.

(ii) Assumes nightsoil is still collected and dumped at sea or deposited on land equivalent to 1974

population of 268, OOO, A considerable amount of domestic sullage is also disposed of on land.

Therefore population in terms of treatment and disposal cost is considerably less than 4,170,000.

(iii) Removal of these contaminants from marine and inland waterv/ay discharges.

(iv) Including additional cost of nutrient removal in Sector C - Tolo Harbour.

Environmental Resources Ltd


Environmental Resources Ltd

SECTION III

NOISE POLLUTION AND ITS CONTROL


54 - Emironmenta! Resources Ltd

III

NOISE POLLUTION AND ITS CONTROL

3*1 It is unlikely that the noise levels experienced in

the external Hong Kong urban environment will have

a physical impact on the health of the general

population; that is, that members of the community

will suffer from deafness earlier than would occur

naturallv.

But noise in Hong Kong must be recognised as a

severe nuisance to the community. Continuous high

noise levels and intermittent noise interferes in

some areas with everyday activities, with work/

including schooling, and with sleep. Experience in

other countries suggests that the general level of

noise is unacceptably high (see Appendix A, Section V)

The approach adopted by the majority of the

protection authorities in Europe and North America

is to ensure that noise does not interfere with the

use to which the environment is put. This means that

high noise levels in busy urban areas during the day

may be acceptable; but they must be reduced to a low

level in residential areas at night if that end is

to be achieved.

In this Section we outline:

the sources of noise, the opportunities to

reduce the noise, and methods for protecting

the individual from noJse;

a suggested noise control programme for the

territory.

We discuss the control measures before the question

of objectives because to some extent the limited

options available for reducing the general noise

levels will dictate the overall approach.


5 5 - Environmental Resources Ltd

Two points should be noted at the outset:

we are concerned solely with the noise in

the external environment and not with the

place of work from which noise

emanates;

we are in this Section primarily concerned

with the development of a general strategy

for noise control rather than with

commenting on individual noise problems.


Environmental Resources Ltd

3.2 Noise from stationary sources; noise sources

and present controls

Information from the Industrial Health Division of

the Labour Department (ref 19) suggests that about

15 complaints are made each month about industrial

noise. "The problem is exacerbated because of the

proximity of industrial to domestic premises. About

70% of manufacturing establishments, albeit the

smaller firms, are sited in domestic premises. ,

It will be seen from Appendix B that there are no legal

provisions for the control of industrial noise,

except that provisional registration of a factory

may be withheld on grounds of noise nuisance.

ii.

Construction_noise

In the crowded conditions of the urban areas, and

with so much civil engineering and construction

work being undertaken, noise from construction sites

is more of a nuisance than in most countries. Under

the Summary Offences Ordinance S13, it is an offence

to use a pile driver between the hours of 8:00 p.m.

and 6:00 a.m. or on any public holiday; and it has

been proposed that this prohibition be extended to

other types of construction equipment• Although

the implementation of this proposal will doubtless

bring relief to many people, so many factors are

involved: economic, technical, and the circumstances

in which the work is being done, we doubt that this

simple extension of the present provision would^

produce controls whica are both fair and effective.

Quieter equipment is now becoming available, and

construction noise can be reduced by its use. We

understand, however, that baffles on existing /-

modern equipment are often removed to facilitate

their operation and maintenance.

e '


5 7. Environmental Resources Ltd

We note also that there are terms in public works

contracts to restrict noise from construction

equipment (see Appendix A, paragraph 5.6), but

understand that strict observance of these terms

is rare.

iii„

Other noise nuisances reported to EPCOM (ref 329)

include:

loudspeakers on the Kowloon motor bus;

shouting by bus conductors;

record shops and street hawkers;

Kung Fu and Dragon Dance practices;

drama rehearsals at night;

playground noise;

dogs, monkeys and frogs;

water pumps;

the much publicized Jardine gunfire;

air conditioning noise.

In many instances these can be dealt with under the

Summary Offences Ordinance. Although proceedings

can be instituted by any complainant (ap 228 S33),

enforcement in practice depends on public authorities,

Complaints can always be made by the individual to

the relevant authority/ and the proposed publication

of referral points for pollution complaints may help

in this respect. The sources of noise nuisances are,

however, so diverse, and many of the problems so

different in character, that we do not feel that it

is possible to deal with them all satisfactorily in

one simple summary offences provision.


58. Environmental Resources Ltd

3.3 Recommendations for control of noise

from stationary sources

Industrial noise

We recommend that with the introduction of land-use

planning controls, noise standards be adopted by the

planning authorities as guidelines to be used in the

exercise of other controls.

A recommendation has been made in paragraph 6.4ii

to prevent new factories being established in

existing domestic premises.

We would further recommend:

that no manufacturing industry employing

a noisy plant should be permitted to

operate in residential areas;

that consideration should be given to

changing the noise monitoring methods

employed: where complaints are made

about the nuisance in the house, then

readings should be taken inside the

complainant 1 s house and not at the

window of the factory as is currently

the practice; the relevant factor so

far as environmental protection is

concerned is that the individual should

not be unreasonably disturbed,

ii *

Construction_noise

There is no reason why a system of type approvals

should not be applied to construction equipment as

it is to motor vehicles. We have noted that quieter

equipment is becoming available. Under it the

approval of the control authority would be needed

for the manufacture, import or use of any particular

type of civil engineering construction equipment.

Refusal to approve would be subject to right of appeal,


59 • Environmental Resources Ltd

The present ban on the use at night of pile drivers,

soon to be extended to other types of equipment,

has undoubtedly proved a useful^piece of legislation,

but with the establishment of a pollution control

authority which will have, and will develop, expertise

in noise measurement and control, we feel that this

could be replaced by controls which would be more

extensive and more flexible.

We therefore recommend that once the authority is

established, all outdoor construction work shall

require its prior consent, and that the consent

can be given subject to such conditions as the

authority thinks fit relating to levels of noise

emitted, type of equipment used, use of screens and

mufflers, and times at which specified kinds of work

can be carried on. In this case we recommend that

provision be made for appeal by the applicant against

refusal of consent or stringency of conditions, and

by any person with a residence or place of work where

noise is likely to have an effect against the grant

of consent, or against the conditions or lack of

conditions.

from_other_stationarY_sources

To deal with many different noises which may be

classed together as "neighbourhood noise, 11 we

recommend that a new form of summary proceedings be

provided. These would give designated public officers

the power to serve abatement notices, specifying

the steps to be taken to abate the noise nuisance

in questiono The recipient of the notice would have

a right of appeal to a summary court, the court

would have power to punish a person who unlawfully

failed to comply with a notice. There would be an

alternative procedure under which a person aggrieved

by a noise nuisance could himself apply to a summary

court for an abatement order.

Whether or not a special defence of "best practicable

means" should be made available to anyone creating

a noise nuisance in the course of a trade or business,

is a policy decision, on which we therefore make no

recommendations at this stage.


60 • Enviroamentai Resources Ltd

Most of the noises in question can be reduced by

a combination of good management and concern for

neighbours; therefore compliance with abatement

notices will in most cases present no difficulties,

Air conditioning noise, however/ presents a more

difficult, and not infrequent, problem. Apart

from construction work, more complaints have been

received by EPCOM (See Appendix A, Table 5.1(c)

about this source of noise than any other. We

therefore feel that it warrants some special

statutory provision.

We recommend that a type approval scheme be

introduced for all new air conditioning equipment,

coupled with powers governing installation.

This would mean that all new plants would be

capable of operating within acceptable limits and

would be installed so as to do so. For existing

plants, the new summary proceedings outlined above

could be used where the plants would be quietened

without undue cost or loss of efficiency. It

would provide a flexible instrument with adequate

safeguards for the owner.


62. Environmental Resources Ltd

NOISE FROM MOBILE SOURCES

;.4 Motor vehicles - noise emissions and present

controls

Available data on Road Traffic Noise (see Appendix A,

£4) in Hong Kong suggest that the noise nuisance

from this source is considerably in excess of the

nuisance in, for example, London and that high

noise levels from this source continue through the

day up until midnight. An LSQ level of 76 dBA and

a maximum level of 82.5 dBA has been reported: this

is about 5 dBA higher than for London (or half as

loud again)* There are a number of reasons:

the roads are congested: at five of the

monitoring stations where traffic movement

is recorded by PWD, the flow at 8:00 a.m.,

noon and about 5:30 p.m. is in the region

of 5,000 to 6,000 vehicles per

the vehicles are, because of the congestion

and the hilly terrain slow moving and, in

lower gears, the noise is greater; (it has

been suggested to us that the average

speed of vehicles is 7 m.p.h.);

some vehicles are poorly maintained and

ineffective silencers exacerbate the

situation;

some motor cycles are noisy, and their

silencers may have been replaced by less

effective ones.

The control of traffic noise is thought to be

effected principally by regulations relating to

the fitting and maintenance of silencers which are

"sufficient for reducing as far as may be

reasonable" the noise caused by the escape of

exhaust gases, and by prohibiting the use of a

vehicle on the road "in such a manner as to cause

any excessive noise. 11 Road Traffic (Construction

and Use) Regulations 26, 102 and 1O7 C There are,

of course, other regulations relating to noise


6 3 « Environmental Resources Ltd

viz 86, 108 and the Road Traffic (Road Signs)

Regulation 18, but with the exception of the last

named, these deal with special problems rather than

with general traffic noise. Some attempts have

been made to reduce noise by traffic regulation.

Nothing has been attempted by way of type approvals

for vehicles, and no powers of land-use planning

control have yet been available for the purpose.


6 4 * Environmental Resources Lid

Motor vehicles - methods of control

and recommendations

Control of noise at source

There are in principle two types of solution for

reducing the noise in the enviornment caused by

vehicles:

ensuring that the individual cars make

less noise;

prohibiting the use of cars in certain

places at certain times

Type-approved silencers and vehicle inspections

can assist in reducing the noise produced by individual

vehicles; but in the latter case it is recognised in

Hong Kong and other countries that enforcement is

both difficult and manpower intensive.

One fundamental change that could be made would be

to encourage the use of vehicles that are not

powered by combustion engines. These are not only

quieter but also cleaner. Existing models of

electric cars are/ we understand, able to achieve

distances and inclines compatible with use in

Hong Kong. But they are more expensive to run and

there would be an increase in air emissions from

electricity generating plants.

The most effective way of minimising traffic noise

and fumes is by control of traffic itself. Schemes

which have been employed to reduce traffic include;

improving the traffic flow;

outright prohibition of certain vehicles,

e.g. private cars, using certain

thoroughfares at certain times;


65 * Environmental Resources Lid

increasing the cost of parking in

commercial areas to reduce the numbers

commuting to work;

provision of priority traffic routes

for commercial and public transport

and reduction of traffic lanes for

private cars.

In recent years, action has been taken to improve

flow and at present there are consultants considering

transport problems in Hong Kong 0 We have been

informed, however, that environmental impact was

not a major factor that these consultants were asked

to consider. We feel that that was an unfortunate

omission.

ii

As for aircraft noise (see 3.7), effective noise insulation

of buildings can assist the occupant to work and

relax undisturbed by traffic. Such insulation could

not reasonably be installed without proper air

conditioning.

iii. Conclusions

Our conclusions in respect of traffic noise are as

follows:

that the nuisance caused by noise from

individual vehicles can be dealt with

by type approval schemes and by inspection;

that high noise levels in the urban

areas arise from the number of vehicles

that are used and only fundamental

measures will bring about a reduction;


6 6 * Environmental Resources Ltd

consideration should be given to the

use of electric vehicles, but it is

our view that these will prove to

be unreasonably expensive owing to

their inefficient use of energy;

but that any overall improvement in

traffic noise must stem from a traffic

policy designed with noise reduction

as a major criterion.

In Hong Kong, as elsewhere, the ownership of a

vehicle provides not only considerable personal

convenience, but also for some it represents a

symbol of achievement. Elsewhere, attempts to

curb its use have met with vigorous opposition.

It is clear that in Hong Kong vehicles contribute

considerably to the deterioration of environmental

quality: further, the relatively limited area

should assist in the development of a mass

transport policy. But the people may consider

the curbing of their rights to use their own

vehicles to be too high a price to pay for noise

and fumes.

Recommendations

We would therefore recommend:

a type approval scheme to cover all

classes of motor vehicles and all the

relevant component parts; for obvious

reasons the standards required must be

based on those in the major markets;

in areas of new development, careful

land-use planning can, to some extent,

prevent the growth of noise nuisance

from traffic on the roads; standards

should be adopted as guidelines to be

used when planning roads and adjacent

developments;


67. Environmental Resources Ltd

if further studies of traffic flows show

that curbing of traffic in urban areas is

feasible in Hong Kong, powers should be

granted to the relevant authorities to

regulate traffic for the purpose of

environmental improvement.


6 8. Environmental Resources Ltd

3.6 Aircraft - noise emissions and present controls

Consultants retained to advise on a new airport

(Ref 37) showed that large portions of the North-

East corner of Hong Kong Island and of North

Kowloon are severely affected by aircraft noise;

and that as aircraft operations increase, so will

the disturbance.

We have estimated in Append X, Section V, that

616 schools with almost 420 f 000 registered pupils

(that is about 34% of the total Territories pupils

at September 1974) are within the NNI.42 contour.

Seventy-six of the schools are recorded as being

on roof-tops or on the top floor. In the UK, it

is recommended that schools should be situated in

areas where the NNI does not exceed 35.

It is possible that about a million people are

affected by noise levels that are intrusive in

ordinary housing (NNI 35); again, the degree of

interference is expected to increase.

Controls over aircraft noise are limited by the

special circumstances of the Kai Tak Airport.

There is a prohibition on aircraft movement

between midnight and 6.30 a.m. except for

aircraft diverted to Hong Kong and delayed

passenger flights. Operators have also agreed

that there shall be no engines running for

maintenance purposes at more than ground idling

speed between midnight and 7.00 a.m.


Environmental Resources Ltd

3*7 Aircraft - methods of control and recommendations

The methods of controlling noise from aircraft include;

moving the airport to a location where the

flight paths would affect fewer residential

areas; we understand that a new airport

could not be operational before the late

1980's at the earliest;

altering the operation of the airport to

reduce night flights and flights over

sensitive areas and operate engine cutback

procedures to reduce take-off

noise; we understand that the Civil

Aviation Department believes that all

possible action has been taken;

discouraging noisier planes by outright

prohibition or by a scale of landing fees.

Our attention has been drawn to the importance of the

airport to Hong Kong's economic activity. It has

been suggested that action- that would affect the

operation and costs of aircraft could lead to

fewer flights into the airport with a consequent

impact on local business and tourism.

On this we can make no judgement.

comment as follows:

We would, however,

there is an increase in the proportion of

quieter new aircraft and that there are

f hush kits 1 available for older aircraft:

the latter may add as much as HK$11 million

to the cost of an aircraft.


70 * Environmental Resources Ltd

an investigation should be carried out

to establish whether noisier aircraft,

i.e. those aircraft which noticeably

exceed the average noise level, represent

an increased nuisance as compared with

the average;

if this is the case f there could be a

case for introducing higher landing fees

for these aircraft.

Thus decisions need to be taken in the context of:

the additional nuisance caused by such

aircraft;

the absence of other methods of reducing

noise from aircraft in the short-term;

the available methods of protecting the

recipient from noise (see below) and their

cost;

whether by dissuading the noisier aircraft

from visiting Hong Kong (which would be

the purpose of higher landing fees) there

would be any damage done to the economy.

Measures to protect the recipient from aircraft

noise include:

moving the residential areas f schools and

hospitals away from the flight paths: while

future planning must restrict the siting of

new sensitive recipients under the flight path,

the scope for large scale resiting must be

seen as limited;

insulating the buildings to reduce the internal

noise*


Environmental Resources Ltd

If schools, hospitals and domestic dwellings lying

within the 42 NNI contour are to be provided with a

reasonable internal environment of a noise level

acceptable for the health, work and relaxation of

the occupants, then the only satisfactory solution

would appear to be a combination of the above.

Noise insulation can be carried out by:

- double glazing and air conditioning;

or, more satisfactorily, at the consrruction

stage, by increasing the mass of the

building , use of fabrics designed to

minimise noise, an_d reduction in the size of

the windows and other design features:

this will considerably increase the initial

cost of the building (by about double),

but will save on running costs.

We estimate the capital cost of noise insulation by

double glazing and air conditioning to be in the

region of $50 per square metre of living space. For

an average residential block with 3.5 sq. iru of

living area per person (excluding kitchen, w.c., etc.),

the cost would be about $200 to $300 per head

assuming the air conditioning unit was centralised.

The additional annual running costs would be about

$70 per person. Noise insulation would probably

add between 20% and 50% to the existing cost of

housing each person.

The cost of insulating a school for noise should be

less expensive since space utilisation is much

higher. If, taking account of the two shift system,

the average pupil density is one per square metre,

the added capital cost would be about $50 per pupil

and the running cost about $2O per year.


Environmental Resources Ltd

iii. Ai£S£g|;b_-_cgnclusions and-^commendations

It is accepted that noise nuisance from aircraft

cannot, be eliminated without the removal of the

airport to a new location. Noise emissions will be

reduced as quieter aircraft come into use, and

although Hong Kong cannot influence aircraft

development, it may be possible to discourage the

use of noisy aircraft for journeys to the territory

by differential airport charges.

Another approach to the problem of aircraft noise

is to control the use of land in the affected areas

so as to keep poise sensitive developments away.

(In an unreported United Kingdom case in 1965,

Widgery said, "An essential feature of planning musr

be the separation of different uses or activities

which are incompatible the one with the other. 11 More

than one local planning authority in the United

Kingdom has developed and applied a policy relating

to developments near the local airport).

We would therefore recommend:

that an investigation should be carried

out to establish in which schools and

hospitals the noise levels are unacceptable;

that a programme should be developed and

costed for insulating these buildings

that similar investigations should be

undertaken and a programme developed for

domestic dwellings; but these must have

lower priority

that no permissions for new schools,

hospitals or domestic dwellings should be

granted in the areas where aircraft noise

causes interference and disturbance to

house and school life.


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Environmental Resources Ltd

3.8 A Programme for the Progressive Reduction of Noise

In the previous paragraphs we have discussed the

main sources of noise and commented on methods for

their control; we have made some recommendations

for strengthening the existing noise control

legislation. We have also noted the high background

levels of noise that exist in Hong Kong.

We consider that in order for Hong Kong to achieve

an improvement in the noise environment F a programme

for the reduction of noise should be developed.

The purpose of the programme should be to provide the

framework within which the necessary decisions can

be taken for the progressive reduction of noise levels

in different areas and at different times, to a level

compatible with the use of the environment by the

community in that place or at that time.

*• *

Noise_Control_Authori ty

We consider that such a programme would require a single

noise authority.

Up until now, laws to prevent noise nuisances have

been passed as those nuisances have become a problem.

The result is a diversity of laws relating to noise from

different sources. More significantly for the

person concerned with monitoring and control, the

powers to suppress noise nuisances have been given to

a number of different authorities. We note that the

Urban Council has recently agreed to accept responsibility

for noise from air-corditioners, and has trained

members of its staff in the use of noise meters; and

that the Labour Department has a team responsible for

monitoring industrial noise. For a form of pollution

which requires a considerable degree of expertise for

official monitoring and effective control, and in a

small territory where expertise is therefore scarce

and financial resources limited, this is probably not

the most efficient use of resources. Although we accept

that enforcement can be more effectively exercised by

those whose work brings them frequently into close

relationship with the source of noise, as with police

and road traffic, we believe that the centralisation


7 4 . Environmental Resources Ltd

of responsibility for noise control in a single

authority would have considerable advantages over

the present diversity* Accordingly, we recommend

in Section VII that a single authority be

responsible for noise control in Hong Kong.

We believe that the Authority should develop noise

standards for different areas and times.

We are aware that quality standards for noise

expressed in absolute terms can be difficult to

a PPly* that individuals differ in their

sensitivity and that the human ear is often best

at determining 'excessive noise 1 .

However, quality standards have a value in

determining the levels at which an

individual's work and relaxation are

unreasonably interfered with;

assisting with planning in the territory

so that noisy activities are not located

in residential areas.

In the previous paragraphs, we have frequently

suggested that action be taken where noise levels

are thought to be unacceptable. In particular:

to establish whether schools, hospitals

and residential premises require to be

insulated from aircraft noise;

to establish the need for a transport

policy to reduce noise;

to ensure that users of construction

equipment take action to reduce noise;


7 5. Environmental Resources Ltd

to provide a basis for action to be

taken to reduce industrial noise*

We should like to suggest that:

standards are established for background

noise levels for different zones in

Hong Kong for different times of day;

standards are established for background

noise levels inside schools/ hospitals

and houses.

These standards should be used as guidelines for

planning purposes, for taking decisions about the

need for action on existing noise problems and

determining the potential noise impact associated

with new developments {including transport plans).

iii. Establishin2_Noise_Level_Ob^ectives

As mentioned above and as discussed in Appendix A,

Section V, most countries in Europe and North

America have established noise quality objectives for

various types of district or zones and for various

times of day.

There is an international proposal for "Noise

Assessment with Respect to Community Response":

this proposes noise differentials between areas

and between times to be based on a standard

minimum: examples of the corrections to the minimum

(a level of 35-45 dBA is proposed) are as follows:

Rural residential

Urban residential

City (business, trade, etc.)

Heavy Industry

No correction

+ 10 dBA

-f 20 dBA

+25 dBA


76 „ Environmental Resources Ltd

Evening time - 5 dBA

Night time

- 10-15 dBA

There are other correction factors (see Appendix A

5.9)

We would recommend that monitoring is carried out

to establish the existing noise levels in different

zones (see Appendix A, 5.9), and, based upon these

objectives should then be agreed and established.

Based upon these objectives, a programme should be

developed which should indicate where levels

appear to be the most excessive in relation to

land-use f what the options are for improving the

local situation and what they would cost.


77 * Environmental Resources Ltd

SECTION IV

AIR POLLUTION AND ITS CONTROL


78 * Environmental Resources Ltd

IV

AIR POLLUTION AND ITS CONTROL

4.1 In Appendix A, Section III, we review the main

sources of air pollution and comment on the

available information on air quality.

Emissions into the atmosphere in Hong Kong arise

mainly from

the combustion of fuel oil: about two

million tonnes of oil are used each

year for electricity generation, steam

raising and other industrial and

commercial purposes; this results in

the discharge of over 300 tonnes of

sulphur dioxide each day and the release

of other gases and particulates into

the atmosphere each day (see Appendix A,

1.11 and 3.6);

refuse incineration: this gives rise to

steam, grit, dust, sulphur dioxide

and other gases; the Air Pollution

Control Unit has estimated that emissions

of dust at Kennedy Town incinerator are

0.9% of refuse incinerated (ref 61A) -

(see Appendix A, 3.3);

manufacturing industries: apart from

emissions from the combustion of

fuel, industries may release particulate

matter, gases and smells associated with

the process;

construction, civil works and mining:

these give rise to large quantities

of dust and grit.

From mobile sources, mainly vehicles, the pollutants

include carbon monoxide, unburnt hydrocarbons,

nitrogen oxides and lead. Slow-moving congested

traffic coupled with the high-rise buildings lining


79 * Environmental Resources Ltd

the streets exacerbate the problem; several people

told us that traffic fumes (mainly the unburnt

hydrocarbons) gave rise to the most unpleasant form

of pollution in Hong Kong. We have little evidence

on the levels of pollutants from traffic; some

limited monitoring suggests there may be localised

high concentrations.

Available evidence suggests that levels of sulphur

dioxide and nitrogen oxides are not generally high

in relation to standards set by other countries

(see Appendix A, 3.9 and 3.10); and that levels of

sulphur dioxide have declined following the use of

low sulphur fuel by the Hok Un generating station

and other changes (Appendix A f 3.9). But information

on the quality of the atmosphere is far from

satisfactory.

The levels of smoke have declined since the

introduction of the Clean Air Ordinance. But

levels of particulate matter in the atmosphere do

give rise to concern; because of the dangers to

aircraft of reduced visibility and the impact on

amenity.

With the possible exception of sulphur dioxide and

the oxides of nitrogen, we have no evidence that

Hong Kong is, as yet f troubled by fumes. It is

envisaged f however, that more heavy and technically

advanced forms of industry will be atrracted to

Hong Kong, in which case more sophisticated controls

over fumes will be needed.

In this Section, we examine methods for controlling

sulphur dioxide (4.2) and emissions from other

stationary sources (4.3) and the existing legal

controls over stationary sources (4.4). We make

proposals for further controls (4.5). We examine

methods for controlling fumes from traffic (4.6)

and the existing legal controls (4.7), and we make

proposals for further controls over mobile sources

(4.8). Finally, we submit proposals for the

development of an air pollution control programme

(4.9).


80 • Environmental Resources Ltd

4.2 Methods for the Control of Sulphur Dioxide

Of the estimated 315 tonnes of sulphur dioxide

emitted each day from stationary sources in the

combustion of oil products, (by reference to

Appendix A, 3.6), it will be noted that:

electricity generation accounts for

80% of the total emissions of sulphur

dioxide: but much of this is from

high stacks in the west of the territory

and would not usually be expected to

influence ground level concentrations

of sulphur dioxide;

- over 100 tonnes daily are low level

emissions: of these, 40% is from

electricity generation (mostly Hok Un),

45% is from industrial users and the

balance is from domestic and commercial

users;

- about 80% of the low level emissions

occur in the Kowloon/Tsuen Wan area

(PPUs 2 and 3) where over 75% of the

industrial emitters are located.

The distribution of sulphur dioxide emission by PPU,

by source and by level in 1974 and 1984 is illustrated

in Map 4.2. The concentration of industrial fuel

use-and thus of sulphur dioxide emission is

illustrated in Map 4.3.

The sulphur content of fuel showed an increase

between 1972 and 1974: in 1974 the average sulphur

content was 2.65%, in 1973 2.43%, and in 1972 2.48%.

Some variations would be expected because of supply

factors, but reference to Appendix A, Table 3.6(a)

shows that while in 1972 53% of fuel used had a

sulphur content of 2*5% or above, in 1974 the

proportion had increased to 72%.

Data on the concentrations of sulphur dioxide in

the atmosphere does not, however, suggest a

deteriorating situation: readings from the four

government stations show that in 1974 there were


High level

1974

High level

S0 2 1984

1974

1984

1974

1984

1974

1984


81. Environmental Resources Ltd

35 days when the S02 levels in Hong Kong exceeded

200/A.g/m 3 compared with 316 days in 1969;

similarly, there were only two days when this

concentration was exceeded at the Queen Elizabeth

Monitoring Site, compared with 85 days in 1969.

However, the monitoring stations only provide

information on daily averages and peak concentrations

may occur unrecorded; and pollutants may also

accumulate in places other than where the limited

number of recording situations are located.

The two principal methods for reducing the emission

of sulphur dioxide are:

to require the consumers of fuel oil (and

other sulphur-bearing fuels) to use an

oil with a lower sulphur content;

to improve dispersion of the sulphur

dioxide by increasing chimney heights

and taking account of meteorological

conditions when siting the emitter: this

course of action has been adopted in

Hong Kong especially for the power stations

which emit over three-quarters of the

sulphur dioxide emissions.

Fuel oil with a lower sulphur content has a

marginally higher heat value, but overall, for

reasons of supply and demand, reducing the sulphur

content of the fuels used"will increase the cost of

energy in the Territory.

We cannot accept the argument that fuel users could

make more efficient use of fuel than is the existing

practice and thus offset the cost: clearly industry

should in any case use fuel efficiently and the fact

remains that lower sulphur fuel is more expensive.

It is difficult to estimate just what the added cost

would be. We note that some local estimates suggest

the figure would be about $17 per tonne for each

percent reduction in the sulphur content. Discussions

with oil companies suggest that there are several

relevant factors (quantity, transport costs, supply

and demand in other parts of the world) and we have

therefore taken a higher figure of $24 per tonne. But

we stress that the calculations below are provided to

indicate only the overall area of cost.


82 * Environmental Resources Ltd

We have calculated the cost of reducing the sulphur

content of fuel from 2.75% S to 2.5% S, 1.5% S or

O.l% S. Tables 4.10 (a) and 4,10(b) show the effect

of these alterations on the territory as a whole

(Table 4.10(a)) and on the low level emitters on Hong

Kong Island, Kowloon and the Tsuen Wan/Tsing Yi complex

(Table 4.10(b)). (Tables appear at the end of Section,

following paragraph 4.1O).

We estimate that

in terms of added fuel costs, the cost of

reducing sulphur dioxide emissions by one

tonne per day is in the region of $265,000

to $375,000 per tonne;

if every user of fuel oil in the territory

used 2*5% S fuel the cost of fuel would

increase by about $10 million; if the

sulphur content were reduced to 1.5% S

the cost would increase by about HK$54

million;

about 44% of the cost would be borne by

industry, about 35% by commercial users

and the balance by domestic users; (these

costs take account of the extra cost paid

for electricity);

if only the low level emitters in PPUs 1,

2 and 3 were required to use lower sulphur

fuel oil, the cost of reducing to 1.5% S

would be $12 million per year; this would

have the effect of reducing low level

emissions by almost half.

It will be appreciated that while lower sulphur

content fuels are, in percentage terms up to only

about 15% more expensive than existing fuels, the

additional cost in terms of the balance of trade

would be considerable. It would also be possible

to'limit the emission of sulphur dioxide by:


o o

Environmental Resources Ltd

requiring that under certain meteorological

conditions companies reduced their fuel

use or used lower sulphur fuel {as is the

practice at Hok Un);

requiring that in areas of high sulphur

dioxide concentrations an alternative

energy source (electricity) were used.

We suspect that with small emitters the first of

these alternatives would be difficult and expensive

to enforce and police, and with the second the cost

would be far too great.

We believe that the most practical solution is the

continuous use of lower sulphur fuels in areas where

levels of S02 are considered unacceptably high; but

in terms of the cost it would be necessary for the

controls to be applied selectively. It would be

difficult to enforce or police such a measure if

cheaper higher sulphur bearing fuel were available

locally. We would suggest that the price of the

lower sulphur grades of fuel, costing perhaps

HK$30 per tonne more than those grades currently

used, could . be artificially lowered by the Government

to keep these in line with the higher sulphur content

fuel oils. The cost could be recovered by an

equalisation tax on all fuels* The tax would

remove the incentive for companies to burn higher

sulphur content oils in areas scheduled for low

sulphur oil use.

It was suggested to us on several occasions -in Hong

Kong that the government should impose a general tax

on all higher sulphur grades to encourage the use of

lower grades. Table 4»10(a) shows what this would

mean in terms of cost of imports and of Hong Kong's

international competitive position. On the present

evidence, we consider such a measure would be a high

cost for^ the community to pay in relation to the

overall sulphur dioxide problem. ,


84. Environmental Resources Ltd

4*3 Methods for the control of other emissions from

stationary sources

Since the Clean Air regulations, we understand that

dark smoke emissions from shore based installations

have not proved a problem. Isolated incidents tend

to be caused by inefficient combustion of the fuel

and, in the first instance, the Air pollution Control

Unit aims to assist the plant manager to improve the

operation of the plant. Smoke from ships in the

harbour is . considered a problem: we find it difficult

to assess the .extent to which these emissions are in

fact a major contributor to air pollution problems.

However, since the smoke is easily seen and is clearly

a source of irritation and concern and since the

controls are relatively easy for the ships to obey, we

would support the proposed legislation.

Dust and grit, however, do present a problem in Hong

Kong. They cause a local problem as well as adding to

the overall dust load in the atmosphere and impairing

visibility* Below we list some of the major sources

that have been drawn to our attention.

Work by the APCU (61A) suggests that dust and grit

emission from the Kennedy Town incinerator is about

0.9% of refuse incinerated, amounting to about 4 to

5 tons of grit and dust each day, depending on

throughput. Consideration is being given to further

reducing the grit and dust emissions from all

incinerators; the situation at Lai Chi Kok in

particular has given rise to complaints because on many

days the plume flows through a local high rise

estate.

The cost of additional controls will depend on many

factors, including costs of contracting locally* It is

therefore difficult to spell out all the economic

implications and therefore difficult to make clear

recommendations. We draw attention to the following:

- in our view, the emission from the

incinerators does, under certain

meteorological conditions, add considerably

to the overall dust burden in the atmosphere;


85 - Environmental Resources Ltd

but more often, the dust and grit may be

carried out and away from Hong Kong; we

feel more data from monitoring is needed

to decide the extent to which the grit

and dust from the incinerator is adding

to local problems;

visually, much of the problem, and therefore

a cause of the complaints, arises from the

steam emissions caused by the high moisture

content of Hong Kong's refuse; we are told

that during the months when conditions are

such that the steam is less noticeable, very

few complaints are received;

to remove grit and dust to a low level would

be very expensive; in addition there are

special problems relating to space

availability that could increase the cost

of existing incinerators.

We have been given a very rough guide to cost by a

UK equipment manufacturer. We have been told that to

reduce the grit and dust emission to the region of

0.1% of quantity incinerated, the cost of the

necessary cooling and removal equipment for a new

incinerator of about 800 tonnes per day or so would

be the equivalent of about HK$10 million. The cost

for an older incinerator of this size could easily

exceed HK$15 million at today's costs. These are

costs for the UK. In very rough figures this could

add about HK$5 per tonne of refuse incinerated.

The question must be asked whether, given the other

environmental problems, the limited resources should

be spent in this way and whether a real environmental

benefit would accrue. This decision therefore needs

to be taken in the light of other priorities and with

additional data relating to the local distribution of

grit and dust.

Dust

We have been told about, and we have ourselves noted,

the dust arising from the transport and use of

construction materials, expecially cement, and from

civil works and quarrying.


86 * Environmental Resources Ltd

We understand that in PWD contracts there is a

requirement for 'damping down 1 to minimise dust

levels. This should be made a general requirement

for all dust producing work.

Action is also required to minimise dust arising

from the transport of loads in lorries. Such loads

should be carried in a, truck covered with at least

a plastic sheet.

111*

Emissions other than sulphur dioxide and dust may

arise from certain process industries as byproduct.

These include small particles of metals

and fibres, particularly from textiles, and various

fumes and unpleasant smells. In Appendix A, Section 3,

we list those industries that may be considered to

give rise to a hazard or a nuisance by nature of

their activities. We are not aware of any specific

problems arising from air emissions from the process

industries, other than one report of dust from a

textile plant. Recent investigations into the levels

of lead inside factories by the Labour Department

suggest that the local external environment should

not be affected.

Emissions from process industries tend to be not only

process-specific, but also to differ between

manufacturing plants in the same industry using

similar processes. The control of these emissions

will often be related to the design of the particular

process used; costs will vary according to the

solution. In the UK, the approach has been the 'best

practicable means 1 which has been criticised insofar

as one body, the Alkali Inspectorate, has in the

past had the authority to take account of all factors •

including cost to the manufacturer, and environmental

impact, when judging the extent to which the emissions

should be reduced. The Inspectorate has also been

"criticised on the grounds that the best practicable

means are being used it has no power to deman a

reduction or to close the source, however damaging

the-emissions might be. In some cases, this has

resulted in levels of environmental damage considered

by some to be intolerable. The supporters of this


87. Environmental Resources Ltd

approach have argued that some essential processes

such as brick-making, would have to close down

altogether if strict air pollution control measures

were applied.


8 8 * Environmental Resources Ltd

4.4 Existing legal controls

The principal legal controls over emissions to air

froia stationary sources are found in the Clean Air

Ordinance and regulations made thereunder. Further

legislation has been proposed to supplement the

present Clean Air Ordinance. The details of that

legislation have not been made known to us, and the

comments below are made in the knowledge that some,

or all, of the points may be covered by the proposals,

i. Smoke

The present legislation is effective in providing

control over emissions of smoke and grit from

furnaces, although we note that an application has

been submitted for more enforcement staff.

Prosecutions are relatively few, but we understand

that officers work more by persuasion than by coercion

and fulfil a most useful advisory role.

ii.

Dust

Dust is included in the definition of smoke (Clean

Air Ordinance S2). Emissions from sources other

than furnaces can, in many cases, be dealt with

under Section 4 and 14 of the Ordinance. S4,

however, does not give a sophisticated form of

control, and the emissions may not be from an

'industrial plant' within the meaning of Sll (see

SS2 and 14(1)). More detailed and wider ranging

control could be given by separate control over

dust emissions.

iii.

Fumes are also included in the definition of smoke

(Clean Air Ordinance S2) . The most common form of

pollutant within this class is sulphur dioxide.


89 * Environmental Resources Ltd

iv.

Odours

Apart from the legislation concerning offensive

trades, there is no statutory provision for the

suppression of offensive or unpleasant odours in

Hong Kong.

In addition to these controls r the impact of

proposed developments on the atmosphere is taken

into account by the Secretary for the Environment,

advised by the Royal Observatory, the Air Pollution

Control Unit and other interested parties; and

recommendations are given on siting and chimney

heights; or, in some cases, for reasons of air

quality, it has been recommended that the

developments should not proceed (e.g. the sludge

incinerator at Sha Tin).


90 * Environmental Resources Ltd

4.5 Proposed legal controls;- stationary sources

i. Smoke

The present legislation appears to be satisfactory

for the control of smoke itself, although we accept

that smoke provisions of the Merchant Shipping

(Port Control) Bill can serve a useful purpose. It

is necessary to include in the definition of smoke

'soot, ash, grit or gritty particles emitted in

smoke or steam, " but we do not consider that it is

necessary to include also 'noxious vapours, dust or

fumes*' In our view, it would permit more effective

control if separate provision was made for fumes,

including noxious vapours, and for grit and dust.

ii»

Grit and dust

Grit and dust arise from a number of industrial

processes, including the loading and transport of

materials, and different arrestment methods are

appropriate to each* We consider that this problem

can best be solved by legislation which allows the

control authority to require the installation of a

specified type of equipment or the adoption of a

specified procedure.

iii *

It is difficult to say what further measures are

needed to control emissions of sulphur dioxide until

further monitoring has been done. If the need for

further control is established, by far the most

effective method is by the control of fuel oils

or by increasing chimney heights. We have already

proposed the use, in these circumstances, of

restrictions on the use of high sulphur content

fuels in specified areas, coupled with the use of

a fuel equalisation tax (see 4.2).


9 •*•" Environmental Resources Ltd

1 v • 2ther^gaseous^pollutants

We note,in paragraph 4.3, that although there is

as yet no clear evidence of the need for controls

over gaseous pollutants from other stationary sources,

our brief requires us to take into account any

probable future developments. These may well include

the establishment in Hong Kong of more complex

industries; for example, petro-chemical plant. We

therefore attempt here to indicate in general terms

what we consider would be the most appropriate

provisions.

As we have noted above/ 4.3, emissions tend to be

industry related. We consider that in these

circumstances control can best be effected by a

combination of two powers. First the processes and

gaseous emissions to be controlled must be specified.

The Governor can then be empowered to impose limits

on the emissions of any of those gases; the pollution

control authority can be empowered to require the

adoption of specified control measures, taking into

account what is technically and ecomonically feasible.

This, of course, will entail the recruitment of staff

of high calibre with relevant industrial experience.

The control authority should also be empowered to

require minimum chimney heights.

v. Odours

In some areas there are complaints of pollution by

odours. The most sensitive instrument for assessing

odours is the nose, therefore they are best dealt

with according to subjective standards. We therefore

recommend that the summary procedure proposed for

noise nuisance should be applied also to nuisance

arising from odours.


92* Environmental Resources Ltd

4*6 Air pollution from mobile sources: methods for

controlling traffic fumes

Fumes from traffic give rise to environmental concern

because of

the nuisance associated with excessive

smoke;

the nuisance associated with smelly

fumes (mainly partially burnt

hydrocarbons);

the health hazard from the lead additive

in petrol;

the health hazard from other contaminants

in the environment*

Air pollution arising from traffic can be dealt with

in two ways; by modifications to the fuel or the

vehicle, or by curbing the use of the motor car.

Excessiye^smoke

\ survey of excessively smoky vehicles made by the

Transport Department and reported to EPCOM (ENV 25/43

41/21) records about 500-600 vehicles reported

each month for discharging excessive smoke. The

nuisance from excessive smoke can be alleviated by

good management, maintenance and the correct use of

vehicles (e.g. only using the choke for starting

the vehicle and not overloading lorries).

This is therefore a question of inspection and

enforcement rather than of technical solutions, We

understand that there are four gazetted testing

stations examining about 35,000 vehicles a year (less

than 20% of all vehicles). At present there is no

requirement for inspection of smoke at the regular

inspections. Hartridge Meters are now available for

measuring visible smoke.


9 3 • Environmental Resources Ltd

Methods for alleviating the problem include:

requiring the chokes on diesel-powered

goods vehicles to be outside the cab;

requiring vehicles emitting excessive

smoke to report to an inspection centre;

this aspect is considered later in the

report.

Lead

The reduction of lead emitted by cars can be achieved

by:

the reduction of the quantity of lead

added to the petrol;

the use of * lead traps 1 fitted to the

exhaust;

the use of other fuels.

In the UK, the quantity of lead has been reduced from

0.64 grams per litre to 0.55 grams per litre and

a further reduction to 0.40 grams per litre has been

planned. In Hong Kong, fuel has a lead content of

up to O.8 grains per litre.

Removal of lead from petrol would increase petrol

consumption by about 12-15% and would require adjustments

to be made to the combustion engines.

It has been suggested that lead traps would be cheaper.

The trap developed by Tube Investments and Associated

Octed will add about HK$300 to the cost of a car,

should last about 36,000 miles and, using petrol of

0*55 grams per litre, reduce lead emissions to a level

similar to that of a car using petrol with a lead

content of 0.30 grams per litre.


9 4 * Environmenta! Resources Ltd

Lead traps would therefore add about HK$10 per

thousand miles; depending on the price of petrol

and on other factors (petrol consumption,

modifications to'plant and vehicles, etc.),

reducing the lead in petrol would cost about

HK$20 per thousand miles to achieve the same

emissions.

Lead levels could also be reduced by the

substitution of petrol driven cars by diesel or

electric vehicles.

Other contaminants

Carbon monoxide and the hydrocarbons can be oxidised

by a catalytic converter provided that the petrol

contains no lead; (lead damages converters). These

converters do increase the emission of sulphuric

acid mists.

Several companies have announced that they have

'pollution-free 1 engines under development: General

Electric (USA), for example, have announced a

"transpiration burner 1 which produces less than 3%

of the nitrogen oxides, virtually no hydrocarbon

emissions and minimal carbon dioxide.

In addition to other contaminants, diesel and petrol

driven vehicles emit sulphur dioxide. The only

practical method of reducing the sulphur dioxide

is through reducing the sulphur content of the fuel

with the resulting increase in price.

At present, sulphur dioxide emissions from vehicles

represent a very small fraction of the total low

level emissions in Hong Kong. However, reduction

in sulphur content of petrol and diesel fuel would

be required if catalytic converters were used to

reduce carbon monoxide and hydrocarbon emissions.

We have already commented in the section on noise

(III) on methods for reducing the environmental

impact of traffic.


Environmental Resources Ltd

Our conclusions on the control measures required

for fumes from vehicles are as follows:

we have no evidence on whether or not

lead in exhaust emissions represents

a health hazard to the inhabitants

of Hong Kong; elsewhere what evidence

there is has not proved conclusively

that lead in petrol is a major

contributor to lead in human blood

levels;

we suggest that levels of lead could

be monitored as part of a general

monitoring exercise and if levels

appear to be high then action should

be taken;

again, there is no evide'nce whether

the other hazardous pollutants in

exhaust emissions are giving rise to

serious problems: some work on carbon

monoxide levels in the blood of

policemen on traffic duty suggested f

we understand, that there was no

immediate cause for concern;

Hong Kong does not manufacture vehicles

nor does it represent a large market

for vehicles: it is therefore not in a

position to insist on stricter exhaust

emissions than other countries;

but there is a trend to curb vehicle

emissions by Japan and North America

from which Hong Kong should benefit

if the vehicles supplied for Hong Kong

h are the same.


Environmental Resources Ltd

4.7 Existing controls over mobile sources

The Road Traffic (Construction and Use Regulation)

27A, last year, introduced.a type approval scheme.

The provision contains mandatory regulations,

relating to types of motor vehicles, but we note

that there are no provisions relating to individual

components which might be fitted as replacements.

We note also that there is no provision to ensure

that each vehicle conforms to type (cf the UK Motor

Vehicles (Type Approval) Regulations 1973 Reg. 6,

which requires that for each vehicle there shall be

a certificate of conformity).

New regulations have been prepared to limit emissions

from diesel engined vehicles and to limit visible

smoke from all vehicles.

One of the causes of visible air pollution is the

use of a choke in diesel engines vehicles. The

UK Road Traffic (Construction and Use) Regulations

forbids the use of a choke which can be operated

from inside the cab of the vehicle. There is no

equivalent provision in the Hong Kong regulations.

Perhaps the most difficult task in controlling

pollution from motor vehicles is to ensure proper

maintenance. In Hong Kong reliance must be placed

on inspection, prohibition on use, and refusal or

revocation of licence. There are provisions to

cover these points, and we note that the police are

very active in reporting defective vehicles (35,89O

were reported in 1974)„ We note also that further steps

by: the computerisation of records, which will help

to identify defective vehicles the provision of

additional testing stations; the appointment of

additional inspectors; and for diesels the use of

Hartridge smoke meters. We agree that the only

effective means available to the Hong Kong

authorities of ensuring satisfactory maintenance

standards is by an adequate system of inspection,

backed by powers to take vehicles off the road.

There remain matters of detail which are more

appropriate for discussion in our Stage 2 Report.


Environmental Resources Ltd

Some concern has been expressed about fumes from

buses left at termini with their engines idling.

It has been pointed out to us that the Road Traffic

(Construction and Use) Regulation 108 is not

effective to prevent this, because it permits a

bus to be left with the engine running so that

ancillary equipment may be operated. It is also

relevant to note that the engine must be stopped

only "so far as may be necessary for the prevention

of noise". In both respects some provision seems

necessary.

We note that there is nothing in the laws of Hong

Kong to control emissions of lead from petrol

engined vehicles or sulphur dioxide from diesel

engines. The need for any such controls cannot,

however, be established until further monitoring

has been done .

The responsibility for controlling gaseous emissions

from vehicles has rested with the Police, acting with

the co-operation of the Commissioner for Transport.

Although the Advisory Committee on Environmental

Pollution has kept the situation under review, and

although the Secretary for the Environment has

responsibility for formulating policy and recommending

further legislation, there is no single public

authority with the necessary expertise to devise a

monitoring programme, and make detailed recommendations

as to future action. The Police make recommendations

for changes in the law in so far as these laws are to

be enforced by their officers, but some forms of

control may fall outside the scope of their duties.


9 8 • Environmental Resources Ltd

4.8 Proposed controls over mobile sources

The most effective ways of reducing air pollution

from road traffic are by type approval schemes, by

controls over fuels and by traffic regulation.

Hong Kong has recently introduced a type approval

scheme for petrol engined vehicles, and is about to

introduce one for diesels. In this matter the

Hong Kong Government must clearly follow the

developments in the vehicle producing countries

so that on the one hand it maintains feasible

regulations, and on the other avoids the dumping

of vehicles which cannot be sold on the principal

We note that there is no type approval scheme for

component parts, or for motor cycles, and recommend

that these matters be given due consideration.

There have been complaints of smoke from diesel

engined vehicles as they are driven hard to ascend

a hill. We understand that this is partly due to

the use of a 'choke 1 in the cab. The United

Kingdom Motor Vehicles (Construction and Use)

Regulations forbid the fitting of a choke which

can be operated from the cab (Regulation 103).

We recommend the issue of a similar regulation in

Hong Kong.

Only further monitoring will show whether control

over fuels is necessary. In the case of lead

emissions, there are two alternative forms of

control; the use of lead traps and the restriction

on lead in petrol. The respective merits of these

methods are discussed above in paragraph 4,6. and,

if controls over fuel or lead traps are required,

the necessary legal powers will be provided.


99 * Environmental Resources Ltd

4.9 The development of an air pollution control

policy and programme

We have, in Appendix A, III, and in the previous

paragraphs noted some of the existing and potential

air pollution problems from stationary and mobile

sources. There is little evidence that the quality

of the atmosphere represents a serious risk to

health, although the fumes are extremely unpleasant,

But the concentrated use of fuel oil by electricity

generating stations, by industrial, commercial and

domestic users and the concentration of mainly oil

driven vehicles in the context of Hong Kong's

topography, meteorology and urban environment

suggests that there is the potential for the buildup

of contaminants. Further, new and more

sophisticated industrial activity is expected over

the next decade which will require to be controlled

if the atmospheric quality is not to deteriorate.

However, new and existing industry may be discouraged

by controls that are more stringent than are

required by the state of the environment-

It is our view that it is neceasary to develop an

air pollution control programme. This programme

will include;

the setting of air quality objectives

that will ensure that levels of

contaminants do not pose an unacceptable

threat to health or amenity;

the phased reduction of emissions in

areas where present levels exceed the

targets set for the programme: this

reduction must take account of

technical, economic and social

considerations.


Environmental Resources Ltd

The programme would provide the framework for

taking decisions on the further control of

emissions from mobile and stationary sources

and would assist in providing advice on future

industrial sitings.

It will be appreciated that the question of

monitoring pollution levels is essential to the

development of an air pollution policy. Air

quality objectives require some quantitative

support; otherwise it is not possible to determine

whether the situation is improving or deteriorating,

whether air pollution control programmes are

effective or whether plans for new industry should

or should not be accepted. With reference to the

last of these, industrial siting, even with

monitoring it is not easy to predict the impact

of a new industry in Hong Kong: the particular

topography and the urban environment complicate

any such forecasts and very much enlarge the

potential margin for error. Nevertheless,

adequate baseline data would assist the authorities

to demonstrate the responsibility of a major new

industry if pollution levels increased and to

require further pollution control measures to be

instituted.

But there is a counter argument to the establishing

of a monitoring network:

there is no evidence that the levels

of contaminants in Hong Kong's

atmosphere are a serious threat to

health or amenity (see comments on

S02f ref 29): available information

on SC>2 levels, though limited, shows

these to be reasonably low compared

with international standards (see

Appendix A, 3.8), and it is extremely

rare for levels of S02 and for

particulates to peak at the same

time (analysis carried out by the

APCO);


101 * Environmental Resources Ltd

a more comprehensive monitoring network

would be expensive: 1974 estimates for

a more limited network than originally

proposed by Parker (Ref 7), show a nonrecurrent

capital cost of HK$3.6m and

operational costs of about HK$60O,OOO

(ref 4A, 4B)

if air pollution does not present a

real problem, it is unnecessary for the

community to use its limited resources

to provide additional data that will

only show the extent to which it is not

a hazard.

In our view, there is a need for further information

on the quality of the atmosphere; we do not believe

that current monitoring activity is adequate to

determine the extent of local air pollution hazards.

In their proposals for a monitoring network (ref 4) ,

the Royal Observatory commented on the deficiencies

of the current system. In particular, we would

stress

that none of the instruments currently

available is capable of continuous

recordings and peak concentrations could

be occurring for short periods;

there are insufficient daily stations,

particularly in relation to the

topographical and urban nature of

Hong Kong f s environment: local

concentrations of pollution could develop

and persist undetected by current monitoring,

that smoke is less adequately monitored

than S02, and certain other pollutants,

such as lead and nitrogen oxides, are not

monitored at all on a regular basis.

Furthermore, we do consider that further baseline

data is desirable for planning furtner developments

We consider that an initial programme based on a

mobile monitoring unit would provide sufficient


102 * Environmental Resources Ltd

data to allow decisions to be taken on:

the extent of air pollution in different

areas of Hong Kong;

whether a more comprehensive network is

necessary;

whether further air pollution controls are

required*

We suggest, that this programme uses a mobile air

pollution monitoring unit employing a traversing

technique; the research programme should be

constructed to take account of varying meteorological

influences. A mobile unit designed to provide

information on:

sulphur dioxide

nitrogen oxide;

nitrogen dioxide;

oxone;

carbon monoxide;

hydrogen sulphide;

dust;

hydrocarbons;

fluoride;

lead;

would cost about HKS1.7 million, Skilled technicians

would be required to operate the unit* This is

discussed further in Section VII.


103 « Environmental Resources Ltd

Based on the data provided by the prelirninarv

monitoring programme, decisions should be taken on:

(i)

whether the more complete monitoring

network (Ref 4A, 4B) is required or

whether the existing network supplemented

by the mobile unit carrying out*a regular

programme would meet the needs of the

Territory. We suggest the decision criteria

should include whether or not any serious

local concentrations of pollutants were

identified that required monitoring of the

type envisaged by Parker and the Royal

Observatory.

(ii)

the development of air quality objectives;

(iii)

what, if any, further controls would be

justified for the reduction of sulphur

dioxide, nitrogen dioxide, fumes from

vehicles or other pollutants.

Air Quality Objectives

We suggest that in developing the air quality

policy, consideration be given to the setting of

air quality objectives minimising risks to human

health, to local fauna and flora, other specified

risks (e.g. to aircraft when landing or taking off)

and based on improvements to amenity.

We believe that these objectives should be achieved

through the use of product standards, design and

installation standards, and operating standards.

Except in the case of smoke emissions (which can be

easily seen), we do not consider that emission

standards are appropriate for use in Hong Kong.

Control through emission standards requires continuous

or at least regular monitoring; the data is used to

check whether emitters are exceeding their standards

and to ask them to reduce these emissions under certain

meteorological conditions. In Hong Kong, where there

are a large number of small fuel users, we do not

believe that this is practicable: firstly because it

would rarely be possible to determine the contribution

of a particular source and secondly because the

number and type of emitters would make enforcement

difficult and expensive.


104 • Environmental Resources Ltd

The objectives would be used to provide guidance for

planning reductions through the measures outlined

above (including the use of low sulphur fuel) and,

in the case of new developments, for determining the

siting and control requirements.

4.10 In the following Tables we analyse the costs of

reducing sulphur dioxide (4.10(a) and 4.10(b)) and

we summarise alternative control methods discussed

in this section for stationary (4.10(c)) and mobile

(4.10(d)) sources.


105,

TABLE 4.10(a)

ESTIMATED EFFECT ON ANNUAL FUEL COSTS OF REDUCING THE

AVERAGE SULPHUR CONTENT OF FUEL FROM 2.75% (i)

Sector

Fuel Use

'OOO tpa

Added Cost HK$ Million p.a. (ii)

for Sulphur Content of:

2.5% S 1.5% S O.l% S

Industry

- fuel oil

296.8

1.6

8.1

17.5

- electricity

575.1

3.2

15.7

33.8

Total 871.9 4.8 23.8 51.3

Commercial

- fuel oil

27.4

0.2

0.8

1.6

- electricity

663.8

3.6

18.1

39.0

Total 691.2 3.8 18.9 4O.6

Domestic

- electricity 402.0 2.2 11.0 23.6

Total for

all consumers

I f 965.1 10.8 53.7 115.5

Notes:

(i) It has been assumed that all consumers currently

use fuel oil with 2.75% sulphur content.

(ii)

Estimated additional costs per tonne, including

allowances for extra thermal value, would be for:

2.5% S: $5.5

1.5% S: $27.3

0.1% S: $58.8

No account has been taken of costs associated

with changes in viscosity.

Environmental Resources Ltd


106.

TABLE 4.1O(b)

ESTIMATED EFFECT ON FUEL COSTS OF REDUCING THE AVERAGE

SULPHUR CONTENT OF FUEL USED BY LOW LEVEL EMITTERS (i)

Area

Fuel Use

! 000 tpa

Added Cost HK$ Million (ii)

for Sulphur Content of:

2,5% S 1.5% S 0.5% S

PPU 1

24.4

134.2

661.1

1,424.7

PPU 2

(iii)

314.8

1,731.4

8,594.0

18,510.2

PPU 3

106.6

586.3

2,910.2

6,268.1

Total

445.8

2,451.9

12,170.3

26,213.0

Total Saving in

SO2 Load in:

- tonnes

per day

6,6

32.8

69.4

- % reduction

of SO 2

daily load

9.2

45.5

96.2

Notes:

(i) Fuel used by industry and commercial premises

and by Hok Un power station only.

(ii)

As in Table 4.2(a).

(iii) Only 70% of Hok Un f s fuel is included: we have

assumed the extra 30% is already 1.5% S, and

if required to reduce to O.l% then extra load

would be borne by Tsing Yi power station.

Environmental Resources Ltd


TABLE 4olO(c)

TECHNICAL SOLUTIONS TO AIR POLLUTION PROBLEMS ARISING FROM STATIONARY

AND THEIR IMPLICATIONS

SOURCES

Source of

Pollutant

Pollutant

Method of

Control

Economic and Environmental Implications

1 . Combustion

of fuel oil

1.1 Sulphur

dioxide

(a) Reduce

sulphur

level

in all

fuel.

Cost about $17.00 - $24. OO per tonne of fuel oil used.

every tonne of SO per day removed. Cost would be $275 -

$375,000. Currently over 3OO tonnes per day emitted:

total cost about $1OO million per year to reduce emissions

by about 95%. About $lOm p.a t to reduce sulphur maximum

to 2.5%: emissions reduced by about 3O tpd SO . But the

effect on ground level SO may not be very great.

o

(b) Selective

reduction

of SO 2 by

area.

If only low level emitters in Kowloon and Tsuen Wan/Tsing

Yi were required to use low sulphur fuels. Then cost of

95% reduction would be about $2 5m. A local reduction

of 3O tpd for low level emitters (about $lOm p. a.) would

halve the low level emissions and would be more likely to

lower ground levels to acceptable limits. But selective

measures would be difficult to enforce unless lower sulphur

fuel subsidised by the fuel users.

(c) Selective

reduction

of S0 2 by

time.

At present, Hok Un power station uses 1.5% where

meteorological conditions are adverse 0 Difficult to

enforce with smaller users.

/continued. * .

HONG KONG - CONTROL OF THE ENVIRONMENT

Environmental Resources Ltd


TABLE 4,lO(c) - continued

TECHNICAL SOLUTIONS TO AIR POLLUTION PROBLEMS ARISING FROM STATIONARY SOURCES

AND THEIR IMPLICATIONS

Source of

Pollutant

Pollutant

Method of

Control

Economic and Environmental Implications

1*2 SO^ and

other

oil

combustion

products

(NO X , etc.)

(a)

Improve

dispersion

by higher

chimneys„

Limited application: cost of land results in buildings

being constructed to maximum permitted heights; Civil

Aviation Department lay down maximum heights near the

flight paths.

(b)

Move

emitters

to other

areas.

Nature of terrain offers limited flexibility. Location of

industry on west of the Territory has been the practice so

that prevailing easterly winds carry pollutants out to

sea* Further work may identify areas where dispersion

characteristics are favourable*

O

GO

(c) Require

low level

emitters

to use

electricity,

The inefficient conversion of fuel to electricity would

make this too expensive an option. It would probably

treble fuel import costs; for many processes it would not

be practical.

/continued..*

HONG KONG - CONTROL OF THE ENVIRONMENT Environmental Resources Ltd


TABLE 4.1O(c) - continued

TECHNICAL SOLUTIONS TO AIR POLLUTION PROBLEMS ARISING FROM STATIONARY

AND THEIR IMPLICATIONS

SOURCES

Source of

Pollutant

Pollutant

Method of

Control

Economic and Environmental

Implications

1.3 Smoke

(a)

Improve

combustion.

APCU achieved considerable progress. Often a net

economic advantage through improved fuel utilization.

2. Incineration

2*1 Dust

and grit

(a)

Install more

effective

control

equipment

Practical difficulties associated with existing

incinerators. Precipitators designed to reduce

emissions from existing levels to O.l% of local

likely cost to $lOm - $2Om per incinerator. Increase

cost of incineration by about $5 per tonne.

O

2 0 2 All refuse

combustion

products

(a)

Higher

chimneys

to aid

dispersion

Damp plumes tend to trickle over the side.

there are plans to install Venturi nozzles.

Currently

3. Building

sites, civil

works f etc.

3,1 Dust (a)

Management

practices

Localised problems require good local management:

damping down, covering lorries, etc.These requirements

can be built into contracts but enforcement problem

remains.

/continued...

HONG KONG - CONTROL OF THE ENVIRONMENT Environmental Resources Ltd


TABLE 4.lO(c) - continued

TECHNICAL SOLUTIONS TO AIR POLLUTION PROBLEMS ARISING FROM STATIONARY

AND THEIR IMPLICATIONS

SOURCES

Source of

Pollutant

Pollutant

Method of

Control

Economic and Environmental Implications

4. Industrial

processes

4.1 Various (a) At source

or by

control

equipment

Varies by type of process

O

HONG KONG - CONTROL OF THE ENVIRONMENT

Environmental Resources Ltd


TABLE 4*lO(d)

TECHNICAL SOLUTIONS TO AIR POLLUTION PROBLEMS ARISING FROM VEHICLES, AND THEIR IMPLICATIONS

Pollutant

Method

of Control

Economic and Environmental Implications

Excessive smoke

Lead

1*1 Proper maintenance and

correct use of vehicles

2,1 Reduction of lead

in fuel

2.2 Use of lead traps

2.3 Use of alternative fuels

Problem of enforcement rather than of a. technical

nature. Further inspection will require additional

resources.

Increases fuel consumption. Reduction to UK target

level (O.4O gin/litre) from' O.64 gin/litre would cost

an additional $2O-$3O per vehicle per year. No

evidence that lower level is required.

These may be cheaper: about $1O per vehicle per

thousand miles for a lower level.

Diesel and electric vehicles no not emit lead.

Electric cars use considerably more fuel (at least

twice as much) and emissions from power stations

would increase, etc. Diesel vehicles emit more

particulates than petrol-driven vehicles.

/continued...

Environmental Resources Ltd


TABLE 4»lO(d) - continued

TECHNICAL SOLUTIONS TO AIR POLLUTION PROBLEMS ARISING FROM VEHICLES, AND THEIR

IMPLICATIONS

Pollutant

Method

of Control

Economic and Environmental Implications

3. Other contaminants 3,1 Catalytic converters,

pollution-free

engines, etc.

3.2 Use electric vehicles

4,1 Curb on traffic

Converters may increase sulphur emission but cut

down on carbon monoxide, nitrogen oxides, etc.

Ideally, low-lead, low-sulphur fuel should be

used with converters 0

As above.

Congestion exacerbates situation. Reduction in

number or total bans could improve situation.

Environmental Resources Ltd


113. Environmental Resources Ltd

SECTION V

COLLECTION AND DISPOSAL OF SOLID WASTES


114 - Environmental Resources Ltd

V

COLLECTION AND DISPOSAL OF SOLID WASTES

5.1 In Appendix A Section IV we discuss the collection

and disposal of municipal and industrial waste and

the litter problem. We estimate that excluding

builders 1 rubble and earth (construction debris)

about 3,000 tonnes of solid waste is currently

generated per day: by 1984 the Territory may be

generating 6,000 per day. The current situation

is shown diagramatically in Figure 5.1 (a) on the

following page.

In this section we outline some of the existing

and potential problems associated with solid waste

and its disposal; and we discuss possible

technical and legal solutions. It should be noted

that the Government has asked for and received

advice from consultants on solid waste disposal;

similarly there are plans for consultants to be

appointed to study the question of solid waste

collection (Ref 333 para 6.8). It will be

appreciated that the solution of many of the

problems associated with the collection and safe

disposal of solid waste are of a technical nature

as distinct from requiring a legislative approach.

The central problem relates to the need to find the

most cost-effective solution to disposing of the

increasing quantity of solid waste - given the

limited space available. For these reasons we

have concentrated in this section on technical

solutions. The details of any necessary legislation

will be dealt with in our Stage II report.

The problems discussed below are:

the impact associated with

collection (5.2), existing and

proposed controls (5.3, 5.4);


TABLE 5,1(a)

SOLID WASTE ARISINGS AND DISPOSAL (i)

en 0*z*

I

I

HONG KONG ISLAND j MARINE { MAINLAND

H

w

H

Earth, rocks

cons txuction

debris etc.

125O tpd

Industrial

solid

waste

scavenging

Industrial

solid

waste

Earth, rocks

construction

debris etc.

§ MBOW

O

f'o

£H

t—t

W

M W 01

PWD

PC

INCINERATION

550 tpd

BARGE

180

tpd

INCINERATION

1250 tpd

Land

Reclamation

1280 tpd

CONTROLLED

Land

Reclamation

9OO tpd

Abbreviations:

MD « Marine Department

PC ~ Privat^ Contractors

HONG KONG - CONTROL OF THE ENVIRONMENT

PWD = Public Works Dept.

USD = Urban Services Dept-

Note (i) Position in late 1974

when Lai Chi Kok 'B 1 operational.

Figures derived from r

Environmental Resources Lid


116 • Environmental Resources Ltd

environmental impact associated

with existing and possible future

solid waste disposal methods (5.5),

existing and proposed controls

(5.6, 5.7);

the problem of litter (5.8, 5.9,

5.10);

the question of an integrated

approach to solid waste planning

(5.11).

5.2 Environmental Impact Associated with Solid Waste

Collection

At present, in the majority of cases household

refuse is kept in bins (which are often stored in

the common parts of the building) and are

transferred by private collectors (who scavenge

many reclaimable materials) to USD collection

points.

Problems may arise:

when bins of refuse left in the

common parts overspill or are

overturned; the requirement for

a secure lid is apparently not

always adhered to;

when refuse accumulates in

common parts from this and other

causes (such as throwing of

garbage into the wells of blocks)

since in many cases no-one is

responsible for its removal;

in the provision of suitable USD

collection points: on-street points

are being phased out (primarily to

relieve traffic congestion) and

off-street sites are being built to

meet criteria prepared by USD (Ref 256)


117.

Environmental Resources Ltd

Trade and industrial wastes are delivered to PWD

disposal sites either by the companies generating

the waste or by private waste disposal contractors:

the latter tend to be small 'one man and a lorry 1

concerns* We understand that the requirement

that the USD should collect only 3% cubic feet free

of charge is not strictly adhered to.

We have received no evidence that the collection of

industrial wastes presents any environmental problems,

However, as industry becomes more sophisticated, the

wastes that are collected and transported may

become more hazardous in character.

We understand that at present there is no collection

service for refuse from the boat dwellers. There

are considerable practical difficulties in providing

a service to the boats and the USD encourages the

boat dwellers to use facilities on-shore. However,

we are told that much of refuse is dumped overboard.

There are 60,000 to 80,000 residents and they probably

generate 10,000 to 15,000 tonnes per year. Much of

this drifts through the harbour areas and out to sea;

some is deposited on beaches.

The proposed cost of a more comprehensive harbour

scavenging service is HK$ 4k m. (1974 prices) *

There can be little doubt that much of the harbour

litter emanates from this source.

5 * 3 Collection - Present Controls

The Authority^ power to provide services, or by

licence or contract permit any other person to

provide services for the removal of house refuse

(Ref: Cap. 132, S16) , gives it sufficient legal

control over collection procedures. This is

supplemented by offence provisions in the Summary

Offences Ordinance (see particularly S4) , the Public

Health and Urban Services Ordinance (see particularly

SS 12, 20, 22 A), and the Public Cleansing and


118 * Environmental Resources Ltd

Prevention of Nuisance Bye Laws (see particularly

B/L's 4 and 5). Difficulties can arise, however,

in some large blocks of flats, because of

the lack of suitable facilities for storage and

collection. Neither refuse chutes nor any other

particular kind of facility must be provided, and

there is no provision for approval of facilities,

or refusal of consent under the Buildings Ordinance

because of the lack of satisfactory facilities.

Further difficulties arise in large blocks of

flats in joint ownership, where no one person or body

of persons is responsible for management. A step

has been taken towards solving this problem by the

Multi-storey Buildings (Owners 1 Incorporation)

Ordinance. This Ordinance, however, merely enables

a minimum number of owners to form a management

committee and have it incorporated. Much time and

effort may be needed on the part of individuals, in

some cases the City District Officer, in establishing

a corporation. There is no obligation on the

owners to form one.

Recently a working party considered the question of

whether refuse chutes should be mandatory (ref 333).

These overcome many of the problems associated with

the current collection system: refuse is discharged

direct to collection chambers from which the USD

would collect. However, the committee identified a

number of major problems:

in many developments, there would

be problems of access or suitability

of the service lanes;

the provision of collection chambers

would lead to a loss of revenue to

the developers for which compensation

would probably be required;

poor management in multi-ownership

buildings could lead to the chambers

becoming dirty and a hazard to health,


119 * Environmental Resources Ltd

The Committee believed that chutes should not be

made mandatory but that the compulsory use of

plastic bags by the householders could overcome

many of the problems. The provision of facilities

for the storage of these bags while awaiting

collection could be arranged more easily and at

less cost than would be the case for refuse chutes.

The Committee concluded (para 6.8) that a

consultant should be appointed to study the whole

question of refuse collection.

We support the suggestion that the question of

the clean and efficient collection of refuse from

the household should be studied: clearly such a

study will take account of the implications

relating to the collection of the refuse by the

USD and the final disposal. Attention must also

be paid to the associated problem of keeping free

from refuse and litter, the common parts of buildings

held in multi-ownership. The 20 foot rule does

not of itself provide a solution to the problem

and successful management corporations cannot easily

be promoted by the authorities under the present

law* Such a study is likely to provide specific

proposals for any necessary legislation or

reorganisation. We consider it premature for us

to give any detailed recommendations in this report*

We note also that there are the problems arising

from the presence of factories in domestic premises,

The Government is aware of this problem and has

already taken steps to deal with it. We welcome

this action and in paragraph 6.4(ii) we recommend

a further measure to prevent new factories being

established in existing buildings.

Collection points have been provided outside

buildings where USD vehicles can collect the refuse*

There is a new programme for the provision of more

off-street collection points, and they will be of

a higher standard than the old. While there are,

however, no minimum stnadards required by law, the

USD has, as stated above, laid down certain criteria

for their construction.


120 '• Environmental Resources Ltd

New Territories

In the New Territories a three year programme is

under way for the construction of refuse collection

and,disposal facilities points. Until adequate

facilities for the collection and disposal of refuse

are provided, there can, of course, be no effective

protection by legal measures.

A different and more difficult problem arises with

those dwelling on boats in typhoon shelters.

Refuse from these boats is frequently dumped over

the side, much of which drifts round the coast to

foul other areas. This is, of course, an offence

under the Summary Offences Ordinance S4, but

enforcement under present conditions is virtually

impossible.

5-4 Collection - Proposed Control Measures

i- Household^Refuse

It has already been noted that the Urban Services

Department faces considerable difficulties in

ensuring environmental protection during the

temporary storage and collection of household refuse,

and we have noted that a special study of this

problem should be undertaken.

In view of this possible study, and because no

substantial question of costs or policy is involved,

as we have already stated, we consider it would be

oremature for us to raake any detailed proposals at

this stage* tfe think it helpful to suggest, nevertheless,

that legislation along the following lines might provide

a useful framework within which new procedures might

be developed and enforced:

1. More precise specifications should

be laid down for household receptacles

for refuse. The Urban Services

Department could supply them at cost

price.


121.

Environmental Resources Ltd

2- Building regulations to require

adequate facilities within blocks

of domestic flats for the

temporary storage of household

refuse and its collection by the

Urban Services Department.

3* Powers to require the occupiers of

multi-storey buildings in

residential use to appoint a

management corporation for each

building, if necessary backed by

default powers granted to the Urban

Services Department.

More detailed recommendations will be submitted in

our Stage II report- We do, however, regard this

as an on-going process. This will require an

authority with a duty to review the collection

facilities and procedures from time to time and to

make such further recommendations as they think fit.

As we have also noted, the high moisture content

of wastes causes some disposal problems. An

examination of the cause of this problem should

be undertaken: we find it difficult to believe that

humidity alone is responsible* If necessary,

steps should be taken to require that the refuse

is kept dry during collection and transfer to

disposal centres.

ii.

Small Craft

We appreciate that refuse from boat dwellers presents

a particularly intractable problem. Licence

conditions relating to the provision of receptacles,

and regulations governing the disposal of refuse


2 * Environmental Resources Ltd

would be the most difficult to enforce; yet openly

to permit dumping overboard and to concentrate on

clearing the resulting mess would be a policy of

despair. We accept that no measures to prevent

the dropping of litter can be wholly successful, but

have been impressed by the success of the Keep

Hong Kong Clean campaign. A similar campaign is

unlikely to have a comparable effect on boat-dwellers

but with a community contained in a small area some

extra pressure can be brought to bear. Once again

we must also emphasise that it is unreasonable to

penalise improper disposal until facilities for

proper disposal have been provided.

Detailed proposals on measures to reduce this litter

belong to Stage 2 of our Report/ and further

consultations with Marine Department will be necessary

before any final recommendations can be made; but

because some measure of policy is involved we here

outline a proposal for consideration.

i. The duties of the present harbour

cleansing service to be extended

so as to cover:

1. a refuse collection service

for small craft;

2. the present cleansing

service.

ii.

iii*

Licence fees to be increased so as

to make a substantial contribution

to the extended service.

A publicity campaign to be mounted

to impress on boat-dwellers that

licence fees can be kept down by use

of the collection service.

With the introduction of a collection service/

we feel that consideration might be given to

giving USD the responsibility for the whole

operation.


12 3 * Environmental Resources Lid

The Environmental Impact Associated with Solid

Waste Pretreatment and Disposal

In this paragraph we discuss the impact associated

with the disposal of solid or semisolid wastes other

than those wastes that are inherently potentially

hazardous; the latter are discussed below.

In general, refuse disposal centres (transfer points,

incinerators, composting, controlled tips) are a

source of local environmental nuisance: there is

dust and smell resulting from their operation and

from the transport of the refuse,and potential

nuisance from flies, birds and vermin in the case

of tips. These nuisances may be overcome by high

standards of operation and maintenance and the

evidence available to us suggests that disposal

centres and sites are operated to a high standard

in Hong Kong. We were particularly impressed by

the Gin Drinker's Bay site, operated by contractors

to standards set by PWD.

But the effect of these localised nuisances can be

minimised by good planning: ensuring that where

possible such centres do not adjoin residential

areas, and, where they do, that adequate precautions

are taken to reduce any nuisance (see 5.7).

Specific problems associated with the incineration

and tipping are discussed below.

Refuse incineration in Hong Kong has led

to air pollution problems associated with

dust and grit emitted.

It was calculated by the Air Pollution

Control Officer that quantity of dust and

grit emitted from the stacks was

equivalent to 0.9% of the total quantity

of refuse burnt. By the use of

additional air pollution control equipment

it would be possible to reduce this burden.


124 ° Environmental Resources Ltd

lt is difficult to estimate the cost

because each incinerator presents a

separate design problem, but we have

been informed by equipment manufacturers

that the approximate cost of reducing the

dust and grit to about 0,1% of the

quantity incinerated would be about

$HK 1O million for a new incinerator with

a throughput of about 800 tpd. This

would increase the cost of refuse

incineration by about HK$5 per tonne of

refuse incinerated. Further improvements

could be achieved (to about 0*02%) for a

further HK$1 per tonne incinerated. These

costs include the cost of cooling the gases.

On existing plant, the costs would probably

be higher because of space problems and

the difficulties of fitting the additional

apparatus.

In addition to the problems associated

with the dust and grit, the thick plume

of steam gives rise to complaints. Attempts

have been made to assist its

dispersion, but the primary cause is the

very moist nature of Hong Kong's refuse

(50%-75% compared with about 30% in the UK).

Apart from general nuisance associated with

controlled tipping the main hazards in Hong

Kong are the possibility of water pollution

from the tip leachate and from flocks of birds

attracted to the tips increasing the risk of

aircraft bird strikes.

The PWD has been investigating the problem of

water pollution and has been carrying out

experiments at the Nga Tau Mei tip. Clearly,

controlled tips should not be situated in

areas where the ground water contributes to

water draining into reservoirs.


12 5 * Environmental Resources Ltd

The Director of Civil Aviation has

commented (ref 39) that, provided the tip

is properly controlled and is not within

eight ^miles of the airport, then there is

no objection so far as possible bird

strike is concerned*

We have been told by PWD that apart from

small quantities of oily wastes, no hazardous

wastes (that is wastes which are dangerous

to humans and to fauna and flora) are disposed of,

However, we understand that some solutions

containing-chrome compounds have been disposed

of at Gin Drinker's Bay*

A considerable number of pesticides are

imported for use in Hong Kong. We have seen

no evidence that the use of these or their

residues constitute a risk.

5.6 Disposal of Wastes - Present Controls

Controls over the disposal of solid wastes by

individuals are outlined in Appendix B. They

relate mainly to deposit in public places and in

the waters of Hong Kong, and to the dropping of

litter.

The Public Works Department accepts at its tips

all wastes delivered there, and makes no charge for

their disposal.

5 • Disposal - Proposed Control Measures

If a single authority for environmental protection is

established, as we recommend, it will have overall

responsibility for pollution control. As the

disposal of solid wastes can affect land, water or

air, this is obviously the body to be responsible for


126 * Environmental Resources Ltd

waste disposal, acting after consultation with

the Solid Waste Steering Group and the interested

Departments.

There is little dangerous, hazardous or intractable

waste produced in Hong Kong, There is likely to

be more, however, as industry develops. The

Central Unit would be required to make provision in

its disposal plan for dealing with it.

The Public Works Department accepts all trade and

industrial waste when delivered to its tips. We

understand that rattan baskets, because of their

character and number, can be troublesome. The

Department may wish to consider requiring some form

of treatment, such as shredding, before delivery.

We have noted that the Public Works Department

accepts at its tipping site all trade wastes, and

disposes of them without charge. To this extent

there is an element of subsidy to those engaged in

trade and industry. We appreciate that the

imposition of a charge may result in dumping

elsewhere, but the proposed planning controls and

the licensing of disposal contractors can go some

way to preventing this. The Government may wish to

consider whether, as in other countries, some

charge should not be made for the disposal of

industrial and trade wastes.

There have been reports that dust from controlled

tipping sometimes constitutes a nuisance. In so far

as the dust arises from the tip and from roadways,

the nuisance can be prevented by spraying. The

spread of dust from the unloading process, on the

other hand, cannot be prevented. The nuisance can r

to some extent, be abated however by the provision

of screens, perhaps in the form of trees planted

at the perimeter of the site. No legal provision

is necessary to ensure that this is done, although

the people could be given the right to raise this

at a public enquiry and have the satisfaction of

seeing it incorporated as a condition in a planning

consent, but we feel that persons outside the

Government should be given opportunities to make

representations before a plan to use any new site

for tipping is put into effect.


127. Environmental Resources Ltd

The introduction of stricter controls on the

deposit of oily and hazardous wastes to the sewer

or to water courses,as outlined in Section II

is likely to increase the quantity of oily

wastes and chemical sludges requiring disposal.

We would recommend that where possible consideration

should be given to the reclamation of wastes:

- oily wastes/ provided

contamination does not exceed

10% by weight, should be

reprocessed and resold;

- consideration should be given to

the use of oily wastes that are too

contaminated as a source of fuel

to replace some of the oil

currently used for refuse

incineration; we understand that

this should be practicable and that

provided the necessary pollution

control steps are taken, it should

not cause increased air emissions;

- solvents, spent catalysts and

other sludges produced by industry

should where possible be reclaimed*

However, there will still be some chemical wastes

that will require disposal. Attention should be

paid to whether any of the tips (existing and

planned) can accept toxic wastes; if so, this

should be the priority for the use of the tip and

only that amount of refuse required to "mop up"

the toxic wastes should be deposited there*

It is possible that specialist toxic waste treatment

facilities may be required. We would estimate

that the cost of central treatment plant for toxic

sludges would cost about $15 m. to set up. This

would treat about 20 tonnes per day of sludge at

a cost of about $400 per tonne. This cost has

been taken into account in calculating the cost of

effluent controls.


128. Environmental Resources Ltd

A survey of the type and condition of oil would

be necessary before the cost of any reclamation

could be estimated. Furthermore, a system for

its collection and redistribution would need to

be set up. We estimate the value of the oil that

could be reprocessed each year to be about $5 m.

There are at present no legal controls governing

the safe disposal of toxic wastes. We understand

that some toxic liquids and sludges have been

tipped at Gin Drinker's Bay. We recommend

that scheduled industries and users of scheduled

substances should be required to notify the

authorities as to how they dispose of their

wastes.


129. Environmental Resources Ltd

5.8 Litter and the Deposit of Other Solid Wastes

The problems of accumulation of litter in the urban

areas, on beaches, in the country parks, in other

areas in New Territories and in the sea around Hong

Kong causes a considerable loss of amenity to the

community: it also represents a financial loss and,

in so far as the problem arises from the behaviour

of the individual, an unnecessary cost to the

community*

In monetary terms:

the teams of USD litter wardens

cost dbout HK$3m per year in

manpower alone;

- the Keep Hong Kong Clean campaign

will cost HK$3m in the current year;

In addition:

the cost of harbour scavenging in

1975/76 will be about HK$1.3m;

the Marine Department recognises

that about HK$4%m would need to be

spent to remove debris and refuse

from the 67 square kilometres of

harbour water; we have commented

above (5.2) that much of this

refuse probably emanates from

boat-dwellers.

the Forestry Division of the AFD

spent considerable time and effort

on the problem, collecting an

estimated 350 tonnes of refuse per

year;

litter, particularly plastic bags,

blocks the intakes of ships, power

stations, etc., considerably adding

to the cost of maintenance (Ref 24) ;

(an additional problem is plastic

nets and ropes which foul propellors) ;


Environmental Resources Ltd

accumulations of refuse in the New

Territories block streams and add

to the water pollution problems: the

AFD and the New Territories

Administration devoted time and

resources to clearing some black

spots.

It would not therefore be unreasonable to estimate

that litter costs the community at least HK$10rn per

year and possibly considerably more.

The main sources of litter are discussed in

Appendix A, 4.

5.9 Controls over Litter

Dropping litter is an offence under the Public

Cleansing and Suppression of Nuisance Bye Laws

and the equivalent New Territories Regulations

(Bye Law 4 and Regulation 4) , and active steps are

taken to enforce these laws, but the number of

offenders prosecuted does not diminish substantially

(see, Table 5.9(a)). We recognise that the Keep

Hong Kong Clean campaign has been remarkably

successful, but it appears now to have reached the

stage where a modified approach to the litter

problem is needed to effect further improvement.

Progress has been made with the removal and disposal

of abandoned vehicles. We are informed that

disposal can be profitable, and that a number of

tenders for the work have been received. There is,

however, no special provision to deter people from

abandoning vehicles. Given that the primary

objective is the prevention of pollution, as opposed

to clearing it after it has occurred, there is here

a gap in the law which might usefully be filled.

Although offenders can be prosecuted under the

Public Cleansing Prevention of Nuisance Bye-Laws

and Regulations (Bye Law 4 and Regulation 4), a

special provision which includes a power to recover

the cost of removal merits consideration.


131.

TABLE 5. 9 (a)

CONVICTIONS UNDER THE PUBLIC CLEANSING & PREVENTION OF

NUISANCE BYE LAW 4 AND THE PUBLIC CLEANSING & PREVENTION

OF NUISANCE (NEW TERRITORIES) REGULATION 4

1974

1

H.K.

Island

Kowloon

New

Territories

Whole of

Hong Kong

June

712

1,395

813

2,920

July

811

1,981

1,163

3,955

August

697

1,811

1,129

3 f 637

September

647

1,958

1,284

3,889

October

511

1,478

947

2,936

November

619

1,676

813

3,108

December

596

1,637

996

3,229

Total

4,593

11,936

7,145

23,674

Total for H.K. Island and Kowloon June/December 1974 - 16,529

Total for H.K. Island and Kowloon during full year 1972/73 - 18,1OO

Environmental Resources Ltd


Environmental Resources Ltd

5.10 Litter - Proposed Control Measures

This problem of litter is one which probably cannot

be solved by one method alone. Some progress can

be made by education and an adequate provision of

litter bins. It is an established and heartening

fact that as the environment becomes cleaner, people

develop a greater appreciation for cleanliness"

There is no evidence that prosecutions for litter

offences have had a marked and lasting effect (see

Table 5.9 (a)), and an increase in the maximum fine

is unlikely to make a substantial difference, for

courts will not impose heavy fines for what are/ in

themselves, trivial offences. To increase the risk

of detection and prosecution does more to increase the

value of the deterrent. It may, therefore, be more

profitable to concentrate supervision on specified

areas such as gazetted beaches. Reduction in

certain types of litter may also be effected bycontrols

on the use of non-returnable drink

containers and plastic bags.

The use of non-returnable containers can be controlled

by legislation which gives the Governor or Governor

in Cquncil a power to make regulations which prohibit

the manufacture, import, distribution or sale^of any

specified article made from a specified material,

or any article of a specified class which does not

meet with certain standards. The Danish Government

is considering preventing the sale of non-returnable

bottles by requiring that they should have a certain

minimum weight and the Swedish Government has given

consideration to the use of recycling taxes.

Consideration should be given to the imposition of a

recycling tax on all plastic bags and drink containers

(unless they were returnable): every bag or pack

imported or locally produced would be liable to an

additional tax (that would need to be less than the

cost of producing the packs). When the bag or

container was returned to a recycling centre the

depositor would be reimbursed with the tax. If the

plastic bags were made from thermoplastics, they

could be recycled.


13 3 • Environmental Resources Lid

The advantages of such a scheme would include

giving plastic bags and beverage

containers a value so that the

individual would be less prone to

use so many or throw them away

minimising the waste of plastic

with the consequent import saving;

encouraging local drinks

manufacturers to use refillable

containers;

recovering glass and some tins

from the refuse requiring

disposal;

a reduction in the overall waste

load.

The disadvantages include:

- the problems of abuse: the tax

would need to be set lower than

the cost of production or else

there would be a trade in

producing bags to obtain the

refund of the recycling tax;

however the increasing cost of

plastic should help to overcome

this problem;

the difficulties of using cullet

(broken glass) if the bottles

were returned broken.

Recycling taxes can also be employed to ensure that

vehicles are not abandoned. An extra HK$15O paid

by the original purchaser would be repaid to the car

owner when he delivered the vehicle back to a

recycling centre.


134 - Environmental Resources Ltd

We are aware that EPCOM has given consideration

to recycling and its potential and that any

further materials 1 reclamation will primarily

reqaire either economic or legislative incentives.

We would again stress that for every tonne of

solid waste not tipped there is a saving to

the community of about $50 (see paragraph 5.2).

5*11 Solid Waste Planning

We have stressed above that minimising the

problems associated with solid waste collection

and disposal requires above all effective

planning. The Government has already established

a Solid Waste Steering Group which, we understand,

has responsibility for forward planning for solid

waste collection and disposal. We note that

on this body the following departments are

represented: Public Works Department, Urban

Services Department, New Territories Administration

and Marine Department. We welcome this development

and recommend that it be carried one stage further.

Thus far the planning of waste collection and

disposal is placed in the hands of one body; we

feel that the whole problem of solid waste, from

restriction which may be placed on its generation,

through collection, reclamation, recycling and

final safe disposal, should be under the supervision

of one body. If our main recommendations are

accepted, that will be a central authority for

environmental protection (see Section VII). The

Steering Group could be retained as a co-ordinating

executive body. The authority would be

responsible for overall planning.


13 5 * Environmental Resources Ltd

Hong Kong has limited space available for the

final disposal of solid waste. The population

is increasing, an increase in the quantity of

refuse generated per person may be expected and

the quantity of solid waste produced by expanding

manufacturing industries will increase. But

land available for the final disposal of the

solid waste is restricted by the nature of the

Territory, particularly by the pressure for

alternative land uses, many of which conflict

with controlled tipping. We discuss below some

methods available for minimising the quantity of

waste requiring tipping*

Hong Kong currently incinerates about

1,800 tonnes of refuse per day; by

1980 the incineration capacity will

have been increased to about 2,90O

tonnes per day. Incineration reduces

the weight of refuse requiring

disposal by over 60%; it reduces

the volume even further. The ash

produced can be used for reclamation

projects (as is the case on Hong Kong

Island - see Appendix A 4*4).

Incineration in Hong Kong is not

without its problems* Its presents

an environmental nuisance (see 5.3

below). The low calorific

value of the waste and the high

moisture content result in a need

for added oil in order to burn

refuse. And incinerators are

expensive pieces of equipment to

install and operate - particularly

if stringent air pollution requirements

are to be met.


Environmental Resources Ltd

Apart from incineration, the other

alternative method of increasing the

life of the available tipping space is

to ensure that those wastes that could

be used elsewhere for reclamation projects

are not depsoited in the valuable and

limited controlled tip sites. We note,

for example, that

some incinerator ash is currently

tipped at Gin Drinker's Bay:

apparently the high metal content

and incomplete combustion of the

refuse makes the ash unsuitable

for reclamation projects or for

use as a covering material; at

least 180 tonnes of ash per day

and possibly more is currently

tipped;

about 600 tonnes per day of waste

classed by the PWD weighbridge

operators as building rubble is

tipped at Gin Drinker's Bay.

Clearly, it is necessary wherever possible

to separate out these inert materials and use

them for the reclamation projects. 50O tonnes

of rubble per day is taking up space that

could be occupied by the refuse from over

500,000 people (once the refuse has fully

settled).


13 7 " Environmental Resources Ltd

. ytsng^the^Waste Stream

Industrialised countries have been focusing

attention and diverting resources into the

development of systems to make use of the

solid waste*

One system which is not new but falls into

this category is composting. In effect,

composting speeds up the eventual

biodegradation of the organic part of the

refuse; the resulting "compost 11 is

relatively innocuous, safe to handle and

can be used as a soil conditioner, (not as a

fertiliser). The criticisms of the system

are that it is not cheap, costing HK$30 per

tonne and it is often difficult to find an

outlet for the resulting "compost"* In

Hong Kong only a limited area is under

cultivation and previous experiments with

compost were not altogether satisfactory*

In particular, glass cut the bare feet

of the agricultural workers. However, we

understand that there are plans for a new

composting plant: it is argued that the end

product can be shipped abroad or used for

covering material.

Another system is the baling of refuse and

employing the bales for reclamation work.

Experiments are planned to establish whether

the Hong Kong refuse is suitable. Baling

has advantages associated with solid waste

transport and the precompaction of the bales

reduces problems of environmental nuisance

.and settlement in reclamation.

The two types of system that have recently

been under study in Europe and North America

are those designed to utilise the energy

content,and those designed to reclaim

materials from mixed refuse streams. A note

on the available systems is included in

Appendix A, 5.7. It should be stressed

that most of the systems are little more

than experimental at present and they cannot


138 * Environmental Resources Ltd

be considered as an immediately available

option. However, most of them offer a

method for considerably reducing the solid

waste stream as well as providing a potential

source of income to offset the cost of the

plant.

iii. Mi5i5£§iSSL;^

For the quantity of waste produced to be

minimised at source/ it is necessary for

householders and traders to separate out

reclaimable materials and for the authorities

to organise a system for their collection.

We appreciate that some scavenging and

materials 1 reclamation is carried out by

private collectors; we also understand that

a large proportion of glass bottles

(beverage containers/ etc.) are returnable.

Nevertheless/ the information available to

us on the composition of refuse and other

solid wastes would suggest that there is still

further potential for minimising the waste

stream (see Appendix A/ 4.7). We estimate

that over 100 tonnes of glass are thrown

away daily mainly in the form of bottles.

Glass has little value as a material for

recycling once it forms part of the waste

stream; but a well-constructed bottle is

capable of between 15 and 40 trips before

it need be thrown away. Investigations

should be conducted to determine whether the

optimum number of bottles are being returned

or whether the deposit should be increased to

provide an added incentive (see 5.10).

We have doubts about whether Hong Kong

householders would be prepared to further

separate out paper/ tin cans/ glass/ etc.;

since schemes in Europe have not been

particularly successful.

However/ traders and industrial concerns should

be encouraged to separate out reclaimable

materials: their wastes are frequently more

homogeneous.


139 • Environmental Resoorces Ltd

We believe it to be essential that this limited

space availability should be taken into account

when planning for the disposal of waste. In

particular, it should be noted when comparing

pre—treatment methods and their costs: only

incineration substantially reduces the quantity of

refuse for final disposal.

In Table 5. 12 (b) we include a calculation designed

to exemplify this point. For the purposes of the

example, we have assumed that 1800 tpd are

incinerated, 1400 tpd are tipped and 800 tpd are

composted: this may be the situation in the late

1970s. We have made two sets of alternative

assumptions:

that compost is only used for

covering and reclamation of the

disposal site as,alternatively /

it is disposed of elsewhere;

that the cost of tipping is only

$20 per tonne (about the current

cost of new sites) or that it is

$50 per tonne since tipping sites

are a limited resource in Hong

Kong and should be valued more

highly than the alternatives such

as incineration.

It can be seen that if the compost is only used for

cover and site reclamation the cost per tonne of

raw refuse disposed of will be about $42 per tonne

(if the tipping is valued at $20 per tonne) or

$64 per tonne if the higher tip value is used.

This compares with $44 and $51 respectively for

the cost per tonne of waste incinerated. If the

compost is used on soil, then the cost is only

$28.2 (assuming some is used for tip cover).

If the compost were used for new reclamation projects,

there would be a further saving of between $5-10 per

tonne.


140 • Environmental Resources Ltd

The purpose of this example is to draw attention

to the need to examine alternatives in the context

of the total situation: particularly in the context

of the limited tip space. If compost ends up by

being tipped, it may prove an expensive option.

Further and more detailed consideration will be

gvien in our Stage II report to planning the

disposal of solid wastes. For the present purpose

it is sufficient to say that:

(a)

the control authority and its

advisers should be required to -

i. estimate the composition

and sources of wastes

generated in the Territory,

particular attention being

paid to trade wastes

and the moisture content of

various classes of waste;

ii.

ensure, where possible, that

wastes suitable for

reclamation projects are

not deposited on controlled

tips, except where they are

used for covering purposes.

(We have in mind particularly

ash and builders 1 rubble).

iii. to investigate in detail

what constituents of solid

wastes could be reclaimed,

to be recycled or exported;

to examine what incentives

can be employed to encourage

reclamation;


14 -^ - Environmental Resources Ltd

iv.

appraise the various

possible methods of

treatment and disposal,

e.g. incineration/

composting, baling, to

ensure that the Territory

is employing the most cost

effective means of

disposing of its solid

wastes;

(b) an integrated approach is required

to the whole problem of solid waste

collection and disposal, and for the

right decisions to be taken, this

approach must be based on analyses

which take into account the whole

problem.

Wastes

The Authority should also be concerned with the

safe collection and disposal of hazardous and

oily wastes.

Further information is required on:

the quantity and nature of

trade wastes currently tipped;

the quantity and value of trade

wastes that will be tipped given

effluent control schemes (we have

made some quantity estimates -

see Section II).


14 2 * Environmental Resources Ltd

Where the waste is hazardous to the water supply

or there is danger of other contamination (e.g.

build up of toxic metals) , then the waste should

not be tipped unless -

the tip is known to be secure and

it can be shown that the leachate

will not be released into the

environment;

adequate precautions are taken

associated with the tipping of

the waste to minimise any

potential hazard to tip operators,

etc.

Should the studies show that the quantity of waste

is such that further facilities are required to

destroy toxic wastes, such a facility should be

provided and operated, preferable by the Government

and under conditions specified by the Government,

Reclamation of Trade Wastes

Many trade wastes arise in a homogeneous form: that

is, they are not mixed in the same way as household

and market refuse. In particular, waste oils,

tyres, some plastic wastes, metals and board.

We understand that a large proportion of the latter

are already reclaimed.

We proposed that the Authority should set up

(preferably under contract) a waste reception centre

for oily wastes and pay an incentive sufficient to

encourage traders to enable the waste to be

reprocessed or substituted for refuse incineration

oil without loss to the reprocessors or the

Government. The deposit of qily wastes to

watercourses or on land should be forbidden (see

Sections II and III)-


143. Environmental Resources Ltd

We propose that an investigation should be held

into the potential for the re-use or reclamation

of rubber. Some can be used (and, we would

assume, already is) for retreads. A local plant

could use local reclaim to save on imports.

When information is available on the question of

other industrial wastes, the reclamation potential

of solvents, catalysts, sludges, etc., should be

investigated.

Litter""

~2-~32y^

We recognise that overcoming the problem of litter

requires education, exhortation and effective

legislation.

However, recycling taxes applied to non-returnable

containers, plastic bags, cars, etc., would encourage

their return to a centre; in some cases, the material

could be re-used. This should be investigated.

Recycling incentives would encourage the use of

returnable containers and reduce the solid waste

stream.

5.12 In the following Tables we summarise some

of the alternatives for minimising the solid waste

problems discussed in this Section (5.12(a)) and

estimate of the cost of refuse disposal 5.12(b).


TABLE 5.12(a)

Problem

Environmental &

Other Implications

Possible Solutions

Comments on Status

of Solutions

Operational &

Environmental

Factors

Economic Balance

1. Limited

Final

Disposal

Space

Increasing quantity

of solid waste

recovery disposal.

Tip sites limited

& land valuable.

Cost of tipping

$8.80-$28.80 per

tonne. Value to

Territory of limited

resolve should be

set higher - at

least $5O per

tonne.

1.1 Incineration of

refuse.

Currently 18OO

tonnes incinerated

further 9OO tonnes

capacity planned.

Weight reduced

to 40% . Ash

suitable for

reclamation

projects .

Ferrous metals

may be reclaimed

But causes air

pollution (see 3

below) .

High capital cost

($2. 9m per tonne

hour) . Cost of

incineration

$4O per tonne

plus $1.5 per

tonne for further

pollution control.

Landfill cost

saving equivalent

to 4O% of weight

incinerated.

1.2 Only tip wastes

unsuitable for

reclamation

projects.

Currently at least

78O tonnes of waste

suitable for

reclamation projects

disposed of to

landfill.

Saving in space

equivalent to new

incinerator or to

household refuse

from about 1

million people

could possibly be

achieved.

Saving of up to

5OO tonnes of

landfill. May

save cost of new

incinerator or

delay expenditure*

/contd. „ . .

HONG KONG - CONTROL OF THE ENVIRONMENT Environmental Resources Ltd


TABLE 5.12 (a) - continued

Problem

Environmental &

Other Implications

Possible Solution

Comments on Status

of Solutions

Operational &

Environmental

Factors

Economic Balance

Limited

Final

Disposal

Space

(contd)

Increasing quantity

of solid waste

recovery disposal.

Tip sites limited &

land valuable. Cost

of tipping $8.8O-

$28.8O per tonne.

1.3 Utilise waste

stream to save

tipping space.

(i) Composting

Initial experiments

unsuccessful.

Further experiments

associated with

sewage sludge

composting to be

tried.

No reduction in

quantity (beyond

that which would

occur naturally

at tip site) but

end-product

suitable for

reclamation

projects and as

soil conditioner,

therefore save

space with

minimum hazard.

Capital cost abou

HK$1.6m p.t.h.

Cost of compostinc

about HK$30

per tonne.

Providing all

compost used for

reclamation or

for soil then

saving of cost

disposal

equivalent to

quantity

composted.

en

(ii) High density

baling.

Examination to be

carried out of

where system

suitable for HK.

May cause slight

effluent problem

Saves on transport

costs and on tip

space it bales

suitable for

direct reclamation

Saving in tip

pace in all

refuse baled. May

be saving in

transport costs.

Baling costs

c.HK$12 - 48

per tonne.

HONG KONG - CONTROL OF THE ENVIRONMENT Environmental Resources Ltd


TABLE 5.12(a) - continued

-

*

Problem

Environmental &

Other Implications

Possible Solutions

Comments on Status

of Solutions

Operational &

Environmental

Factors

Economic Balance

1. Limited

Final

Disposal

Space

(contd)

Increasing quantity

of solid waste

recovery disposal.

Tip sites limited

& land valuable.

Cost of tipping

$8.8O-$28.8O per

tonne .

(iii) Energy

reclamation

Alternatives of

pyrolysis and

systems to separate

out combustible

fraction. High

moisture content

will reduce

calorific value of

latter and may cause

other problems.

But new technology

not yet fully tried.

See also Appendix A,

4.7

Reduce quantity

of refuse for

tipping by at

least 6O% : more

if other

constituents

(metals, etc.)

were separated

out as part of

system.

System unlikely

to show much

profit: may break

even. Benefit of

cost of about

6O% of quantity

processed.

(iv) Materials

reclamation

from household

refuse.

Separation may be

undertaken by

similar systems to

energy reclamation

systems (Appendix A

4.7). Fibre

reclamation and

metal reclamation

has best potential.

Local reclamation

industry or

foreign outlets

would need to be

established.

Saving of about

3O-4O% of quantity

processed.

System unlikely

to show much

profit: may break

even. Benefit of

about 4O% of

quantity processed

in terms of

disposal space

saved.

/contd . . .

HONG KONG CONTROL OF THE ENVIRONMENT Environmental Resources Ltd


TABLE 5«12(a) - continued

Problem

Environmental &

Other Implciations

Possible Solutions

Comments on Status

of Solutions

Operational &

Environmental

Factors

Economic Balance

Limited

Final

Disposal

Space

(contd)

Increasing quantity

of solid waste

recovery disposal.

Tip sites limited &

land valuable. Cost

of tipping $8.8O -

$28.8O per tonne.

(v) Materials

reclamation

from trade &

industrial

waste.

These wastes tend

to be more

homogeneous (e.g.

plastic effluents);

also use of waste

oil & tyres for

reprocessing &

retreading possible

Removal of

lubricating oil

waste from

environment (8.1

below). Only

certain proportion

of tyres can be

used for

retreading or

reclaim (see

Appendix A r 4.6) ,

Other materials

could be reclaimed

if satisfactory

markets/centres

available.

Oil reprocessing

should show some

net benefit even

if incentive paid

for delivery.

Reduction of

potential tip

hazard.

Encouragement of

reclamation could

show small saving

in space - say

5O-1OO tpd.

1*4 Minimise waste

stream by

reclamation of

materials at

source by

increasing

incentives, e.g.

recycling tax

/contd.

Private collectors

currently reclaim

paper and ferrous

metal. Separation

by householder

probably impractical

But re-use could

be encouraged by

/contd. :

Could reduce

quantity of refuse

Saving difficult

to estimate, but

at present about

185 tonnes of

glass disposed of

per day.

Also

/contd.

Small savings in

disposal costs.

Also saving in

cost of

containerisation.

/contd...

HONG KONG - CONTROL OF THE ENVIRONMENT Environmental Resources Ltd


TABLE 5.12(a) * continued

Problem

Environmental &

Other Implications

Possible Solutions

Comments on Status

of Solutions

Operational &

Environmental

Factors

Economic Balance

1 * Limited

Final

Disposal

Space

(contd)

Increasing quantity

of solid waste

recovery disposal.

Tip sites limited &

land valuable. Cost

of tipping $8*8O-

$28*8O per tonne.

1.4 Contd/. . .

on re-usable

bottles ;

higher tax for

one-trip bottles

use of selective

taxation .

reduce glass in

compost and help

litter problem

(5~1) . Removal of

paper causes

incineration

problems .

2. Environmental

Impact of

Disposal

Systems

Waste transport &

disposal tends to

be intrinsically

dusty/ smelly/

noisy and to

attract insects &

vermin .

2*-** Planning so that

the hazard is

minimised is an

essential

starting point.

Disposal centres

must be isolated

where possible

from residen tial

areas.

The siting of a

new incinerator

adjacent to Lai

Chi Kok has caused

complaints.

The crowded and

compact nature

of Hong Kong makes

this solution

difficult.

Transport

constraints must

also be taken into

account .

Cost of

additional

transport if

waste transported

further from

residential areas.

CO

3, Environmental

Impact of

Incineration

Steam f dust & grit

in air emissions.

I

3.1 Air pollution

control

equipment*

Existing equipment

unsatisfactory

(ref .61A) . Further

equipment planned.

Equipment

difficult to fit

on existing

equipment .

High capital

costs (in excess

of $lOm per

plant) . Adds $5

or more to cost

of incineration

per tonne,

HONG KONG CONTROL OF THE ENVIRONMENT Environmental Resources Ltd


TABLE 5,12(a)

Problem

Environmental &

Other Implications

Possible Solutions

Comments on Status

of Solutions

Operational &

Environmental

Factors

Economic Balance

3 . Environmental

Impact of

Incineration

(contd)

Steam, dust & grit

in air emissions.

3.2 Shut down

incinerators

Incinerators

currently both

reduce quantity of

waste but also

make it suitable

for reclamation

projects thereby

saving on space.

Further savings on

transport.

Alternative

disposal for

about 175O tpd

would need to

be found .

Saving of

about $12 per

tonne (running

costs only) .

Depending on how

tip space is

valued, added

cost would be

up to $25 per

tonne .

4. Controlled

tipping

Apart from general

nuisance , leachate

from tip can

contaminate water

below*

4.1 Treat leachate

at drainage

point

PWD currently

carrying out

experiments at

Ngau Tarn Mei

4.2 Planning: the

siting of the

tip in a

geologj cally £

geographically

suitable area.

Leachate is only

one factors to be

taken into account

when siting tips :

transport, etc.

important .

Could add to

transport costs.

/contd. . .

HONG KONG CONTROL OF THE ENVIRONMENT Environmental Resources Ltd


Table 5,12 (a) - continued

'roblem

Environmental &

Other Implications

Possible Solutions

Comments on Status

of Solutions

Operational &

Environmental

Factors

Economic Balance

Controlled

Tipping

(contd)

Deposit of

Hazardous

Wastes

Apart from general

nuisance, leachate

from tip can

contaminate water

below.

Hazardous wastes

can be a danger

to disposal site

operators and to

local environment

4*3 Do not permit

tipping of

hazardous

wastes»

5.1 Require

notification

of all

hazardous wastes

& forbid their

tipping unless

under licence.

No hazardous wastes

apart from oil

currently tipped.

Oil should be

reclaimed (1.3(V)),

other hazardous

wastes investigated

(5, below).

Although only oil so

far identified,

attempts to keep

heavy metals, etc.,

out of the sea

likely to give rise

to toxic sludges.

'Safe 1 tips

should be kept

for more

hazardous wastes.

If waste too

hazardous,special

treatment will be

required (5.2.),

Oil reclamation

should pay for

itself. At presen

apparently no

other hazardous

wastes - so no

cost.

At least one

extra member of

staff will be

required in first

instance. Cost

c. HK$4OOO per

month.

tn

O

5.2 Special

disposal

facilities for

wastes too

hazardous to be

tipped.

May be required if

no tip can safely

receive treatment

sludges.

Special facilities

(e.g. chemical

Sealosafe or

incineration) are

expensive.

Cost of disposal

by special means

upto 20 times

that of tipping-,

cost at contract

facility for toxic

sludge cost would

HONG KONG CONTROL OF THE ENVIRONMENT Environmental Resources Ltd


TABLE 5.12( a ) - continued

Problem

Environmental &

Other Implciations

Possible Solutions

Comments on Status

of Solutions

Operational &

Environmental

Factors

Economic Balance

6. Refuse

Accumul-

Amenity and health

hazard.

6 . 1 Internal sys ternsUSD to brief

(refuse chutes, consultants,

plastic bags) to

reduce

opportunity for

spillage, etc.

6.2 Individual (s) to

be responsible

for refuse

accumulation .

Already f 2O foot

rule 1 * Problems of

management

committee and their

standards currently

under study.

7. Litter

Reduces amenity

hazard to shipping,

cleaning up

programmes

expensive.

7.1 Programmes of

education, etc.

'Keep Hong Kong

Clean 1 campaign has

achieved

considerable

improvement .

'Amenity 1 difficult

to value. Total

costs (including

costs of control)

of litter probably

exceed $lOm per

year .

/continued. . .

HONG KONG CONTROL OF THE ENVIRONMENT Environmental Resources Ltd


TABLE 5.12{a) - continued

Problem

Environmental &

Other Implications

Possible Solutions

Comments on Status

of Solutions

Operational &

Environmental

Factors

Economic Balance

7. Litter

/contd.

7.2 Recycling

programmes.

Incentive schemes

to encourage re-use

of containers and

return of plastic

bags.

Plastic bags &

bottles said to

be main litter

nuisance.

Incentives for

their return to

centres could

help with litter

and solid waste

load.

Schemes should

pay for themselves

en

to

8, Refuse

from

Boatdwellers

Major cause of

harbour £ beach

pollution from

refuse.

8,1 Programme to

provide

facilities &

educate boatdwellers

.

HONG KONG CONTROL OF THE ENVIRONMENT Environmental Resources Ltd


153.

TABLE 5.12 (b)

COMPARISON OF PRETREATMENT AND DISPOSAL COSTS GIVEN

ALTERNATIVE ASSUMPTIONS RELATING TO TIP COSTS & DISPOSAL

OF COMPOST

INCINERATION

1800 tpd

COMPOSTING

800 tpd

DIRECT TIPPING

1400 tpd

Pretreatment

Cost per tonne (i) HK$

Total cost for quantity

shown

HK$000

4O.O

72.0

30.0

24.0


-

Disposal

Quantity remaining for

disposal (ii) , tpd

Use of residues for

cover and tip

reclamation (iii) , tpd

Saving on cover, etc.

(iii)

HK$OOO

Amount for disposal, tpd

650

2OO

2.0

450

700

140

1.4

560

1400

-

-

1400

Cost per tonne for

tipping (v) HK$

2O. 0 50.0

20.0 50.0

20. O 5O.O

Cost of tipping

HK$OOO

9.O 22.5

11.2 28.0

28.0 70.0

Total disposal cost per

tonne :

I if compost tipped

HK$

II if compost tipped

HK$

43.8

43.8 51.3

43.8 51.3

42.3

42.3 63.5

28.2 28.2

20. 0

20.0 5O.O

2O. O 5O.O

Notes: (i) Maunsell (Ref 9) costs of $38.5O for incineration and

$27»5O for composting rounded up.

(ii) After reduction for incineration and assuming some

further reclamation from compost.

(iii) Incineration residue can be used for tip cover and

compost for cover and for final reclamation. Assume use

of ash for daily cover at Vth of total tipped by

weight and use of compost at l/5th of weight tipped

for final reclamation.

(iv) Cost of cover or other reclamation material would be

$1O per tonne. Use of residue and compost saves this.

(v) Figures in italics are to include the value of tipping.

(vi) Two conditions: Condition I assumes that compost is not

otherwise disposed of; Condition II assumes it is not

tipped but recovered at no net cost to the community.

Environmental Resources Ltd


154. Environmental Resources Ltd

SECTION VI

THE ROLE OF PLANNING


155.

Environmental Resources Ltd

VI

THE ROLE OF PLANNING

6.1

In "the previous sections we have drawn attention

to the role of planning measures in protecting the

environment and minimising pollution.

Overall land-use planning can assist the Territory

to meet the conflicting demands of the community:

in particular, the demand for industry, tourism,

recreation, agriculture and water catchment. We

have noted (Appendix A, 1.5) that it is believed

that tourism will become increasingly important

to the economy of Hong Kong; and that to maximise

the potential, consideration has been given to

developments in the New Territories (for example,

the Sai Kung peninsulas) to encourage tourists to

lengthen their stays. If there are plans for tourist

developments in the country areas, it will clearly be

necessary to limit the growth of industry and pig

farming in that area. Similarly, we have noted the

increased demand for outdoor recreation and the

establishment of the Country Parks to cater for this

demand (Appendix A 1.12).

In the water catchment areas, the Water Department

has been successful in limiting activities incompatible

with water catchment. But in other areas in the

New Territories there is concern that lack of caution

will lead to a gradual deterioration as land

previously designated or used for agricultural or

horticultural purposes is developed for industrial

purposes * Over the next ten years new towns are to

be established at Sha Tin and Tuen Mun; and Yuen Long

is expected to increase in size. It is government

policy to attract industry to these new towns and

industrial zones will be set aside.

It is our view that no measures to protect the

environment will be effective if developments are not

controlled by land use planning measures. This is of

particular importance in the New Territories.


15 6 - Environmental Resources Lid

In the urban areas it is planning that frequently

provides the most effective method for minimising

the impact from pollution. For example, traffic

fumes and noise undoubtedly cause a serious nuisance:

it is likely that the most cost-effective method of

reducing the nuisance would be to curb certain vehicles

at certain times as part of a comprehensive traffic

policy. Aircraft cause a severe disturbance to schools

as well as to hospitals and local residents; and yet

we calculate that a considerable proportion of

Hong Kong's pupils are in schools that are located

under the flight path. The Lai Chi Kok incinerator's

fumes cause distress to the inhabitants of the adjacent

high rise buildings: but this estate was built after

the incinerator was commissioned. Residents in

multi-storey blocks complain about noise and the

nuisance from industry located in these same blocks;

in many cases these blocks have been designated for

residential use.

Effective planning can also ensure that adequate

facilities exist for the storage, collection and

disposal of waste. Without a satisfactory system,

there is every possibility that wastes will give

rise to nuisance and health hazards.

We are aware that there are many pressures and

constraints other than environmental considerations

that govern the Hong Kong situation and inhibit the

use of planning as a tool for environmental protection,

However, in many cases it is these very pressures and

constraints that make effective environmental planning

essential $o as to allow the expanding population to

undertake their various environmentally incompatible

activities*

There are two problems to face. One is the planning

of new development areas. The other is that created

by the unplanned and even unauthorised developments

in urban areas: here some separation of sensitive

developments from those which are sources

of pollution will be necessary to attain quality

objectives which approximate those considered

acceptable in other communities.


15 7 * Environmental Resources Ltd

In the following paragraphs we comment on the existing

controls and make proposals for additional land-use

planning controls.


Emironrnentai Resources Ltd

6.2 Existing land-use controls

It: is unnecessary to comment at this stage on the

inadequacies of the present Town Planning Ordinance,

These are well known, and a new bill to replace it

will soon be drafted.

It is pertinent to comment, however, on the degree

of co-ordination between planning powers and related

controls* Where there is a multiplicity of controls

governing one activity, in this case the development

of land, even though those controls are applied for

different purposes, close co-ordination between

them makes not only for more coherent legislation,

with one form of control supplementing another,

but for more effective enforcement. Examples of

this kind of co-ordination are found in the English

law in the relationship between planning permission

and the grant of an industrial development certificate

(see Town & Country Planning Act 1971 S67) and

"office development permits" (see Town & Country

Planning Act 1971 S74) and the grant of licences

to dispose of waste (see Control of Pollution Act

1975 S5 (2)) .

The use of lease conditions is as old as the Colony,,

while Colony and Town Plans are relative newcomers.

This has given rise to some difficulties, for existing

leases may contain conditions inconsistent with town

plans. The difficulties arise where the plans are the

more restrictive. Under present law the Board may

ask the Governor in Council to resume possession of

the land where existing development interferes with

plans for the layout of an area (Cap. 131 S4(2)K

If he does so, there is an obligation to pay compensation,

which is a powerful inhibiting factor (see Appendix B,

apragraph 4.3). In other cases, however, the town

plan, enforced through Building Ordinance (Cap. 123

S16 (1) (d) may prevent development which would have

been permitted under the lease conditions. In that

case the lessee has rights which he acquired from the

Crown for a consideration, but which he can no longer

exercise, and for whose loss he receives no compensation.


D * Environmental Resources Ltd

These are inescapable difficulties created by the way

the law has developed. For the future, however, there

is still no provision which directly links the

conditions of new Crown leases with town plans.

The Town Planning Board is concerned with "the

promotion of health, safety, convenience and

general welfare of the community" (Cap. 131 S3). The

Crown, on the other hand, must take many considerations

into account, some of which may conflict with those

of the Board. These conflicts"must, and doubtless

are resolved, but a link between the two powers would

remove any possibility of anomalies, and render

enforcement measures complementary 0

It is noteworthy also that the Crown has increasingly

used lease conditions to exercise some degree of

pollution control (see Appendix B, paragraph 4.4).

This is a sensible and commendable practice when powers

granted to other authorities are inadequate for that

purpose. This form of control, however, is necessarily

crude. In particular it is inflexible, and the sanctions

which may be used are too heavy for all but the most

serious or persistent infringements.

Both lease conditions and town plans are linked with the

control powers under the Buildings Ordinance (see

Building (Administration) Regulations Reg. 16, and

Building Ordinance S16 (1) (d)). With the passing

of the proposed new town planning legislation, reliance

on these control powers will probably no longer be

necessary, but the requirement of compliance with town

plans will remain a useful enforcement process. There

is one respect, however, in which the controls under

the Building Ordinance might usefully be extended.

There is as yet no provision ander the Ordinance or

Regulations to ensure that a multi-storey block for

residential purposes has refuse storage and collection

facilities which today may be regarded as adequate.

Control over the use of premises as a factory, by

means of provisional registration under the Factories

and Industrial Undertakings Ordinance (Cap. 59 S9) ,

is exercised for the benefit, inter alia, of persons

living nearby. In particular, the Commissioner for

Labour seeks to protect those people from undue noise

nuisance. As yet there is no co-ordination with any


16 °* Environmental Resources Ltd

other form of land-use control. Even where the

applicant will clearly be in breach of lease conditions,

and to that extent acting illegally, provisional

registration is not for that reason withheld. If

the proposed new Factories and Industrial Undertakings

(Amendment) Bill 1975 is passed, however, registration

of an undertaking other than a service trade on the

ground floor will not be permitted in any new nonindustrial

building. This is to be welcomed and will

be in line with the new policy relating to enforcement

of lease conditions and the work of the recently

formed Lease Enforcement Unit. There will remain,

however 9 the anomaly of provisional registration of

factories in existing residential buildings. It

is hoped that lease enforcement will later extend to

existing factories, for in so far as dirry and

noise generating activities are not separated from

residential accommodation, pollution control is

rendered so much more difficult. Closer co-ordination

between lease conditions and provisional registration

would not only remove anomalies, but render future

enforcement measures complementary. (Factories in

residential buildings are for convenience dealt with

under the heading "Noise 1 )-


ol *

Environmental Resources Ltd

6.3 Proposals for additional land-use planning controls

Land-use planning legislation

As we have stated above, controls over land-use can

be used to reduce pollution problems, and that the

absence of planning, or inadequate planning can

aggravate them. (It is noteworthy that all the

countries of the European Economic Community use some

forms of land-use control to prevent increases in

pollution damage).

A new town planning bill is now in preparation, based,

we understand, on the United Kingdom Town and Country

Planning Act. We know little of the details of this

proposed legislation, but we do suggest that the

following provisions, which are relevant to planning

legislation, would help in the control of environmental

pollution.

i. "The improvement of the physical

environment" to be expressly stated

as a relevant consideration in

preparing plans and in granting

planning consents. (The words in

quotation marks are used in the

United Kingdom Town and Country

Planning Act 1971 S7 (3) (a), which

deals with the preparation of

structure plans).

ii.

Every application for planning

permission to be accompanied by a

statement giving an estimate of the

waste which will be generated by the

proposed new development. This

could vary from a statement such as

"Domestic sewage and refuse from a

block of residential flats for 2OO

families/" to a detailed statement

relating to a new chemical plant.


16 2 * Environmental Resources Ltd

iii.

The Secretary for the Environment,

after consultation with the principal

officer of the Central Unit for

Environmental Protection (see

Section VII), is to have power to

require the submission of an

environmental impact statement of

such nature as he shall determine.

Appeal against the requirement to the

appeal tribunal to be established

under the Act. Details to be covered in

Stage II.

It is clearly impractical for the Control Unit to

view every application for planning permission in

order to decide whether or not an impact statement

is required. We believe it should be left to the

discretion of the Planning Authority to decide

whether or not to pass the application papers to

the Secretary of the Environment and to the Central

Unit for Environmental Protection. However, this is

a question that raises procedural difficulties and

that requires further discussion before we can make

any definite recommendations.

The cost of the preparation of the statement should

be borne by the applicant. If the Secretary of the

Environment should require in addition a statement

prepared by an organisation independent of the

applicant, then the cost of this additonal statement

should be borne by the government. However, we hope

that the setting up of the Central Unit will obviate

the need for the use of independent consultants in

this context.


15 3 • Environmental Resources Ltd

6.4 Co-ordination with other forms of control

In paragraph 6.2 we commented on the degree of

co-ordination between existing town planning and

other forms of control of development. For the

reasons given in that paragraph, we consider that

it would be advantageous to link those controls in

the following way:

New leases not to permit development

which conflicts with -development plans

published under the new legislation

Lease conditions which are positive

in form not to conflict with land-use

planning consents. We appreciate that

this could create administrative

difficulties, but if both a new lease

and planning consent is needed, we see

no reason why a provision that the two

should not conflict should itself be

a cause of delay.

ii.

Provisional registration under the

Factories and Industrial Undertakings

Ordinance S9 not to be granted unless

the proposed use of premises is permitted

under the terms of an existing planning

consent.

Building regulations

Proposals relating to the powers of control granted

by the Building Ordinance appear in the relevant

sections*


15 4 * Environmental Resources Ltd

SECTION VII

THE CONTROL AUTHORITIES


Environmental Resources Ltd

:i THE CONTROL AUTHORITIES

In the previous sections, we have discussed the

environmental problems facing Hong Kong and we

have outlined the action that might be taken to

protect the environment and improve its quality.

We have indicated that the solution to many of the

major problems will require a planned and

integrated approach taking account of scientific,

technical, economic and social factors. We have

proposed a scheme for legislation that will form

a framework for a flexible system of control;

we have stated that the imposition of fixed

standards would not, in most cases, be the most

economic method for achieving an improvement in

the quality of the environment

But the success of a flexible system of control

will depend primarly on its administration. The

authorities will have to be competent not only to

a Pply the powers of control they are given, but also

to develop a programme for progressive improvement,

and adapt the controls in response to technical and

industrial development, changes in society and

social habits, and changes in economic circumstances*

To some extent, it will also be for the authorities

to promote change, e.g. further progress in the

technical development; the adoption of new techniques

which have been developed elsewhere, changes in

agricultural practices.

In order to proceed with the programme of environmental

protection that we have proposed, the functions of

the control authorities will include:

1. Determination 7 or advice on the

determination, of environmental

objectives and when and how these

are to be implemented. The

work will include:

monitoring of the

relevant receiving

medium;


16 6 * Environmental Resources Ltd

estimate of damage, or

comparison with some

accepted standard;

where necessary or

desirable, consultation

with representatives of

interested parties;

application of Government

policy;

decision on objectives or

standards to be adopted:

these may take the form of

environment quality objectives

and standards, emission standards

process standards or some other

form of protection standard.

2, Advice on control measures to be applied

and the most cost effective methods for

waste disposal.

3. Enforcement.

This will include monitoring

or surveillance, and the

application of enforcement

procedures as appropriate.

4. Promotion of improved practices and the

adoption of better plant and equipment,

e.g. in agriculture and industry.

5, Promotion of research into and

development of recycling, cleaner

products and processes, and less

damaging ways of disposing of waste.

In this section, we outline our recommendations for

the organisation and powers for the authorities who

will administer the proposed legislation.


167 - Environmental Resources Ltd

7.2 At present, the overall responsibility for

environmental protection lies with the Secretary

for the Environment. The executive functions

relating to environmental monitoring and

enforcement are undertaken by the relevant

departments: these include the Agriculture and

Fisheries Department (AFD), the Public Works

Department (PWD), the Urban Services Department (USD),

the Marine Department, the Labour Department, the

Royal Observatory and the Police. In Hong Kong,

as in many other countries, powers to control

pollution have been created whenever the need has

become apparent and enforcement powers conferred

on the public authority whose work is most closely

connected with that form of pollution or where

officers have frequent contact with the sources of

pollution. These authorities have undertaken

environmental monitoring necessary to assist them

to take their decisions: for example, the PWD

monitors levels of pollution in coastal waters to

assist with the decisions on sewage dispersion and

treatment plant; the AFD also monitors marine

waters in connection with their interest in fisheries.

All the departments have developed a considerable

expertise and knowledge of their particular

environmental problems.

Where there is a single issue of relevance to a

number of departments, an interdepartmental

committee is set up: for example, the solid waste

steering committee, which includes the PWD, USD,

New Territories Authority and the Marine Department.

Where Environment Branch requires to take a complex

decision which involves a number of the deoartments

(such as the export of manure) , the individual heads

of department will be asked for their advice and,

with Environment Branch, will in effect form an

ad hoc committee. The members of Environment

Branch, in common with most other branches of the

Secretariat, are not required to have technical

expertise of direct relevance to their functions.


16 8 - Environmental Resources Ltd

7.3 We have given detailed consideration to whether

the existing organisation would be adequate to

implement the proposed approach to environmental

protection and to carry out the functions listed

in 7.1.

We have concluded that there would be a considerable

advantage in strengthening the organisation by the

establishment of a centralised specialist body

responsible to the Secretary for the Environment.

For the purposes of this Report we have termed

this body the Central Unit for Environmental Protection,

In making this recommendation for a centralised

body we have taken the following factors into account.

(i)

As we have stated above (7.1), we are

advising a planned and flexible

approach to environmental protection.

Action can be taken on many fronts

to improve the quality of the

environment: inland waterways may

be cleaned, discharges of toxic

materials,grease and oil forbidden;

further monitoring of the atmosphere

may be undertaken, perhaps leading

to a reduction in the sulphur content

of oil; a comprehensive programme may

be introduced to reduce background

noise, etc. It is unlikely that the

Territory could afford to proceed with

all the various proposals at once.

It will be necessary to take a decision

on the overall objectives for each

environmental medium and on where the

priorities for action lie. Such a

decision depends on scientific, technical,

economic and political factors.

We believe that a qualified central

unit is required to assist the

Secretary of the Environment to judge

the priorities in context of the

environmental and financial constraints.


16 9 * Environmental Resources Ltd

(ii)

In taking decisions on the need

for action to improve the quality

of the environment, we have stated

that further information will be

required: in particular, monitoring

information on the state of the

environment. At present several

authorities have an interest in the

monitoring of each medium: for air,

the Royal Observatory records the

meteorological conditions, the Labour

Department records the concentration

of pollution, but no department

measures emissions from motor

vehicles; the AFD and the PWD both

are concerned with the water quality;

for noise, while no regular monitoring

is undertaken at present, several

departments including the USD,

Labour Department and Police carry

out measurements.

Although for practical purposes

there are advantages for many of

the inspection and enforcement

duties to be carried out by officers

of departments, it is wasteful of

financial resources for each of the

separate departments to build up

its own body of expertise.

We believe that monitoring activity

should be controlled and evaluated

centrally by a qualified unit so as

to ensure that the limited monitoring

resources are used most effectively,

that the data is collected in a form

suitable for environmental decisionmaking

and so that the information is

centralised for decisions affecting

more than one medium.

(iii)

Pollution control is not a series of

separate problems. It is a largely

single problem of disposing of wastes

without doing undue damage to the

environment and harm to those who use

it. This can involve a decision on

alternative methods of disposal, e.g.


170 * Environmental Resources Ltd

by tipping or burning, by disposal to

sewers, or streams, or by dumping at

sea. If each receiving medium is

protected by a different authority,

there is at present no single body

which has the necessary knowledge

and expertise to make an impartial

choice between the alternatives.

Furthermore, solutions to waste

problems often require that every

stage of the collection-treatmentdisposal

chain is examined to determine

the potential for reducing the

quantity, for changing its composition,

for reclamation so as to offset some

of the cost. In the case of solid

waste, for example, there are a large

number of departments concerned with

the solution: the USD, two or three

officer within the PWD, the Labour

Department (emissions from

incinerators), the AFD (use of compost

and disposal of pig solids), the

Marine Department (harbour scavenging),

We believe that a single specialist

unit could assist the Secretary for

the Environment and the departments

to take complex decisions relating

to minimising the- hazards associated

with waste disposal.

(iv)

We have stressed the need for

environmental objectives and for

implementing the necessary controls

to achieve these objectives. At

present, the control of pollutants

discharged into each medium is

undertaken by separate departments.

For example, noise from different

sources is controlled by separate

authorities: noise from road traffic

by the traffic police; noise from

pile driving and other street noises

by the PWD and the Police, noise from

aircraft by the Civil Aviation Department;

noise from factories in domestic premises

to some extent by the Labour Department;

noise from air conditioners by the Urban

Services Department.


Environmental Resources Ltd

Air pollution from stationary

sources is mainly controlled by

the Air Pollution Control Unit of

the Labour Department, although

the Mining and Quarrying Division

has an interest in dust emissions;

but air pollution from motor

vehicles is controlled by the Police

liaising with the Transport

Commissioner. At present, the

PWD is the department mainly

concerned with water pollution: but,

given the present organisation, we

would expect the AFD would become a

control authority for agricultural

effluents.

We believe that to administer the

controls effectively in relation to

quality objectives, a central unit

is required that can implement a

programme of progressive improvement

of the quality of each of the

environmental media.

(v)

A number of departments are, and will

remain, through their own activities,

polluters of the environment, e.g.

Civil Aviation Department, Public Works

Department. They are also the control

authorities. We appreciate that not

only are they very concerned to reduce

pollution, but that it is through their

care and attention to environmental

problems that the Hong Kong environmental

problems have been minimised. We are

also aware that they are subject to the

supervision of the Secretary ,for the

Environment. However, if the control

authority is to have a discretion in

establishing emission standards

separately for each discharger, as we

recommend for dischargers to streams,

and if the authority is to set those

standards in order to achieve a given

objective, it would be impolitic to have


172.

Environmental Resources Ltd

a system in which private companies

affected could see the authority

setting its own emission standards.

Impartiality, like justice, most not

only be real, but must be apparent

if it is to satisfy.

Furthermore, if control is by a

department which itself generates

some of the pollution in question,

the conflict of interest between

inexpensive operation and

environmental protection is resolved

within the department. The process

of decision being entirely within the

department, there is no guarantee to

the public that the case for

environmental protection has been

presented as clearly and vigorously

as it might have been. Where there

is an agency whose sole function is

to present the case for environmental

protection, the public have a better

guarantee that it will be presented

with due vigour and clarity.

(vi)

As the methods of environmental

protection used become more sophisticated,

with the degree of control determined

according to quality objectives, and

with discretionary powers vested in the

control authorities, a high degree of

expertise is needed in the control

authority. We have pointed out

throughout this report that many of

the major environmental problems will

require further technical and economic

investigations in order to select the

best solution. In many cases this will

be a continuous process.

Furthermore, it is possible that more

technically sophisticated industry will

be established in Hong Kong. Complex

environmental impact statements will

need to be examined and the Government


173 * Environmental Resources Lid

may feel the need to carry out

additional investigations.

Decisions will be required on the

necessary controls. The activities

of these industries will need to be

monitored.

Up until now the Government has

relied heavily on the use of

specialist consultants for this

purpose and for taking other

environmentally complex decisions.

We believe that a technically

competent central unit is required

to advise the Secretary for the

Environment and help to reduce this

reliance on outside expertise.

7.4 We are aware that these proposals for a new

Protection body may be open to criticism: specifically,

on the grounds that the Unit would be an added

expense at a time when there is concern everywhere

about the future prospects for economic growth; that

the Unit would be disruptive and would set back the

cause of environmental improvement while it was

being set up; that a specialist unit would fail in

Hong Kong because it would be impossible to attract

staff to a situation where the career prospects were

limited.

In developing our proposals for the Central Unit for

Environmental Protection we have taken these factors

Junto account.

We propose that, while the Central Unit for

Environmental Protection would be responsible to the

Secretary for the Environment as the Control Authority f

it would in the first instance have primarily a

co-ordinating and planning role: the functions of

monitoring and enforcement would remain with the

individual departments. To this extent the Unit

would be superimposed on the existing system. As

the programme for environmental improvement

developed, we envisage that the Unit would acquire

its own monitoring and staff. Rome of the


173a

Environmental Resources Ltd

personnel required could be drawn from the

departments. In many fields, however, inspection

and enforcement could continue to be undertaken by

departmental officers and police, often under

delegated powers.

We further propose that the senior members of the

Unit (referred to as "Environmental Officers"

below) could be drawn from the departments for a

minimum period of two years and could return to

the departments. But the posts from which they

are drawn must be refilled: their functions would

be wholly different from their departmental roles

and we saw no evidence that the departments

concerned with environmental protection were

overstaffed. The officers should also suffer no

disadvantage through their term of duty with the

Unit. And the system should improve the understanding

of the Unit and the departments of the problems

that each has to deal with.

The Unit does, therefore, require additional

expenditure. We discuss the annual budget below.

Whether or not such expenditure is justified must

be judged in relation to its value. It is our

view that Hong Kong needs such a unit to enable

them to prepare and implement a programme of

environmental protection; the cost of the Unit and,

eventually, of the control measures must be

considered in relation to other priorities. We

would expect there could be some benefit in terms

of savings in the use of expert consultants and

in an increasingly efficient use of resources

required for environmental protection. We have not

attempted to evaluate such benefits in monetary terms,

We should mention that we have given consideration

to a number of alternatives: these included -

bringing together those parts of the

departments at present concerned

with monitoring and enforcement of

environmental legislation to form a

new environmental protection

department; but this would cause

considerable desruption and many of

the environmental functions are

integrally connected with other

functions of the department;


174 * Environmental Resources Ltd

setting up a number of specialist

units within the departments

concerned with the protection of air

quality, water quality, noise

reduction and planning for waste

disposal, and establishing an

interdepartmental environmental

steering committee; but we believe

that this would prove cumbersome,

would not leave a single body

responsible for planning and

implementing a control programme

and would not develop the

multidisciplinary team approach that

we consider to be essential.

In recommending the Central Unit for Environmental

Protection, we have taken account of the

recommendations made and the reorganisations made

following the work undertaken by McKinsey and Co.

on the Machinery of Government. Our proposals are

not in conflict with McKinsey's recommendations and

could be implemented with the minimum of disruption.

Finally, it is not irrelevant to note than when

countries in recent years have restructured their

pollution control authorities, they have usually

decided in favour of integrated authorities,

e.g. USA 1969, New South Wales 1970, South Australia

1972, Western Australia 1971, Victoria 1970,

Malaysia 1974, Denmark 1973, Singapore 1972,

Tasmania 1973, Japan 1971, Ontario 1971.

Proposals for the Central Unit for Environmental

Protection

Given the proposed comprehensive and flexible system

of environmental controls, it is our view that the

responsibilities of the Secretary for the Environment

in that field would be more easily and effectively

discharged through a Central Unit for Environmental

Protection* The functions of the Director of this

Unit would be:


5 " Environmental Resources i td

To advise the Secretary for the

Environment on any matter relating

to environmental protection. This

advice might: concern matters outside

the direct responsibilities of the

Unit, e.g. advice on the impact of

land-use proposals, requirements as

to environmental impact statements,

environmental aspects of the work

which is principally the responsibility

of some other branch. It would

include advice on the need for any

new legislation. He would have a

duty to submit advice when called

upon by the Secretary to do so, and

would be free to submit advice on

his own initiative.

To assist the Secretary for the

Environment in developing and

implementing a programme for

environmental improvement and

establishing objectives for

environmental protection.

To enforce or supervise the

enforcement of pollution control

legislation. He would have power

to delegate enforcement powers to

other officers r whether employed

within the Unit or not. This would

mean that in many cases the work of

enforcement would remain with the

Departments and Police.

4. TO carry out or have carried out such

monitoring as he considers necessary

for the discharge of his functions.

Monitoring powers could be delegated

as in 3 above.

To promote research into matters

directly related to environmental

protection.


Environmental Resources Ltd

T ° promote the development and

adoption of processes, products,

methods of treatment of waste,

and the means of abating the

effects of pollution, in so far

as they are directly related to

environmental protection.

The Director would report and would be responsible

to the Secretary for the Environment.

The Director would be assisted by a number of

Environmental Officers who would each be responsible

for the protection of an environmental medium and

by a waste disposal officer who would be responsible

for waste planning and the promotion of recycling,

reclamation and for less damaging ways of disposing

of waste.

7.6 The Central Unit for Environmental Protection:

Its Development and Functions

The work to be undertaken by the Unit, its manpower

requirements and its cost will depend both upon the

availability of resources and upon the priorities

to be given to the protection programme as seen by

the Government and its advisers.

In this paragraph we make recommendations for the

essential requirements, comment on the future

developments; we provide estimates of the cost in

paragraph 7.7.

(i)

We recommend the early appointment

of a Director for the Unit.

We suggest that the post is

advertised internationally at a salary

of about HK$12,000 per month (equivalent


177.

Environmental Resources Ltd

to Administrative Officer Staff Grade

B). We feel it would be an advantage

in this new position if the Director

were to come from outside Government.

To interest a man of high enough

quality it may be necessary to offer

the post on a fixed term but renewable

contract.

We envisage the Director will have

had experience of a wide range of

environmental issues and their

potential and economic consequences.

His previous experience may have been

with an environmental protection

agency, for example, in North America,

Australia or Japan; alternatively

he may have worked on the practical

problems of the environmental in some

other post - such as the Environmental

Control Director of a major multinational

company.

He will have overall responsibility

for the Unit to the Secretary for

the Environment. In the first instance,

he will be required to work with the

Secretary for the Environment and

his advisers to prepare a programme

for environmental protection with

respect to the needs and priorities

for monitoring, pollution control,

research and development. He will

be required to work with heads of

departments to co-ordinate and establish

monitoring programmes required for

environmental decision-making. He will

be required to implement the protection

legislation and co-ordinate the

activities of the existing control

authorities (see also (ii) to (iv)

below) so as to achieve the agreed

objectives.

He would be required to prepare an

annual report outlining the Government's


178 " Environmental Resources Ltd

environmental objectives and

indicating the progress made

in the previous year.

He would be required to advise on

new industrial developments and

their environmental consequences.

With other members of his Unit he

may be asked to advise on the preparation

of reports on the potential environmental

impact or to comment on such

reports prepared by industry. He

would be required to assist industry

to develop in Hong Kong without

causing unacceptable hazards.

He would be required to advise on

the appointment of all consultants

called in to advise on environmental

matters and he, or a member of his

Unit, would be a member of all such

consultant steering committees.

(ii)

Air Pollution

We recommend the immediate appointment

of an Environmental Officer : Air,

to the Unit.

We suggest that the post is advertised

internationally at a salary of about

HK$8,000 per month but that qualified

members of the Hong Kong Government are

encouraged to apply. It would be

stressed that the successful candidate

would be expected to hold the post for

two to four years and might then return

to a relevant governrv nt department.

We envisage that ideally the officer

will have some knowledge of inetereology,

air pollution and air pollution control

techniques.


179 * Ernsronmcntal Resources Ltd

In the first instance, he would

be required to assist the Director

in the preparation of air quality

objectives for Hong Kong taking

account of both stationary and

mobile sources. He would be

required to give more detailed

consideration to the proposals for

a monitoring system. We have given

our recommendations in paragraph 4.4

but the method and expenditure

involved must be considered in

relation to other priorities. He

would be required to assist the

Director to co-ordinate the

activities of the Air Pollution

Control Unit and, where these are

relevant, to the monitoring and

control of air pollution, the Royal

Observatory, the Police, the

Transport Department and the Marine

Department.

He would further be required to

advise on the air pollution

implications of new industrial

sitings.

Should it be decided to proceed

with the air pollution monitoring

scheme, then he would need to assist

the Director and the Secretary for

the Environment to decide who should

be responsible for implementing the

monitoring programme. It is our

view that if, as we recommend, the

Territory introduces quality

objectives and does not set emission

standards, then the Royal Observatory

would be the most logical group to

undertake air pollution monitoring.

The interpretation of the data is

closely connected with knowledge of

the atmospheric conditions and

eventually, if a monitoring network

were shown to be necessary, it is

likely that the monitoring points

would transmit information on climate

and pollutants.


18 °* Environmental Resources Ltd

A further development of the Unit

would be the transfer of the Air

Pollution Control Unit from the

Labour Department to the central

unit. Powers of control of

excessive emissions from individual

vehicles would remain with the

Police.

(iii)

Water Pollution

We recommend the early appointment

of an Environmental Officer : Water,

to the Unit.

We suggest that the post is advertised

internationally at a salary of about

HK$8,QOO per month but that qualified

members of the Hong Kong Government are

encouraged to apply. It would be

stressed that the successful candidate

would be expected to hold the post for

two to four years and might then return

to a relevant Government department.

We envisage the officer will have an

appreciation of fresh water and marine

monitoring and water pollution control

techniques.

In the first instance he would be

required to assist the Director in the

preparation of water quality objectives

and prepare and cost a programme of

action for improving the quality of

inland waterways and the coastal waters,

taking account of potential benefits ,

particularly the needs for potable

water and recreaction.

He would be required to assist the

Director to co-ordinate the relevant

monitoring programmes; we would suggest


181 * Enuronmental Resources Lid

that he might consider integrating

the University monitoring activities

into the programme if an arrangement

could be arrived at that would be

satisfactory to both parties. He

would be required to gain a full

understanding of the research,

development and implementation of

the water pollution control programmes

currently being undertaken by the

PWD, AFD and Marine Departments.

If it were decided to proceed with a

programme of control of discharges

into inland waterways and the control

of the discharge of toxic materials,

grease and oil into the sewers, inland

waterways and coastal waters, he would

require an inspectorate, advisers on

pollution control techniques and back

up technical staff. We have suggested

that the programme of improving inland

waterways must proceed slowly and we do

not believe that a large staff would

be initially required. We note the

proposals made by the Director of

Engineering Development to the DPS for

a water pollution control section

(ref 207): while the proposal called

for three additional senior officers

with a total annual cost (including

on-costs) of $435,792 there would have

been a saving of $401,472 from existing

posts (1973 costs). We would envisage

the need for three inspectors (in

addition to the Environmental Officer)

in the early stages of the programme and

a chemist and biologist to assist with

analyses. The total cost of this staff

would be about $750,000 p.a. (excluding the

Environmental Officer) but some savings

could perhaps be made in existing

Government staff.


182 * Environmental Resources Ltd

(iv)

Noise

We recommend the immediate appointment

of an Environmental Officer : Noise

to the Unit.

'

We suggest that the post is advertised

internationally at a salary of about

HK$8,000 per month, but that qualified

members of the Hong Kong Government are

encouraged to apply. It would be

stressed that the successful candidate

would be expected to hold the post for

two to four years and might then return

to a relevant Government department.

The officer must have some knowledge

and expertise in noise control and

noise monitoring techniques.

In the first instance, he would be

required to assist the Director in the

preparation of a programme for the

setting of noise objectives and for the

control of noise.

He would be required to assist the

Director in setting up a monitoring

programme (see Appendix A, 5. ) and

co-ordinating the activities of

departments and other bodies concerned

with noise measurements; again, it is

possible that the relevant University

experts could assist with this programme

He would also be required to assist the

Director to implement the control

measures with relation to industrial

noise/ aircraft noise, construction

noise, traffic noise and other

neighbourhood noise, including noise

from air conditioning equipment.


Emironmental Resources Ltd

We have no information on what

other functions the noise

measurement sections in the USD and

Labour Department are responsible

for* But noise measurement requires

both technical competence and

specialist equipment and we consider

that the noise measuring unit should,

if practicable, be brought together

into the Unit and provide a service

where required to the Department and

implement the noise measurement

programme as recommended. We have

noted the staff and equipment

requirements (Appendix A, 5-13) for a

monitoring programme: but we do not

know how many new staff would need to

be appointed*

We have laid stress on the need for a

long term programme to reduce noise

levels (see Section III) and we

consider it to be an important part

of the functions of the Environmental

Officer : Noise to ensure that the

reduction of noise is taken into account

by the authorities and departments with

an involvement in transport (including

aircraft), construction and land-use

planning.

(v)

Waste JDisgosal

We recommend the immediate appointment

of an Environmental Officer : Waste

Disposal to the Unit.

We suggest that the post is advertised

internationally at a salary of about

HK$8,000 per month, but that qualified

members of the Hong Kong Government are

encouraged to apply. It would be

stressed that the successful candidate

would be expected to hold the post for


18 4 - Environmental Resources Ltd

two to four years and might then

return to a relevant Government

department.

We envisage that the officer will

have an appreciation of the survey

methods, cost-benefit appraisals and

will have a knowledge of the waste

arisings from domestic, agricultural

and domestic sources.

He will be required to assist the

Director to:

examine waste arising from

domestic, industrial,

agricultural and commercial

sources including such

wastes as waste oil, abandoned

vehicles, etc.;

examine the potential for

further reclamation and

recycling of waste oil, waste

chemicals (especially solvents),

other industrial and domestic

wastes, taking account of the

high costs of disposal of waste;

estimate the impact of new

environmental legislation in

terms of the extra waste load

requiring disposal and to ensure

there are plans for the required

facilities.

We propose that a new Committee should

be established f similar in composition

to the Solid Waste Steering* This

committee should include representatives

of the departments concerned with the

collection and disposal of domestic,

industrial and agricultural wastes, and

should include a member of the Planning

Authority.


185tt

Environmental Resources Ltd

The Environmental Officer, Waste

Disposal, should be chairman of that

committee.

The committee should be required to

prepare an annual waste disposal plan

and to consider the cost-effectiveness

of waste collection and disposal

methods within the context of this

plan and, where relevant, make

recommendations for research and

development.

We have summarised our recommendations for the

Central Unit for Environmental Protection on the

following pages (Table 7.6 (a)).


TABLE 7.6 (a)

RESPONSIBILITIES OF CENTRAL UNIT FOR ENVIRONMENTAL PROTECTION UNIT

First Phase

Possible Further Development

Officers Responsibilities (i)

Director

Preparation of environmental protection programme.

Organisation of environmental monitoring.

Liaison with Planning Authority. Implementation

of environmental legislation. Control of

pollution from all sources. Publish an annual

report.

Environmental

Officer ; Air

Preparation of air quality objectives. Proposals

for and implementation of monitoring programme.

Assessment of air pollution impact of new

developments (including transport schemes).

Implementation of ail" pollution legislation.

Control of air pollution from all sources:

powers of enforcement delegated to departments.

Move Air Pollution Control Unit to Central

Unit:. Powers for control of excessive

smoke from vehicles to remain with Police.

Environmental

Officer :

Water

Preparation of water quality objectives.

Co-ordination of monitoring of waters.

Implementation of water pollution legislation.

Control of water pollution from all sources:

powers of enforcement delegated to departments,

Set up inspectorate to control discharges:

size depends on rate of implementation*

Back up technical staff required.

/continued...

Environmental Rcsouices Ltd


TABLE 7.6{a) - continued

RESPONSIBILITIES OF CENTRAL UNIT FOR ENVIRONMENTAL PROTECTION UNIT

First Phase

Possible Further Development

Officers Responsibilities (i)

Environmental

Officer :

Noise

Preparation of noise standards. Development of

monitoring programme for establishing need for

action. Implement noise pollution legislation.

Control of noise from all sources; delegation of

powers of enforcement to departments.

Establish central noise monitoring unit

responsible for monitoring programme and

investigating all complaints. Establish

inspectorate responsible for control of

noise from all sources except individual

vehicles (powers of enforcement for

vehicles delegated to Police.

Environmental

Officer :

Waste Disposal

Prepare a waste disposal p n an. Examine waste

arisings, collection and disposal plans and

methods. Investigate potential for recycling

and reclamation. Estimate extra waste arising

from new protection legislation and ensure plans

for extra disposal facilities are adequate.

Chair solid waste committee.

Note (i): In all cases responsible to the Secretary for the Environment

directly (in the case of the Director) or through the

Director of the Unit in all other cases.

Environmental Resources Ltd


188 * Environmental Resource.** Lid

7,7 The Cost of the Unit

The cost of the Environmental Protection Unit will

depend upon the priority given to implementing the

environmental protection programme and the extent

to which members of the Unit (other than the

Director and his four Environmental Officers) can

be drawn from executive departments without the

need for replacing their posts*

We have recommended that the Unit should have a

central 'core 1 of a Director and four senior officers,

We estimate that the annual recurrent salary cost

will be about HK$530,000. This is based on"

Government salary scales: it assumes the Director

will earn the equivalent of an administrative officer

Staff Grade B and the Environmental Officers will

earn the equivalent of the top end of the range for

an Air Pollution Control Officer or similar.

With the necessary secretarial and clerical staff

we estimate the annual cost will be about $HK850,OOO

per year. It is possible that there may be some

potential for saving where officers could be replaced

in the departments at a lower salary scale.

We believe that the Unit could also offer some

savings in Government expenditure in terms of:

a more efficient use of monitoring

resources: we have stated above

that the co-ordination of the

expertise and the monitoring

programmes could help to avoid

duplication and provide the

information required for

environmental decision-making;

some reduction in the use^of

specialist environmental consultancies:

the Unit would under certain

circumstances be able to undertake

studies that are currently contracted

out to consultants; it could also

hold centrally relevant information

to avoid the need for consultants to

gather basic data for each assignment;


189 * Environmental Resources Lid

some improvement in decision-making

for capital projects: with a central

specialist Unit required to take

account of all aspects of waste

arisings and pollution control in

the Territory, some savings could

arise where all environmental

considerations, the costs and benefits

of control, were to be taken into

account at the outset.

These are f we appreciate, intangible benefits and

we have not attempted to evaluate them. The most

important benefit is the assistance that such a unit

could be to the Government and the community and

implementing a programme for environmental protection.

We have stated above that the net cost of enlarging

the Unit will depend upon the extent to which additional

staff can be drawn from existing posts and the priority

and urgency with which the programme is undertaken*

We have, in the previous paragraph (7.6) discussed

the development of the Unit and the requirements.

AdvisoryCommittee on Environmental Pollution

The present Committee on Environmental Pollution

does valuable work by presenting to the Environment

Branch, and hence to the Departments, the views of

people outside Government on the need for further

pollution control. It is an informed body with a

range of expertise in its ranks.

When the Central Unit on Environmental Protection is

established, there will be a body of expertise

reporting directly to the Secretary for the Environment

which will have powers of control over persons outside

Government, and will, through the Secretary for the

Environment, inform Departments when greater measures

of control are expected of them. We do not see this

as in any way reducing the need for an advisory

committee.


Emironmental Resources Ltd

In its work, both when it acts under its own powers,

and when it advises the Secretary of State, the

Central Unit on Environmental Protection will be

concerned to protect the public in general and

particular sections of that public. It will have

to take into account not only the interests of those

who might be affected by discharges, but also the

interests of the dischargers, who are attempting to

maintain viable industrial, agricultural or other

enterprises. It will often be a problem of

maintaining a fair balance. For this purpose the

Unit will need to be as fully informed as possible,

and advised of the wishes and the reactions of those

concerned. Naturally, and properly, direct

consultations can and doubtless will take place.

We envisage, however, that the main stream of advice

and comment will be from the Advisory Committee.

The existing Committee already discharges that

function most satisfactorily. We do think,

however, that as the Committee is to represent the

public, as distinct from the Government and its

various departments, that no person holding office

in the Administration should be a member of the

Committee. This does not mean that officers of the

Government should not attend any meetings of the

Committee or its sub-committees: it does mean that

the decisions of the Committee should be those of a

body independent of Government.

It will not be a function of the Committee to engage

or promote any research into environmental

conditions; its deliberations will be based on reports

and data already available from governmental and

other sources. The Committee will need, however, as

it has now, expertise within its ranks so that the

information it receives can be evaluated and its

implications understood. We believe that there should

always be expertise in the sciences, including

medicine, and in law*

Finally, we would like to see a wider range of

representation on the Committee. The Port

Executive Sub-Committee on Oil Pollution has members

who are representatives of the oil companies, the

shipowners and agents, and dockyard interests. Since

industrial, agricultural interests and the like, will


191-

Environmental Resources Ltd

be affected by pollution control measures, there

is good reason for having a similar representation

on the Advisory Committee. For example, the

Federation of Hong Kong Industries and the Chinese

Manufacturers Association could easily be given

representation; and we were impressed by the

interest and expertise in pollution control matters

shown by the Hong Kong Productivity Centre's

Environmental and Technical Unit. It would be

more difficult to have representatives of such

bodies as the Federation of Pig Breeders

Association, but we feel that every effort should

be made to include them. Because of the difficulties

involved, we make no detailed recommendations; but

we believe that the objective should be that the

Committee should be partly representative, partly

expert, and independent of Government.

A Country Parks Authority

Drafting instructions have already been prepared

for the establishment of a Country Parks Authority.

The Authority would be the Director of Agriculture

and Fisheries, and would have the power to make

bye-laws. There would be a Country Parks Advisory

Board.

Within the areas in question, there is already some

conflict of interest between the Department of

Agriculture and Fisheries, the Public Works Deparment

and the New Territories Administration. This

conflict is likely to intensify as the parks are

developed. It has been suggested that the Authority

could be a group of people representing these three

Departments, with the Department of Agriculture and

Fisheries providing the chairman; we see much merit

in this proposal.

It has further been suggested that the country parks

should be areas where no departure from existing

land-use would be permitted without the permission

of the Authority. We agree, and further suggest


19 2 - Environmental Resources Ltd

that under the proposed new planning legislation,

the Authority should be the planning authority.

We agree with the proposal that the Authority

be given powers to make bye-laws f and emphasise the

importance of those powers being sufficient to

enable it to deal with special problems of

pollution control in recreaction and high amenity

areas *


19 3 * Environmental Resources Ltd

SECTION VIII

RESPONSIBILITY FOR THE COSTS OF POLLUTION CONTROL


194. Environmental Resources Ltd

RESPONSIBILITY

FOR THE COSTS OF POLLUTION CONTROL

In the previous Sections, we have indicated the

magnitude of the additional expenditure that

would be required for establishing a control

authority and implementing control measures.

We briefly outline below the principles that we

propose should be adopted with respect to the

responsibility of different parties for meeting

these costs.

All the countries of the European Economic

Community have accepted what has loosely been

called "the polluter pays principle". It is

open to different interpretations, but we set out

here the one that we find the most acceptable, to

the extent that it has a bearing on pollution

control in Hong Kong.

When a person, by his own act, causes

pollution or a risk of pollution it is

right in principle that he should be

required to pay for:

- all steps reasonably taken

to prevent or mitigate damage;

the cost of remedying damage

caused by the pollutants;

- damage unavoidably caused by

steps reasonably taken to

prevent or mitigate pollution

or the cleaning process, e.g.

damage to marine life caused

by oil emulsifiers.

In this context the term damage refers to

loss or injury to man, his property and his

- interests.


19 5 * Environmental Resources Ltd

It follows therefore that where a polluter is

required to meet higher standards relating to

his discharge, the cost of the necessary action

will be borne by the company: for example,

reducing the quantity or improving the quality of

the liquid effluent.

The costs of the disposing of wastes safely

should also be borne by the_polluter.

Where a permitted discharge, e.g. to inland waters,

causes pollution and where there is a known risk

of pollution damage, the costs of all monitoring,

supervising and controlling reasonably undertaken

are, on these principles, costs to be borne by the

discharger. To that extent the Government is

justified in charging fees for consents or licences

sufficient to cover the costs of these services.

When all members of the community discharge waste

of similar character and in approximately the same

quantities, as with domestic sewage and household

refuse, the cost of collection, treatment and

disposal may more conveniently be borne by public

funds,

In certain cases, it may be decided to spread the

cost of certain measures so that they are borne by

a wider section of the community.

There are sone industrial or agricultural activities

which are of particular importance to Hong Kong

and these may not be in a position to bear all the

costs specified above (8.2). The Government may

themselves decide as a matter of policy that a part

or a whole of these costs should be borne by public

funds. To this extent, there will be an element of

subsidy.


19 6 - Environmental Resources Ltd

We have proposed above that the cost should be

spread if it is decided that fuel users in

selected areas should use lower sulphur fuel

than in other areas. This is primarily to

overcome potential enforcement problems. If

there were only one price for the fuel oil

whatever the sulphur content, users in areas

where low sulphur fuel was ordered would not be

tempted to use the higher sulphur fuel which

normally would be less expensive.

But we should stress that the main value of the

polluter-pays-principle is to incorporate the

added cost into the product from which the waste

arises: the product may be a transistor radio,

or a vehicle where the user is required to fit

emission controls. Spreading the cost will

result in a subsidy for that product.

All things being equal, the producer will

bear only the initial liability for costs

associated with pollution control. They will

become another production cost (or, in the

economist's jargon, he will 'internalise 1 the

cost) and will be taken -into account when the

price of the product is revised.

The industrial producer will themselves pass on these

costs as part of the price of his products, so

that ultimately the consumer of the product bears

them. Thus 1 the polluter pays 1 is translated into

'the consumer pays 1 . This again is right in

principle - the person who takes the benefit,

pays the cost.

But it will be recognised that for a trading

nation such as Hong Kong the additional costs of

pollution control for industry will have an impact

on the competitive position of goods in the

international market; in some other countries

producing similar goods the community may^ accept

a more polluted environment and produce cheaper

goods.


19 7 - Envirorunental Resources Lid

In our view f industrial prosperity at the

complete expense of environmental protection will

offer only a short term advantage. Pollution

damage brings about financial loss to a

community in terms of its impact on health,

property and amenity; and there is some evidence

that new industry and skilled management are not

attracted to polluted areas.


198. Environmental Resources Ltd

SECTION IX

REPORT SUMMARY


199 * Environmental Resources Ltd

REPORT SUMMARY

INTRODUCTION

In this Stage I report, we have outlined proposals

on the type and structure of the environmental

control authorities and the control system that

we consider necessary for the protection of the

environment and that we believe take account of

the special environmental, economic, legal and

social characteristics of Hong Kong.

We commented at the outset (1.2) that Hong Kong's

environmental problems derive, as in other

countries, from two main causes: wastes discharged

into the environment have, with a few exceptions,

been largely untreated; and in planning the

community's activities (particularly industry,

agriculture and transport) there has until recently

been no special account taken of the impact of

wastes from the various new developments on the

environment*

The situation has been exacerbated by an increasing

population: we have noted (Appendix A, 1.2 - 1.4)

that over the next ten to fifteen years the population

will probably continue to grow at the rate of

100,000 per year. At present, about 80% live in

the urban areas of Kowloon and Hong Kong island;

but it is government policy to encourage their

distribution through the Territory*

The nature and growth of industry and other

economic activity also has a direct impact on the

existing and future state of the local

environment (Appendix A, 1.5, 1.6). Hong Kong

enjoyed an average annual growth rate of about 9%

(measured as increase in gross domestic product

at constant prices) between 1963 and 1973: that

was equivalent to a growth rate of almost 7% in

per capita terms. In 1974 there was a slight

decline in per capita GDP. At present, manufacturing

industries account for between 30 and 35% of the total


20 °* Environmental Resources Ltd

economic activity; but there are some indications

that over the next ten years service industries

will become increasingly important. In terms of

exports, clothing and textiles have traditionally

been the most important to the Territory; but

since the early 1970s exports of electronic

products have increased so that in 1973 this

industry was the second largest exporter after

clothing.

It has been stressed to us that the policy of

non-interference adopted by the Government wherever

feasible has contributed to a large part to the

growth and prosperity of Hong Kong ! s industries.

We have also been told that the nature of industry

in Hong Kong is changing: increasej in wage costs

and changes in world markets are likely to result

in a move away from the traditional industries and

from the small manufacturing units. This trend

towards larger, more sophisticated industry may

be expected to lead to the arrival of potentially

more serious polluters: although these larger units

are often able to pay more attention to effective

pollution control methods than can the smaller firms,

While of no great importance in terms of overall

economic activity, local livestock production forms

a significant part of the food consumed locally:

42% of all live poultry and 12% of all live pigs

consumed in 1973 were produced in the Territory

(Appendix A 1.7). It has been pointed out to

us that this has a certain strategic importance if

supplies from other areas were to be interrupted

for any reason.

It is expected that over the next ten years there

will be a considerable .increase in tourism: it

has been estimated that the number of visitors to

Hong Kong could increase fivefold by 1985. If

these estimates were correct, there would be a

resulting increase in aircraft movements, in hotel

construction and in domestic wastes. At peak

times, visitors staying in Hong Kong in 1985 could

be responsible for an increase of 10% in the overall

output of domestic-type wastes (Appendix A, 1.8).


2 °1* Environmental Resources Ltd

Aircraft and traffic contribute considerably to

Hong Kong's pollution problems. It is expected

that the number of flights in and out of Kai Tak

Airport could at least double over the next ten

years. Proposals for a new airport to be

situated on an island north of Lantau are

currently under consideration. There are about

2OO/OOO registered motor vehicles on Hong Kong f s

roads: this represents over 300 vehicles per mile

of road. Of these, about 120,000 are private

cars. A sharp increase in the licence fee early

in 1974 together with an increase in petrol prices

has resulted in a small decrease in the number of

cars registered during the past year: this follows

regular annual increases of about 10% per year*

Motor vehicles use about 350,000 tonnes of fuel

per year, just over 10% of the total fuel

consumption (Appendix A, 1.9, 1.10),

The major fuel users are the power stations which

together account for about 1.7 million tonnes of

fuel oil. Industry accounts for about 14% and

trade (mainly hotels and restaurants) for about 9%,

Only about 4% is used for domestic purposes.

We understand that a large proportion of meals are

eaten out. Over the past few years,electricity

demand has increased at about 10% per year until

1974 when there was a decline: assuming a continuing

growth-of about 7^% in the next ten years, then

total fuel use will about double by 1984 (Appendix A,

1.11).

After 1980, the desalting plants may account for

about 10% of total fuel use. There are outline

plans for a nuclear power station, possibly to

be sited on the south west tip of Lantau, to meet

any further increases in demand for electricity

and to provide power for further desalting plants

if required. In recent years, demand for water

has increased by about 8-lO% per year: in 1974

there was a small decline. About 30% of total

water is used by the industrial sector; of this,

about 7O% is used by the textile industry (see

Appendix A, 1*12).


20 2. Environmental Resources Ltd

9.3 Action to improve the quality of the environment

inevitably involves expense. It may also involve

changes in the siting of industry and agriculture

and methods of industrial and agricultural

production. Care must be taken to keep disruption

to a minimum.

It is therefore essential that decisions should be

taken on what the priorities are for environmental

protection and improvement: to decide the extent

to which resources should be made available for

environmental protection and how these should be

used to best effect.

We have f in this report, aimed to provide

sufficient information to enable these decisions

to be made and, r erha P s raore importantly, to

prepare a framework to enable this decisionmaking

to become a continuous process which will

allow Hong Kong to achieve the objective of

environmental improvement and protection.

9.4 In the paragraphs below, we first summarise the

problems and proposed controls for water pollution,

noise pollution, air pollution and solid waste

collection and disposal and litter; we then

outline proposals relating to the role of planning,

the control authorities and the responsibilities

for meeting the cost of pollution control.

In order to assist in the process of decision

making and to provide some basis for the selection

of priorities, we have provided an indication of

the costs of control and of the control authority.

It will be appreciated that actual control costs

depend on many factors: in particular on the

technical method used by the polluter to reduce

his waste and on the approach adopted by the

control authority to improve the environment in a

specific area. Similarly, the cost of the control

authority will depend on the approach adopted and

also on whether savings can be made elsewhere in

the administration to offset its cost. It has

therefore been practical to do no more than provide

some order of magnitude of the costs involved; these

costs must not be considered as a precise statement

nor should they be quoted as 'the cost of cleaning

up Hong Kong'.


203 * Environmental Resources Ltd

WATER POLLUTION AND ITS CONTROL

A. INLAND WATERWAYS

9.5 In Appendix A, Section II, we have reviewed the

problem of Water Pollution.

We have noted that many of the lowland streams in

the New Territories are grossly polluted: this

pollution is caused primarily by the dumping of

household refuse into the streams and by the

discharge of agricultural and domestic effluents.

In most areas, industry contributes only a small

proportion of the effluent discharged into streams:

but some of the industrial discharges (such as

those from tanneries, paper manufacturers, chemical

companies and a few textile and plating companies)

may have an impact out of all proportion with their

number.

The streams in the water catchment areas are, with

few exceptions, unpolluted.

9.6 We appreciate that many of the streams are at a

very low level for much of the year; nevertheless

they do provide a source of water for potable

water, for freshwater fish farming and for

irrigation. In addition, some of the larger

streams could be made attractive and offer a positive

value in terms of their amenity value. There has

therefore been a demand that their quality should

be improved.

But treatment of discharges would prove expensive

and, in the case of agricultural effluents, would

give rise to practical difficulties. We consider

that a programme of treatment and control should

be undertaken that would be:


204 • Environmental Resources Ltd

directed to the attainment of

specified quality objectives;

implemented in accordance with

a system of priorities.

We propose that these quality objectives should

take account of the potential uses (2,3).

9.7 To increase the amenity value of the grossly

polluted streams, streams should be free from

effluent solids causing objectionable deposits,

floating debris oil and scum and objectionable

odour and colour. To achieve this, it would be

necessary to prevent the deposit of pig and poultry

faecal matter and household refuse in the streams,

remove solids from domestic effluents and remove

any objectionable characteristics (colouration,

gross solids and odour) from industrial effluent.

In practice, the main problem would be the

removal of solids from the pig effluent and

poultry droppings. A thousand pigs produce

2,4 tonnes of solids (wet weight) per day for

which alternative disposal facilities would be

required. The Agriculture and Fisheries Department

has undertaken work on this problem and discussions

have been held on possible uses and outlets for

agricultural wastes.

In addition to the above measures, improving the

water quality to make it more suitable for

irrigation and fish farming would require that any

toxic materials, grease and oil were removed from

the effluent. In the case of irrigation, crops

should not be gathered for one to two weeks after

watering because of the potential danaer from

pathogens. But no legal provision could ensure this.

We appreciate that currently grossly polluted

streans are used for both fish farming and irrigation:

but we have been told of problems from flooding

and -excess nutrient levels and there is no doubt that

some control could prove desirable.


Emironmental Resources Ltd

Uncertainty as to the methods of treatment and

disposal that would be employed makes it difficult

to estimate the costs of control. Furthermore,

we would recommend the selective improvement of

streams depending on the potential benefits to the

community. But as a guide, we have calculated the

approximate cost of treating and disposing of

solid matter from domestic, agricultural and

industrial sources and of toxic materials from

industrial sources. We calculate that the initial

cost of the programme would be about $80 million

(see 2.12} and the annual costs (that is, operating

costs and the amortised capital costs) would amount

to over $3O million per year. Over 50% of the

cost would be for removal of agricultural solids

We have assumed that only a small quantity would

require final disposal (as opposed to use as

fertiliser) ; if this does not prove to be the case,

the cost to the farmers (and of the programme) would

be higher.

Treatment to this quality would not make the

inland waterways safe for swimming: the waters

would still contain unacceptably high levels of

pathogens.

Removal of these would require, in addition to the above,

chlorination or some other means of sterilisation

of the effluents from agricultural and domestic

sources* This could, we estimate, increase the

capital expenditure by about 20 million and the

annual costs by over $30 million as the chemicals

required for sterilisation of the pathogens are

expensive.

But we stress that we consider that all the

measures should be applied selectively.

We have also calculated the cost of treating effluents

from all sources to a high standard so that the

streams could be classed as clean and the waters

used for catchment purposes. We estimate that for

the treatment of all discharges to inland waterways

and disposal of resulting sludges the capital cost

would be about $600 million and the annual cost

about $130 million- We have considerable doubts


206 • Environmental Resources Ltd

about whether it would be practical to treat pig

discharges to a high enough standard. So, in the

case of the North-West New Territories (Sector D

on May 2.1) for 'cleaning up 1 the waters the capital

cost would be about $280 million and the annual cost

$60 million; or, if the pigs were moved, the annual

cost would be about $10 million. We have been told

that this area could realise up to 20 million gallons

per day (90,GOO cubic metres) or perhaps 5,OOO

million gallons per year (23 million cubic metres)

of water for catchment purposes. If the cost of

treatment is compared with the cost of producing

water by desalting ($3.5 per cubic metre or more),

it can be seen that the value of the water (at

desalting costs) is about $80 million per year.

There are, of course, many other factors to be

considered but there could be a case for re-examining

the possibility of the potential for Sector D.

9.8 The present legal controls over the discharges to

inland waters are set out in Appendix B. Those

that are designed to protect inland waterways in

general take the form of simple prohibitions and

are largely unenforced. The provisions restricting

discharges or deposits into sewers and drains relate

to solid matter and substances which may cause a

hazard to workmen or damage to the sewer.

We have made the following proposals for the

protection of inland waterways (2.6):

An Authority should be established

with discretionary powers to control

discharges to inland waters .. ... ...

Rl

The Authority would, subject to

policy control by the Secretary

for the Environment, have a duty

to establish quality objectives

for the various stretches of

inland waters • * - R2


207. Environmental Resources Ltd

In establishing these

objectives, the Authority

would take account of the

potential benefits and costs

and would be designed to bring

about progressive improvements

R3

We have proposed that the control powers would

be in the following terms:

(a) The Authority to have power

to prohibit or control all or

any class of: polluting discharges

into inland waters, deposits into

the waters which might pollute

or obstruct the flow of a stream,

deposits of wastes in a place

from where they might fall into

any inland waters ... R4

(b) The Authority to have power to

grant consent to discharge liquid

(and solid) wastes into a stream,

subject to conditions which may

relate to:

i. place of discharge or

deposit;

ii.

time of discharge or

deposit;

iii. composition of discharge

or deposit;

iv.

temperature of discharge

or deposit;

v. maximum quantity of any

given period;

vi.

providing monitoring

equipment or paying a

monitoring fee *. ... * • - • R 5


208 • Environmental Resources Ltd

(c) The Authority to have power to

require the installation and use

of plant or equipment for the

pre-discharge treatment of any

effluent

A breach of any prohibition under (a), any consent

under (b) or any requirement under (c) would be a

criminal offence. On convicting a person, the

court would have power to order the cessation of any

discharge (or of any practice which led to the

commission of the offence) and to order the convicted

person to pay the costs of restoring the stream to

the condition it was in before the commission of the

offence.

We further proposed that

Any individual should have a right

to object to the grant of a consent,

and a right of action for breach of

statutory duty for damage caused by

any act which constitutes one of the

above offences. He should have no

right of action for a discharge

which is in conformity with consent

conditions. To facilitate the

enforcement of these rights/ all

applications, consents and data

about the actual discharges collected

by the authority should be published .. R7

The Authority will also be required

to promote improvements in treatment

and disposal facilities; for this

purpose it may be given power to

promote or assist in Research and

Development and establishing pilot

schemes »

The Authority will co-operate with

the Department of Agriculture and

Fisheries in the administration of

the grants scheme in so far as they

may relate to waste treatment and

disposal *** *•- -


209 * Environmental Resources Ltd

The Authority should also be

responsible for the control of

trade and agricultural effluents

to sewers and should have the

power to impose a fee for its

registration

RIO

B. COASTAL WATERWAYS

9.9 About 85% of Hong Kong's total effluent (measured

as BOD) is discharged direct into coastal waters;

65% of the total load is from domestic sources,

2O% from industry (about 80% of this from the

textile industry) and about 15% from agricultural

sources f most of which is discharged initially

into inland waterways (Appendix A, 2.5),

About 80% of the load (measured as BOD) is

discharged into the area around Victoria Harbour

(Sector A).

We have estimated that about 2 tonnes of toxic

metals and about 15 , 000 tonnes of waste oils may

be discharged each day.

9.10 We have considered the quality of the coastal

waters in relation to their use (2.9).

We note that available monitoring data suggests

that levels of pathogens in the waters at

scheduled beaches are within the maximum levels

recommended by the Commission for the European

Communities in their proposed directive on water

quality. The levels of pathogens are above the

target 'guideline values 1 : but there is no

indication that the quality of the water is

deteriorating.


210 • Environmental Resources Ltd

We have noted reports that the oysters can

become grossly contaminated with faecal bacteria;

and that it is argued that long living bacteria

from the Pearl River waters may be largely

responsible.

We have noted that there is no evidence that

coastal fisheries have suffered from pollution.

There have, however, been some incidents where

marine fish farms have been affected.

In addition to their use for recreation and fishing,

the coastal waters provide a facility for waste

disposal; much of Hong Kong's effluent is currently

untreated and is dispersed and degraded by the sea.

It is important that the sea should not become so

overloaded with wastes that its powers to assimilate

them are impaired - with the resulting impact on

recreation, fishing and general amenity.

We note the long term objectives for the state of

harbour waters developed by PWD and we support these

proposed guidelines* We note also the hazards

associated with the discharge of wastes into the

enclosed waters of Tolo Harbour.

We have estimated the cost of recovering toxic

metals, grease and oil from all discharges into the

coastal waters. We calculate that to treat

effluents from existing plants this would require

capital expenditure of the order of HK$4OO million

and annual expenditure (amortisation of capital

and operating^costs) of about HK$10O million.

The cost would fall largely on industry; particularly

on textile manufacture, electroplating, chemical

manufacture, tanning and food and drink manufacture.

We have also estimated the cost of secondary

treatment of all discharges in addition to the

steps outline above. This would effectively

remove any serious potential impact of effluent on

coastal waters. We calculate the capital cost

would be of the order of HK$4OOO million and the


21 °" Environmental Resources Ltd

annual cost about HK$850 million or HK$200 for

every person living in Kong Kong.

9.12 We have outlined the relevant legal controls in

Appendix B, 4.37 and 4.44.

We note that the Public Health and Services

Ordinance S6 prohibits the discharge of oil or

petroleum spirit into any public sewer or drain;

but that there is no equivalent provision

prohibiting discharges to watercourses or nullahs.

The Merchant Shipping Ordinance S71(A) provides

that an offence is committed if oil is discharged

or escapes from a vessel or place on land "into

the waters of Hong Kong 11 / but that term does not

appear to apply to inland watercourses.

We also note that controls over the discharge of

oil from vessels or places on land into the waters

of Hong Kong are now similar to those in the United

Kingdom Prevention of Oil Pollution Act 1971,

except that there are no restrictions on the transfer

of oil at night, as in S10 of the United Kingdom

Act. The Dangerous Goods Ordinance gives close

control over the storage of petroleum, but not

over other oils. Recommendations have already

been made, however, for statutory requirements

relating to oil from tank farms and terminals and

to enable the Director of Marine to require specified

precautions to be taken during tankering. It has

also been suggested that the Governor in Council be

asked to use his powers to give the Director of

Marine powers to control all ship movements in Hong

Kong waters, so as to reduce the risk of pollution

accidents.

We have made the following proposals for the

protection of the marine environment:

The Authority recommended

above (9.8 ) for inland

waterways should also have

discretionary powers to control

discharges to coastal waters -. . R11


21 ! * Environmental Resources Ltd

The Authority should be

responsible for monitoring

the levels of contaminants

in the coastal waters and

for ensuring that levels of

contaminants are not of an

order that could create a

hazard

R12

We have commented that attention should in

particular be paid to reducing discharges of

toxic materials, grease and oil from land-based

sources.

We have noted the existing situation relating to

the dumping of waste at sea and oil pollution

from marine sources (2.11). With regard to

the latter, we note the proposal that the owner

or the master of a vessel responsible for an

oil pollution incident should be required to

appear in court in person; we suggest a better

solution might be the requirement that the owner

should lodge a bond, equal to the maximum fine if

necessary, before sailing*


212 * Environmental Resources Ltd

NOISE POLLUTION AND ITS CONTROL

9.13 We have reviewed the problem of noise pollution

in Hong Kong in Appendix A, Section V, and the

existing legal controls in Appendix B, 4.57 -

4.62.

About fifteen complaints each month are made to the

Labour Department about noise from industrial

sources; the problem is exacerbated because of the

presence of industrial enterprises in domestic

multistorey blocks. There are no legal provisions

for the control of industrial noise except that

provisional registration of a factory may be

withheld on grounds of noise nuisance (3.2(i>).

The high noise levels from construction work in

the urban areas proves to be a considerable

nuisance "in the crowded conditions of Hong Kong.

Under the Summary Offences Ordinance S13 it is an

offence to use a pile driver between the hours of

8.OO p.m. and 6.00 a.m. or on a public holiday;

there are proposals to extend this prohibition to

other forms of construction equipment. We doubt

whether a simple extension of the present provision

will prove fair and effective. We note that often

baffles on existing equipment are removed to

facilitate operation (3.2.(ii)).

Other neighbourhood noises, including noise from

advertising, recreation and air conditioning give

rise to complaint. These are currently dealt

with under the Summary Offences Ordinance.

We have made the following proposals for the control

of noise from these stationary sources;

With the introduction of

land-use planning controls,

noise standards should be

adopted by the planning


213 * Environmental Resources Ltd

authorities as guidelines for

the limiting of industrial noise

in residential areas

R13

A system of type approvals should

be applied to construction

equipment under which approval of

the control authority would be

needed for the manufacture, import

or use of any particular type of

civil engineering construction

equipment


214. Environmental Resources Ltd

for existing plant the summary

proceedings outlined above (RL6)

could be used

We question whether the defence of 'best practicable

means 1 should be made available to anyone creating

a noise nuisance in the source of trade or

business*

9.14 Available data on noise from traffic would suggest

that the noise nuisance is considerably in excess

of the nuisance in, for example, London, The

roads are congested, the traffic slow moving,

some vehicles are poorly maintained and some car

and motorcycle silencers may be less than

effective.

The control of traffic noise is currently

undertaken primarily by regulations relating to

the fitting and maintenance of silencers and to

the use of the vehicle (Road Traffic (Construction

of and Use) Regulations 26, 102, 107). There are

other regulations relating to noise but these

mainly deal with special problems rather than

general traffic noise.

We have noted that there are two types of solution

for reducing traffic noise: ensuring individual

cars make less noise (through type approval,

improved maintenance, etc.) and by curbing the

volume of traffic and easing congestion. The

latter solution includes the outright prohibition

of certain vehicles (e.g. private cars) using

certain thoroughfares at certain times; improving

the traffic flow; using financial disincentives to

reduce the number of vehicles using central urban

areas; the provision of priority traffic routes

for commercial and public transport.

We note that consultants are currently studying

Hong Kong's transport problems; we regret that

noise reduction was not one of the objectives of

the study.


2 1 5 * Environmental Resources Ltd

We have made the following proposals:

A type approval scheme should

be established to cover all

classes of motor vehicles and

all relevant component parts

R18

In areas of new development,

careful land-use planning can,

to some extent, prevent the

growth of noise nuisance from

traffic on the roads; standards

should be adopted as guidelines

to be used when planning roads

and adjacent developments

R19

If further studies of traffic flows

show that curbing of traffic in

urban areas is feasible in Hong

Kong, powers should be granted to

the relevant authorities to

regulate traffic for the purpose

of environmental improvement

R20

We have suggested that consideration be given to

the use of electric vehicles; this would ease

noise and fumes from vehicles but would increase

the cost and emissions from power stations.

However, the new electric buses might merit

consideration - - - -

Noise from aircraft represents a particularly

intractable problem. It interferes with

teaching in schools (about 34% of Hong Kong's

pupils are taught beneath the flight path); it

interferes with work and conversation (about a

million people live close to the flight path);

it interferes with rest and relaxation and

convalesence in hospitals*


* JtLn virofune nt'is i'" 'iSHsJu is k'iESa' U !L c u

Controls over the operation of aircraft have

been instituted. There is a prohibition on

aircraft movement between midnight and 6.30 a.m.

and every effort is made to ensure that planes

land and take off over the sea during the late

evening and night. Operators are not permitted

to rev up their engines between midnight and

7.00 a.m.

The solutions to the nuisance for aircraft noise

are of two types: controlling the noise at source

and protecting the recipient. Methods in the

first category include moving the airport/

reducing operation further and penalising noisy

aircraft. Of these, probably only the latter is

practical in the foreseeable future. It has

been suggested that noisy aircraft should pay

higher landing charges (a method adopted by other

airports such as Manchester in the DK) . Before

action is taken/ we suggest that preliminary work

is carried out to establish the extent to which

the noisier aircraft constitute an additional

nuisance. Consideration also needs to be given

to the effect on local airlines/ on movements in

and out of Hong Kong and on safety; at London,

Heathrow/ there is a tendency for pilots of

aircraft to try to f beat the meter 1 by throttling

back or climbing away from the monitor. At Kai

Tak such tactics could prove hazardous.

In the absence of any satisfactory methods for

curbing aircraft noise/ measures should be

considered for the protection of the recipient of

noise. In particular/ consideration should be

given to insulation either during the construction

of the building or by more insulation of existing

buildings. Schools are a priority target. For

domestic dwellings/ the cost could be about $200

to $300 per head (assuming a housing density of

one person per 3.5 square metres of living space).

There would also be additional running costs of

the order of $70 per person. The cost of insulating

a school per pupil should be less: give the two

shift system/ the cost might be of the order of

$50 per pupil and the running cost $2O.


2 -^7 * Environmental Resources Ltd

We have proposed that:

An investigation should be carried

out to establish in which schools

and hospitals aircraft noise is

unacceptable and a programme be

developed and costed for their

insulation

R22

A similar investigation be

carried out for domestic dwellings;

but this must take lower priority

R23

No permission for new schools,

hospitals or domestic dwellings

should be granted in areas where

aircraft noise interferes with

schoooling or relaxation *. R24

We consider that in order for Hong Kong to achieve

an improvement in the noise environment, a

programme for the reduction of noise levels should

be developed. The purpose of the programme should

be to provide the framework within which the

necessary decisions can be taken for the progressive

reduction of noise levels in different areas and

at different times, to a level compatible with the

use of the environment by the community in that

place or at that time.

We note that currently noise monitoring and noise

control is the responsibility of a number of separate

authorities. For a form of pollution which requires

a considerable degree of expertise for official

monitoring and effective control, and in a small

territory where expertise is therefore scarce and

financial resources limited, this is probably not

the most efficient use of resources. Although we

accept that enforcement can be more effectively

exercised by those whose work brings them frequently

into close relationship with the source of noise,


Environmental Resources

as with police and road traffic, we believe that

the centralisation of responsibility for noise

control in a single authority would have

considerable advantages over the present diversity<

We believe that the authority should develop

noise standards* These standards should be used

as guidelines for planning purposes, for taking

decisions about the need for action on existing

noise problems and determining the potential

noise impact associated with new developments

(including transport plans)*

In order to establish these standards, a noise

monitoring programme would be required.

We have therefore proposed:

The setting up of a single

authority responsible for the

control of noise from all

sources

This authority should be

responsible for developing a

programme for progressive

noise reduction; to achieve

this, monitoring should be

carried out to establish noise

standards for different areas ... . .- R26


219. Environmental Resources Ltd

AIR POLLUTION AND ITS CONTROL

9.17 We have discussed the main sources of air

pollution and the available data on the quality

of the atmosphere in Appendix A, Section "ill.

We have noted that the combustion of fuel oil and

the incineration of refuse releases about

315 tonnes of sulphur dioxide into the atmosphere

each day. Of this about 80% is emitted by the

electricity generating stations. However, about

65% of all emissions are from chimneys of over

100 metres and reasonable dispersion of the

pollutant might be expected. The * low level

emitters 1 are mainly situated in the Kowloon/

Tsuen Wan area (PPUS 2 and 3) and, apart from

Hok Un power plant, these low emissions are

mainly from small industry. The sulphur dioxide

emission is dependent on the sulphur content of

fuel and there was some increase in sulphur content

of fuel imported into the Territory in 1974 as

compared with 1972. However, the limited

monitoring data does not suggest a deteriorating

situation: through the efforts of the authorities

and the electricity generating companies there

has been a marked decrease in concentrations of

sulphur dioxide since the late 1960s. However,

the monitoring stations are few in number and do

not record peak concentrations: there is concern

that high levels may build up undetected.

When the desalter is running at full capacity,

a further 140 to 200 tonnes of sulphur dioxide will

be released, depending on the sulphur content of

the fuel oil.

Smoke, dust and grit are released into the

atmosphere by the combustion of fuel/ refuse

incineration, construction and civil works and

certain process industries. These contaminants

impair visibility, reduce amenity and may effect

health. We understand that the problem of smoke

has been reduced through the efforts of the air


Environmental Resources Ltd

pollution control officer in assisting fuel oil

users to increase the efficiency of their

combustion. Grit and dust from incineration

causes concern and is undoubtedly a major source

of these emissions. Plumes of steam arising

from the incinerator also give rise to complaints

and onlookers may sometimes confuse steam with

smoke *

Nitrogen dioxides, hydrochloric acid and other

gases are released during the combustion of oil,

refuse and manufacturing industries. We have no

evidence that any of these fumes are creating an

environmental problem*

Vehicle fumes, however, do give rise to

considerable concern. The pollutants include

carbon monoxide, unburnt hydrocarbons, nitrogen

oxides, particulates, lead and comparatively small

amounts of sulphur dioxide. Slow moving congested

traffic coupled with high rise buildings

exacerbate the problem; under certain conditions

the streets become extremely unpleasant. We

have little evidence on the levels of pollutants

from traffic; some limited monitoring suggests

that there may be localised high concentrations

of some pollutants. Analysis of carbon monoxide

levels in policemen's blood undertaken some years

ago suggested no cause for concern.

9.18 We have commented on the methods of controlling

emissions from stationary sources (4.3, 4.4).

We calculate that the annual cost of a general reduction

of the sulphur content of fuel from 2.75% to

2.5%S would cost the Territory about HK$lOm and to

1.5%S would cost about HK$50m; 44% of the cost

would be borne by commercial users, 35% by

commercial users and the balance by domestic users.

The textile industry might bear as much as 3O% of

the total cost.


2 2 - 1 * Environment a! Resources Ltd

We have also calculated the cost of just reducing

the sulphur content of fuel for 'low level

emitters 1 in the Hong Kong-Kowloon-Tsuen Wan area

(PPUS 1, 2 and 3) where the problem of sulphur

dioxide appears most acute. The cost for

reduction to 1.5%S would be about HK$12iru per year.

We do not accept that the increased cost could

be offset by increasing the efficiency of fuel use

We feel this to be a spurious argument since it

is in everyone f s interest that this increase

should be achieved in any case: it will still be

necessary to pay the premium for lower sulphur

content. / x

We have also examined the cost of reducing the

grit and dust emissions from the incinerator;

this would cost $10m or more per incinerator and

would add $5 or $6 per tonne of refuse incinerated,

We have noted that reducing grit and dust from

construction sites and mining is a matter of good

management and of 'damping down 1 where possible.

For other emissions from stationary sources,

reduction requires improving dispersion and,

where possible, minimising the quantity of the

contaminant produced at source.

9.19 We have reviewed the existing legal controls over

emissions from stationary sources in Appendix B»

The principal legal controls are to be found in

the Clean Air Ordinance and Regulations made

* thereunder; further legislation has been proposed

to supplement the present Ordinance but we have

no details of these proposals. We note that the

present legislation appears effective so far as

smoke control is concerned and that dust and fumes

are included in the definition of smoke.


222. Em iroomental Resources Ltd

In addition, steps are taken to minimise the

impact of new developments on the atmosphere by

the siting of industries and by recommendations

on chimney heights.

There appears to be no legislation covering the

suppression of odours.

We have made the following proposals for the

controls over emissions from stationary sources:

'soot, ash, grit or gritty

particles emitted in smoke steam 1

should be included in the

definition of smoke but in our

view separate provisions should

be made for fumes, including

noxious vapours, and for grit

and dust

R27

grit and dust from industrial

processes, including the loading

and transport of materials should

require different arrestment

methods appropriate to each; the

control authority should be given

powers to require the installation

of a specified type of equipment

or the adoption of a specified

procedure

if further investigation shows a

need for the reduction of levels

of sulphur dioxide, the control

authority should have the powers

to require increased chimney

heights or restrictions on the use

of high sulphur fuels

R29


2 2 3 * Environmental Resources Ltd

for other gaseous emissions,

the processes and emissions should

be specified and the Governor

empowered to impose limits on the

emissions of these gases; and the

control authority should be

empowered to require the installation

of specified equipment or the

adoption of specified control measures

or the construction of a chimney

of specified height .. . ..

R30

If the control authority should decide that

sulphur dioxide levels should be reduced by

selective restraints on high sulphur fuels (for

example, low level emitters in Kowloon) then

we consider that the added cost should be borne

by all fuel users through a fuel cost equalisation

tax. This is in the interests of enforcement

(low sulphur fuel would not cost the the consumer

more so there would be less tendency to use the

high sulphur fuel in the area where low level

sulphur fuel should be used) as well as in the

interests of equity.

9.20 We have reviewed the methods for controlling air

pollution from traffic.

We note that nuisance from excessive smoke from

vehicles can be alleviated by good management/

maintenance and regular inspection; at present,

there is no regular requirement for measurement

of smoke emissions at the regular inspections

carried out on certain vehicles. Smoke from

diesel vehicles is increased if the cold-start

(choke) is used to assist the vehicle to climb

a gradient.

To remove lead from emissions of vehicles a

lead trap can be used or the lead additive in the

petrol may be reduced or removed; the added cost

is of,the order of $10-20 per thousand miles.


2 2 4 * Environmental Resources Lid

Carbon monoxide and hydrocarbons can be

oxidised by a catalyst converter provided that

the petrol contains no lead; the fuel should

contain no sulphur or else there is the danger

of emissions of sulphuric acid mists.

But, as for noise pollution, fumes from traffic

can be effectively reduced by reducing the volume

of traffic and increasing its flow. This may

be achieved by curbing the use of the private

car provided adequate public transport facilities

have been provided.

9.21 We have reviewed the legal controls over the

emission of fumes from vehicles in Appendix B.

The Road Traffic (Construction and Use Regulations

27A) last year introduced a type approval scheme:

but we note there are no provisions relating to

individual components which may be fitted as

replacements nor is there a provision to ensure that

each vehicle conforms to type. New regulations

have been prepared to limit emissions from diesel

engined vehicles and to limit visible smoke from

all vehicles.

We agree that one of the most effective methods

for limiting emissions from-individual vehicles is

to ensure satisfactory maintenance standards backed

up by an adequate system of inspection: but we

accept that this involves substantial resources.

Whether or not these should be made available must

depend on the overall availability of funds for

environmental improvement and the priorities that

are established for use of such funds.

We have made the following proposals:

Consideration should be given

to a type approval scheme for

components, for motor cycles and to

a scheme to ensure that all

vehicles conform with type

R31


2 2 5 • Environmental Resources Ltd

The fitting of a choke in

the cabs of a diesel vehicle

should be forbidden

R32

The Control Authority should

consider tne need for lowering

the emissions of carbon monoxide,

lead, hydrocarbons and other

pollutants; this need only be

established by further monitoring

and tne availability of vehicles

and equipment to meet stricter

emissions standards need to be

taken into account

R33

These measures need to be supplemented by controls

over traffic movements if the quality of the air

in the busy urban thoroughfares is to be

substantially improved ..* R34

We have proposed that the Control Authority should

develop an air pollution control programme. The

programme should include:

the setting of air quality

objectives that will ensure that

levels of contaminants do not

pose an unacceptable threat to

health of amenity;

the phased reduction of emissions

in the areas where present levels

exceed the cargets set for the

programme: this reduction must take

account of technical, economic and

social considerations.

We have proposed this programme because measures to

reduce air pollution are expensive and it is

important that the most cost-effective measures are


226. Environmental Resources Ltd

employed. At present there is no framework

within which such decisions can be taken.

We have given detailed consideration to the

question of monitoring (4.8). We have proposed

that a mobile monitoring unit should be acquired

to measure atmospheric pollution from stationary

and mobile sources. The cost would be about

HK$1.7 million to acquire the unit: skilled

technicians would be required for its operation.

We consider that an initial monitoring programme

based on a mobile unit would provide sufficient

data to allow decisions to be taken on:

the extent of air pollution in

different areas of Hong Kong;

whether a more comprehensive

network is necessary;

whether further air pollution

controls are required.

We consider that in principle the air quality

objectives should be achieved through use of

product standards, design and installation

standards and operating standards. We do not

consider air emission standards to be appropriate

for Hong Kong; control by this means would be

difficult to enforce and would require comprehensive

monitoring.

We therefore propose:

that a single authority should

be responsible for the development

of an air pollution control

programme; this programme to

include the setting of quality

objectives *


227. Environmental Resources Ltd

that further data on environmental

quality is required to enable the

necessary decisions to be taken:

a mobile monitoring unit should

provide this data . * R 36

* controls over sources of emission

I should be through methods other

. than emission standards R 37


2 2 8 * Environmental Resources Ltd

SOLID WASTE

9.23 We have reviewed the quantities of solid waste

arising from municipal and industrial sources and

the methods employed for their collection and

dispersal (Appendix A, Section V).

We estimate that excluding construction rubble

about 3,000 tonnes of solid waste is generated

each day; by 1984 the quantity may have doubled.

A large proportion (about 70%) is collected by

the Urban Services Department; this is mainly

domestic refuse but includes some industrial

and commercial solid waste* Private companies

collect the bulk of the remainder (mainly

industrial in origin) rubbish from harbour waters

is collected by a scavenging team working for the

Marine Department.

Over the next ten years, we envisage an additional

solid waste load arising from sludge produced by

the treatment of domestic and agricultural effluents,

and from the treatment of industrial effluents which

contain toxic materials (which would be precipitated

out as sludges).

Incineration capacity is being increased to handle

over half of Hong Kong f s current solid waste

arisings; there are plans for a further plant with

a capacity of 900 tonnes per day. No other form

of pretreatment is currently undertaken but there

are plans (and a pilot plant) for composting and

consideration is being given to other forms of

treatment*

9.24 In the Report (Section 5.2, 5.3) we have examined

the position with regard to the collection of solid

waste.


229 . Environmenta! Resources Ltd

We note that some problems arise with the

accumulation of refuse in the common parts of

buildings, particularly through bins

overspilling and through indiscriminate littering.

A Working Party on Refuse Chutes recently concluded

that it would not be practical to make the provision

of refuse chutes mandatory. There is at present

no provision for the approval or requirement of

any refuse collection or storage facilities under

the Building Ordinance.

A further problem arises with large blocks of

flats in common ownership where no one person is

responsible for the cleanliness of the common

parts; the Multi-Storey Buildings (Owners*

Incorporation) Ordinance provides some assistance

in overcoming this problem.

It has been suggested by the Refuse Chute Working

Party that consultants should be appointed to

consider problems caused when refuse is transferred

from the household to the collection point. We

agree with this suggestion.

The USD is overcoming problems associated with

on-street collection points by the construction

of purpose-designed off-street points. We note

that there are no registration requirements for

private collectors and for the carrying of trade

wastes.

We understand that there is at present no

collection service for refuse from boat-dwellers:

the USD encourages them to make use of land-based

facilities. We estimate that as much as 1O,OOO to

15,OOO tonnes of refuse could be dumped overboard

each year. While this is an offence under the

Summary Offences Ordinance (S4), enforcement is

virtually impossible.

Consideration should be given to the following

proposals designed to help to provide the necessary

framework for overcoming some of the present


230 ' Environmental Resources Ltd

difficulties associated with refuse collection

More precise specifications

should be laid down for household

recepticles for refuse

Building regulations should

require adequate facilities be

provided within blocks of

domestic flats for the temporary

storage of refuse

R39

Powers should be provided to

require the occupiers of multistorey

buildings for residential

use to appoint a management

corporation for each building, if

necessary backed by default powers

granted to the Urban Services

Department

R4O

The Authority should give

consideration to ways of

protecting refuse awaiting

collection from becoming wet:

the high moisture content gives

rise to problems during

incineration *

We appreciate that the dumping of refuse from small

boat-dwellers presents a particularly intractable

problem. Further discussions will be required

before we can make firm recommendations. But we

proposed consideration be given to the following;

The duties of the present harbour

cleansing service to be extended

so as to cover a refuse collection

service for small craft and the

present cleansing service

H42


Environmental Resources Ltd

Licence fees to be increased

so as to make a substantial

contribution to the extended

service

^43

A publicity campaign to be

mounted to impress on boatdwellers

that licence fees can

be kept down by use of the

collection service

R44

Furthermore, consideration should be given to USD taking

over responsibility for the operation of the harbour

scavenging fleet and for this operation and that

their responsibilities for refuse collection be

extended to cover the boat-dwellers

R45

We are aware of the serious practical difficulties:

but in view of the extent of the problem we consider

that some programme for action is required.

9.25 We have discussed the environmental impact associated

with solid waste disposal methods and the environmental

controls (5.5 - 5.7).

We have noted that there is little dangerous or

intractable waste produced in Hong Kong at present;

although we are informed by a private source that

chrome sludge has been tipped at Gin Drinker's

Bay. Stricter water controls would increase the

quantity of hazardous waste requiring disposal.

rattan baskets, because of their character and

/" ^ number, are said to cause disposal problems. There

is some dumping of oily wastes.

We have estimated the cost of a specialist treatment

centre for toxic sludges able to handle up to 2O tonnes

per day as being about $15m. The cost of treating

a tonne of sludge would be of the order of $4OO per

tonne .


232 * Environmental Resources Ltd

Incineration and controlled tipping of municipal

wastes may give rise to problems of air and water

pollution that should be dealt with by the relevant

authority: reducing the emission of dust and grit

to a low level may cost well over HK$10m per

incinerator and add about $6 per tonne to cost of

refuse incinerated.

We have made the following proposals:

The Control Authority should

prepare a disposal plan that

should take account of future

requirements for disposing of

oily and toxic wastes (see

also 9*33 below)

R46

The Control Authority should

investigate whether any of the

tips are suitable for

receiving toxic materials

R47

j.

The Control Authority should

consider potential for the

reclamation of waste oils/

waste solvents and chemical

sludges R4 8

- "• "\ The Control Authority should

consider the use of screens,

vperhaps trees, to reduce the

nuisance for disposal sites

, v"" ^v v * \yr*~ that scheduled industries and

*" * ^ ^ users of scheduled sxibstances

should notify the authorities

as to how they dispose of their

wastes

We have suggested that the Government may want

to consider whether some charge should be made

for the disposal of industrial or trade wastes.

R49

R5O


233. Environmental Resources Ltd

9.26 We have reviewed the problem of litter (5.8 ~

5.10). We have commented that apart from its

impact on amenity, litter represents a real and

unnecessary financial loss through the costs of

cleaning up and the damage it causes to xnland

waterways and to water intakes on boats and

industrial plant.

Dropping litter is an offence and through the

Keep Hong Kong Clean Campaign every effort has

been made to reduce the problem. Some progress

has also been made with the removal and disposal

of vehicles; but we note that there is no power

to recover the cost incurred in removing the

abandoned vehicle.

We have commented (5.10) that the problem of

litter is not one that can be solved by one

method alone; and that increasing the risk of

detection and prosecution probably is a more

effective deterrent than increasing the maximum

fine. We also discuss the possibility of

minimising the potential amount of litter by

increasing deposits on returnable containers etc.

We make the