Monday, 22 February 2010

Loopholes in Environmental Impact Assessment

Loopholes in Environmental Impact Assessment
Written by Guan Zhong

     The following article presents a very real and disturbing example of the threat of pollution to the ecology of Beijing and to the health of its population and how local citizens were able to expose attempts by local government departments to hide the dangers posed by a proposed refuse incineration plant. It is significant for its universality, yet at the same time for revealing the serious challenges to environmental protection faced in China. The fact that the attempt by certain key government institutions to hoodwink local citizens was effectively uncovered and made known to the public says volumes about the advancement of political rights and improvements in terms of the transparency of the press in China. On the down side, it is nothing short of terrifying to imagine that the central government, even here in the nation’s capital, was either unaware of, indifferent to, or supportive of a project which would have devastating implications for the city’s environment, including the poisoning of Beijing’s only source of drinking water.

     Liulitun should loom large as a key chapter in any future written history of the management and disposal of domestic refuse in China. Not only are the residents in Liulitun fighting for the environmental rights and rights to existence that they deserve with wisdom, rationality, and persistence, they are also setting a brave and effective example for people living in Shanghai, Nanjing, Wuhan, and other cities, in fighting for their legitimate rights and interests.
     Due to suspicions and doubts raised toward the Environmental Impact Assessment (EIA) Report of a local project, the residents of Liulitun studied the report in great detail, only to discover one problem after another. And by seizing upon so many fundamental errors with the EIA, they were finally able to protect their rights with confidence and conviction. In the face of strong public resistance, the question of whether or not to build a refuse incineration power plant in Liulitun has become a real dilemma. The root of the stalemate, and a series of related consequences, lies in the Environmental Impact Assessment of the project that was released by the Beijing Academy of Environmental Sciences.

EIA Supports Incineration

     Liulitun’s domestic refuse landfill site - the first phase of which was finished in 1999 and the second in 2001 - is the only domestic waste disposal facility in Beijing’s Haidian District. It was designed to handle 1,500 tons of garbage per day. Although not originally anticipated, the first phase had been fully filled within 5 years due to the increase in refuse resulting from an accelerated rate of urbanization. Based on the current refuse disposal requirements of 2,700 tons per day, the capacity of the project’s second phase will run out in 2013. Such a predicament presents a truly serious issue in urgent need of resolution.
Entrusted by the Environmental and Urban Landscape Services Center of the District of Haidian, the Beijing Academy of Environmental sciences undertook an assessment of the environmental impact of the proposed landfill and drew up an environmental impact assessment report. According to the report: “The project is feasible in terms of environmental protection, based on the condition that its implementation and design adhere to carrying out measures for the prevention and control of pollution as mentioned in the report.”
The report by the Beijing Academy of Environmental Sciences entitled, “An Environmental Impact Assessment of the Refuse Incineration Power Plant and Comprehensive Treatment Plant of Beijing’s Haidian District” was submitted by the Beijing Environmental Protection Agency, as environmental review document [2005] 1066, to the Municipal Administrative Management Commissioner of Haidain District on November 11, 2005, and posted on the Internet on January 30, 2007. The review states, “The construction of a refuse incineration power plant and a comprehensive treatment plant to the southwest of the Liulitun waste landfill has been officially approved. The proposed project is designed to dispose of 1,600 tons of waste per day, including 1,200 tons to be incinerated for power generation, and 400 tons for composting, at a total investment cost of 1 billion RMB.” The report had given the green light for the construction of the project. However, this news aroused a great stir in Liulitun. People had heard about the refuse incineration plant, but they felt the environment impact assessment on the Internet lacked credibility and were greatly shocked by the fact that the key arguments and conclusions of the assessment flew in the face of basic common sense. The malodorous gas from the garbage landfill had already affected the daily life of the residents and the number of people living near the landfill with respiratory disease as well a high incidence of tumors had clearly increased. One Liulitun resident, named Huang Shiping, who has been studying the EIA over the past several years, said: “The garbage landfill brings great harm to residents here and there is lack of strong supervision by the government. The EIA is neither objective nor scientific. Support for an incineration project here would only make it worse for Liulitun residents who have already suffered greatly.”

Project’s Site Selection Fraught with Huge Risks

     The EIA concludes that, “The proposed site of the project has been selected to be located to the southwest of the Liulitun waste landfill. The project, which has already been listed in the White Paper on Beijing’s Domestic Refuse Disposal, is in accordance with urban development planning.”
There is an obvious contradiction in the statement, “… in accordance with urban development planning”. According to the Beijing Municipal Comprehensive Plan (2004-2020), the area behind the Haidian mountains has been designated as an important base for high-tech development and research and innovation in Beijing. It is a key tourist area of the city’s northwest, which should step up the pace of its development in order to fully realize urbanization. The establishment of ecological, pastoral, and modernized natural ecological systems should be combined with an urban ecological system to form a comprehensive new city district. A High quality and collectively based developmental mode should be maintained and emphasis should be placed on harmony with the surrounding natural landscape. When referring to the building of a refuse incineration power plant designed to burn 1,200 tons of garbage per day how can one possibly speak of “high quality” or “emphasizing harmony with the surrounding natural landscape”? Item 3 of article 134 in Chapter 12 of the comprehensive plan regarding municipal infrastructure clearly states, “Waste pollution is forbidden in water conservation areas and other key areas.” So how can one speak of keeping water conservation areas free of waste pollution when the proposed site for building a refuse incineration power plant is only 1 kilometer away from the Jingmi diversion canal, Beijing’s only water supply channel?
     Special topographic and climatic conditions adverse to the diffusion of pollutants also exacerbate pollution and increase environmental risks. The planned location for waste incineration is in the northwest part of Beijing. According to standards outlined in The Guiding Principles for Atmospheric Environmental Assessment, the proposed site is located in an area of complex topography, which is surrounded by the foothills of Baiwang Mountain in the south, and the Yan mountain range in the west. Thus, the area has a lower solar radiation grade. In addition, the cooling of the ground surface in the area is sped up by the Jingmi diversion canal, which flows from west to east every evening. The surrounding Baiwangshan foothills form a 'dustpan' topography, which decreases the angle of wind direction and wind speed in the area. All of the aforementioned unfavorable topography and climatic conditions lead to highly stable atmospheric conditions, which may easily form a thermal inversion layer and frequently produce pollution from smoke and fume at high concentrations. Owing to the increased range in pollution caused by the thermal inversion layer’s effect on downwind pollution, in conjunction with Beijing’s dustpan topography which is surrounded on three sides by mountains, the dissipation of pollutants is made more difficult. At the same time, it also brings higher risks and exacerbates atmospheric pollution in the areas upwind of and surrounding the Liulitun Waste Incineration Power Plant.
     The waste incineration factory would, in reality, increase rather than decrease the threat caused by pollution. According to the Environmental Impact Assessment, “Atmospheric projection results predict a very slight influence on the atmospheric conditions in the residential areas being assessed.” However, this viewpoint is, in fact, very difficult to support. As stated by the laws of conservation of mass, we can only change the state of matter, but not its mass. As much research work done both domestically and abroad reveals, aside from the residue created after the incineration of 1 ton of household garbage, the remainder can only be converted into approximately 5,000 cubic meters of gas. Thus, it is apparent that the harm brought about by incineration to the surrounding residents would be increased. The former brick factory, cement plant, and refuse landfill have created an enormous strain on the environment, so it would be intolerable for the citizens, already unable to bear any further affects caused by pollution, to see black fumes spewing out from an 80-meter high chimney all day. Research done by the Ecological Environmental Research Center of the Chinese Academy of Science in 1999 showed the emission of acidic gases such as carbon dioxide, sulfur oxide, and nitrogen oxide would contribute to global warming and acidification. The impact on acidification from incineration is ten times as great as that for sanitary landfills, sixteen times greater than that of simple landfills, and four times that caused by comprehensive treatment. It is a huge irony to describe such a project, which aggravates pollution problems, as a measure for alleviating pollution.

A Misinterpretation of ‘Protective Distance’

     According to the results of the Environmental Assessment report, “Considering the requirements of environmental security, it is necessary to establish a sanitary protective distance of 300 meters. At present, there are no environmentally sensitive targets within a distance of 300 meters.” But the distance mentioned above refers to the protective distance from the odorous stench of a sanitary landfill site, while here it is misrepresented as the appropriate protective distance to safeguard against the effects of gaseous pollution from an incineration plant.
     Closely connected to protective distance is the concept of sensitive targets. A military unit is located to the north of the planned Liulitun incineration plant, the Xiliu Construction workers dormitory is located within 200 meters, and the Yongyou Software Park is located within 500 meters of the proposed site. With respect to the Liulitun incineration plant - including the seismic belt, the Jingmi diversion canal, over 200, 000 local residents, the Beijing Botanical Garden, the Fragrance Hill Park, the Yuan Ming Yuan Relics Park, the Summer Palace, and the site of a military unit - which of these cannot be considered as sensitive targets? As Huang Shiping points out, the planned incineration plant is only 7 kilometers away from Yuquan Mountain and the Summer Palace, a world cultural heritage site and a state-level imperial garden, and is also within 5 kilometers distance of Fragrance Hill Park - a natural scenic spot, the Beijing Botanical Garden - an ecological natural reserve, the Daoxiang Lake Manmade Wetland Park, and the Baiwang Mountain Forest Park. As to the question of whether or not such areas are sensitive, the answer could not be more obvious.
Surrounding the planned incineration plant site are many scientific research institutes and high-tech enterprises, such as the Beijing Aerospace City (an astronaut training center), the Zhongguancun Science and Technology Park, and the Yongfeng Industrial Base, etc., among which Yongyou Software Park is only 200 meters away from the refuse landfill, and less than 500 meters away from the planned incineration power plant. At the same time, many medium and large-sized residential areas have been built in the vicinity, such as Yihe Villas, Qianqiu Gardens, Jade Water Gardens, Baiwang Jasmine Gardens, Zhonghai Fenglian Villas, Autumn Dew Gardens, Summer Rain Gardens, Baoli West Hill Forest Gardens, etc. In addition, there are also plans to build more residential complexes and residential services projects, including the Capital Iron and Steel Co. Estate, the Beijing University International Hospital, Phoenix City, and so on. The site chosen for the incineration plant is next to several Science and Technology Parks such as the Yongfeng High-tech Industrial Base, Zhongguancun Software Park, Aerospace City, the Shangdi Information Industry Base, etc. - an area comprised of a population of several hundred thousand employees and residents. It is truly inconceivable that building a refuse incineration plant in such a densely populated residential area could not be considered ‘sensitive’.

Persistent Shadow of Dioxins Hard to Dispel

     The EIA report states: “The refuse incineration plant intends to invite bids for the use of advanced and mature foreign technology and equipment, while dioxin emission levels will meet EU Standards.” During administrative review pleadings on dioxin emission standards, the Beijing Environmental Protection Bureau stated: “In terms of dioxin, which is of concern to the general public, our national emission standard is 1 nanogram per normal cubic meter, while there are even stricter controls set in the design of this project, so that emission concentrations may also meet the strictest current standards of developed nations of 0.1 nanograms per normal cubic meter. This figure is beyond dispute in international academic circles and there are no related control threshold values with respect to environmental risks.” Yet this conclusion is overly absolute and does not match up the reality of the situation. The incineration of refuse at high temperatures inevitably produces dioxins, as does the cooling process. Although applicable in theory, based on many years of practice both domestically and abroad, the technology of preventing the production of dioxins in the rapid cooling process, as well as the absorption of dioxins, has yet to meet with satisfying results and, in many cases, has led to failures. The EIA report claims that the detection of dioxins can only be carried out by examining the concentration of carbon monoxide in the smoke produced by incinerating refuse, so as to indirectly measure the concentration of dioxin emissions. According to section 7.3.3 of “The Technical Standards for Domestic Waste Incineration Engineering”: “In 1977, it was first reported in Austria that dioxins were detected from within the electrostatic device of a domestic waste incinerator furnace. The concentrations of dioxins in the smoke from the vent of an electrostatic precipitator with a temperature of less than 300°C are 100 times greater than that from the vent of a refuse incinerator furnace at a temperature of 800°C.” Thus, re-synthesis of dioxin will occur at temperatures below 800°C. Furthermore, the primary heavy metal component in domestic waste is copper, which acts as a catalyst for producing dioxin. Therefore, merely depending on testing carbon monoxide emission concentrations to determine the emission concentration of dioxin is unreliable. Internationally speaking, it is currently impossible to conduct on-line detection of dioxins.

Deliberately Avoiding the Question of Water Pollution

     The “EIA Report” deliberately chose less stringent monitoring of the quality of surface water and groundwater within the area of the proposed project by avoiding examining the impact of incinerated pollutants such as dioxins, heavy metals, mercury and other substances on the surface water, especially on that of the Jingmi diversion canal. The incineration of refuse converts solid waste into highly toxic gaseous pollutants. Dioxins and heavy metals produced by refuse incineration have an enormously harmful effect on humans, as well as on animals and plants. The project’s EIA report calculates, “the highest ground-level concentrations of dioxins would occur at a distance of 1,332 meters downwind of the chimney” while the proposed site for the Liulitun incineration plant is only 1,114 meters away from the Jingmi diversion canal - a key protected zone of the municipality of Beijing - and precisely the area in which the maximum concentration of heavy metals and dioxins would occur. Gases resulting from the incineration of refuse would cause varying degrees of pollution within a five-kilometer-wide radius, resulting in irreversible damage to the unique ecological environment of Beijing’s West Mountain area, while the surrounding downwind and downstream terrain will aid in creating even more widespread pollution.
     The EIA report has deliberately avoided characteristic pollutants. In the EIA report there are a total of 11 items for testing underground water quality including: pH, total hardness, total dissolved solids, chloride, ammonia nitrogen, nitrate, nitrite, sulfate, volatile phenols, total bacterial count, and total coliform bacterial count. In fact, the required inspection items for the testing of groundwater quality standards are as follows: pH, ammonia, nitrate, nitrite, salt, volatile phenols, cyanide, arsenic, mercury, chromium (hexavalent), total hardness, lead, fluorine, cadmium, iron, manganese, total dissolved solids, permanganate index, sulfate, chloride, coliform bacteria, as well as other items to reflect the main issues associated with water quality in the area around the proposed project site. This means that characteristic pollutant heavy metals such as arsenic, mercury, chromium (hexavalent), lead, fluorine, cadmium, iron, manganese, etc., which comprise more than 10 items, were simply not included in the scope of EIA testing. Not surprisingly, the EIA report claimed: “According to four test points of drinking water of groundwater streams in samples taken from four drinking water wells at depths of 80 to 100 meters, the water is of good quality and meets all the necessary requirements for drinking water.” Heavy metals, such as arsenic, mercury, chromium (hexavalent), lead, fluorine, cadmium, iron, manganese, etc., accounting for more than ten sensitive items which would reflect the main water quality issues of the Liulitun area, were simply not tested. Thus, it would be odd indeed if testing results showed that water quality failed to meet drinking water quality requirements.

Erroneous Facts Concerning Public Participation

     As the EIA report describes: “A total of 100 questionnaires were issued during the evaluation period and 85 of them were returned. According to statistics, 100% of respondents expressed dissatisfaction with the current state of the landfill, while 71% agreed to the waste incineration project, and 51% agreed to waste incineration in addition to comprehensive treatment. ” In response, the local residents of Liulitun sent out 400 of their own questionnaires and 387 were returned within a week, of which 358 were valid. Statistical analysis indicated that 98% of people were opposed to the building of the Liulitun incineration plant, while 2% were indifferent. 97.5% of respondents believed that the proposed waste incineration power plant’s pollution prevention and control measures were unreliable, and 96.9% of people believed environmental pollution caused by the building of a refuse incineration plant to be unacceptable. 93.2% of people believed the building of the refuse incineration power plant would have a negative impact on economic development in the surrounding area, while 94.9% of people believed that the incineration plant would have a harmful influence on the lives of the local residents. 95.5% of the people did not accept the argument that the proposed refuse incineration power plant would reduce the impact of the landfill on the surrounding environment. Analysis of the survey also showed that only 3.9% of people believed that the proposed waste incineration power plant would benefit their living and working conditions and that only 6.2% of people believed that it would be beneficial to the development of the local economy.

Originally translated by George Liu
Re-translated and edited by Chris Harry

1 comment:

  1. In a nation with such a large population the problem of garbage disposal and other environmental issues is a very large obstacle that will be hard to overcome.
    In Phuket garbage is a major problem but in latter years recycling has become a profitable business, thus changing the thinking of many people who before littered the streets but can now see the value of garbage separation as a way to make money.