http://www.lingfeiqi.cn/plus/view.php?aid=871
时间:2012-08-30 07:45来源:自然之友 作者: 点击: 27次
We are a group of non-governmental organisations and individuals who care about China’s environmental protection and social wellbeing. In this letter we would like to express our heartfelt concern regarding the investment and construction arrangemen
FROM:
21 Chinese NGOs and 16 Citizens
August 8, 2012
| TO:
KfW Bankengruppe
Palmengartenstraße 5-9
60325 Frankfurt am Main
Germany
E-Mail: info@kfw.de
Telefon: 0049-069 74 31-0 |
CC:
KfW Office Beijing
1170, Sunflower Tower
No. 37 Maizidian Street
Chaoyang District, Beijing 100025
PR of China
Tel: +86 10 85 27 51-71 / 72 / 73 / 74
EMail: kfw.beijing@kfw.de |
Dear Sir or Madam,
We are a group of non-governmental organisations and individuals who care about China’s environmental protection and social wellbeing. In this letter we would like to express our heartfelt concern regarding the investment and construction arrangements of the Beijing Nangong Municipal Solid Waste Incinerator, and would like to seek an opportunity to develop a frank dialogue with your bank.
In early May 2010 the Beijing General Municipal Engineering Design & Research Institute website revealed that the Chinese and German governments “will include Beijing NangongMunicipal Solid Waste Incinerator as a financial cooperation project under the Sino-German Financial Cooperation Framework. According to a 2006 feasibility research report the total investment allocated to this project is 775,530,000 Renminbi (about 99,000,000 Euros). 55,000,000 Euros will come from the Sino-German Financial Cooperation Fund, and will be implemented by the KfW Bank.” [1]
It was through the above information that we realised that your bank is a direct investor and important interested party in the Nangong Waste Incinerator. We believe that your bank can exert influence over this project, and that whether or not it is successfully operated will affect the reputation of German government and enterprises’ economic and environmental protection cooperation with China.
We noticed that your bank’s official website states: “The sustainability of our own actions and the projects we promote are at the top of KfW’s corporate agenda, and are even part of our global promotional mission. Our aim is to help stimulate sustainable investment that benefits the natural environment and economic development equally. Conversely, KfW therefore does not fund projects that are likely to generate unacceptable ecological or social impacts.”[2]
We have also noticed that the KfW Bank adopted the Equator Principles quite early, and such principles require banks look out for possible social and environmental risks and dangers to clients and other major stakeholders during the construction, production and operation of projects.
We deeply appreciate and acknowledge your bank’s above statement on environmental protection and sustainable development, and hotly anticipate that such principals will be applied to the investment and construction activities for the Beijing Nangong Waste Incinerator. However, according to our information, there are widespread problems associated with the use of waste incineration technology in China. Some aspects of environmental hygiene facilities in Beijing, which Germany has helped construct, are also worthy of re-examination. If these already existing problems are not addressed, resolved, or taken seriously by the responsible parties, the implementation of the Nangong Waste Incinerator project could harm the public interest of Beijing residents. It would also contradict your bank’s investment principles and harm the international reputation of the German government and companies.
In China municipal solid waste incineration is already an environmental pollution source that cannot be ignored. First, it is commonly known that the burning of waste will produce and emit dioxin-type pollutants. The Chinese government’s “People’s Republic of China National Implementation Plan for the Stockholm Convention on Persistent Organic Pollutants” lists municipal solid waste incineration as an emissions source whose control must be prioritised.[3] In 2009 academics from the China Urban Construction Design & Research Institute published an article stating that in 2007 the estimated airborne dioxin emissions from municipal solid waste incineration (there were less than 70 incinerators in operation in that year) in China was 157.93g TEQ (toxicity equivalent), which was a big increase on the 2004 figure of 125.8g TEQ. For comparison, in 1994 airborne dioxin emissions from municipal solid waste incineration in Germany were only 30g TEQ. It is estimated that this figure has been below 0.5g TEQ since the beginning of the 21st Century (around 70 municipal solid waste incinerators are running in Germany now). [4]In the same year, scholars from the Chinese Academy of Sciences published the results of their research into the airborne dioxin emissions from 19 municipal solid waste incinerators in China. According to their results, 13 incinerators did not meet the EU standard of 0.1ng TEQ/m3. Three incinerators even exceeded the Chinese national standard of 1ng TEQ/m3.[5] In addition, whilst investigating the environmental quality of soil around a waste incinerator in Shanghai’s Jiading District, researchers from the Shanghai Academy of Public Measurement discovered that dioxin levels were markedly higher than the surrounding area. Based on this, they made the following conclusion: waste incinerators are a source of dioxins in the Shanghai area’s land.[6]
Apart from dioxins, China’s waste incinerators also emit a large amount of the heavy metal mercury. According to a 2011 article by academics from the South China University of Technology, mercury emissions from municipal solid waste incineration account for 21% of total man-made mercury emissions in the Pearl River Delta, second only to emissions from coal-burning (28%).[7] In other case studies, Chinese academics have discovered that airborne emissions from municipal solid waste incinerators have resulted in sharp increases in the mercury content of surrounding land and flora.[8]
Why do waste incineration facilities that can be operated relatively safely in some European countries and Japan “fail to acclimatise” when they reach China? Apart from the complicated mix of Chinese waste (high moisture content, low burning value, large quantity of hazardous waste products), the low standard of engineering technology and a lack of investment in pollution control, we believe that the main reason is that government departments are seriously lacking supervision and control over waste incinerators.
According to a 2011 article by scholars from the China Urban Construction Design & Research Institute, apart from a minority of cities including Shanghai and Guangzhou, the majority of fly ash from Chinese municipal solid waste incinerators is not handled safely.[9] Faced with this situation, it cannot be denied that there has been negligence from supervisory departments. The media has also reported cases of waste incinerators operating in breach of standards. For example: fly ash from the Macau Waste Incinerator was improperly dumped, ash residue from the Shenzhen Nanshan Waste Incinerator flowed into a black brick yard, and leachate from the Shenzhen Nanshan and Laohukeng waste incinerators was dumped directly into the sea without treatment. A programme televised by Shenzhen TV revealed that in May 2011 an incinerator operated by the Herrel Group in Sichuan was fined 50,000 Renminbi by the Chengdu City Environmental Protection Bureau for failing to adhere to regulations concerning the reporting of fly ash production, transportation and handling. However, in July the HerrelGroup and the Environmental Protection Bureau “agreed to mediate” and the fine would not be enforced. We can say that these incidents have resulted from a lack of government supervision and control.
In addition, some important supervision and control information concerning the operation of incinerators is frequently not publicly disclosed in a timely manner, and monitoring data are not completely trustworthy. From February to April of this year the environmental non-governmental organisation Wuhu Ecology Centre applied to China’s 31 provinces, cities, and autonomous regions’ environmental protection bureaus and the Ministry of Environmental Protection for the release of a list naming companies that emit large quantities of dioxins (waste incinerators count as major emission source companies). However, only six provinces and cities’ environmental protection bureaus responded meaningfully.[10] As to the monitoring data concerning waste incinerator emissions of harmful pollutants (dioxins, heavy metals, polycyclic aromatic hydrocarbon, PM2.5), it is extremely rare for environmental protection departments to voluntarily release this information or to do so in response to an information disclosure request application. Some scholars have emphasised that most data in scientific research articles concerning legal dioxin emissions from waste incinerators is based on measurements taken under the most favourable conditions.[11] As a result, it is questionable whether or not these data can represent the normal operating situation of waste incinerators in China.
Because waste incineration in China has already resulted in significant amounts of pollution, and due to insufficient supervision and control and a lack of transparency, waste incineration projects in many urban and rural locations face increasingly strong opposition from local residents. Some opposition activities have even evolved into serious street protests, involving urban residents in cities including Beijing, Shanghai, Wuhan and Nanjing, and residents from towns or villages in locations including Likeng Village in Guangzhou’s Taihe Township, PingwangTownship in Jiangsu’s Wujiang, and Huangtutang Village in Wuxi’s Donggang Township. It can be said that waste incinerators cannot avoid causing anxiety to local residents wherever they are planned.
In reality, apart from problems associated with the supervision and control of harmful pollutant emissions, “low level” mistakes are often made in planning, investment and operation of waste incineration projects in China. This exacerbates the public’s serious lack of trust. First, due to irregular operation, bad smell from waste discharge pits or storage pools often covers the surrounding areas. Loud noise bothers residents living nearby. Second, the site selection for incinerators in some places does not accord with planning procedures. This might be one reason for the abandonment of the Beijing Liulitun waste incinerator plan. Third, the overall quality of public opinion solicitation for waste incinerator environmental impact assessments is very low. Some units in charge of carrying out environmental impact assessments have been found to have fabricated public opinion statements. In light of this, residents of planned incinerator sites in numerous locations have expressed anger. For instance, because of these problems, farmers from Panguanying Village in Liushouying Township in Hebei Province’sFuning County managed to force the Qinhuangdao West Waste Incinerator being brought to a standstill.[12]
Apart from the fact that the overall development of waste incineration technology in China is a cause of concern, the operation of Beijing’s environmental hygiene facilities funded by the German government in the past ten years also needs re-examining. We believe that if problems exist with these facilities and that if they are not effectively resolved, the future construction and operation of the Nangong Municipal Solid Waste Incinerator – as the extension of a long-term cooperation between China and Germany in the field of environmental hygiene projects – is an even larger cause for serious concern.
At present, there are five environmental hygiene facility sites funded by Germany in Beijing, including Majialou Transfer Station, Xiaowuji Transfer Station, Anding Landfill, BeishenshuLandfill and Nangong Composting Plant. On the whole, this system has played an active role in reducing waste transportation cost as well as controlling waste treatment pollution. However, the actual effectiveness of the “transfer station mechanical sorting + composting plant composting” sub-system has not met expectations, and has possibly resulted in secondary pollution that cannot be ignored. According to our on-site investigations, although waste entering the Nangong composting plant has been mechanically and manually sorted, it still contains a large amount of plastic bags, plastic and metal packaging and disposable chopsticks. In the composter, it is even possible to find harmful waste such as used batteries and expired medical products that should not be allowed to enter the composting production line. They will also once again be transported to landfills for final treatment, increasing transportation costs and energy input. In addition the quality of the compost is low. According to a report by Beijing Municipal Government department technicians, the content level of arsenic and mercury in some composting products from this factory exceeds the Control Standards for Urban Wastes for Agricultural Use (GB8172-87) and these composting products are difficult to sell.[13] Furthermore, our on-site investigation revealed that the working environment in the composting facility is filled with foul and irritating air, workers hardly wore necessary protective equipment such as masks, and their health might be seriously damaged in the long term.
Another surprising phenomenon is that the temporary medical incinerator inside the Nangong composter, which was set up due to the outbreak of SARS in 2003, was going to be developed by Beijing as a “permanent” medical incinerator after being renovated in 2004.[1 However, when we carried out on-site investigation in 2007, the operation of this incinerator had been stopped and to this date once dilapidated workshops and equipment have been demolished. As we all know, if the administration of medical incinerators is insufficient, not only will it produce pollution containing infecting bacteria, but also the emission level of dioxins and heavy metal is very high. This might directly affect the composting plant workers’ health as well as the compost quality. As far as we know, the planned site of Nangong incinerator is also next to the composting plant. Its influence on the composting work naturally deserves attention.
We also visited residents living within a one-kilometre radius of the Nangong composting plant. They told us that at the beginning of the composting plant’s construction, government departments did not inform them of the content and risk of the project. After the completion of the composting plant, it frequently emits unbearable bad smell which affects villagers’ daily life so severely that they call the composting plant the “human excrement plant”. They already blocked the plant entrance many times to protest. These protesting activities only temporarilyquietened down after the villagers received some compensation. Presently, although the residents have been informed of the construction of the incinerator next to the composting plant, they complain that the local government did not solicit their opinions to the full and failed to truly present the pollution risk of the incinerator. Considering that the level of public participation has always been too weak in the construction of environmental hygiene facility projects, we have all reasons to be concerned that big problems might exist in public opinion solicitation in the Nangong incineration project.
Based on all the existing practical problems we have identified about waste incineration technology development in China as well as those in environmental hygiene projects funded by Germany in Beijing, especially in Beijing’s Nangong district, we respectfully ask your bank to pay a high level of attention to these issues. Meanwhile, we will also put forward the few suggestions below for your bank to consider so that we can ensure the Nangong incineration will not repeat history or experience the same problems that are happening to other incinerations in China.
First, designate one department or certain officers to have dialogues and work closely with interested parties connected to the Nangong incineration project and environmental public interest groups in China. Carry out serious examination to ensure that your bank’s investment activities will not harm the local environment and health rights, and interests of the Chinese public and citizens of Nangong.
Second, promoters of the project including German government departments, the Beijing Municipal Commission of City Administration and Environment, project designers, consultants, and units in charge of the environmental impact assessment, should release information from the entire environmental impact assessment process related to the project’s planning, design, finance and equipment procurement. This will make the decision making process of this public project open and transparent.
Third, establish an independent investigation group that will assess the operation and effects of all environmental hygiene facilities in Beijing funded by the German government, including these projects’ economic, technical, social, and environmental impacts.
Fourth, in cooperation with the Beijing Municipal Government and social organisations, directly solicit the opinions of residents living in the Nangong district and identify potential social and environmental risk of the project.
Fifth, organise independent German technology experts to investigate the use of waste incineration technology in China and its overall situation. In particular, find the reasons for the pollution emitted by those problematic incinerators mentioned above.
Sixth, carry out activities that will inform Chinese government departments, waste treatment enterprises, social organisations and the media about Germany’s experience and safe operation conditions of waste incinerators.
Seventh, carry out activities that will inform Chinese government departments, waste treatment enterprises, social organisations and the media about Germany’s experience with reducing waste production, establishing extended producer responsibility, promoting waste sorting and recycling that have been prioritised in Germany’s waste management system.
Finally, for the sake of public interest and environmental health and happiness of Beijing residents, and for the sake of good cooperation between Germany and China across all different areas, we would like to establish a direct and frank dialogue with your bank and/or other relevant German organisations or enterprises based on the content of this letter and the suggestions that we have put forward. We believe that such a dialogue would be extremely valuable. It would not only benefit the careful investment, construction and operation of the Beijing NangongMunicipal Solid Waste Incinerator, but would also set a new model for German government and enterprises’ consideration of sustainable development and social welfare in overseas investment projects.
We look forward to hearing from you soon.
Yours Sincerely,
Signatories
Organisations:
Friends of Nature
Nature University
Yunnan Green Watershed
Green Anhui
Green Stone Environmental Action Network
Environmental Protection Service Association of Green Zhuhai
Green Beagle
EnviroFriends
Beijing Waste Management Technology Co. Ltd.
Wuhu Ecology Centre
Fujian Green Home
Green Henan
Eco Canton
Xiamen Greencross Association
Green Camel Bell
Friends Of Green China Tianjin
Rock Energy and Environment Institute
Greenovation:Hub
Blue Dalian
Qinhuangdao Entrepreneur Association
Qinghuan Volunteer Service Center
Individual Citizens:
| MAO Da |
(Researcher, Nature University) |
| CHEN Fu |
(P. S.: No double standard for the health of German and Chinese) |
| FENG Yongfeng |
(Co-Founder and Researcher, Nature University) |
| MO Jingteng |
|
| ZHANG Boju |
|
| YUE Caixuan |
|
| ZHAO Zhangyuan |
(Researcher (retired) , Chinese Research Academy of Environmental Sciences; P. S.: There has been a fact regarding municipal solid waste incineration in China: almostevery new incinerator project will cause fierce opposition from surrounding residents, and pose heavy burdens to governments and enterprises!) |
| CAO Ke |
|
| XUAN Zhi |
|
| LI Bo |
(Commission on Environmental, Economic and Social Policy, IUCN; Board Member of Friends of Nature) |
| YANG Xiaojing |
|
| LI Jiamin |
|
| Basuo Fengyun |
|
| MA Tiannan |
|
| RAN Liping |
|
| CHEN Zhiqiang |
|
Contact persons:
CHEN Liwen (School of Waste, Nature University, Mobile: +86-15210347427, E-mail: liwenchen9230@gmail)
MAO Da (School of Waste, Nature University, Mobile: +86-15210033727, E-mail: elephantmao@gmail.com)
[1]Beijing General Municipal Engineering Design & Research Institute,”Our Institute Signed Consulting Service Contract with Pöyry Energy (Germany) on the Beijing Nangong Municipal Solid Waste Incinerator Project”, http://www.bmedi.cn/qydt/qyyw/6973.shtml.
[2]KfW, “Demonstrating our activities for sustainability through specific projects”, http://nachhaltigkeit.kfw.de/EN_Home/Corporate_social_responsibility/Environment_and_sustainability/index.jsp.
[3]The Coordinating Office for National Implementation of the Stockholm Convention, “People’s Republic of China National Implementation Plan for the Stockholm Convention on Persistent Organic Pollutants”, Beijing: China Environmental Science Press, 2008, p. 49.
[4]Zhao Shuqing, Huang Wenxiong, and Xie Li, “The Current Situation and Trend of Dioxin Emission from Municipal Solid Waste Incineration in Our Country”, Urban Managerial Technology, 2009 (2), pp. 58, 59; The Coordinating Office for National Implementation of the Stockholm Convention, “People’s Republic of China National Implementation Plan for the Stockholm Convention on Persistent Organic Pollutants”, p. 42; Steffi Richter and Bernt Johnke, “Status of PCDD/F-Emission Control in Germany on the Basis of the Current Legislation and Strategies for Further Action”, Chemosphere, 54 (2004), pp. 1299-1302.
[5]Yuwen Ni, Haijun Zhang, Su Fan, Xueping Zhang, Qing Zhang, and Jiping Chen, “Emissions of PCDD/Fs from Municipal Solid Waste Incinerators in China”, Chemosphere, 75 (2009), 1153-1158.
[6]Deng Yunyun, Jia Lijua, and Yin Haowen, “Preliminary Study on the Level of Dioxin-like Compounds in Soil of Shanghai”, Journal of Environment and Occupational Medicine, Vol. 25, No. 4, 2008, pp. 353-359.
[7]Junyu Zheng, Jiamin Ou, Ziwei Mo, Shasha Yin, “Mercury emission inventory and its spatial characteristics in the Pearl River Delta region, China”, Science of the Total Environment, Volumes 412-413, 15 December 2011, 214-222.
[8]Tang Qinghe, Ding Zhenhua, Jiang Jiaye, Yang Wenhua, Cheng Jinping, and Wang Wenhua, “Environmental Effects of Mercury around a Large Scale MSW Incineration Plant”, Environmental Science, Vol. 26, No. 1, 2005, pp. 2786-2791.
[9]Zhao Shuqing, Song Wei, Liu Jinghao, and Pu Zhihong, “Pollution Status and Suggestions for Emission Reduction of Dioxin from Incineration of Municipal Solid Waste in China”, Environmental Engineering, Vol. 29, No. 1, 2011, pp. 86-88.
[10]Wuhu Ecology Centre, “The First Report of ‘Tracing the Information Disclosure of the Key Dioxin Emission Source of the Whole Country'”, http://www.waste-cwin.org/node/654.
[11]Zhao Shuqing, Song Wei, Liu Jinghao, and Pu Zhihong, “Pollution Status and Suggestions for Emission Reduction of Dioxin from Incineration of Municipal Solid Waste in China”.
[12]Liang Jialin, and Wang Lu, “Farmers Complained to MEP, Intending to Postpone Zhejiang Weiming’s IPO, Economic Information, May 8, 2012, http://www.jjckb.cn/2012-05/28/content_377793.htm。
[13]Li Yuchun, Li Yanfu, and Wang Yan, “A Report on Promoting the Sale of the Composting Product of Nangong Composting Plant”, http://wenku.baidu.com/view/27c6e31efc4ffe473368abab.html。
[14]Ma Nina, “SARS Warning, Beijing’s First Medical Waste Treatment Plant Starts Operation”, The Beijing News, December 29, 2004, http://www.people.com.cn/GB/huanbao/1073/3086663.html.
Appendix: Photos of Beijing Nangong Composting Plant
Photo 1: Mixed waste entering the plant (1)
Photo 2: Mixed waste entering the plant (2)
Photo 3: Mixed waste entering the plant (3)
Photo 4: Workers dealing with the waste
Photo 5: Waste battery in the compost
Photo 6: Waste battery and plastic in the compost
Photo 7: Waste medicine in the compost
Photo 8: Waste plastic containers and medicine in the compost
Photo 9: Abandoned medical waste incinerator next to the plant
Photo 10: Dilapidated equipments in the abandoned medical waste incinerator
