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The Conservancy Association has taken an interest
in the Harbour Area Treatment Scheme (previously called Strategic
Sewage Disposal Scheme) ever since its inception over a decade ago.
In response to the Government’s publication of the Consultation
Document for HATS Stage 2, we would like to submit our views below:
1. Level of Treatment
We welcome the confirmation by the Government that biological
treatment is needed as a sustainable solution to our sewage problem
in the metro area. This level of treatment is not only essential to
improving water quality in the harbour area and beyond, but also
serves a much-needed demonstration effect to our neighbouring cities
in the Pearl River Delta. Without a concerted regional effort our
water quality will always be at risk. However we are disappointed
that the government has not yet committed to full-blown secondary
(biological) treatment with a clear timeline and resource
allocation. Secondary treatment is a legal minimum in most developed
countries and in mainland China. Without this the water quality in
the harbour cannot possibly get up to the standard which most of the
proposed harbour plans now require - a harbour that can accommodate
recreational uses.
2. Centralised or decentralised?
Whilst we still believe that decentralised options as contemplated
by the International Review Panel (IRP) in 2000 have merits beyond
what the centralised option can offer, on balance we agree that a
centralised plant at Stonecutters Island is an acceptable solution
provided that it can be implemented immediately in accordance with
the precautionary measures and safeguard mechanisms outlined below.
However, we must point out that our support for a centralised option
is conditional upon (1) full commitment by the Government for
secondary treatment with clear timelines and resource allocation;
(2) precautionary measures adopted to prevent a repeat of the
contractual and construction problems encountered in the deep tunnel
construction in SSDS; (3) institutional changes to be implemented
immediately to improve efficiency, enhance accountability and
promote transparency and public participation in the entire project
life-cycle.
3. Design Flow
Selecting an appropriate design flow for the treatment plants is
very important to achieving a cost-effective scheme. When estimating
the size of facilities required, the Consultation Document assumes a
40% increase of harbour-catchment population from 4.56 million in
2003 to 6.28 million in 20xx, and a corresponding 56% increase in
flow volume from 1.8 million cubic meters per day to 2.8 million.
Considering that there will be no more reclamation and that the
public has demonstrated its aspiration for a gradual lowering of
development density in the urban area, this assumption is
unjustified. These highly inflated figures translate into highly
inflated cost estimates for Stage 2. Furthermore, these estimates do
not allow for water conservation, including the use of financial
instruments (water and sewage charges) to reduce water consumption,
which should be the default measure to mitigate the risk of
excessive sewage volume in the distant future. Moreover, the IRP
recommends using a lower design peak factor (the ratio of peak
design flow to average daily flow) of 1.4 instead of 2. We
understand that this ratio can be confirmed from the actual
operating conditions of the Stonecutters Island Plant over the last
three years. When a lower population projection and a lower peak
design factor are adopted, the cost estimate for the entire Stage 2
will be much reduced.
4. Phasing
We do not believe that the current phasing of Stage 2A and Stage 2B
is appropriate. We believe that the government should commit
immediately to full-blown secondary treatment with a technical
phasing in line with sewage volume increase. Under our proposed
scenario Phase 2A should include the construction of the deep
tunnels and secondary biological treatment modules that can satisfy
the current sewage flow of 1.8 million cubic meters per day. Phase
2B should be the construction of further secondary treatment modules
up to the revised estimate (lower than 2.8 million cubic meters day)
of final capacity. Using this new phasing the intermediate step of
chlorine disinfection can be omitted unless it is deemed necessary
after the completion of Phase 2A. Alternative biological treatment
technologies with or without chemical-enhanced primary treatment
should be evaluated before the commencement of the design for
treatment modules in Phase 2A. A firm commitment now to full
biological treatment will remove any interim considerations and
allow the most cost-effective technologies be chosen as soon as
possible. However, the construction of the deep tunnels can begin
immediately whilst the evaluation for the best available
technologies takes place.
5. Institutional Changes
As expressed in the Joint Statement by eight green groups in 2001
(see attached), a major cause to the problems arising in SSDS is the
confused lines of responsibilities and the lack of accountability in
government departments. Unfortunately the question of institutional
defects has not been tackled in the Consultation Document. The
Government must address this issue before embarking on HATS Stage 2
which involves very significant public funds. There should be
broad-based participation by the community in project design and
monitoring. We believe that the concept of a Water Authority which
shoulders the integrated responsibilities of water supply and sewage
treatment should be adopted as a clear policy objective. This will
allow the concept of total water resource management be reflected in
the institutional set-up.
6. Private sector participation
We are open to the idea of private sector participation provided
public interest can be safeguarded in the process. A new
institutional mechanism should be set up to evaluate what are the
public interest at stake in this process, to ensure that appropriate
contractual terms are built in, and to monitor the progress of such
scheme. This mechanism should be designed in accordance with the
principles of transparency, accountability and public participation.
7. Public participation in decision-making
Since this is a strategic project involving significant public funds
and important public interest, the public should be provided with
full access to participate in the decision-making. The HATS
Monitoring Group, which had been set up to monitor the progress of
the scheme since 2001, was actually dissolved prior to the issue of
this Consultation Document. Hence it is doubtful as to whether this
Consultation Document receives the support of the experts in the
Monitoring Group. This makes a mockery of the public participation
process over the last three years. It is clear that a more
transparent, accountable and broad-based public participation
process must be installed to avoid the past mistakes and to oversee
the future of HATS Stage 2.
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