Date: 22 January 2007
To : Environmental Protection Department
Re: Environmental Impact Assessment under Study Brief No. ESB-126/2005 for Liquefied Natural Gas (LNG) Receiving Terminal by Castle Peak Power Company
Clear The Air Response to EIA based on objectives of the study brief
1. Proposed capacity
“The objectives of the EIA study are as follows:
(ii) to provide information on the intended uses of the LNG and justify the proposed capacity of the facilities;”
Clear The Air
Clear The Air submit that there is no justification for the proposed capacity. Below is a graph of the “fuel mix” as used by CLP in 2004 and a proposed “fuel mix” by Clear The Air for 2013. The need for proposed LNG capacity can be eliminated because the existing gas supply can be extended by the fuel mix below which will also significantly reduce air pollution.
CLP Power can:
a. Eliminate electricity sales to China
b. Eliminate the 50% discount for large users to encourage less energy use
c. Start practicing proper demand management to reduce energy use by 30% using techniques that have been successful in Thailand, South Korea and the US.
c. Invest in renewable energy through
– large scale renewable energy projects
– small scale electricity generation reducing the total annual need for natural gas
2. LNG carrier route
(iv) “to identify and describe the elements of the community and environment to be affected by the Project, including any loss of natural coastline, rocky or sandy shore, the population close to the LNG carrier route, and/or to cause adverse impacts to the Project, including both the natural and man-made environment and the associated environmental constraints;”
Clear The Air:
CLP Power provided an incorrect carrier route. LNG ships going to and from the Black Point site can use existing shipping lanes and the Tong Gu Channel (under construction) If this Channel is extended into Hong Kong waters, as was originally proposed, the route would not be close to any population centres.
(v) “to consider alternatives including, but not limited to, location, size of reclamation, scale of development, design layout, with a view to avoiding and minimizing the potential environmental impacts on marine waters and the ecological sensitivity areas and other sensitive uses; to compare the environmental benefits and dis-benefits of each of the different options; to provide reasons for selecting the preferred option(s) and to describe the part of environmental factors played in the selection;
Clear The Air
Clear The Air submit the following alternatives that are not included in the EIA:
- Extend the existing contract with the Chinese company CNOOC so they can drill new gas wells to provide methane beyond the current contract period. CNOOC has indicated in the press that they are willing to do so.
- Pursue the energy demand reduction plan shown above.
- On-board Re-Gasification of LNG instead of terminals – a more flexible and significantly less destructive technology than building terminals.
- Invest in proven “clean coal” technology
- Use the Chinese company SINOPEC as a methane supplier as they have shown interest in supplying Hong Kong from an LNG facility they are planning to build on Huangmao Island.
(xiv) to compare the environmental merits and demerits of the Soko and/or Black Point Option with other options;
Clear The Air
The merits and demerits of the Black Point Option should have included extending the dredging of the Tong Gu channel in Hong Kong waters so that LNG ships can get to and from Black Point
Clear The Air note that In May 2003, the EPD issued a study brief for the Shenzhen Port Tonggu Channel Developing Office so that they could write an EIA. In March 2005, The Director of the EPD ruled that the EIA submitted for the Tong Gu Channel section in Hong Kong waters did not meet the study brief requirements. In June 2005, just three months later, the study brief for the LNG terminal was released.
With the full knowledge, therefore, of the issues regarding dredging near Black Point, we believe that the EPD is aware that extending the dredging of the Tong Gu channel is an alternative and therefore, we are surprised that this EIA has not been rejected by the EPD as also not meeting its study brief requirements.
5. Methane (LNG) global environmental damage
(vi) to identify and quantify emission sources and determine the significance of impacts on sensitive receivers and potential affected uses;
(xi) to identify the risk due to the transportation and storage of LNG and to propose measures to mitigate the impact;
(xii) to identify the risk to environmental sensitive receivers, including the marine and terrestrial habitats, due to LNG leakage and the consequential fire hazard and to propose measures to minimize the potential risk;
Clear The Air
As a signatory to the Kyoto Protocol to the United Nations Framework Convention on Climate Change, China (and therefore Hong Kong) is responsible for measuring the entire global impact of shipping and using methane (LNG) one of the six greenhouse gases addressed by the treaty. Methane that is lost through the original liquefaction process, evaporation during transhipment from the host country and transfer to the LNG facility, and loss during re-gasification should be included in the EIA. Since the origin of the LNG is unknown, a range of figures need to be supplied given the best and worst scenarios available today.
Furthermore, since many countries shipping methane are in or near areas of civil unrest, the impact to the environment if the LNG supplies should not arrive because of political reasons – compared to sourcing methane from China, should be included.
End of submission