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CLP Plant Can Flout Pollution Cap

Cheung Chi-fai
Updated on Jan 01, 2008 – SCMP

Limits on the amount of pollution CLP Power’s gas-fired power station may emit have been renewed, but with the proviso that the company may breach them if it reduces pollution from its coal-fired turbines.

The Environmental Protection Department said the proviso was intended to encourage the company to use more gas.

“This offsetting arrangement will ensure a greater net reduction of the overall emissions from power generation, which is the biggest local source of air pollutants,” a spokeswoman for the department said.

However, CLP Power says it faces a shortage of gas supplies – the reason for its application to build a liquefied natural gas terminal on South Soko Island, in a marine reserve off Lantau, to receive overseas gas supplies shipped by tanker.

There are no figures for its output of pollutants last year, but it announced in December 2006 that the proportion of electricity it would generate in 2007 from gas would drop by a third to conserve supplies from its Yacheng gas field off Hainan , and that it would burn more coal, pushing up emissions.

The power station at Black Point, Tuen Mun, will be allowed to emit 520 tonnes of sulfur dioxide, 5,200 tonnes of nitrogen oxides and 65 tonnes of particulates per year this year and 2009. In 2006, the latest year for which figures are available, emissions of sulfur dioxide and nitrogen oxides came in far below the caps, at 180 tonnes and 1,962 tonnes respectively, but particulate emissions, at 70 tonnes, breached the cap.

The cap extension was announced as the deadline for agreement between the government and Hong Kong’s two electricity suppliers on new scheme-of-control agreements regulating profits on their investments passed without a deal.

“The talks have been very difficult. So far there is no comprehensive and concrete agreement,” a source close to the negotiations said. The source would not say whether the talks would be extended.

The government had said earlier that if the deadline passed without agreement, it intended to draft a law to regulate the companies.

Tso Kai-sum, managing director of the other power generator, Hongkong Electric, said three weeks ago that a deal was close.

Both companies were tight-lipped yesterday over the talks.

Power Plant Emission Figures

The following statistics were gatherered from both China Light and Power and HK Electric Holdings in reference to the total electricity sent out and the resulting emissions of Carbon Dioxide (CO2), Sulphur Dioxide (SO2), Nitrous Oxides (NOx) and Particulates emitted.

Year 2006


HK Electric Holdings


Daily Amount

Total Electricity Sent Out 2006 (Gwh)



37,223,000 Mwh

101,980.82 MwH

C02 emitted – Kilo Tonnes (Kt)



27,840,000 tonnes

76,273.97 tonnes

S02 emitted (Sulphur Dioxide) Kt



66,000 tonnes

180.82 tonnes

N0x emitted (Nitrous Oxides) Kt



41,800 tonnes

114.52 tonnes

Particulates emitted Kt



2,800 tonnes

7.67 tonnes

2006 emissions by HK Power plants Source:

The following letter was sent by James Middleton on behalf of Clear The Air Hong Kong, to the Director for Environmental Protection:

Dear Sir,

I refer to a letter in another local English language daily last week ‘Naive view of HK pollution’ by Angela Jackson which refers to the administration chief’s intention to match Hong Kong with London’s and New York’s pollution levels by 2005. For this we must now read ‘2010’.

The Hong Kong Government has frequently stated that most of Hong Kong’s pollution emanates from the Pearl River Delta. I think they have been watching too many ‘Yes Prime Minister’ shows and tried to copy the antics. Strange then that on major chinese public holidays when the factories over the border were shut that Hong Kong was still in pea soup air.

If one follows the weblinks on the two local power company websites to audited emission figures provided by the coal burning local polluters it shows that the two between them emitted 76,576 tonnes of pollutants and greenhouse C02 gas into Hong Kong’s air on average every day of the year in 2006 (yes that is three thousand one hundred and ninety tonnes per hour) – then we have the old diesel buses, trucks and PLB roadside pollution and ship emissions in the harbour on top of this number and that’s before anyone smokes tobacco.

Having raised this with the EPD we received the following reply:

Dear Sir,

Thank you for your messages addressed to this department on 15 and 16 November 2007.

Curbing emissions from power plants is one of the top environmental agenda of the HKSAR Government. Under the Air Pollution Control Ordinance, power plants are classified as specified processes requiring licensing control and the use of the most advanced control technology to prevent the emissions and ensure the meeting of the relevant air quality objectives.

Also, from 1997, we have established the policy that all new generating units have to be natural gas-fired plants which emit virtually no sulphur dioxide and particulates, 80% less of nitrogen oxides and about half of the carbon dioxide emissions.

To improve air quality, the Hong Kong SAR Government reached a consensus with the Guangdong Provincial Government in April 2002 to reduce the emission of SO2, NOx, RSP and volatile organic compounds by 40%, 20%, 55% and 55%, respectively by 2010 compared to 1997 levels. Both power companies are required to cap their emissions progressively during their licence renewals to achieve the 2010 emission reduction targets.

Please be assured that the HKSAR will continue its best efforts to ensure the maximum reduction of power companies’ emission for protecting the public from any adverse health effects. On carbon emissions disclosure, you may have noted that the two power companies have provided CO2 emissions data of their power plants in Hong Kong at their corporate websites.

Yours faithfully,

Louis Chan for Director of Environmental Protection

LNG Receiving Terminal by Castle Peak Power Company

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

Fuel Mix Used by CLP in 2004 and proposed fuel mix by Clear The Air for 2013

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.

3. Alternatives

(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.

4. Options
(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

Gradual Reduction Approach For Emission Caps

Good caps & a good penalty to get the blue sky back

The Environmental Protection Department (EPD) is going to renew the process license for the Lamma Island power plants of Hongkong Electric Company (HEC) very soon. It will also be the first time for the EPD to include emissions caps for the 3 air pollutants in the license. Greenpeace and Clear The Air urge the EPD to make good use of this renewal process to hold HEC accountable for their major role in Hong Kong’s air pollution, by setting yearly emission caps from now till 2010, and raise the penalty of excess emissions to a level that can deter non-compliance.

HEC is the second largest air polluter in Hong Kong. HEC supplies electricity to only 20% of Hong Kong’s population, but it emits 40% of SO2 in the power sector. (Note: appendix 1) Gloria Chang, Greenpeace campaigner, emphasized that, “It is high time for our government to set more stringent emission caps and raise penalty so as to push HEC to clean up our sky.”

Greenpeace and Clear The Air propose a gradual reduction approach for emission caps. The license for power companies should include a set of yearly emission caps that can ensure a decrease in emissions from now up to 2010. This approach can enable Hong Kong people’s ‘right to know’ the progress of planned reductions, whether the power companies are successfully approaching the overall 2010 reduction target and make sure that power companies cannot delay their actions to reduce emissions at the expense of society.

Furthermore, Greenpeace and Clear The Air demand that the EPD raise the penalty of excessive emissions to a level that is high enough to impact shareholder profits, not only to pressure the power companies to reduce air pollutants at a faster pace, but also to cover the social and health costs brought by air pollution.

Greenpeace and Clear The Air support the financial penalty as proposed in the “Future Development of the Electricity Market in Hong Kong: Stage II Consultation”, in which the permitted rate of return of power companies would be reduced if they fail to meet the statutory emission caps. This measure will be much more effective than the existing penalty as stated in “Air Pollution Control Ordinance” which is [a fixed fine of] HKD 100,000. (Chapter 311, Section 10, Claust 7b)

Also, Greenpeace and Clear The Air suggest that the EPD consider the penalty imposed on power companies under the US government’s “Clean Air Act”, where HEC would be fined US $2,000 per tonne of SO2 emission that exceeds the cap. If we use this level of penalty together with our gradual reduction approach, the penalty of HEC last year is estimated to be HKD 70 million. (Note: Appendix 2). Even this penalty would only amount to less than 2% of the total profit of HEC last year.

From 1997 to 2004, SO2 emissions in Hong Kong did not show the slightest decrease, but actually increased hugely – by 50%. (Note: Appendix 3) Only if the government is taking real action to tighten up the emission caps and penalty of power companies, can we have a chance to get the blue sky back.

Appendix 1: HK air pollutants emissions (1997- 2005) – HEC and CLP
Appendix 2: Gradual reduction approach and penalty
Appendix 3: HK air pollutants reduction progress, impacts of air pollution to health

Earth Day 2004

Earth Day 2004

South China Morning Post Editorial
Friday April 23 2004

Facts on pollution must get public airing

Earth Day brought distressing news about the quality of the air we breathe…

Then there was the revelation by our largest power producer, CLP Power, that emissions of sulfur dioxide and nitrous oxide particles have increased dramatically over the past year – thanks in large part to soaring demand from Guangdong and increasingly heavy reliance on coal.

The CLP report raises different issues, some of which are best addressed on a region-wide basis. Demand from factories on the mainland soared last year. Coupled with restricted supplies of gas, this meant a heavy reliance on coal and increased pollution. CLP hints at continued reliance on coal in the immediate future and plans to install equipment for filtering the rising level of pollution.

See the full post on our Clear The Air News Blog here: