Mr Chairman, members of the International Review Panel,
As a local green group, the Association has been following the issues surrounding SSDS ever since its inception over twenty years ago. For those SSDS-watchers, there is no doubt that SSDS has been a long-lasting, expensive saga over two decades. Its history was plagued by cost overruns, work stoppages, geotechnical problems, contractual disputes, wasted capacities, and above all, a lack of accountability over why these problems occur and who should take responsibilities.
We do not enjoy making criticisms. Indeed, we are saying all these with a sense of sadness because the biggest sufferer out of these is our environment, our polluted waters in Victoria Harbour and beyond.
Two decades later and nearly 10 billion dollars spent, today we can only claim that about 20% of BOD pollution load are being removed from the harbour. Nearly all of the pollution load from nutrients are being poured into the harbour every day now as it was twenty years ago.
Despite the brave words by the officials involved, SSDS is all but an acknowledged failure by the community and the Government. It has generated a high level of public discontent and public distrust on the scheme. The Chief Executive has certainly felt that he could not go on with the future stages of SSDS without carrying too heavy a political burden. Hence the need for this International Review Panel.
The Association shares with the Government one common objective: we want water pollution controlled, and controlled quickly and effectively. Hence we agree that this Panel should serve as a means to build a consensus for the way forward. Without a consensus in society, any sewage disposal scheme that requires a big sum of public funds and prolonged effort will run into trouble sooner or later. When that happens, the environment will again suffer.
Yet in order to build a consensus, we need a few ingredients:
First, we need an understanding of the lessons learnt over the inception and implementation of the SSDS over the last two decades.
Second, we need a widely acceptable plan, a plan that is not merely a prisoner of the past but one that has a vision, that is sustainable, that can withstand the test of time, taking into account of the future uncertainties in our neighbouring environment.
Third, we have to find a way to implement the new plan so that the public is confident that past mistakes will not be repeated. And that is the only way that can rebuild public confidence to the new scheme.
Therefore, looking back into the past is as important as looking forward to the future.
So what are the possible findings for the past failure?
The first possibility: SSDS is the best choice of all possible sewage disposal schemes for Hong Kong but its execution is incompetent.
The second possibility: SSDS is not the best choice but its execution is so far competent.
The third possibility: SSDS is not the best choice for Hong Kong and its execution is incompetent.
The fourth possibility: SSDS is the best choice for Hong Kong and its execution has been competent. This is an interesting possibility since it will no doubt raise further questions. Can all the troubles in the past twenty years be blamed on bad luck, bad contractors or bad weather?
I am sure the wise members of the panel will give the public a convincing answer as to which possible finding is closer to the truth.
In order to build a consensus for the future, the Panel will have to consider two key questions:
The first question is whether SSDS as proposed by the Government is the best choice of sewage disposal schemes for today’s Hong Kong and for our future generations.
The second question is, given the results to date, whether the present executing agency should be replaced and the delivery mechanism for the new scheme be reformed.
Let’s take a closer look at the first question: whether SSDS is the best choice?
Green groups and many other professionals have proposed in the past a number of alternative options to SSDS which involve a distributed or semi-distributed system combined with a higher level of treatment, including biological nutrient removal. I am not prepared to provide evidence to the Panel today as to why one of these alternatives is a better option. We have made submissions to the Government in the past about the merits of these alternatives. I am sure the Panel will have access to those information.
I believe it is more useful for us to raise a few points that the Panel may wish to consider when making comparisons between SSDS and other alternatives.
1. The Government has spent millions and millions of dollars in numerous research, study and design on SSDS over the past twenty years. No other group, least an NGO like the Conservancy Association, can match its resources in research and study on any alternative option. If you compare the level of details on these alternatives and on SSDS, it is like David and Goliath. It is easy to brush off the merits of alternative options simply because there is neither enough data nor details to back up their claims. Should the Panel therefore request or conduct its own research on alternative schemes before fair comparisons can be made on an equal footing? I’ll leave the Panel to reach its own conclusion.
2. Time is a critical element in pollution control. One more sewage treatment plant in operation, whether large or small, is one more batch of pollution load removed from the harbour. A scheme that can show early results is better than one that promises a lot more on some future distant dates.
3. Public confidence is very fragile today on any new scheme proposed. Any scheme that has a lesser risk of further mishaps, or that such risk is less concentrated, is better than one that is prone to controversies.
4. Hong Kong waters is an integral part of the water body in Pearl River Delta. Adopting a set of static water quality objectives without allowing for the worsening boundary conditions is bound to lead to some nasty surprises in future. In choosing a new scheme, we must have the courage to build in such unpredictable boundary conditions, and not just be satisfied with only some design flexibilities.
5. When making cost-benefit comparisons, there is nothing more misleading than ignoring the time value of money, or the time value of benefits. Time-sensitive indicators such as Economic Internal Rate of Return are worth serious consideration.
6. Any decision-maker who has an appreciation of political reality would realise that a successful project cannot only be successful in its own right, but also be perceived to be successful by the public. SSDS in its present form carries a lot of political baggage and public distrust. Some would say too much political baggage for it to be ever successful.
Let’s turn to the second question : whether the present executing agency should be replaced and the delivery mechanism for the new scheme be reformed?
I do not want to guess what the reasons for the past failure are. Bureaucratic arrogance? Entrenched interests? Professional incompetence? Blurred responsibilities or some other reasons? The wise members of the Panel will give us better answers.
Some relevant points that the Panel may wish to consider may include the following:
· Should the players be changed? Should the rules of the game be changed? Or both?
· Given the level of public distrust, how do we install sufficient confidence building measures in the future execution of the new scheme?
· Should there be an increased level of public participation in the decision making process during the many years of implementation to come for the new scheme?
· As an alternative delivery mechanism, is it worthwhile to make better use of private sector initiatives by, for instance, using a BOT or BOO scheme to solve the sewage disposal problems for some of the urban areas? Hong Kong ’s private sector is well-known for its energy and innovation. Why can’t we take advantage of this?
Some members of the Panel may frown upon me and say what I’ve just asked is more than they bargain for. Yet the scope of review clearly stated that the Panel should make recommendations on the most sustainable way forward. Without the above issues fully analysed and the questions fully answered, it is impossible to find a sustainable way forward.
The public has high expectations on this Panel. And I hope the public will have their expectations fulfilled by the Panel in six months’ time.
We, on the part of the Conservancy Association, are prepared to participate in this review with a sense of humility and intellectual honesty. We hope that all other parties, not least the Government, will be prepared to do the same.
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The Conservancy Association
28 May 2000