In late 2007 and early 2008, during my term as minister of the Environmental Protection Administration (EPA), two major development projects, heavily polluting and with high energy consumption, were planned at the sixth naphtha cracker in Mailiao Township (麥寮), Yunlin County. Based on Article 8 of the Environmental Impact Assessment Act (環境影響評估法), the EPA decided that the two projects — Kuokuang Petrochemical Technology Co’s proposed eighth naphtha cracker and Formosa Plastics Corp’s planned steel mill — both required a phase two environmental impact assessment (EIA).
The main reason for the decision was that if the development were approved, the resulting pollution would exceed the environmental carrying capacity, and the developers could not come up with ways of adjusting the environmental cost by reducing the pollution.
When reporting to then-president Chen Shui-bian (陳水扁), I said: “These two major development projects, heavily polluting and with a high energy consumption, will spew out black smoke together with the sixth naphtha cracker day in and day out. How can that be a good thing?”
When Chen asked: “So what should we do?” I had no choice but to frankly say that: “The best thing would be to re-evaluate the two projects; the best thing would be not to build them at all.”
All the members of the EIA committee felt that there was a risk that the projects would have a major impact on the environment and that we should go on with a phase-two EIA.
The result was that the Kuokuang plant could not be built in Mailiao, and the company instead proposed building it in Changhua County, at a 2,000 hectare wetland close to Dacheng Township (大城). Should we really allow that area, now almost free from pollution, to also be so polluted that it exceeds the environmental carrying capacity? And what does environmental carrying capacity mean? It is a so-called “environmental and health standard” setting a maximum pollution value that we are supposed to accept just because it has been arrived at by a lot of so-called “academics and experts” who consider themselves smart. The question is if we should all be forced to just accept this maximum value? Former associate administrator of the US’ Environmental Protection Agency Milton Russell often says that many people think pollution emissions are unethical, but that the question being asked is how much pollution is needed for it to be considered unethical: Talking about what levels of pollution are acceptable is a bit like talking about how many times a child can be sexually molested before it is seen as immoral.
There are not many people who think there is no risk that the Kuokuang project will have a major environmental impact. This is why there should only be two possible outcomes of the assessment of the environmental impact of building a plant at the Dacheng wetlands in Changhua: Moving on to a phase-two EIA in strict accordance with Article 8 of the Environmental Impact Assessment Act, or an all-out rejection and abandonment of the project. If the project is handled in the same way as the EIA for the Suhua Freeway project, where the authorities first set a timetable before “conditionally” accepting the EIA, that would smack of political considerations. In addition, supervising the project in accordance with the EIA after it has been approved would both increase the cost to society and waste national resources, not to mention raising concerns about violating the law. The academics and experts appointed by the EPA to sit on the EIA committee should give careful consideration to the issue and follow the law.
Winston Dang is a former Environmental Protection Administration minister.
TRANSLATED BY PERRY SVENSSON
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