Open Letter to the Ministry of Housing and Local Government

We, a group of civil society organisations committed to environmental sustainability and social justice, wish to express our objection to the proposed construction of 18 Waste-to-Energy (WTE) plants in Malaysia.

First and foremost, we would like to know whether comprehensive Social Impact Assessments (SIA) and Environmental Impact Assessments (EIA) have been conducted prior to proceeding with this proposal. These assessments are critical to understanding the true impact of this project on our communities and environment. Without robust SIA and EIA to support the effectiveness and safety of these WTE plant proposals, the implementation of this construction plan is premature and unreasonable, given that the operation of these plants could potentially harm the health and well-being of local communities, especially those living near these plants.

Studies raised by Shukla et. al (2024) indicates that waste incineration produces harmful byproducts, and filtering these byproducts and residues requires complex, advanced, and meticulous filtration systems. What evidence is there to show that these waste incineration plants will not emit dangerous air pollutants such as dioxins and furans, as well as toxic gases, fine particles, and heavy metals, and that they have advanced filtration systems capable of isolating these harmful air pollutants before release?

The construction of WTE plants is a false solution to addressing climate change, waste crises, and plastic pollution. It also does not align with the circular economy direction. WTE plants will compete with recycling centres for the same materials, and this competition will undermine government efforts to enhance recycling. It also discourages waste reduction or redesigning packaging and products, thereby leaving the responsibility of managing packaging and product waste on consumers. The Zero Waste approach, which aims at “Reduce Waste, Reduce Waste Generation,” should be incorporated into the National Waste Management Plan. This approach is not only more sustainable but also more equitable and effective in the long run. Zero Waste emphasises reducing waste at the source, reusing, refilling, recycling paper, glass, cardboard, aluminium, steel, and composting, which can replace reliance on WTE plants and minimise environmental pollution.

According to a report [1], Malaysians generate approximately 16,720 tonnes of food waste daily, comprising almost 44 percent of the total domestic waste. Composting will divert more than a third of food waste from final disposal. Additionally, plastic waste, which makes up almost a third of domestic waste in Malaysia, is very concerning. Therefore, an Extended Producer Responsibility (EPR) system, reuse, and refill systems need to be implemented to address the plastic crisis. The use of WTE technology in Singapore has led to a significant drop in their recycling rate to 52% in 2023 (Ganesan, 2024). This decline in recycling rate could lead to the loss of resources that can and should be recycled, such as food waste, paper, concrete, wood, textiles, aluminium cans, and so on. In Denmark [2], when their recycling efforts increased and waste decreased, they had to import waste from other countries to maintain the operation of their WTE plants. This also affected their goal of reducing carbon dioxide emissions as committed in the Paris Agreement 2015. We worry that Malaysia will face a similar future if the construction of these WTE plants proceeds.

The Zero Waste approach can also provide significant economic benefits. It can create job opportunities in the recycling and resource recovery industries and reduce waste management costs in the long run. Additionally, it can help Malaysia achieve sustainability goals and comply with international commitments to environmental protection.

The Federal Government, state governments, and local authorities need to invest in transitioning to a circular economy, Zero Waste, and not fund false solutions that will cause more problems like WTE. This means investing in zero waste policies that build a circular economy, new zero waste hubs that reduce waste and recover resources, new composting systems, and only supporting genuine recycling efforts. These steps are simpler, cheaper, and quicker to implement, requiring lower costs and offering more job opportunities.

We urge the Ministry to reconsider this proposal and involve civil society in the planning and implementation of national waste management policies. Community participation is essential to ensure that decisions made are fair, transparent, and beneficial to all parties.

Your cooperation and attention to this matter are greatly appreciated, and we extend our thanks in advance. Please contact us if you wish to discuss this further. We hope to see positive changes in the national waste management policy that are fairer and more sustainable.

Notes:

[1]https://www.bernama.com/en/thoughts/news.php?id=2280475

[2]https://www.politico.eu/article/denmark-devilish-waste-trash-energy-incineration-recycling-dilemma/

Sincerely,

The undersigned.

  1. Greenpeace Malaysia
    Representative:
    Thing Siew Shuen
    [email protected]
  2. Sahabat Alam Malaysia
    Representative:
    Mageswari Sangaralingam
    [email protected] 
  3. Consumers’ Association of Penang
    Representative:
    Mohideen Abdul Kader
    [email protected] 
  4. Persatuan Tindakan Alam Sekitar Kuala Langat
    Representative:
    Thew Kim Guan
    [email protected] 
  5. Pertubuhan Pelindung Khazanah Alam Malaysia  (PEKA)
    Representative:
    Sophine Tann
    [email protected] 
  6. Persatuan Perlindungan Alam Sekitar Malaysia (Environmental Protection Society Malaysia, EPSM)
    Representative:
    Lee Jing
    [email protected] 
  7. Gabungan Darurat Iklim Malaysia (GDIMY)
    Representative:
    Tan Koon Hong
    [email protected] 
  8. Alliance of River Three (ART!)
    Representative:
    Kennedy Michael
    [email protected]
  9. Zero Waste Sabah (ZWS)
    Representative:
    Ruth Yap
    [email protected]
  10. Jaringan Rawang Tolak Insinerator
    Representative:
    Esther Woo
    [email protected]
  11. Persatuan Kesedaran dan Pendidikan 3R Kuala Lumpur
    Representative:
    Lam Choong Wah
    [email protected]
  12. Jawatankuasa Bertindak Kuala Lumpur Tak Nak Insinerator (KTI)
    Representative:
    Lee Chong Tek
    [email protected]
  13. Gabungan Anti Insinerator Kebangsaan (GAIK)
    Representative:
    Wong Wai Kong
    [email protected] 
  14. Center to Combat Corruption and Cronyism (C4 Center)
    Representative:
    Nabila Zulkeflee
    [email protected]
  15. Persatuan Aktivis Sahabat Alam (KUASA)
    Representative:
    Hafizudin Nasarudin
    [email protected]
  16. Suara Rakyat Malaysia (SUARAM)
    Representative:
    Amirah Haziqah
    [email protected] 
  17. RimbaWatch
    Representative:
    Adam
    [email protected] 
  18. Parti Sosialis Malaysia (PSM)
    Representative:
    Cheong Huei Ting
    [email protected] 
  19. Malaysian Nature Society (MNS)
    Representative:
    Donovan Louis
    [email protected]
  20. Saya Anak Bangsa Malaysia (SABM)
    Representative:
    Jayanath
    [email protected] 
  21. Pertubuhan Alam Sekitar Sejahtera Malaysia (GRASS)
    Representative:
    Mohd Yusaimi Md Yusoff
    [email protected]
  22. CERAH Malaysia
    Representative:
    Dennis Chan
    [email protected]
  23. Aliran
    Representative:
    Anil Netto
    [email protected]
  24. Gabungan Bertindak Malaysia (GBM)
    Representative:
    Stanley Yong
    [email protected]
  25. AJ Rimba Collective
    Representative:
    Noina Baharuddin
    [email protected] 
  26. Ikatan Demokratik Malaysia (MUDA)
    Representative:
    Amir Hadi
    [email protected] 
  27. Treat Every Environment Special (TrEES)
    Representative:
    Leela Panikkar
    [email protected]
  28. Persatuan Petaling Jaya Lestari
    Representative:
    Chakra Thilainathan
    [email protected] 
  29. Persatuan Penduduk Seksyen 22 Petaling Jaya
    Representative:
    Parimala Nesamany
    [email protected] 
  30. FANS of PJ (Friends and Neighbours of Petaling Jaya)
    Representative:
    David Yoong
    [email protected] 
  31. Pusat KOMAS
    Representative:
    Faribel Maglin Fernandez
    [email protected]

    — Endorsements accepted after 29 July 2024 —
  32. Pertubuhan Rangkaian Pembangunan Kesinambungan Malaysia (SUSDEN Malaysia)
    Representative:
    Jafri bin Abdullah
    [email protected] 
  33. Zero Waste Malaysia
    Representative:
    Sue Yee Khor
    [email protected]  
  34. Persatuan Pendidikan dan Penyelidikan Untuk Pengguna-Pengguna Pahang
    Representative:
    Mohd Saiful bin Abdullah
    [email protected] 
  35. MADPET (Malaysians Against Death Penalty and Torture)
    Representative:
    Charles Hector
    [email protected]
  36. Jawatankuasa Pro-tempt United Batu Arang
    Representative:
    Karl Ngo
    [email protected]

C/O:

1. Prime Minister’s Office of Malaysia
2. Ministry of Natural Resources and Environmental Sustainability

If your organisation is interested in endorsing this open letter, please email the name of organisation, name of representative, email address to [email protected]