Tuen Mun district councillors consulted about the sludge plant's design said it would be the last unpopular facility they would accept. Councillor Lothar Lee Hung-sham said the leisure and education facilities were a gimmick to woo Tuen Mun residents into accepting further waste incineration facilities."Why do we need such heated pools or an education centre? We don't need to be educated about incineration if such a facility does not exist here in the first place," he said.The government has not ruled out seeking approval for a proposed solid waste incinerator next to the sludge incinerator in Tuen Mun, or on outlying island Shek Kwu Chau. Yet Lee said the council strongly opposed any more polluting facilities in Tuen Mun as the district already had two power stations, a cement-making plant, steel-mill, landfill and an aviation fuel storage. Chan Shue-ying, another councillor, said the sludge plant was not opposed as they hoped it would be the final facility. Such opposition will be a blow to officials who had hoped the extra facilities would win public acceptance of thermal waste treatment. The government unveiled details yesterday as it announced it had awarded a contract to design, build and operate the plant to VW-VES Hong Kong, a subsidiary of French environmental giant Veolia. The burning chamber will be hidden behind glass exterior walls with the 50-metre stacks barely visible from outside. To allay fears over emissions, the Environmental Protection Department has also agreed to set up a new air-quality monitoring station in Tuen Mun to closely track air pollution in the area, but its exact location has not been decided. The incinerator, at the northern end of the Tsang Tsui ash lagoon, is environment officials' long-awaited solution for treating the foul-smelling sludge now dumped in landfill sites. Able to handle 2,000 tonnes of sludge a day, the facility will take all of the 800 tonnes now produced each day, which is expected to grow to 1,500 tonnes in 2014. Officials have blamed the undesirable practice of burying the sludge in landfills for creating a bad smell affecting Tseung Kwan O residents. With incineration, the landfills will take only the burnt residue. Edward Yau Tang-wah, the environment secretary, hailed the plan, saying it would incorporate the latest incineration technology and meet the most stringent emission standards in the world. "The project shows modern technology can offer a much better solution and also provide facilities that will be popular with the local community," he said after a ceremony to sign the contracts. |
Thursday, October 28, 2010
SCMP.com - Heated pools and Deep Bay views, but it's still just a sludge incinerator
SCMP.com - Refuse mountain makes HK most wasteful place in world
Oct 26, 2010
Last year, the city generated 6.45 million tonnes of rubbish, more than double the amount two decades ago. Translated into a per capita figure, each of its seven million people produced 921 kilograms of municipal solid waste - refuse excluding construction and hazardous waste.
That made Hong Kong the most wasteful place in the world - it was 91kg more per capita than Norway, which topped a list of 30 economies surveyed by the Organisation for Economic Co-operation and Development (OECD) last year. On average, Hong Kong people produced more than twice as much rubbish as those in Japan (410kg) and South Korea (380kg).
But to the bureaucrats, every cloud has a silver lining.
Speaking to legislators last week, Edward Yau Tang-wah, secretary for the environment, said the increase was a natural outcome of economic activities, population growth and the arrival of millions of tourists.
"Despite the rise in waste generation ... the waste dumped in landfill has been decreasing," Yau said.
Hong Kong dumped 3.27 million tonnes of waste in landfills last year, a 1.3 per cent drop from 2008. Government officials hailed the decline as the result of "years of effort in promoting waste separation".
Of the 6.45 million tonnes of rubbish generated last year, only half ended up in landfills. The rest was dealt with through recycling and other means.
Although this may sound impressive, the figures are less convincing when compared with those of economies at a similar development stage and with an identical cultural background in the region - Taiwan and South Korea.
About half of the waste dumped in landfills is generated by the more than two million households. And of this, about 44 per cent is mixed food waste.
The commercial and industrial sectors are the second-largest source of waste, accounting for about 22 per cent. The rest is mixed construction and special waste.
Last year, Hong Kong dumped 1.28kg of refuse per day per head in landfills, compared with 0.52kg in Taiwan and 0.44kg in South Korea. Unlike these two places, Hong Kong has very limited options when it comes to refuse disposal. After recycling, landfills are the only option for handling waste since the city's last incinerator was shut down in 1997.
This change - under the statutory waste disposal plan in 1989 - is now blamed for the current dispute over expanding landfill. "What is wrong with this policy is that it promotes indiscriminate use of landfills. It raised the question of why we have to rely on landfill alone to handle waste," said Dr Chung Shan-shan, a waste management specialist with Baptist University.
Green NGOs have for years promoted the idea of reducing food wastage or finding other uses for leftovers.
In Lam Tin, housewife Kwok Tsoi Chau-leung opens a plastic container in her kitchen and adds her family's dinner leftovers.
On top, she scatters a layer of what looks like breadcrumbs. It's actually harmless bacteria - and it's an important step in the process because it stops the food from smelling as it decomposes. Two weeks later, this will be compost and Kwok will be able to use it to fertilise her plants.
"This is a great method. It is simple and there is little smell, but it can cut a third of the waste we dump," said Kwok, who lives with her children and was given the 30cm box by her daughter, who works for environmental group Greeners Action.
More and more families like the Kwoks are trying to improve their environmental awareness and do their bit to reduce food waste.
"We've already tried to control the size of the portions we cook. But there's always going to be food waste that has to be disposed of," she said.
Officials say that the problem of food waste is now so pressing that the government has had to resort to unpopular plans to extend landfills - and waste-to-energy incineration is next.
For the past two decades, nearly all the city's solid waste was buried in the landfill sites in Tuen Mun, Tseung Kwan O and Ta Kwu Ling - and the lack of alternatives means the landfills will eventually become full.
"While landfill is a necessity, it should be treated as a precious asset and not for daily use. These sites should be used to handle only waste that cannot be recycled," Chung said.
Half of the waste generated in Hong Kong is now recovered by the city's recyclers - and mostly exported for reprocessing - but the rest is still thrown into landfills.
This mounting waste has been filling up the three landfill sites - which have a combined size of 270 hectares - at a rate much faster than anticipated. By 1997, the landfill sites held 16,000 tonnes of waste. That was four years sooner than expected, according to a 1989 forecast.
It rang alarm bells for officials, who tried to find extra space for waste, eventually coming up with some bold suggestions including a never-pursued idea of creating an island for refuse in the sea, south of Cheung Chau. The idea proved too drastic and highly unpopular at a time when public sentiment was against sea reclamation.
Attempts have also been made to revive waste incineration using the most advanced technology. It would be completely different from the system previously used - which was considered a health risk - and could even do better than the stringent emission standards of Europe or the United States.
It has taken more than 10 years for the government to make any progress on its study of waste incineration since then chief executive Tung Chee-hwa outlined the plan in his 1999 policy address.
But the Environment Bureau is yet to resolve the sensitive issues of whether the incinerator should be located in Tuen Mun or on the outlying island of Shek Kwu Chau - as well as how it might overcome local opposition to the plan.
In 1998, the city's quest to reduce waste was laid out in a framework by the then Environment and Food Bureau. It set the target of doubling the amount of waste recovered for recycling in 10 years.
That was also the year when the three types of recycling bins were introduced in public places.
But not only was the target not met, the waste dumped in landfills grew - and outstripped the target for recyclable waste by 25 per cent.
In 2005, the Environment, Transport and Works Bureau rolled out another policy framework for solid waste management, which ran until 2014 and set out measures and a timetable to gradually reduce waste generation and boost recycling.
Five years later, measures considered critical to reducing waste - such as charging fees for disposal and most of the product responsibility schemes - are still on the drawing board.
The only breakthrough achieved was the introduction in 2006 of a landfill charge for construction waste, which has reduced by 50 per cent the waste in landfill - it instead goes to sorting facilities for reclamation use locally and on the mainland.
It has been a long-time worry of green activists that the government would prefer to rely on bulk reduction technologies such as incinerators to dispose of waste over other controversial financial incentives or disincentives to reduce waste.
They also say the quest for a means of disposal is like putting the cart before the horse and overshadows the most crucial issue of how to prevent the creation of waste in the first place.
"We do not oppose waste incineration. We also agree that landfill is a necessity. But there are things the government needs to do first such as honouring what it has promised to boost waste recovery and recycling," Hahn Chu Hon-keung, environmental affairs manager of Friends of the Earth, said.
Chu was worried that once an incinerator was built, government efforts to push forward recycling would slow down.
"What is an incinerator fed on? It feeds on recyclable waste like plastic and papers," he said.
When the government decided to go for large-scale landfill sites and shut down the incinerator in 1989, it did acknowledge the importance of waste recovery and recycling.
"Strategies to limit the amount of waste must now be developed and the recovery and recycling of waste encouraged," the government's waste disposal plan said.
But Chung from Baptist University said the reluctance of the government to assist or subsidise the waste recovery and recycling industry meant the policy statement was just empty words.
Lau Yiu-shing, a long-time recycler of waste and plastic, said the lack of government support was slowly killing the industry and if nothing is done the city could see recycling go into decline.
Lau has been battling to stay at the base in Kwun Tong where his business operates from, along with other recyclers. The area is set to be redeveloped as a waterfront promenade.
"There is no policy at all to support us and different departments are only taking care of their own business, no matter whether it is good or bad for the environment," he said.
Lau said local recyclers were also facing stiff competition from overseas, as foreign recyclers often received government subsidies. "That explains why sometimes waste paper shipped from the United States is cheaper than that collected locally."
Green activists are pushing the government to start charging for solid waste disposal in a bid to discourage people - and businesses - from producing excessive waste and to encourage the separation of rubbish. They are also urging the government to expand the product responsibility scheme - from plastic bags, which now attract a levy, to other products such as drink bottles and electronic appliances.
But the idea of charging for waste disposal has never appealed to officials. In 1995, the government tried to ram through a landfill charging scheme for privately collected waste. Approved by the then governor-in-council, a law was passed by the legislature to impose a HK$45 per tonne charge on waste dumped in landfill.
In the face of strong opposition from waste truck operators, the scheme was eventually withdrawn and the law was repealed in 2004.
In the 2005 policy framework, environment officials pledged to introduce a solid waste charge by 2007. But four years later - and after a series of trials and studies - a concrete proposal or timetable has yet to materialise.
While green groups believe charging for waste disposal is necessary, Chung wonders how significantly different things would have been if a charge was introduced in 1995.
"It is unlikely the government would set the charge too high, but a low charge - which could just mean one or two dollars per day per person - is not at all a strong disincentive for creating waste," she said.
Chung noted that the landfill charge in Britain was so high that the tax imposed on such dumping could be more than HK$400 per tonne.
On top of charging for disposal of waste, Chung urged environment officials to focus on specific generators of waste such as the commercial and industrial sector, which accounts for a quarter of the waste dumped in landfills - a figure that continues to mount.
She said businesses could play a significant role in reducing waste through better product design, packaging and inventory control. "There is always a limit to the amount an individual can do, such as they have no choice over how much packaging a product has," she said.
Chung is pessimistic about the future of waste disposal in Hong Kong. She said the problem was not just a natural outcome, as Yau said, but a political and social one, too.
"On the one hand, we have seen too much politicising of the issue, which has overshadowed rational discussion on the merits of each proposal ... but on the other hand, we don't see the political will of the government to do what it thinks is right.
"We need a leader who insists the right policies are pushed forward - even though he knows he will be extremely unpopular," she said.
SCMP.com - Study backs incinerators but says five, not two, needed
Oct 26, 2010
That is among recommendations in a Baptist University study, released yesterday, into use of incineration to rid the city of its solid waste.
The report cites European and Asian economies where incineration is a popular and effective form of waste disposal, and says it is especially suitable for such densely populated cities as Hong Kong. In Japan, three-quarters of solid waste is burned, and only 1.7 per cent goes to landfills, says the report by the university's Advanced Institute for Contemporary China Studies.
not enough. "In the long run ... our study recommends that the government can build one incinerator in each of the five districts as defined by the geographical constituencies," the report says. "This would not only ease the pressure on landfills, but also minimise pollution brought about by transporting the waste across districts, and thus saving costs and boosting efficiency."
It cites Tokyo as an example and says there is an incinerator in each of its districts.
The report acknowledges that many people in Hong Kong still consider incineration an unclean way of handling rubbish, but it says technological advancements have made incineration a clean and effective method of waste disposal. One advantage, the report says, is that incinerators can also generate electricity. It cites Macau, where the local incinerator can generate sufficient electricity for 33,000 families. In Germany, 75 incinerators handle 18 million tonnes of rubbish a year and provide job opportunities for about 60,000 people.
Public concerns about disposal of rubbish have mounted since a government move to expand the landfill in Tseung Kwan O was voted down by the legislature.
Environment officials have warned that the city's three landfills will soon be full and other ways of handling the rubbish need to be explored.
Hong Kong's daily production of municipal solid waste grew from 8,600 tonnes in 2000 to about 9,800 tonnes last year. At present, about half is recycled and the rest is sent to the three landfills.
SCMP.com - Hong Kong has much to learn from Japan on waste reduction
The problems we face with our landfills need to be dealt with immediately. Hong Kong is so small and using landfills is still the best way to dispose of waste here.
However, we should also look at waste disposal methods elsewhere. For example, we could learn a lot from Japan. Its main method of waste disposal is incineration.
I am not saying we should follow suit, as incinerators would not be feasible in Hong Kong. However, I would say that Japan does more with regard to environmental protection.
It has a successful recycling policy and this is an area where we can learn from Japan.
Waste is separated and classified into refuse that is not combustible, what is combustible and what material can be reused.
This efficient separation and classification system lightens the load for the incinerator.
There is also a great deal of education regarding handling and separation of waste.
This means that all Japanese have a keen sense of the need to protect the environment and they see this as an issue that must be addressed on a daily basis.
We do have a waste recycling policy, but how many Hong Kong citizens make an effort to separate their refuse? We have to ask how much support the government gets from its citizens when it comes to environmental protection.
Officials should note how things are done in Japan.
The government should try to educate Hongkongers, and promote the right message so that they become aware of the need for environmental awareness and think about this issue every day.
Helen Keung, Tsuen Wan
料可減堆填區壓力 49.6億建污泥焚化爐
污泥焚化設施位於屯門稔灣曾咀海傍，佔地7公頃，暫時命名「屯源」，意思指屯門是環保之源。設施的設計配合附近自然環境，在大樓外設有濕地公園予野生生物棲息，內裡設有環保教育中心介紹整個污泥焚化過程。
該設施落成後，將處理由淨化海港計劃，及其他10個地區污水處理廠所產生的污泥，減少堆填區的負荷，並估計可減少溫室氣體的每年排放達26萬噸。屆時污泥廠會採用高溫焚化技術，運作過程中所產生的熱能，將會被轉化成電力，供應予設施本身的電力需求，如供公眾使用的水療中心、室內暖水池等，而剩餘電力將會輸出至電網。
環境局長邱騰華表示，承建商日後會監察排出的污染物濃度，以確保符合標準；環保署亦將會在屯門市中心設立空氣監測站，評估設施所排放的二氧化硫及氮氣對居民的影響。他強調，本港不能單靠堆填區處理廢物，希望焚化廠能起示範作用，政府更考慮在曾咀興建垃圾焚化爐，年底會完成環境評估報告，並會繼續與區內居民商討。
區議員反對建厭惡設施
不過，屯門區議員陳雲生認為，區內已有不少排出廢氣的設施，擔心區內空氣會受污染。他指，區內已有兩座發電廠、兩間水泥廠及一間鋼電廠，「全部都係要爐燒出嚟，每間排少少有害物質，積聚起嚟就好多，而且佢哋全部都係咫尺之間。」他又稱，既然區內已興建污泥焚化爐，便難以再容納垃圾焚化爐等厭惡設施。
Wednesday, October 27, 2010
New levy planned for waste collection
RTHK 26-10-2010 |
| The government plans to reveal details of a new waste collection levy early next year. The Environment Secretary, Edward Yau, said the public would be consulted on how the charges should be imposed.The government is also trying to find sites for two new incinerators. Mr Yau said burning rubbish could not be the only solution, and extra landfills would have to be opened. |
Get ready to pay more for waste disposal next year
Standard Post
Tuesday, October 26, 2010
Residents and businesses will soon have to pay more for the removal of waste.
But to know by how much, they must wait until early next year, environment chief Edward Yau Tang-wah said yesterday.
Yau also said the public will be consulted on implementing the new charging scheme for the removal of solid waste under the "polluter pays" principle.
"The scheme can also help in waste reduction since polluters will be charged according to the amount of waste to be disposed."
The Advisory Council on the Environment will also have to assess the effectiveness of the scheme to reduce waste at source, which "may encounter difficulties as some may dispose of waste away from their residences."
Yau's comments came as a Baptist University study recommended that power-generating waste incinerators be built in each of the five geographical constituencies to deal with the solid waste problem.
This may help burn 8,000 tonnes of waste and generate electricity for 200,000 households each day, the study said.
Since legislators rejected the Tseung Kwan O landfill extension plan, the government is now looking for sites on which to build two incinerators, Yau said. He hopes once the sites are chosen there will be no opposition from the public, "since one of the landfills will be full by 2013."
However he emphasized that burning rubbish will not suffice.
Baptist University Contemporary China Studies professor Sit Fung-shuen said the five incinerators should be built within 10 years.
"The two government proposed locations - Tuen Mun's Tsang Tsui and Lantau Island's Shek Kwu Chau - can be built in the next two to three years to relieve the solid waste problem after the Tseung Kwan O landfill is full in 2013," Sit said.
However, he too agreed burning rubbish will not solve all waste problems and that landfills will still be needed.
Monday, October 18, 2010
SCMP.com - Inaction on pollution benchmarks riles greens
Oct 14, 2010
Friday, October 15, 2010
日本のごみ処理方式導入を検討＝来月訪日、焼却施設視察へ－香港行政長官
SCMP.com - Landfill vote puts incinerator on front burner
Oct 15, 2010
Incinerators or landfills? In the wake of the opposition to the landfill extension plan at Tseung Kwan O, the government is being backed into a corner to put incineration back on the agenda as a solution to the city's mounting waste problem despite its notorious unpopularity.
With reference to the recent controversy over columbariums, during which Tsang called for each district to shoulder some of the responsibility, Yim called on the districts to share the waste burden by either having an incinerator or helping to reduce waste. "They should have their own incinerators and if they don't want one, please show us they have done enough to reduce waste to a satisfactory level," he said. "The people just can't generate as much waste as they want, knowing that the waste will be transferred somewhere else." Yim proposes dividing the city into five areas and building an incinerator in each area. If a district does not want an incinerator, it should show it has done its best to minimise waste. The Environmental Protection Department has long been aware of the obstacles in siting an incinerator in Tuen Mun, home to the city's largest landfill and proposed as the site for a sludge incinerator. It is studying an alternative site for the incinerator on Shek Kwu Chau, off south Lantau. The department had initially considered decentralising waste incineration but later concluded it was more cost-effective to build one big plant capable of handling at least 3,000 tonnes a day. It has tried to convince the public that incineration using the latest technology is much less polluting than the type of incinerators used in the 1970s. Hong Kong's last incinerator closed in 1997 and since then the city has relied solely on landfills. Yim's idea was cautiously received by Kowloon City district councillor Bruce Liu Sing-lee, who belongs to Yim's party. Liu said the matter should be studied from a wider perspective. "Every district might have some unwanted facilities which the other district doesn't have," he said, citing funeral halls in Kowloon City as an unwanted element in his district. An environmental activist warned that the discussion about the city's waste management should not be limited to a choice between landfills and incineration, otherwise the real issues would be ignored, and that the attitude of "not in my backyard" should be dropped for a more co-operative approach. "We don't oppose incineration but we should be cautious about it before we have properly done everything we can to reduce waste," Friends of the Earth environmental affairs manager Hahn Chu Hon-keung said. Chu cited the experience of Taipei, which has three incinerators but only one is being used because a change in government policy to promote waste reduction and recycling dramatically cut the amount of burnable waste being produced. "The local community's long-standing opposition to incinerators built up sufficient pressure on the authorities to introduce more aggressive waste-reduction policies like waste charging. As a result the waste volume dropped sharply," he said. Chu criticised Tsang's professed satisfaction with the rate of recycling in Hong Kong, which stands at about 50 to 60 per cent. He said South Korea had achieved a recycling rate of more than 90 per cent, with less than 10 per cent of the country's waste going to incinerators or landfills. "The government still owes us what it promised to do on waste reduction. It should be committed to finishing that first," he said. |
Thursday, October 14, 2010
SCMP.com - Lawmakers back motion to scrap landfill plan
Oct 14, 2010
Chief Executive Donald Tsang Yam-kuen refused last night to say if his administration would take legal action, saying the issue was being looked at by Secretary for Justice Wong Yan-lung. Unless the government persuades a court to overturn the motion, the move to extend the Tseung Kwan O landfill into five hectares of the Clear Water Bay Country Park will be blocked, cutting three years from the life span of the tip.
Defending the government's recycling efforts, which he called among the best anywhere, Tsang warned of dire consequences for waste management and called for work to begin immediately to identify sites for new landfills. "We need to do this now if we are to avoid the consequences of having our rubbish just abandoned in the streets," he said. He will also seek to find out during a trip to Japan next month how every district there could have an incinerator, an option he said lawmakers also did not favour. Tsang also questioned whether the motion - which drew support across the political spectrum, including from government allies - was election-driven. "We all know there is an election ahead and everybody will scramble for Tseung Kwan O." If legislators were seeking political support in Tseung Kwan O, they seemed to have succeeded. Residents joined local politicians in a champagne celebration. Some lawmakers appealed to the government to reconsider seeking a judicial review of the vote, saying it would have far-reaching, and undesirable, consequences. "It is not about whether you can launch a review, but whether you should," said legislator Wong Yuk-man, of the League of Social Democrats. "This is a clearly a political issue, not a legal one and therefore should not be settled in court." Gary Chan Hak-kan, from the Democratic Alliance for the Betterment and Progress of Hong Kong, warned it would create a lose-lose situation for lawmakers and the administration, regardless of the result. "If we are defeated, our constitutional power will be lost. If the government loses, its authority will also be undermined," he said. The motion, proposed by Civic Party lawmaker Tanya Chan, was backed by 55 of 59 lawmakers. The only votes against came from Lau Wong-fat and Lau Kong-wah - both also members of the Executive Council. Chim Pui-chung, who represents the financial sector, abstained, while Timothy Fok Tsun-ting, who represents the sports, arts, culture and publishing sectors, was absent. As Chan's motion was passed, a government motion tabled to delay the commencement date of the chief executive's order by 14 months to January 2012 was not put to a vote. "The matter has developed beyond our expectations. But what we face today is all the government's fault," Chan said. A history of town planning flaws and poorly implemented policies on waste management were also to blame. She said after the vote that she believed the government would announce the repeal of its plan tomorrow, but this did not mean officials had ruled out legal action. Secretary for the Environment Edward Yau Tang-wah began his final appeal for support for the extension by admitting he had not anticipated the way events unfolded. "The issue has developed in a way that the government did not want to see. But we don't want to see the legal dispute hinder efforts to handle the waste problem." He said lawmakers and the administration had a "collective responsibility" to reach a consensus on waste solutions. "If you ask me if I feel frustrated and see the massive stumbling blocks ahead, I can only say there remains an urgent issue we must deal with," he said. But his appeal fell on deaf ears among lawmakers, many of whom attacked the government for its failures of waste management.
Wednesday, October 13, 2010
SCMP.com - Lawmakers likely to block order to expand Tseung Kwan O landfill site in Legco
SCMP.com - Tseung Kwan O residents protest landfill plan
6:49pm, Oct 12, 2010
This comes as legislators on Wednesday prepare to move a motion to scrap an order by the chief executive authorising the extension of the landfill site into five hectares of Clear Water Bay Country Park.
The protesters, yelling slogans and waving banners, urged the government to halt the landfill expansion and close down the Tseung Kwan O landfill.
They also said that a government plan to postpone the landfill expansion by 14 months would not resolve the current odour problems at the landfill. p>
Environmental group Friends of the Earth (HK) on Tuesday also said that the landfill extension would not resolve Hong Kong’s waste management problem.
Waste charging and producer responsibility schemes were a better solution, a spokesman for the group said.
The latest Friends of the Earth (HK) survey found that at least 26 legislators believed waste charging and producer responsibility schemes were a better solution to the problem.
The lawmakers surveyed included those from the Civic Party, the Democratic Alliance for the Betterment and Progress of Hong Kong (DAB) and independent lawmakers, Cyd Ho Sau-lan and Regina Ip Lau Suk-yee.
The Friends of the Earth spokesman also said he hoped Secretary for the Environment Edward Yau Tang-wah could introduce an ordinance for a new producer responsibility scheme (PRS) for waste electrical and electronic equipment by end of the year and that a public consultation on waste charging schemes could be launched next year.
SCMP.com - Constitutional crisis looms over landfill fracas
Cheung Chi-fai and Ambrose Leung
Oct 12, 2010
Hong Kong may be heading for a constitutional crisis.