1st February 2009

 

An Bord Pleanála

64 Marlborough Street

Dublin 1

 

RE:  Case Reference PL04.PA0010

Waste to Energy Facility and Transfer Station at Ringaskiddy, Co. Cork

 

Dear Sir/Madam,

 

I wish to state my objection in the strongest manner possible to the proposal by Indaver Ireland to build a waste to energy and transfer station (2 incinerators) at Ringaskiddy, Co. Cork.  To this end I enclose the relevant fee of €50.  I hope that as part of your deliberations on the issue you will conduct an oral hearing, and if such a hearing takes place, I request representation at the hearing and reserve the right to call on expert witnesses should I require their services.

 

The grounds for my opposition to this proposal are outlined below.  I trust that you will give these due consideration in your deliberations.  Please note that the opinions expressed in this letter of objection are my own, and are not necessarily those of any organisations with which I am associated.

 

1.    The building of incinerators contravenes the principles of sustainable development.  Incineration has no place in properly structured waste management system, where all “waste” is regarded as a resource for another process.  Incineration (and landfill) should only be used for waste streams which cannot be dealt with in any other way, and any such waste streams should be actively reduced by implementation of alternative manufacturing processes, so that these dirty waste streams are eventually eliminated.  Many countries and regions around the world have implemented this successfully by the development of “zero waste” type policies, which have reduced any residual wastes which might be suitable for use in a waste to energy facility such as the one proposed here to an absolute minimum.

 

2.    When the previous application by Indaver was before An Bord Pleanála for an incinerator on the same site in 2003/4, the Bord granted permission on the basis that incineration was part of Government policy.  There have been a number of indications from the current Government that this policy is changing.  I was part of a team set up by my Green Party colleague, the Minister for the Environment, Heritage and Local Government, John Gormley, which reviewed the terms of reference for a national review of waste policy which is currently being undertaken by consultants Eunomia.  The minister has made a number of statements on the matter of waste policy, including:  “This move away from incineration … is Government policy, and it is backed up by work carried out by waste experts in the Department of the Environment.”  The Department of the Environment has also indicated that its best estimate as to the total expected waste arisings which may be suitable for incineration in the country is of the order of 300 – 400,000 tonnes per annum.  With two incinerator projects already granted planning permission with capacity for more than double this amount (Poolbeg in Dublin with 600,000 tonnes and Carranstown, Co. Meath with 250,000 tonnes) it would be utterly foolish to grant planning permission for further incineration capacity in the state.  Such an act would totally undermine any of the many efforts underway to reduce waste arisings, and to reuse or recycle any such arisings.

 

3.    The draft Cork County Development Plan, which is due to come into force very shortly, demonstrates little or no support for incineration.  It strongly supports the further development of port activities in Ringaskiddy, and with a number of indications that the Port of Cork will be relocating substantial port facilities from the city quays to the lower harbour, including Ringaskiddy, any suitable sites should be reserved exclusively for port related activities.  The zoning on the site in question is industrial, and for port related activities, and with the Port of Cork already having a substantial land bank in the area, including a site just across the road from the site in question, it would be foolish to hinder the possible future development of the Port of Cork.  The Port of Cork is of key economic significance to the whole region, and given the limited availability of sites suitable for port related activities in the lower harbour, any such sites should be reserved exclusively for port related activities and should not be permitted to be developed with facilities such as waste management facilities which have no requirement to be close to the water.

 

4.    A previous application on a nearby site by the Port of Cork (PL04.PA0003) in November 2007 was refused permission by An Bord Pleanála on two grounds: (i) that the road infrastructure in and around Cork City was inadequate to carry the amount of traffic that the development would have generated, and (ii) that there was no possibility of providing rail infrastructure in Ringaskiddy.  With most local and regional plans supporting the move of port facilities from the city to the lower harbour, surely it would be prudent to reserve any available capacity on the road infrastructure in the Ringaskiddy area for port related activities.  The Port of Cork already has substantial activities in Ringaskiddy, and it is likely that these will increase in some manner in years to come.  With substantial traffic congestion at a number of points along the main route to Ringaskiddy, including the N28 at Shanbally, the Bloomfield Interchange, the Jack Lynch Tunnel and the Dunkettle Interchange, it is of strategic regional and national importance that development in this whole area with substantial need for road transportation, such as these proposed incinerators, should be restricted to only those developments which have a very specific need to be located in this area.  The incinerators do not need to be located at the end of a peninsula with only one main road as access.  There are countless better locations for this facility from a transportation perspective.

 

5.    The Cork Area Strategic Plan (CASP), which sets out a vision for development in the whole Cork region until 2020, does not support the development of incineration as a waste management strategy, but does support the development of infrastructure to increase recycling and reuse, and for example specifically supports the development of composting and other biological treatment facilities.  CASP also specifically recognizes the strategic importance of Cork Harbour as having huge development potential in a wide variety of areas, and says it has the potential to become “Europe’s most exciting waterfront.”  Surely the development of two incinerators in such a prominent site in the harbour is completely at odds with the vision for Cork Harbour set out in CASP, and it should be rejected.  To do otherwise would be to seriously damage the possibility of Cork Harbour achieving its potential to become the premium waterfront location that befits the second largest natural harbour in the world.

 

6.    This application contravenes both the Stockholm (persistent organic pollutants) Agreement as it has the potential to create dioxins.  With the recent dioxin contamination problem which shut down the whole Irish pork industry, any facility which has the possibility to create such dangerous contaminants, should only be built when there is sufficient evidence that the facility is absolutely necessary, which this facility is not.  Also if such a facility is to be built, surely it should be sited so as to minimise the potential for any such contaminants that might escape to cause the minimum damage possible, by keeping it well away from any significant population centres, and centres of key economic strategic importance.

 

7.    It would be totally inappropriate for a potentially hazardous installation like this to be located in a residential area, with Ringaskiddy village very close by and the town of Cobh within 2 km, and so close to schools, the National Maritime College of Ireland, the naval base at Haulbowline, the crematorium on Rocky Island and Spike Island, which will hopefully become a major tourist venue in the near future.  This site totally contravenes WHO Guidelines on the Siting of Hazardous Waste Management Facilities, with regard to being sited near static populations.

 

8.    The location of the site may increase the potential difficulties arising in the event of fire or accident.  I am concerned that there are insufficient means to deal with incidents of this nature.  Fires and other hazardous events have occurred at the most modern incinerator plants and storage facilities, usually due to human error.  There is no adequate means of evacuating the harbour population, with only the N28 for those on the Ringaskiddy side of the harbour, and with the Cobh population dependent on a single bridge at Belvelly.  Also an incident at the proposed incinerator site could effectively cut off the maritime college, the crematorium and Haulbowline Island, as their only road access goes directly past the incinerator site.  This is just another reason which makes this site unsuitable for this type of operation.

 

9.    The site fails many of the criteria set out by the WHO for the siting of hazardous waste facilities, including that the site is prone to flooding, is subject to substantial coastal erosion, and the whole area is prone to thermal inversions regularly, such as that which occurred recently on morning of the 28th January last.  The developer has tried to make this site out to be what it in reality isn’t.  The site is just not suitable for such a development.

 

10.  The effect of this proposed development on the amenity value of Gobby Beach is unacceptable.  Gobby Beach is the only accessible beach on this side of the harbour, and is widely used by the public as an amenity.  When on the beach, with its views of Spike Island, Cobh and out to Roches Point, it is possible to forget that there are many large industrial facilities close by.  This development would totally overshadow the beach, and destroy completely its beauty and value as a leisure amenity.

 

11.  Incinerators do not dispose of any rubbish.  They merely convert it, at great expense, into other compounds many of which are highly toxic and carcinogenic and many more unknown and untested.   Some of these are emitted into the atmosphere.  What is not emitted remains in the incinerator as ash, which is highly toxic.  There are no facilities for dealing with this toxic ash in Ireland at present, and so any ash classified as toxic will have to be exported for landfilling elsewhere.  This means that the actual reduction in toxic waste being exported for incineration or landfilling will be minimal.  There is no indication in the application as to how Indaver intend to deal with either the bottom ash or the fly ash from the incinerator.  The projected tonnages of these ashes, which would be classified as non-hazardous, are in excess of the tonnages which the new landfill site at Bottlehill is licensed to take in terms of commercial waste.  Therefore until Indaver explain where they intend to landfill the ash, I believe that these incinerators cannot be given planning permission.  Moreover, it is conceivable that Indaver will in the future be importing toxic substances for incineration in order to fulfil capacity (hence port location) and that the resulting levels of toxic ash going to landfill may well be significantly higher than the amount of toxic waste actually produced within this country.  This makes a nonsense of the facility purporting to be to reduce Ireland’s dependence on exporting its toxic waste.

 

12.  There are insufficient facilities for reclamation of resources from toxic wastes in Ireland.  At present, of the relatively small amounts of toxic waste exported, a significant proportion is reclaimed abroad.  Due to the scale needed to reclaim resources from toxic waste, it is unlikely that such facilities will be sited in Ireland and we will have to continue to export such wastes with or without a toxic waste incinerator in the country.  If there was a toxic waste incinerator in this country, much waste which is currently sent for resource reclamation would be diverted to the incinerator, in order to make the incinerator commercially viable.  This would be utterly unacceptable from a sustainability point of view.

 

13.  There are serious and well-documented health concerns with regard to emissions from incinerators, particularly with regard to the production of microfine particulates.  Two communities in close proximity have incidences of cancer significantly above the national average (Cobh at 44% and Monkstown at 16%).  While it would be impossible to prove the cause of these higher than normal cancer rates, surely it is prudent to avoid increasing the load of environmental toxins on these communities which are already obviously under some kind of environmental stress.  Such emissions from an incinerator would have a particularly damaging effect on foetuses in the womb, and on infants.  The effects of toxins on this section of the population may not show up for many years after they came into contact with the toxins, in which case health problems would be being created to be dealt with in the future, which is irresponsible from the perspective of intergenerational justice.

 

14.  Emissions from incinerators are known to bio magnify and accumulate in the food chain.  They will therefore constitute an ever-present hazard to farming and food safety.  The dioxin contamination problem which shut down the Irish pork industry in late 2008 shows the calamitous effect such a contamination incident could have for both Irish farmers, and for the consumers of Irish food, i.e. us.  Incinerators, wherever they are built, damage the food image of the host area.  At present Ireland’s clean food image is one of our finest assets.  Many prominent food companies refuse to source ingredients from the vicinity of an incinerator.  Studies on fish oils have shown that dioxins (which are released in to the atmosphere in significant quantities by even the most modern of incinerators) accumulate in those oils, thus damaging the viability of the fishing industry.

 

15.  Incinerators would damage tourism and Ireland’s clean food image.  There is a growing impetus, which is reflected in all the relevant local and regional plans, to enhance the tourism potential of Cork Harbour and the surrounding region.  The town of Cobh would be the focus of this, particularly if the proposal to open Spike Island to the public comes to fruition.  With the incinerators clearly and unavoidably visible from Cobh and Spike Island, as well as the amenity walk in Monkstown, this would not be a positive asset for the locality in terms of tourism.  It would also be one of the first things anyone arriving at Ringaskiddy ferryport would see, and likewise those arriving at Cobh Cruise Liner Terminal.  With air travel likely to diminish in importance over the coming decades, ferry traffic and cruise liner traffic is likely to increase in importance globally and locally for tourism.  In this scenario Cork Harbour, if developed properly, has the potential to achieve national and international significance as a tourism gateway and destination in its own right.  To jeopardise this by building a visually intrusive industrial building with a very large stack in such a prominent site in the harbour is foolhardy, to say the least.

 

16.  The scale of this proposal, and its location in a totally inappropriate site, make it highly visible from most locations in the lower harbour.  While the Ringaskiddy area is obviously highly developed as an industrial and port location, all existing developments are well sited into the landscape, and do not intrude visually on the landscape in any excessive way.  The only development that currently affects the skyline in any significant way is the Centocor plant.  Substantial effort went in to masking the effect of that building visually.  With this incinerator proposal there is no such possibility, and its visual impact would be enormous, and inevitably negative for most of the lower harbour.  This is totally unacceptable.

 

17.  The Martello Tower adjoining the site of this proposal is of significance historically, and is a key part of Cork Harbour’s historical naval and military infrastructure.  The effect of this proposal on the Martello Tower, both visually and in terms of access to the tower, is completely unacceptable, as it will almost “hide” the tower from many locations, and makes access to the tower much more difficult.

 

18.  Toxic Use Reduction techniques have been proven in many states in the USA including Massachusetts, and also in Toronto in Canada, to save chemical companies large amounts of money and substantially reduce the quantities of toxic waste produced, particularly POPs (persistent organic pollutants).  It has been clearly shown that these techniques do not get implemented in areas close to toxic waste incinerators.  Dr. Ken Geiser, a top expert and head of the Massachusetts Institute for Toxic Use Reduction, on a visit to Cork a number of years ago, also stated that a toxic waste incinerator in Cork would be a “waste of money”, both for the national exchequer and for the companies that produce the waste

 

19.  Incinerators will bring little or no economic benefit to the region and will stifle recycling and reclamation industries that would otherwise provide jobs.  Incinerator companies are primarily responsible to their shareholders and not to the Irish people.  I believe that the public interest should take precedence over the interests of the incinerator company and its shareholders.

 

20.  Incinerators, by creating a market for waste, will put back the development of economically sustainable alternatives for waste prevention, resource reclamation, organic composting and inert landfill development by a generation.  They have to be constantly fed (24 hours a day, 365 days a year) with waste over a large number of years (typically 25 to 30 years) in order to be economic.  It is hard to produce enough waste to make them economic, as most countries have found to their cost.

 

21.  Incinerators are being phased out in other countries (nearly 70% now closed in the USA, many for economic reasons).  They are now regarded as an outmoded technology in many countries, which have moved towards a more sustainable model of waste / resource management.

 

22.  Alternative technologies for toxic waste are available, which do not have the same level of risk to health and the environment associated with them, and which focus more on recovering valuable resources from the waste.  Different techniques are appropriate for different types of waste, and in fact many are small enough that they can be built on the site where the wastes are being generated.  Closed loop systems for mixed wastes, Alkaline Hydrolysis for animal wastes and Anaerobic Digestion for other organic wastes are now recognised by objective experts as more efficient, sustainable, more economic and eco-friendly than incineration. The EU does not recommend incinerators.  Clean production, waste reduction, separation  & recycling supported by environment taxation is the way forward.  We need many more fiscal measures to cut waste, discourage products with dead end-of-line destinies and encourage environmentally responsible alternatives.  This will also increase business & industrial profitability, as has been demonstrated in the US and elsewhere.  Rank Xerox, for example, has enjoyed increased profitability after implementing a policy to take back used machines and thereby reduce the amount of virgin product having to be sourced.

 

23.  The EPA does not have the expertise, ability or organisation to monitor the proposed toxic waste incinerator.  Indaver will therefore be self-regulatory and I am not happy with this.  Moreover, there has to date been no comprehensive base-line study on health or pollution to land, water and air in the area and therefore it will be difficult to apportion responsibility for pollution in the future.  Moreover the proposed monitoring is based on intermittent and brief spot checks, which fail to measure the real level of pollutants being produced.  In order to get a true picture of the level of pollution, continuous or prolonged monitoring would be required.  I believe that the EPA does not have sufficient resources to do this to a satisfactory standard.

 

I trust that in view of the concerns raised above, An Bord Pleanala will abide by the precautionary principle and have the wisdom to reject this highly controversial application.  With Philip Jones, the senior planner appointed by An Bord Pleanála on the previous occasion an incinerator application for this site came before the board, citing 14 reasons why that application should be rejected, and all of those reasons being equally valid for this application, if not more so, I hope the board will reject this application completely.  I am aware that many others are making submissions to the board in regard of this proposal, and in my submission above I have highlighted the issues which are of most concern to me.  However I endorse fully other points made in other submissions which are in opposition to this futile proposal.

 

Yours faithfully,

 

 

 

 

 

 

__________________________________________ 

Cllr. Dominick Donnelly

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