Madam, – One must agree with the excellent points made by Rosie Cargin (January 5th) emphasising the cost and other implications of proceeding with the proposed Poolbeg incinerator.
Prof Vyvyan Howard gave evidence to the Environmental Protection Agency hearing, on behalf of Combined Residents Against the Incinerator, about the implications of pathogen transfer by micro-particles and the potential danger to surrounding communities.
This was amplified by disquieting evidence from Dr Stefano Montanari, an expert in this research. This alarming aspect appears to have been largely ignored by both Bord Pleanála and the EPA.
However, the EPA, in granting its licence, imposed stringent conditions on the operation of, and discharges from, the plant, which cannot of course be evaluated until it is built. This means the entire construction expenditure may be set at nought, and the facility may become a “white elephant” to dwarf the electronic voting machines.
There are many other uncertainties arising from the proposal:
1. The planning process under which permission was given was a “hybrid” that fell between the normal process and the Strategic Infrastructure Act, and which is of doubtful legality under EU law. Its legitimacy is shortly to be challenged in the courts. This could overturn the planning process.
2. The 600,000-tonne proposed capacity was originally selected on two postulations – that the eastern bypass road would be open before the incinerator was built, and that the population of Dublin in 2020 would exceed two million. The road has been abandoned, necessitating a complex traffic plan whereby most of the waste will travel by the M50 and back through the Port Tunnel to Poolbeg. The population prediction was also clearly flawed.
When the recent judgment confirming the right of the private waste collectors to ownership and disposal of waste collected by them is added, it is clear the amount available for the plant will fall far short of the 320,000 tonnes guaranteed by the councils, so that penalty costs will be incurred. The result will be that bodies like Dún Laoghaire-Rathdown County Council, whose waste is collected by private firms, will still have to pay their share of the compensation, doubtless to be levied on citizens in addition to collection charges. Council waste charges will naturally have to rise considerably.
3. The council’s consultants stated at the planning inquiry that the incoming waste was liable to spontaneous combustion, especially as it would be unsorted. This makes it doubtful if the trucks concerned could go through the Port Tunnel. They would certainly require special provisions. This negates the council’s statement that there would be no congestion on Seán Moore Road.
4. At full capacity, the plant would produce 10,000 tonnes per month of toxic bottom ash. This requires treatment before it can be sold as road metal (for which there appears to be no present market).
The original proposal was to ship it abroad, a process strictly regulated by EU law and which may not be allowed. It beggars belief that, at this stage of the project, there is no clarity on this major part of the process.
This monster of an incinerator would look like an inverted jelly mould, larger than Croke Park, and would present a potential health threat. (No full baseline health study of the community has been carried out.)
Perhaps these concerns will serve to convince your readers that someone, somewhere, (possibly even the Government) must be able to stop this gratuitous waste before it is too late, before irreparable damage is done. – Your, etc,
MAURICE BRYAN,
Technical adviser to Combined
Residents Against Incineration,
Butterfield Park,
Rathfarnham,
Dublin 14.