Letter to various government departments and public bodies
summarizing CHASE position
October 2006

Dear ......

I write to you as Chairperson of CHASE, Cork Harbour Alliance for a Safe Environment. You will recall that we have been in communication with you over a number of years to express our concerns about the Ringaskiddy incinerator proposal and the manner in which it has been dealt with.

We are very aware that there are planning regulations, a planning appeals process and a waste license application process to be followed. We have complied fully with the planning and license requirements, engaged wholeheartedly at every level, and participated in both a planning oral hearing and an EPA oral hearing. Unfortunately, we still have serious concerns that have not been adequately addressed.

Planning problems
The oral hearings clearly demonstrated, and it is a matter of public record, that the Ringakiddy incinerator application breaches the Cork County Development Plan, the Cork Area Strategic Plan, the Cork County Waste management Plan and the National Hazardous Waste Management Plan.

We also now know that the application:

-- Has an inadequate Environmental Impact Statement (EIS),
-- Has no Health Impact Assessment (HIA), though this is required under EU legislation,
-- Fails the World Health Organization’s site selection criteria for hazardous waste incinerators,
-- Contravenes the Basle Convention on waste management,
--- Does not comply with the Irish EPA guidelines on waste licence applications,
-- Poses a thread to public safety in the event of a major accident.

Most of these points are dealt with in detail in the report of the An Bord Pleanála oral hearing. This was compiled by the senior planning inspector who An Bord Pleanála appointed as chairperson of the hearing and as their advisor on the planning issues involved. Having heard all the evidence, the inspector gave 14 solid reasons why the application should not proceed. These were ignored, and no evidence was presented to justify them being discounted.

Inadequate health information systems
Incineration is also premature in Ireland for many reasons, some of which we have referred to in previous correspondence (for example, adopting it at this early stage in our waste management development is a lost opportunity for changing our perception of waste to that of a resource).

Most importantly, incineration is premature in Ireland for the reasons highlighted in a report published by the Health Research Board (HRB) in 2003 and commissioned by the government. These reasons are as follows:

-- Ireland has insufficient resources to carry out adequate risk assessments for proposed
   waste management facilities.
-- Irish health information systems cannot support routine monitoring of the health of people
   living near waste sites.
-- There is a serious deficiency of baseline environmental information in Ireland.

Furthermore, the authors of another report, the Askeaton Investigation and the Failure of Irish Health Information Systems, concluded that: “The investigation highlighted the almost total failure of Irish health information systems to respond to any form of in-depth analysis of population health status.”

These two reports clearly demonstrate the inability of our health system to monitor, assess or evaluate the health implications of major infrastructure facilities that could post a threat to the public. As long as this situation persists in Ireland, there will never be public acceptance of infrastructure such as mass incinerators.

Health risks
We know from a World Health Organisation fact-sheet of 2005 that exposure to the small particles of dust and liquid emitted by incinerators can cause serious health problems and reduce life expectancy substantially.

Moreover, the most recent report from the British Society of Ecological Medicine (Dec 2005) states that: "Incinerators are in reality particulate generators, and their use cannot be justified now that it is clear how toxic and carcinogenic fine particulates are."

The consultation problem
We have repeatedly presented the above evidence to the Dept. of Health, the Dept. of the Environment, the Higher Executive Officer of Waste Infrastructure and Regulation, the Ministers of State for the Depts. of Environment and Health and Children, the Chief Medical Officer at the Dept. of Health and Children, and the previous Chief Scientific Adviser to the Government.

None of these has responded to our concerns in any serious manner. Instead, the responses have been dismissive and patronizing.

While the responses indicate a belief that the planning and licensing processes are robust, CHASE has clearly demonstrated that this is not so. But when we point out the flaws, nobody is willing to address them. Instead there seems to be a total lack of real and meaningful engagement by any of the competent authorities, or anyone we have corresponded with, in relation to this situation.

No matter what our query has been to date, or to whom it is directed, we are receiving the same “cut and paste” letters in response. Officials at all levels have ignored the issues presented to them and instead hidden behind Department waffle. The evidence that we have repeatedly presented is being disregarded, and our genuine and grave concerns are not being addressed.

The purpose of this letter is to ask if anybody is ever going to take our concerns seriously. We have exhausted all the processes; we have presented undisputed evidence as to why the Ringaskiddy incinerator should not proceed; but we have found the consultation process to be a sham, a cynical exercise that seems to have no impact on the decision-making process.

This failure of any Department or competent authority to deal with the issues has cost this community dearly in terms of personal commitment and expense. Because of the failure of the consultation process, we have been left with no option but to resort to the courts, at huge personal and economic cost.

In conclusion, we have had many individual, though uncannily similar, responses to our correspondences, all avoiding the real issues raised by us. While we appreciate being responded to, we feel thoroughly disillusioned and let down by the lack of serious consideration of our evidence and concerns.

Could I now invite all of you to talk to each other and send us your combined, considered and collective response to the issues we have repeatedly raised with you?

Yours Sincerely

Mary O'Leary
CHASE Chairperson