Municipal waste management (ctd)

In today’s Examiner, PJ Rudden estimates the costs of changing government waste policy (as opposed by the ESRI) at around 2.5 billion euro and warns that environmental quality may deteriorate too. As Rudden points out in Friday’s Times, his cost estimate omits the damage to Ireland’s reputation should the government decide not to honour the contract with Covanta, and indeed the cost of breaking the contract.

57 thoughts on “Municipal waste management (ctd)”

  1. @ Richard

    Which ever way it goes, I wouldnt want to be the Greens going to the country after pulling out of Government over stag hunting etc.
    These issues may be resolved through realpolitik in the next few months.

  2. ”The High Court has severely criticised the four Dublin councils for ‘‘massaging’’ key reports into Dublin’s waste sector to influence the outcome of a review.

    The court said that RPS, one of the country’s leading engineering firms, changed a number of draft reports to suit the stance of the councils. The report formed the basis for the councils’ subsequent justification to vary the capital’s waste policy.”

    http://www.sbpost.ie/news/ireland/councils-criticised-by-court-over-waste-report-46693.html

    More on the general topic here http://www.irisheconomy.ie/index.php/2010/02/03/municipal-waste-management-policy/

  3. @Joe

    Hiya Joe! Hope you enjoyed the conference. Apologies for the crowds, and the horses an all dat – not to worry – they will be much, much, much smaller next time! Happy hunting (-;

  4. @ David O’Donnell

    Since Richard only selectively vets comments I’ll reply to your comment: That’s unrelated. Please focus on the subject at hand. Please use proper arguments.

  5. It should also be noted that neither Ireland nor the government is party to a contract with Covanta, so there could be no reputational risk involved. Right? What about the reputational risk if it emerges that national policy is now to be dictated by the terms of third party contracts. Which is worse?

    Dublin City Council is party to the contract and presumably took legal advice and was well aware of the risks associated with entering into the contract in circumstances where it could not control national policy. In fact according to the Panda judgment they couldn’t even control regional policy to a sufficient degree to ensure that the pay element of the put or pay clause would be triggered.

    Finally it is entirely relevant that financial relationships between commentators and relevant parties be declared so that people can judge for themselves what degree of reliance to put on comments. Therefore the fact the PJ Rudden and RPS have been retained as consultants by DCC is relevant as is the fact that ESRI was commissioned by DCC to write a report.

  6. @Paul
    Dublin City Council signed a contract that was perfectly in line with the national government policy, and still is. If the central government were to overrule its own policy and the legitimate local authority, then that does do damage to the reputation of Ireland. It signals that Ireland is ruled by men not law.

  7. Policy is policy. It is not law. Policy is formed, publicised and changed in different ways to law. Central government may change its policy from time to time without changing law.

    The rule of law is a whole ‘nother subject.

  8. @Holbrook Fields

    Point noted Holbrook.

    I refer all readers to today’s brief, and to the point, Editorial in The Irish Examiner. Don’t have the link to hand, but basically – get on with incineration as land_fill penalities are on the near horizon and we can’t affort to be throwing scarce capital away – & Minister for the Environment to cop himself on.

    My apologies Holbrook for straying from the thread – from old, I know you to be a stickler for proper protocol in these matters.

  9. @All
    The appointment of an SC to review the Covanta contract has given me an idea. Could John Gormley not appoint an SC to review the DDDA’s involvement with the Ringsend Glass Bottle site? It is his department’s responsibility. Niamh Brennan is an expert in corporate governance, not an experienced legal counsel afaik. We are currently paying (or is it may have to pay?) the interest for AIB’s loans and are also being sued by one of the parties involved. At the risk of a certain perception of nepotism, might she be able to recommend a tenacious SC who can thoroughly investigate this matter to make sure that everything was above board?

    The minister could also lobby for the appointment of another senior counsel to investigate the blanket bank guarantee.

  10. @All

    Waste disposal – Fines must be avoided

    Monday, March 29, 2010 Irish Examiner Editorial Comment

    NONE of us, especially those who use the roads and byways outside our cities or towns, can be proud of the way we dispose of waste.

    Verges and hedgerows are littered in a mindless and appalling way.
    In this light, Environment Minister John Gormley’s zealous opposition to incineration seems out of step with reality as imagined by the rest of the EU.

    http://www.irishexaminer.ie/opinion/editorial/waste-disposal–fines-must-be-avoided-115726.html

  11. @David O’Donnell
    The Examiner article makes a very strong case for building the incinerator. Unless there is a massive national MBT programme coupled with a generous derogation from the EU then AN incinerator will HAVE to be built at Poolbeg. And if MBT is more expensive then, unless the contract was overgenerous to Covanta, the ESRI was entirely correct to recommend building the incinerator and to criticise the national waste strategy.

    There is a danger however that John Gormley will stall on this until he leaves office and his successor will be stuck between an incinerator and massive fines. Until very recently I thought the Greens, like Irish Tom Bombadillos, just didn’t understand NAMA as they were so focused on healing the planet. Gradually I came to realise that they had sold out for planning reforms etc. Ciaran Cuffe’s comments confirming that they had concealed their intention to play musical chairs with OFFICES OF STATE was the final straw. Now I know that stalling on this issue to the detriment of the country wouldn’t cost them a night’s sleep. Alas the Tom Bombadillos have become the Gollum Party.

  12. @Paul

    Pls do not refer to Dublin City Council as DCC – DCC is better known in corporate governance circles as associated with the board that gave the Harvey Smith to the Irish Supreme Court in 2007 following a little civil case (think bananas) and a bit on the ‘inside’ for a mere €70 million or so – one of its [DCC] directors presently serves on the board of Anglo_Irish ….

    To the best of my knowledge, Dublin City Council has some respect for the Law – and for Contracts.

  13. @Oliver Vandt

    & Paul Gogarty is running for major of Dublin.

    What a Party – an agonising, slow, and principled ascent – then an instantaneous combustion once in office.

  14. @Richard

    You said:

    “If the central government were to overrule its own policy and the legitimate local authority, then that does do damage to the reputation of Ireland. It signals that Ireland is ruled by men not law.”

    The High Court found in the Panda case that men in DCC (and the other three local authorities) broke the law when they attempted to change regional policy and re-monopolise the market. Not only did the court find that their policy changes contravened competition law but that they attempted to subvert the Waste Management Act as well as acting ultra vires and un-constitutionally. Hardly great for our reputation?

    As you said we are ruled by laws and not men, even the Dublin local authorities.

    Policy is dynamic and as long as the legislature acts within the law they may change policy according to their democratic mandate. No one can legitimately expect policy to remain constant over time. Economic considerations of sectoral interests do not automatically over-ride other considerations in a democratic society. For example look at liberalisation of the Dublin taxi market

    You really are losing this argument.

  15. NONE of us, especially those who use the roads and byways outside our cities or towns, can be proud of the way we dispose of waste.

    Verges and hedgerows are littered in a mindless and appalling way.

    And TCH believe that incineration will cure the practice of decades (if not centuries) how, exactly?

    @ Richard Tol

    That’s unrelated. Please focus on the subject at hand. It’s also guilt by association. Please use proper arguments.

    It’s not at all ‘unrelated’, and “guilt by association” is a rather rich accusation from your quarter.

    Not at all impressed by the muppetry around this issue. Some very fine scientists at ESRI (one of them a friend) are seeing the reputation of that organisation brought down by ideology-driven results.

  16. @Paul
    And a good thing it is that the high court held the Dublin authorities to account.

    Governments can and should change policy. They should not, however, do that too often and without good reason — because long-term investment requires regulatory certainty. One should always be reluctant to change the rules retrospectively. And in this particular case, national waste policy has not changed. The PoolBeg incinerator is at odds with potential future policy, but it is perfectly in line with actual current policy. Investors are being punished for operating within the law.

  17. @EWI

    Not sure the editorial makes the explicit link you suggest – personally, I go somewhat livid when I come across road-side dumping etc. the point is: we have waste which needs to be disposed of – this is implicit in the Examiner’s Editorial – and citizens who need to be educated/cajoled/persuaded/fined etc to act appropriately – the plastic bag levy has worked well, for example.
    Thus far I have yet to see an argument, other than incineration, that provides a medium term solution at low cost. And the strange situation of land_fill special interests in coaliton with a ‘Green’ Party – and a Minister acting in clientelist fashion to rival any within FF – and using his power to do so in personal/local interests, rather than public interest.
    I certainly don’t agree with all that comes out of ESRI, I have a little thing about neoclasscial economics meself when not supplemented by broader institutional/societal theory and context, but on this one – their argument is both economically and pragmatically sound.

  18. @Richard

    To focus on the subject at hand, your OP repeats an assertion by PJ Rudden who estimates “the costs of changing government waste policy (as opposed by the ESRI) at around 2.5 billion euro”.

    This estimate is a bit rich coming from PJ. His company MCOS (now RPS) together with their fellow advisors have been paid some 25m euro to date by Dublin City Council. That’s a significant vested interest which should always be considered when PJ makes any statement.

    We do not see any rationale from PJ to support his assertion. In fact the only reviews we are aware of regarding his sums are from McKechnie J in the High Court and from ourselves. Both reviews are highly critical.

    PJ himself has stated that the original 1997 business case for the Poolbeg incinerator has never been revisited.

    We should be ruled by common sense and it would be prudent to re-assess the case for incineration – we have put forward in your earlier blogs a number of pertinent costs omitted by the promoters of incineration in Dublin. When the extra costs are included in the EPA model the gate fee for incineration rises to 122 euro per tonne.

    Having repeated PJ’s assertion it is a bit trite for you to ask for proper arguement when the necessary figures to back up his assertion are not available.

    We would be more than happy to deal with PJ’s claim regarding 2.5 billion euro if you would provide the figures to allow a focused debate on the subject at hand.

    J&V

  19. @Richard
    Contracts are broken all the time. It would not be an international diplomatic incident. Certainly covanta would need to be compensated and this would be costly.

    Again the supporters of this project are resorting to exaggerating the risk of eu fines under landfill directive. I described previously (end of last waste thread) why we still have time to allow the development of alternatives.

    Is there no FOI provision that entitles the public to know the details of this contract? For most public tenders the contract price is released.

  20. @J and V
    If the contract will cost DCC 122e per tonne fixed for 25 Years (all inclusive, including initial capital) then I’d relax about the issue. In todays market it could go to MBT for about 100 but I could sleep at night knowing covanta have only got a 22 percent celtic tiger premium. .

  21. @Richard

    The cost of “it” depends on what PJ Rudden defines “it” to be.

    You quote him as estimating the cost of “it” at 2.5 billion euro yet the Examiner article attributes just “billions” to him (and quotes the County and City Managers Association predicting €2 billion).

    It is hard to pin down these bald assertions and they can not be analysed unless backed up with some details to support the claims.

    J&V

  22. “Governments can and should change policy. They should not, however, do that too often and without good reason — because long-term investment requires regulatory certainty. “

    It’s worth pointing out that the contract for Poolbeg runs until 2037 – is that to be the time horizon before which a change in policy should not be considered? In the intervening time we are legally obliged to have cut our greenhouse gas emissions by 20% by 2020 and to be well on the way towards an 80% cut by 2050. Is it credible that we can do this while our generation of waste continues to grow at Celtic Tiger rates?

  23. @Ryano
    Of course not. Any long-term investor considers a reasonable range of policy changes, including a certain degree of arbitrariness.

    Waste policy has little to do with climate policy.

  24. “Your comment that “Waste policy has little to do with climate policy.” seems to me like a very very odd thing to say.”

    Very odd indeed, as it would require you to assume that climate policy will have no impact on consumption.

  25. SLR Consulting Report 2010 , Dublin Region Thermal Treatment Needs Assessment using ESRI/EPA ISus waste growth data
    ”2.0 The ISus Model
    The ESRI, in collaboration with the EPA has prepared a Sustainable Development Research Model (ISus), which is designed to forecast environmental emissions and is used by the EPA to regulate industrial emissions in a manner that allows Ireland fulfil its obligations under a
    number of EU Directives. The model includes predictions of waste growth with a focus on biodegradable municipal waste, as the EU Landfill Directive1 restricts the quantity of this waste stream accepted at landfill sites in Ireland from 2010 onwards. The EPA can control waste acceptance at all landfills through enforcement of waste licence conditions.
    By its nature, the ISus data must consider worst-case scenarios, giving the EPA a starting position when setting emission limit values and waste acceptance criteria. When the worst case scenario is not borne out, the EPA can reset limits to less onerous values. This has already occurred in licensing of landfills when the ISus forecast of 1.3% growth in
    Biodegradable Municipal Waste (BMW) between 2007 and 2008 was found to be vastly overestimated. The latest figures2 show that instead of 1.3% growth in BMW in 2008 as forecast, the waste arisings were 5.1% down on 2007 figures. The ISus model had overestimated waste growth by 6.4%.
    In response, the EPA now proposes to allow 50% BMW in landfills rather than the previously indicated 40%. We suggest that the ESRI data will continue to over-estimate waste growth and the EPA will continue to revise it downwards on a year-by-year basis. We recognise that
    this is a sensible strategy by the Agency, but we argue that the data should not be used to analyse the future waste market in Ireland.
    In taking a worst-case view, the ESRI made 3 assumptions. Firstly, it assumed that the recession would be over by the end of 2010 with positive growth in 2011. Secondly, it assumed a very strong recovery with growth in GDP of c.5% per annum between 2012 and 2015 and growth of 3% to 4% per annum for the period 2015 to 2025. Thirdly, the ESRI has
    assumed a direct correlation between GDP and municipal waste growth.
    We suggest that each of these assumptions combine to give an over-inflated view of waste growth. The first 2 assumptions are clearly optimistic and the third is clearly inconsistent with previous experience in Ireland and other EU States. As detailed in our November 2009
    report, our analysis has found that during the period 2000 to 2007, when the world economy was growing rapidly, municipal waste grew by an average of 0.4% per annum in the EU as a whole and during the same period, average municipal waste arisings fell by 0.1% in a
    selection of the more developed economies in the EU, i.e. Belgium, Netherlands, France, UK and Germany. Link http://www.slrconsulting.com/100113_501.181.1.2_dublin_region_supplementary_rpt_re_isus_data_final.pdf

    @Richard.
    Is the ERSI still predicting 5% GDP growth from 2012 to 2015, in light of the massive debt burden the economy took on yesterday?

    I’m usually only a voyeur to the economics arguments on this website as i have no formal training at economics, but maybe i should start since my own feelings about GDP and waste growth seem to out perform the analysis of best brains in the EPA and ERSI combined 😉

    Very odd indeed

  26. @Sam
    SLR is just wrong about the assumptions in ISus and how it is used.

    We indeed use the latest projections of economic growth. Some things have turned out better than we expected, and some things are worse. There will updated projections later in the year.

  27. @Richard
    I can’t comment on the models used but do you accept my argument at end of last thread that the BWM to landfill targets are not problematic until 2013 and not very problematic until 2016? Assuming we implement the third bin in line with long standing government policy of course.

  28. @Sam
    There are policy aspirations, as always, but the only policy in place, at present, to make a serious dent in BMW-to-landfill is the incinerators.

  29. Massaged Truthiness: Policy on waste management in crisis, says April Fools Day Expert.

    The Irish Times is again publishing massaged stories dressed up as “expert”.

    The spin is possibly again taken directly from the PR officer of the incinerator promoters (who apparently don’t answer the phone), an apparent Irish Times practice at the oral hearings.

    Irish Times April Fools Day Headline:

    Policy on waste management in crisis, says expert
    The Irish Times – Thursday, April 1, 2010. TIM O’BRIEN.

    The newspaper makes no critical observations on the article’s curious one-sided claims on behalf of an organisation whose expert-employee was adjudicated to have massaged the truth and to have used undue influence in a public process (Judge McKechnie on DCC’s Twomey).

    For instance, Mr Rudden of RPS seems to make uncontested claims about the financial viability of incineration.
    Covanta loudly proclaims the awesome effectiveness of filters on its stacks, but seems to refuse to publish a list of pollutants with quantities. The promoters refuse to produce a clear diagram, claiming its impossible. Does Covanta always blame-shift to house-persons when explosions occur as in a Covanta facility in USA in March 2010? Their engineer at the open day in Dublin in January 2010 pointed liability at residents instead of at absurd industry gaurantees of no health-damaging air pollution.

    Curiously Mr Rudden’s April Fools Day article totally omits any mention of the health costs imposed on future generations from premature deaths in polluted Poolbeg. Poolbeg is already above legal limits: the incinerator itself and the 200 trucks per day will push the burden possibly past a critical tipping point.

    The US EPA prices a human life at $8 million. Mr Rudden’s RPS and other ‘consultants’ have been paid €25 million to spin for incineration. It is quite likely there is a lucrative construction-phase bonus and a completion bonus on offer. After that it is well known that Covanta fully legally hires people after they retire from their old public service jobs.


    What is the cost of 100 premature deaths per year for each of twenty five years? Twenty Billion? Nobody knows. Except for people paid by DCC to claim there is not any risk to health. What did the bankers say about risk?

    ________

    Is the Irish Times revenue still controlled by the galway tent cabal? The property boom kept the paper in business, a boom the patriotic paper did not meaningfully investigate. The cost to Ireland is €80 Billion (€80,000,000,000).

  30. Incineration Means 300 Deaths in Dublin?

    http://galwaytent.blogspot.com/search/label/Amsterdam

    Since 1999, the air across Holland has become cleaner – except in Amsterdam.

    The Amsterdam Council says it does not know why. It’s pertinent to note that a modern Poolbeg-sized incinerator went into operation at Amsterdam-Westerpoort during the 1990s.

    This large modern incinerator has not been ruled out as an explanation for the excess Amsterdam deaths.

    Deaths in Amsterdam from air-pollution are thirty percent above the Dutch average. Based on the November 2006 article in the respected Het Parool national newspaper (see below), it appears 300 extra deaths occur in Amsterdam annually from the higher pollution. As Amsterdam’s population is similar in size to Dublins it’s valid to ask the responsible government department to determine whether the Poolbeg Incinerator will prematurely kill up to 300 people annually. The Environment Minister basically said he was not responsible for environmental matters. Whether his reply was accompanied by the use of two fingers, or just one, is unknown.

    Can an Environment Minister not be responsible for managing the impact of environmental air pollution on people? How about even an honest effort to research the issue?

    By rejecting the Dail Question from the Dublin TD in early 2007, Ireland’s Environment Minister Dick Roach passively confirmed the Poolbeg Incinerator will prematurely kill up to 300 Dubliners annually.

    ————————————

    http://www.davdigital.com/weblog/?article=839

    Amsterdammers sterven vroegtijdig door fijnstof

    FREEK SCHRAVESANDE © Het Parool, 11-11-2006, 12:23 uur

    AMSTERDAM – Tussen de negenhonderd en elfhonderd Amsterdammers per jaar sterven vroegtijdig door fijnstof, goeddeels veroorzaakt door luchtvervuiling door het verkeer. Tot die conclusie komt de Amsterdamse GGD na eigen onderzoek.

    De lucht in Amsterdam is de afgelopen zeven jaar niet schoner geworden, blijkt uit recent onderzoek van de dienst, terwijl dat gemiddeld over heel Nederland wel het geval is.

    De sterfte in Amsterdam door fijnstof is grofweg dertig procent hoger dan het landelijk gemiddelde. In Nederland sterven per jaar achttienduizend mensen aan die oorzaak, blijkt uit gegevens van het Rijksinstituut voor Volksgezondheid en Milieu (RIVM). De slachtoffers – veelal mensen die al met ademhalingsproblemen kampten – sterven naar schatting enkele maanden tot tien jaar eerder dan wanneer zij geen fijnstof binnen zouden hebben gekregen. Deskundigen wijzen er wel op dat fijnstof in steden ‘nu eenmaal’ meer voorkomt dan elders.

    De concentraties fijnstof en stikstofdioxide dalen volgens het luchtmeetnet van de GGD al sinds 1999 niet meer – ondanks de introductie van schonere auto’s. ”We hebben hier nog geen duidelijke verklaring voor”, zegt Fred Woudenberg, onderzoeker luchtkwaliteit van de GGD. ”Op de snelwegen rond Amsterdam is wel sprake van een dalende trend, maar binnen de bebouwde kom blijven de concentraties nagenoeg gelijk”.

    Een ‘verrassende’ uitkomst, vindt ook onderzoeker Ronald Albers van het RIVM, dat landelijk luchtmetingen verricht. ”Het verbaast mij, want je ziet in heel Nederland een dalende trend voor fijnstof in de lucht. Ook bij onze meetstations aan straten in de Rijnmond, Eindhoven en Utrecht nemen deze concentraties af. Dat geldt eigenlijk voor heel Europa”.

  31. @ Richard Tol

    >> “The incinerator has an IPPC license, so that you and anyone can look up their emission limits.”

    🙂 Is that a quote from the financial regulator’s little brother, now in the green industry? 🙂

    Unregulated limits are a red herring. Do you mean ‘look it up’ as in instant Google Goggling (see below)? Or by trying to interpret deliberately obfuscated and deliberately cryptic “data”. Something Dublin City Council (DCC) would never do of course.

    Which Irish institutions do you trust? And are there any you trust to robustly regulate pollution and human health?

    Alternately do you trust a commercial operator with huge debts? Do you trust self-regulated reporting by a company with huge debts ($3 billion) and laughable profits ($0.1 Billion)? And a history of pollution fines.

    At a Jan 2010 ‘Open Day’ the Covanta/RPS/DCC rep finally admitted after 20 minutes of trolling magnificently huge volumes that Ireland’s EPA has NOT YET decided what pollutants will be monitored. Never mind how often (every 60 seconds?). Nor how, nor how accurately, nor how credibly and at what cost.

    Imagine: simply point your GSM enabled camera phone at a Convanta chimney stack and instantly get sophisticated visualisations for deadly particulates, PM 1.0, PM 2.5, furans, dioxins, toxic metals. That’s called Goggling Convanta.

    Another iPhone App could keep a running total for all pollution fines paid by Covanta.

    _____________
    The EU’s limits for PM pollution are far less robust than California or WHO standards. EU limits seem to be controlled by the German chemicals industry. Do you trust German chemical companies?

    The USA governmental site referenced by Covantas engineer for a Covanta Maryland incinerator is God’s gift to deliberate obfuscation. Though the site does report how many African Americans are employed. And Homeland Security will check you out (posing as Governer O’Malley’s office).

  32. @Richard Tol

    >> @Galway Tent
    “You may want to brush up your Dutch. The copied article does not refer to incineration at all.”

    Exactly my point. Nobody knows the reason. So what about the big elephant in the room, the huge incinerator opened and expanded in Amsterdam/Westerpoort in the 90’s. A condition-change that appears not to apply to other cities. Incineration can not be ruled out. What is a more likely reason?

  33. @Galway Tent
    You may want to brush up your logical skills.

    The particulates situation in Amsterdam is not quite understood, but no one local or in the know blames the incinerator. The reason is that incinerators are point sources: easily monitored and with a distinct fingerprint. If the reason were so simple as you think it is, the problem would have been solved a long time ago, as Dutch environmental scientists and engineers are world class.

  34. @Richard Tol.

    Logic? Thanks for the kind advice. You may wish to consider that a proposed possibility is not ‘what I think’. It is a possibility to be scientifically examined.

    Please do not place words in my mouth. I did not state anything was simple. Although it is interesting that some problems are only simple after they have been solved, not before, even for world class scientists.

    You avoided my question – what is a more likely reason?

    Have the Dutch experts definitely ruled out the incinerator as NOT contributing to the EXCESS death rate in Amsterdam since the incinerator fired up? Please provide peer reviewed references. That would be valuable.

    When premature death levels have dropped across the rest of NL and across Europe a 30% higher premature death rate in Amsterdam is most odd (if my Dutch is not too much in need of rehab). What’s different in Rotterdam or in Delft?

    Have Dutch scientists examined Amsterdam cadavers for the chemical signatures of PM 1.0 particulates, for instance? Or gases from Schipol mixing with pesticides from the flower business with non-understand reactions related to micro-particles or nano-particles escaping from the incinerator? Or any other possibility?

    Is there any chance that budgetary effects would impact the science?

    What are the top-3 or even top-10 possibilities being examined by the NL experts?

    Please stick to the point, use an objective scientific mind-set and please avoid personalisations.

  35. @Galway Tent
    You come up with a wild hypothesis, so the burden of proof is on you.

    If you want to know what Dutch experts think is causing the high PM concentrations in Amsterdam, you could start at RIVM.

    You may also want take a look the distribution of particulate matter and the location of incinerators in the Netherlands. That should rapidly dispel your fears.

  36. @Galway Tent
    I think Richard has you on this one. There is so many diffuse and uncontrolled sources of pollutants, why would you look to an incinerator where the best available technology is used.

    You say these deaths in amsterdam is caused by air pollution and that the pollution level is higher there than in rotterdam etc. What type of air pollution has been detected?

    Anyway if you don’t trust the EPA to regulate this incinerator why do you trust it to regulate the other activities that will be needed otherwise. I think the urgency is being exaggerated but we do need someone to deal with this waste

  37. @ Richard Tol

    >> … IPPC Licence …

    Do you trust the EPA and its pieces of paper? Please refer to the chromium pollution of Cork Harbour, done on EPA’s watch.

    At a Jan 2010 ‘Open Day’ the Covanta/RPS/DCC rep finally admitted after 20 minutes of trolling magnificently huge volumes thatIreland’s EPA has NOT YET decided what pollutants will be monitored. Never mind how often (every 60 seconds?). Nor how, nor how accurately, nor how credibly and at what cost.

    Do you trust the EPA where the politically appointed Directors (condemned by current government party in 2005) make critical decisions such as approving the Poolbeg Incinerator just a few days after a politically influenced Bord Pleanála ruling (with ex-RPS employee on the Board), and months in advance of EPA Oral hearings? Do you trust the EPA with directors who hop between gigs in the incineration industry and in the regulator’s agency?

    EPA scientists may be world class. But the EPA hierarchy and its pieces of paper do not inspire confidence. [Hint: same culture as financial regulator].

    ________________

  38. @ Richard Tol

    You again appear to avoid my question. I am asking a question.

    Please do not re-word my question as a wild hypothesis (which is anyway a good approach to get started to a solution for known unknowns). It is a question and a valid possibility. Since when does asking an obvious question to be answered by peer-reviewed experts become transformed into a burden of proof by a non-expert questioner? It may be useful to refer to the 20th century tobacco industry stance requiring smokers to prove their health was damaged, an outrageous hypothesis at the time.

    You avoided my question – what is a more likely reason? The wind blows over Amsterdam from the west; the incinerator is in the west.

    Have the world class Dutch scientists definitely ruled out the incinerator as NOT contributing to the EXCESS death rate in Amsterdam since the incinerator fired up? Please provide peer reviewed references. That would be valuable. If you do not know please simply say so

  39. @Galway Tent
    You need a mix of people on these boards. Certainly you need people with experience from working in industry.

    The problem with the financial regulators is they showed defference to these super stars of the banking world.

  40. @Galway Tent
    You may also want to reread Popper.

    It is not my job to do your research for you. Go to http://www.rivm.nl/, search for fijnstof or vuilverbranding, and trawl through the material to discover what hypotheses have been tested and remain standing.

    Alternatively, have a look at the ESRI and Eunomia reports to see what is expected to be emitted by the Poolbeg incinerator (which is 20 years younger than the Amsterdam one).

  41. @Richard Tol

    >> @Galway Tent
    “If you want accuse people, I suggest that you reveal your identity and report them to the appropriate authorities.”

    You again put words in my mouth. Do I accuse (your word) or do I make a valid observation about a requirement for total confidence in regulators?

    The observation on one of the EPA Directors is from a press release isued by a current government party, circa 2005, by the current Party Chair of that party. That is public domain information.

    The CVs and Bios of the the other people are in the public domain (although its often not revealed in ‘expert’ reports and decisions). The BIO’s show jobs in EPA, and jobs in the incineration industry, as employees or as paid consultants. That is public domain information.

    Are you comfortable with a fox guarding the hen house? Such a sensitive role demands there be no possible perception of bias, no matter how justified or unjustified the perception. Total confidence is required. Even a 5 year ban on transfer between the regulator and the regulated would be good. Surely that is most obvious now with the NAMA mess?

  42. @sam

    FYI:

    The Dutch newspaper Het Parool reported 900 to 1100 deaths per year in Amsterdam from air pollution particles, mainly caused by traffic (according to the Amsterdam equivalent of DCC).

    Tussen de negenhonderd en elfhonderd Amsterdammers per jaar sterven vroegtijdig door fijnstof, goeddeels veroorzaakt door luchtvervuiling door het verkeer.

    The paper reported the air in Amsterdam had not become cleaner in the past 7 years (1999-2006) in contrast to the rest on the Netherlands.

    De lucht in Amsterdam is de afgelopen zeven jaar niet schoner geworden, blijkt uit recent onderzoek van de dienst, terwijl dat gemiddeld over heel Nederland wel het geval is.

    Deaths in Amsterdam caused by fine particles are 30% higher than the NL median. Eighteen thousand people die in NL from fine particles (people die prematurely by months to up to 10 years prematurely). The same rate for the island of Ireland would translate into 6,000 premature deaths per year (about 20 times the car crash death rate).

    De sterfte in Amsterdam door fijnstof is grofweg dertig procent hoger dan het landelijk gemiddelde. In Nederland sterven per jaar achttienduizend mensen aan die oorzaak, …

    Fine particle and SO2 in A’dam have not fallen any more since 1999, despite cleaner vehicles.

    The city council has no explanation.

    De concentraties fijnstof en stikstofdioxide dalen volgens het luchtmeetnet van de GGD al sinds 1999 niet meer – ondanks de introductie van schonere auto’s. ”We hebben hier nog geen duidelijke verklaring voor”, zegt Fred Woudenberg, onderzoeker luchtkwaliteit van de GGD.

    This also surprises Ronald Albers from the imperial institute for public health and environment.

    Een ‘verrassende’ uitkomst, vindt ook onderzoeker Ronald Albers van het RIVM, dat landelijk luchtmetingen verricht. ”Het verbaast mij, want je ziet in heel Nederland een dalende trend voor fijnstof in de lucht. .

    The article makes no observations about the large incinerator to the west of A’dam which fired up around 1999. That’s my observation and the reason for my question. Has the Amsterdam incinerator been ruled out as a cause for the 30% higher premature death rate in Amsterdam?

    For the proposed Poolbeg Incinerator DCC/EPA has no plans to measure the number of fine particles, especially the dangerous PM2.5s and PM1.0s. All they propose to do is to weigh a ”sample” of PM10’s particles (how, when, how often not stated). Weight is misleading for PM2.5s and PM1.0s. The science is not yet understood.

    EPA Ireland does NOT regulate for health effects. The responsibility is passed to the HSE or to some other agency. DCC will not do a base-line health study recommended by Dr/Professor Staines, (DCU or UCD). Something to hide?

    ==============

    On ‘best available technology’: a Covanta engineer at a Jan 2010 open day explained multiple

    fines at multiple Covanta incinerators as happening apparently because technology is not perfect

    (sort of in a hey lets be real about this manner). …

    Unless already addicted by one of the 200 compounds would you willingly use a best available

    technology cigarette? Would you impose the solution on a city, or even on a village?

    http://1.bp.blogspot.com/_qdRqFPGZw2o/S7Qeb6Ef4KI/AAAAAAAACs4/acPvmcWZ3kQ/s200/Viceroy-Dentist-1.jpg

    ++++++++
    DCC paid ESRI to do an independent report. Did they start from a neutral position? The McKechnie hudgement is relevent here too. Je n’acuse pas!

  43. Regarding air pollution from incinerators.

    In Ringsend, the EPA air monitor on Sean Moore Road shows 7 exceedences of the PM10 limit in March. This equates to 84 per annum when the standard is 35 – a breach of 240%.

    Check the graph at http://www.epa.ie/whatwedo/monitoring/air/data/d/rs/pm/#d.en.25629

    This is not news to us since we drew the attention of the Chairperson at the EPA oral hearing to the fact the every AQ measurement campaign conducted in the area since 2002 has shown the air quality limits to be breached.

    To add another burden of particulates from the proposed incinerator is wrong. In fact the Chairperson recommended that the incinerator be delayed until the air quality met standards but the board of the EPA rejected this recommendation and handed the air quality issue to the relevant authority.

    Surprise, surprise, the relevant authority is none other than Dublin City Council who are compromised by their vested interest in the incinerator.

    The council ought not be judge and jury in their own cause (cf the judgement of McKechnie J in the Panda case and the leaked reports into the DDDA’s activities).


    J&V

  44. Sorry to post on such an old thread, but did anybody ever find out where PJ Rudden got his €2.5 billion figure from? Did he just choose it as a sufficiently big number to scare people or is there some factual basis for it that has been kept hidden for unknown reasons?

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