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Letter to Environment Agency - incinerators

Re. The Environment Agency: Integrated Pollution Prevention & Control

I am writing to you as Chair of the Environmental Audit Committee as I am concerned about the way in which the Environment Agency (EA) deals with planning applications for incinerators, or “Energy Recovery Facilities” as they are otherwise erroneously known.

After a planning application has been discussed and approved the EA assesses the application and decides whether to grant an Integrated Pollution Prevention and Control (IPPC) certificate, without which the incinerator cannot operate. Invariably the certificate is granted. In a recent case, when an incinerator was proposed for Cornwall the EA stated that they were “mindful” to issue the “environmental permit” regardless of the fact that the application had already been rejected by the local council and the Public Inquiry had not yet concluded. In the words of a resident of Cornwall, Paul Matthews, “Whenever the wider public interest is in conflict with the dictates of the market, the Environment Agency bends over backwards to accommodate short-term commercial concerns to the detriment of public health and long-term environmental sustainability.”

This is the personal opinion of a resident who submitted a full and comprehensive presentation to the Public Inquiry and feels that the system is letting down the people who are most likely to be affected by decisions involving large waste facilities: worse still he feels that the EA are trying to influence the final decision (he feels that any comments they make at this stage should be neutral). It could be seen as an extreme view, but it seems to concur with the experience we have had here regarding the Newhaven incinerator: more on this later.

The recent Environmental Audit Committee Report on air quality did not include incinerator emissions, and Tim Yeo, MP, the then Chairman, in a letter to my MP, Norman Baker dated

19th March, 2010, said that the Committee had not looked at research into health issues surrounding incinerator emissions: he seemed interested mainly in traffic fumes.

Regarding the health issue, the EA consults with the Primary Care Trust on every application. The PCT engages with the Health Protection Agency (HPA). The HPA have done no research into the effects on health of incinerator emissions, and are not interested in any such research carried out by anyone else. They prefer to hope for the best that the effects of emissions will be “small.” They fail to accept that air pollution is already quite serious – in Sussex it is shortening thousand of people’s lives already – and that with every polluting facility that is built pollution increases. If more and more incinerators are built all over the country – many have already been approved by the previous government – the cumulative effects on human health in this country could be disastrous.

The following is a brief summary of information collected on the regulation of air quality in the UK, beginning with our local situation.

1. The Newhaven Incinerator Scandal

The planning application for the incinerator to be built on North Quay, Newhaven, in a residential area, was first approved by East Sussex County Council on 21st February, 2007, and the EA issued the IPPC soon after that. Then, due to a technical error the planning application had to be examined again, later in the year. It was finally approved by ESCC on the 7thNovember, 2007.

Similarly, the EA awarded the IPPC in 2008 but this was found to be illegal due to an error in the operator’s paper-work regarding the expected emissions of CO2. A further period of “consultation” ensued, and the EA finally granted Veolia (the waste company) the IPPC on the 13th March, 2009. (This was a surprise to the residents, who could see no significant change in the specification submitted by the operator). Work had been started on building the incinerator in July, 2008. The incinerator is expected to start operating in 2011.

2. Health Risks of Mixed Waste Incineration

Apparently the Newhaven incinerator ticks all the boxes and therefore its operation is within the law as it stands, in spite of the fact that it will be emitting nano-particulates which are dangerous to human health (a fact recognized by the World Health Organization and DEFRA) as well as heavy metals and other toxins including dioxins and furans, all of which are extremely dangerous to human and animal health. The emissions will also pollute the environment, contaminating soil and water and compromising many farms’ organic status.

There is at present no statutory requirement for an incinerator operator to filter out PM2.5’s, but the EU Directive 2008/50/EC, soon to become law, requires member states to reduce emissions of PM2.5’s. Directive 85/337/EEC also requires that the emissions from all sources in a given area be considered before planning consent is granted. (This would have been an obstacle to planning consent for an incinerator in Newhaven, which is already dangerously polluted by traffic fumes!)

The EA is aware that incinerator emissions cause death and illness, but they still granted the IPPC (“permission to pollute”) to the operator. When asked a direct question, at a meeting on the 20th January 2010, a representative from the EA replied: “You don’t get deaths, you get life expectancy changes!”

When asked about PM2.5’s, heavy metals and other toxic products of incineration the EA says: “We take advice from the PCT, and they engage with the HPA.” On applying to the PCT and the HPA I have been referred to the EA or DEFRA. It would appear that nobody is actually doing the job of protecting human health and saving the environment from degradation.

3. The Environment Agency’s remit

The EA’s stated purpose is “to protect or enhance the environment, taken as a whole,” so as to promote “the objective of achieving sustainable development” (The Environment Act, 1995, Section 4). Its duty is to protect the environment from threats such as flood and pollution. The Agency’s vision is of “a rich, healthy and diverse environment for present and future generations.” (­Agency).

The Environment Agency cannot do the job it is expected to do because:

1. it does not have the legislative power

2. it lacks the technical resources

3. it does not have sufficient money

4. it lacks the staff

4. Emissions Monitoring

The system itself is open to abuse: the operator does the monitoring, and self-monitoring is easy to falsify. There are very few spot checks: most visits are carried out by prior arrangement with the operator.

Many toxic substances are not monitored at all. *

Breaches of emission limits are not taken seriously. Such breaches are known as “exceedances” and not treated as crimes. Polluters are rarely prosecuted. Letters are exchanged!

In 1999 and 2000 the ten operating incinerators had exceeded their pollution limits an incredible 553 times and yet there was only one prosecution by the EA. Since then there have been hundreds of exceedances, figures have been falsified and some incinerator operators have refused to give any information, but as of 14.09.2009 “The Environment Agency’s National Enforcement Database has uncovered no prosecutions for offences related to poor air quality arising from incinerator use” – Hansard Written Answer 2107W. *

5. Risk Assessment

The Environmental Impact Assessment (EIA) is not carried out properly. The Onyx EIA for the Newhaven Incinerator used data from Herstmonceux, which is nowhere near Newhaven, and included no assessment of temperature inversions or local wind conditions. River flow, aircraft wake vortices, trains dragging air down and along, new housing, a giant wind farm out at sea – all were ignored by Onyx in the EIA.

The computer simulation assesses averages rather than spikes, but it is the spikes that damage health.

Incidentally, EIA’s for different applications have been found to be remarkably similar, as though each new applicant has copied material from a previous application by another operator in another area ! A Report by Greenpeace in 2001 said: ”Incineration is an unreliable and dangerous technology incapable of being regulated with proper regard to human health and the environment.”

Things have not improved since then: Patrick Sudlow, Greater Manchester Waste Process Controller, in 2009 said: - “The Environment Agency and incinerator operators have proved themselves incapable of supervising the waste management let alone the incinerator.”

In November 2009 Kings College, London Centre for Crime and Justice, reported on the system for regulating air pollution in this country, and came to this conclusion (the emboldened highlights are mine): -

“The existing regime regulating air pollution in the UK lacks neutrality. The penalties imposed for breaching permits are minor in comparison with corporate profits. While such life threatening offences are portrayed as mere exceedances by Government it is difficult to envisage a decline in the harm caused by air pollution….this model fails to capture the deleterious and dangerous effects that air pollution has on human and non-human health and, as such, we should begin to move beyond the rhetoric of exceedance to eco-crime.”

Crime is in the air.

* More information on this is available if required.

In conclusion, I have to say that I think it is a matter of urgency that there should be a thorough investigation into the process by which potentially harmful facilities are given permission to add to an already polluted environment. I would like you please to look into the role played by the Environment Agency in the process of approval in such cases, with particular reference to the Newhaven incinerator. I also think there should be a moratorium on building any more incinerators until some sort of Inquiry has taken place: the harmful effects on health and environment should be given due consideration without further delay.

Could you please let me know how long this investigation is likely to take.

Thank you for your time.

Yours sincerely

Valerie Moffett

Joan Walley, MP,

Chair, Environmental Audit Committee

Room 123/126

7 Millbank