Open letter to the Environment Minister

An Open letter to Mark H Durkan,  Minister for the Environment

Thursday 7th November 2013

Zero Waste NW welcomes the recent withdrawal of the proposed Planning Bill for NI by Minister of the Environment Mark H Durkan because of planning and human rights concerns.

To give further time for consideration of the environmental and human rights issues around waste management, we ask the minister to postpone publication of the revised NI Waste Management Strategy ‘Delivering Resource Efficiency’.

People in the NW of Northern Ireland have twice in recent decades made clear their opposition to the incineration of waste. Instead they have been actively involved in separating and recycling and there are probably few places in the world where the citizens have occupied recycling depots which were threatened with closure! However, when the draft Waste Management Strategy ‘Delivering Resource Efficiency’ was open for consultation from 26 Oct 2012 to 18 Jan 2013, most people in the NW were unaware that waste was a major planning and human rights issue.

It was only in January 2013 that the DOE notified the public about planning permission for an Energy from Waste facility (gasification plant) in Strathfoyle, outside Derry and then, seriously concerned about the environmental and human health impact of such a facility, a group of citizens formed Zero Waste NW and started researching waste management models.

We now ask Minister Durkan to consider these points:

  • Energy from Waste as proposed in ‘Delivering Resource Efficiency’, is at the bottom of the Waste Framework Directive hierarchy (EU 2008).
  • Investing £500 million and signing a 25 year contract for the plant creates a market for waste and undermines targets for recycling and waste prevention which are at the top of the hierarchy.
  • NW Region Waste Management Group statistics indicate that the proposed Energy from Waste plant has a capacity greater than the waste produced in their seven council areas and they are proposing transporting waste in from other areas. This contravenes the Proximity Principle (‘treating or disposing of waste as close as possible to the point of generation to minimize the environmental impact’); increases carbon emissions from road (and possibly shipping) transport and presents the scenario of the NW becoming the dumping ground of NI.
  • £500 million to create 40 jobs is not cost effective. Zero Waste systems create at least ten times more jobs than current waste management systems.
  • Energy recovery from waste is not cost effective. ‘Incineration is an inefficient way to produce energy: energy recovery from waste incineration is lower than energy savings derived from waste recycling. For most of the materials that compose waste, recycling saves more energy than is generated by incinerating mixed solid waste in an incineration facility’ (Morris 1996 and 2008; EPA 2012 quoted in Incineration overcapacity and waste shipping in Europe:the end of the Proximity Principle?).

Zero Waste NW is seriously concerned about the environmental and human health impacts of the proposed energy from waste plant. A 2009 FOE (Friends of the Earth) report states that there are considerable uncertainties about these plants and that much of the data comes from the individual companies – ‘it is often unclear what emissions will be involved, and what sort of ash or other residue will be produced’.
Friends of the Earth (for further information see appendix)

In 2011 when the DOE made the decision to carry out a ‘recast plus’ of the 2006 Waste Management Strategy rather than a ‘fundamental review … along the lines of so-called zero waste strategies’, there was little public awareness of the issues involved. Now that we citizens are rapidly informing ourselves, we want to be involved in the decision making processes for designing community led separation and resource recovery systems.

Zero Waste NW asks Minister Durkan to meet with us and with experts already managing Zero Waste systems in Wales and Scotland. We are confident that Northern Ireland can work towards and achieve Zero Waste, thereby ending the burying and burning of resources, decreasing carbon emissions and creating sustainable jobs.

‘If you are not for zero waste, how much waste are you for?’  Zero Waste Alliance Europe

Appendix

  1. Under EU legislation, energy from waste is classified as co-incineration and regulated in the same way as other types of incineration:
      • Co-incineration plant: any stationary or mobile plant whose main purpose is the generation of energy or production of material products and:
      • which uses wastes as a regular or additional fuel;
      • or in which waste is thermally treated for the purpose of disposal‘.
        Directive 2000/76/EC of the European Parliament and of the Council of 4 December 2000 on the incineration of waste.
  2. The 2008 Report of the British Society for Ecological Medicine highlights ‘the very high release of dioxins that arise during start-up and shut-down of incinerators….Of equal concern is the likelihood that these dangerously high emissions will not be detected by present monitoring systems for dioxins’.
  3. The World Health Organisation factsheet ‘Dioxins and their effects on human health states –Dioxins are highly toxic and can cause reproductive and developmental problems, damage the immune system, interfere with hormones and also cause cancer. Prevention or reduction of human exposure is best done via source-directed measures ie. strict control of industrial processes to reduce formation of dioxins as much as possible.
  4. The Stockholm Convention for the elimination of dioxins (where possible) is incorporated into European Law. Its regulations require that ‘priority consideration’ should be given to processes which do not generate persistent organic pollutants including dioxins. HMSO, The Persistent Organic Pollutants Regulations 2007 Statutory Instrument 2007 No 3106