Donnchadh Ó Laoghaire TD Submission to Oral Hearing of an Bord Pleanála Re Indaver application 25-04-2016 A chigire I am grateful to the Board for the opportunity to make a contribution this morning, and for facilitating that. Táim ag glacadh páirt san plé seo ar maidin, os rud é gur mhaith liom cur leis an méid atá ráite agam cheana féin I mo achainí scríofa. I have already made a 7 page submission outlining my firm opposition to this application, for reasons including my parties opposition to incineration as a solution to our waste management generally, but of more particular interest to an Bord Pleanála, the fact that I believe this site and location to be unsuitable. For those who have not had the opportunity to read the submission, I shall be republishing it on my facebook account this afternoon along with this contribution. I will endeavor to avoid repetition, and to speak henceforth on the basis of issues that I did not include in my first submission. Due to being in Dublin for much of the time since the opening day of the hearing, I have been following, to a large extent, the discussions here at the hearing, through local media reportage, and also notes provided online by organisations such as CHASE, for which I am grateful, and I wish to commend media and volunteers for such information. I note with particular concern, the submission made by the department of Defence, which appears to indicate that a no fly zone over Haulbowline during conditions of Southerly winds. The submission makes reference to an Irish Aviation Authority Circular which warns of the danger of overflying chimneys and through exhaust plumes, and a US FAA safety report which recommends permanent restriction from overflying such chimneys. This raises serious concerns, that air craft would not be able to overfly Haulbowline given the Defence Forces and Naval Service personnel on the island, and the possible need for evacuation of the locality. While the Department Submission can speak for itself, I wish to express I share these concerns, the potential implications for the running of a viable naval base at Haulbowline, and the implications for safety of personnel in event of an evacuation. According to Comdt Brown, “This cannot be an acceptable situation for those that work at or visit Haulbowline, nor for the necessary functioning of a fully operational Naval Base therein.” I urge the Board and the Inspector to take this consideration very seriously – it is not common for a Department to express such strong reservations. Sílim go bhfeafdaí go mbeadh bunús, fiú sa méid seo amháin, an iarratas seo a dhiúltiú. I also note that a submission by Lorna Bogue referenced the question whether Sealed Vehicles were to be used to transport bottom ash, which is a question I would also be interested in having answered, having flagged my concern in my written submission on the issue of residual ash. I would also be interested in an answer to this question. I also note what was said by Mr Joe Noonan, among others, at a number of junctures this far, as regards whether this facility would indeed meet the criteria to be considered Energy Recovery. I wish to support the concerns expressed as to whether this criteria has been met, and I note that the initial application did not, so far as I understand it, vouch this claim, and I know that Indaver have since submitted additional documentation on this matter, including correspondences from the 17th and 23rd of this month, regarding energy coefficients.
However, while I am not expert on this area, I note that these figures have been continuously queried and it is the position of many of those objecting that these explanations and figures are not adequate and do not show that the criteria has been met. Indeed I am aware that Cork County Council believe that there is no proof that it qualifies for that status as Energy Recovery and that it has not been satisfied that the R1 status has been met. Má ghlacann an Bord nó an Chigire nách gcomhlíonann sé na riachtanais don stádas sin a bhaint amach, arís silim gur chóir diúltiú leis an iarratas seo. Ar ndóigh baineann seo le cé chomh inbuanaithe is mar a bheadh an suíomh seo, agus an loisceoir seo, agus loisceoireacht go gininéalta. Táim tar éis a rá cheana go bhfuil imní orainn go bhfuil impleachtaí ag loisceoireacht don sláinte, do ainmhithe agus don timpeallacht, ach ó thaobh polasaithe drámháila, tá an ceist ann, an bhfuil seo ag dul I ngleic le polasaithe an AE. In addition, this is relevent also because it cuts to the core of whether this incinerator can be part of a sustainable energy policy in Ireland. I have already outlined in my submission my view that incineration is not sustainable generally speaking, however, if this incinerator does fail to meet the requirements for Energy Recovery, then it is questionable as to whether this incinerator is sustainable for the purposes of domestic and EU sustainable waste policies. The EU supports the idea, for the purposes of waste and generally, a circular economy “where the value of products, materials and resources is maintained in the economy for as long as possible” and waste is minimised. This is often referred to as closing the loop. That is to see that we would “develop a sustainable, low-carbon, resource-efficient and competitive economy”. Being Wise With Waste, a 2010 EU brochure on the future of waste in European society, states that waste management policies, should seek “to reduce the environmental and health impacts of waste and improve Europe’s resource efficiency”: “The long-term goal is to turn Europe into a recycling society, avoiding waste and using unavoidable waste as a resource wherever possible. The aim is to achieve much higher levels of recycling and to minimise the extraction of additional natural resources. Proper waste management is a key element in ensuring resource efficiency and the sustainable growth of European economies.” According to Towards a Circular Economy: A Zero Waste Programme for Europe, a 2014 European Commission document “A better use of resources could represent an overall savings potential of €630billion per year for European industry.” I know that the applicants will tell you that they are also in support of closing the loop, however, if they fail to meet the criteria for Energy Recovery, then it is clearly not going to be a sustainable part of Waste and Energy policy in Ireland To simplify my argument, it is now EU policy that waste is seen as an asset, to be reused so far as possible. If this facility is not producing adequate energy, then it is quite simply, wasting Waste, and therefore not sustainable. The trend in many countries is now away from Incineration for essentially this reason, including countries such as Germany, Holland, Denmark and Belgium, and I know New Zealand was referenced in other submissions as a Country comparable in size, with no incineration and a relatively sustainable waste policy. The issue of flooding has also been flagged by many submissions. I know opinions on both sides have been aired whether there is a flood risk, or a risk from the tide, and I am not an expert, but certainly locals I have spoken to find that from their experience, it is absurd to believe it is not at risk of flooding, either currently, or in time to come with potentially more
extreme weather conditions or tidal erosion. I further emphasis the traffic implications for an already under pressure village in Ringaskiddy, and support the points made by previous speakers that even if there is an appointments system for HGVs, it could lead to queues through the village. Ringaksiddy is already very heavily affected by freight and this application could well exacerbate that substantially. I also note that the N28 is not guaranteed to be delivered in time, particularly in the context of relying on Dunkettle being delivered first, therefore we could be waiting some time for then n28 to be delivered in order for relief from freight traffic in the village. I also want to address the issue of how this site fits within the strategy for Cork Harbour. I said in my written submission that Cork Harbour is one of the most significant assets we in Cork have, and it has seen significant developments in recent years, and there is considerable potential for future positive developments and growth. I referenced the NMCI, IMERC, Beaufort, and the Wave Energy Research Lab There are three masterplans in the immediate vicinity. This was referred to earlier, by Deputies Coveney and Martin. On that note, I think it is not without significance that not only are the community united on this, that hundreds of community organisations schools and clubs are united, but that 55 county Cllrs, all 4 TDs for the constituency, and indeed former TDs such as Jerry Buttimer, and Deputies from Cork East, who are all opposed in the strongest terms. I can think of hardly any other issue locally, regionally or nationally that has seen such unanimity, and this tells itâ€™s own story. Such worthwhile developments include the ongoing development of the NMCI, and IMERC campus including the Beaufort Building and Wave energy research lab. I reemphasise that it would rather perverse to see that an Incinerator, with all the risks, hazards and potential implications for the local environment, would be located almost side by side with a world class research facility examining Wave Energy, with clean, 21 st Century Energy being researched adjacent to an incinerator. In addition Leisure, and I want to add to that point. Cork Harbour is seen by some as a heavy industrial location, and it is true that industry is a key factor in the location, but it is not the heavy dirty industry that once dominated the area. And more and more a cleaner harbour is paving the way for leisure use of our waters. We want to see the day when there is significant maritime traffic, of all sorts of differing sizes of craft, travelling from Camden to Spike to Passage to Blackrock to Cork, and being able to stop at all the piers and marinas available. Given the history in the Harbour and itâ€™s beauty, this has great potential, and a huge economic byproducts for the towns and villages that make up the Harbour. Tourists, whether domestic or otherwise, donâ€™t want to travelling and visiting a harbour, with an enormous incinerator. It will hamper our ability to promote the Harbour as a destination. The possibility of increasing the tourism numbers in the Harbour would surely be
discouraged by the location of a significant, 240,000-tonne-per-annum waste-to-energy incinerator in the locality, it is far from conducive to such activity. All of these developments, are part of the reorientation of Cork Harbour. Its heavy industrial era is passing, and a new future is opening up, that is potentially kinder to the local community, and the Local environment. The location of a Hazardous Waste Incinerator would be potentially be deeply detrimental and damaging to this potential I also want to touch on the issue of the planning process, and while I know that this case will not be decided by that, I think it is important. My party has long taken a critical view of the Planning and Development (Strategic Infrastructure) Act 2006, we believe it potentially railroads projects through, slants the process against local communities and in favour of the developers. It also to a large extent minimises the role of the Council, who are more familiar with the locality. I say that generally, not only in the context of the application at hand. However, it is particular unfair, that this community have had to deal with this unfair process no less than three times now. They have faced huge odds and costs. The effort and cost that might in other areas have gone towards fundraising for GAA club facilities, for Schools, for community facilities, has had to go towards fighting incineration. In fairness to the people of Ringaskiddy they have managed to do all those things also, to their credit, but the effort asked of them has been enormous here. Applicants should not be allowed to use this particular process three times for the same application. In addition, I have expressed my view that it is wrong, and should be taken on board, that much of the documentation relating to the detail of this application, which residents and those opposed wish to deal with, are being hosted on a website run by the applicant, and that is wrong. To sum up, It is my belief that this would be a bad decision for the area, for Cork Harbour, and it is the wrong site, and not only that it would set a very bad planning precedent, to allow this, as it goes against the strategy set out by numerous statutory bodies, it is premature in terms of infrastructure, and would be detrimental to the local environment. Let us make this decision on the basis of the Cork Harbour of the future, not on the Cork Harbour of the past.
Submission to Oral Hearing on Indaver Application