Environment Agency let down Spott residents

Cardiff Stop the Incinerator have obtained the draft decision from the Environment Agency regarding the Splott incinerator.

(todays BBC News -The £150m plant already has planning permission from Cardiff council but is opposed..Last year Cardiff's planning committee decided the proposal would result in "the unsustainable transportation of waste". But the plans were passed last month after Viridor agreed to pay £182,096 towards "transportation infrastructure enhancements" in the city,,sustainable city???...just what we need more roads for rubbish lorries!!!)

We have begun assessing this draft decision, which we are disappointed to read states that the EA is "minded to" grant an environmental permit to the incinerator. On initial examination it is clear to us that the Environment Agency's draft decision has been written based on outdated and incomplete information.

Most seriously, we note the discussion of the incinerator's effect on air quality management areas (page 46). The EA considers the impact of the incinerator only on the St Mary Street Air Quality Management Area (AQMA), and asserts "that the Newport Road and Philog AQMA’s are no longer necessary". The EA has failed to take note of the fact that in 2010 an AQMA was re-declared for Newport Road, and also ignores the declaration of the AQMA in Stephenson Court.(1) We believe these omissions invalidate the Environment Agency's recommendation in its entirety. Furthermore we observe that as the EA was still considering evidence from incinerator company Viridor Waste Management at least as late as 12 May 2010 (page 50), the EA's failure to consider current enviromental issues in Cardiff shows a failure on its part to put local and environmental concerns ahead of business concerns. The Environment Agency promised at the beginning of the public consultation process that "EPR [Environmental Permitting Regulations] permits are living documents and they can be varied during their life as new information or technology becomes available."(2) We sincerely hope the EA will live up to its word.

We are also dismayed to read the Environment Agency's failure to consider overwhelming preponderance of scientific evidence regarding the carcinogenicity of waste incinerators. In reviewing the existing guidance on the health effects of incinerators (page 52), the EA cite only a single study, the Small Area Health Statistics Unit's (SAHSU) examination in 1993-1994 of the waste effects of incinerators. While this one study did give an inconclusive result, the EA ignores seven newer studies which all show a clear link between waste incinerators and cancers such as non-Hodgkin's lymphoma, liver cancer and breast cancer, both in adults and in children.(3)

In addition we note that the EA cites in support of its conclusion the position of the Department for Environment Food and Rural Affairs (DEFRA)(4) and the Health Protection Agency statements in 2005 and 2009(5) regarding waste incineration (page 54). The DEFRA and HPA documents cited draw their positions from the same single SAHSU study; in effect, the EA cites the same government-funded study four times. The EA presents a misleading picture of the evidence linking incinerators with cancer, and while we do not assert that this misrepresentation is deliberate, it is nonetheless irresponsible and verges on the abuse of science for political gain.

Finally we call attention to the EA's admission of the scantness of its public consultation (pages 91-100). The Environment Agency notes a total of 26 people attending its two public consultations. Since then, the EA has admitted it is unable to adequately consult residents regarding decisions(6). We furthermore note that in the space of less than two months, dozens of local residents have taken part in public meetings and protests against the incinerator, and hundreds have lent their signature to our petitions opposing the incinerator and calling for a greener alternative.

We sympathise with EA spokeperson Dr Norman Allan's concerns(7) that funding cutbacks are partly to blame for the failure of the EA to perform its mission to a sufficient standard. Only with adequate public funding and constant democratic review can an important body such as the Environment Agency carry out its important tasks of defending the interests of the working people of Britain.

The complete draft decision is available online at http://www.environment-agency.gov.uk/static/documents/Research/LP3030XA_CardiffEfW_DraftDD_For_Consultation.pdf.

Cardiff Stop the Incinerator continues to urge all residents of Cardiff to attend our public meeting on 27 July, 7pm in the STAR Centre, Splott in preparation for the EA's public consultation on 30 July. The Environment Agency has reached an incorrect conclusion based on flawed data. We will continue to fight against the incinerator and in defence of the people of Cardiff, whether this means opposing Cardiff Council, the Environment Agency, the Welsh Assembly, or the gods themselves.

Edmund Schluessel

Cardiff Stop the Incinerator

(1) The Stephenson Court AQMA was recommended in the document , available online at http://www.cardiff.gov.uk/objview.asp?Object_ID=17256&. The Newport Road AQMA was declared in early June 2010 and is discussed in the article "Fumes 'risk' to Residents" by Ed Walker, South Wales Echo, 10 June 2010, available online at http://www.walesonline.co.uk/news/wales-news/2010/06/10/fumes-risk-to-residents-91466-26620354/

(2) Agency response from public surgery held 15 June 2009. Cited on page 91 of the draft decision.

(3) For completeness we cite those studies:

Comba, P. et al. "Risk of soft tissue sarcomas and residence in the neighbourhood of an incinerator of industrial wastes". Occup Environ Med 2003;60:680-683

Floret, N. et al. "Dioxin Emissions from a Solid Waste Incinerator and Risk of Non-Hodgkin Lymphoma". Epidemiology 2003;14;4;392-398

Knox, E. "Childhood cancers, birthplaces, incinerators and landfill sites". International Journal of Epidemiology 2000;29:391-397

Viel, J-F et al. "Soft-Tissue Sarcoma and Non-Hodgkin's Lymphoma Clusters around a Municipal Solid Waste Incinerator with High Dioxin Emission Levels". American Journal of Epidemiology Vol. 152, No. 1 : 13-19

Viel, J-F et al. "Dioxin emissions from a municipal solid waste incinerator and risk of invasive breast cancer: a population-based case-control study with GIS-derived exposure". International Journal of Health Geographics 2008, 7:4

Viel, J-F et al. "Risk for non Hodgkin’s lymphoma in the vicinity of French municipal solid waste incinerators" Environmental Health 2008, 7:51

Zambon, P. et al. "Sarcoma risk and dioxin emissions from incinerators and industrial plants: a population-based case-control study (Italy)" Environmental Health 2007, 6:19

(4) "Review of Environmental and Health Effects of Waste Management: Municipal Solid Waste and Similar Wastes", published by DEFRA in 2004.

(5) The more recent of these is "The Impact on Health of Emissions to Air from Municipal Waste Incinerators", first published by the HPA in September 2009.

(6) "Splott incinerator consultation 'not good enough,' say councillors", Hannah Waldram, Guardian Local, 6 July 2010, available online at http://www.guardian.co.uk/cardiff/2010/jul/06/splott-incinerator-viridor-environment-agency



(7) ibid.