5 Questions for Dublin City Manager on Poolbeg Incinerator plans

With the Dail’s public accounts Committee putting some difficult questions to the Dublin City Council’s representatives on Jan 22nd 2014 we feel there is more to be probed than simply the gigantic overspend of taxpayers money on the planning phase.

We think that Dublin City Council has serious questions to answer on the Poolbeg incinerator farce. We already know that they illegally extended a contract with RPS, and the High Court found that they had illegally attempted to prop up the collapsing incinerator project by forcing private waste collectors to use it. The Dail’s Public Accounts Committee needs to investigate deeply why they agreed to take on Covanta as a private partner without re-opening the tender process. They also need to ask why they signed the agreement with Covanta during the 2007 general election campaign when

no government was in place.

As the committee convenes to scrutinize the City Council’s spending frenzy we have some pertinent questions to pose ourselves:

Q.1. Health Impacts.

Present safety measures are designed to avoid acute toxic effects in the immediate neighbourhood, but ignore the fact that many of the pollutants bioaccumulate, can enter the food chain and can cause chronic illnesses over time and over a much wider geographical area. No official attempts have been made to assess the effects of emissions on long-term health.

Is there a baseline health study planned for residents in the downwind locations? Will there be a health monitoring programme over the lifetime of this facility? Who will conduct this?

Q2. Fly Ash disposal.

Incinerators produce bottom and fly ash which represent 30-50% by volume of the original waste (if compacted), requiring transportation to landfill sites. Abatement equipment in modern incinerators merely transfers the toxic load, notably that of dioxins and heavy metals, from airborne emissions to the fly ash. This fly ash is light, readily windborne and mostly of low particle size. It represents a considerable and poorly understood health hazard. This is a hazardous material and must be disposed of in a class 1 landfill site.

What are the arrangements in place to deal with the bottom ash and fly ash? Where will it be stored and how will it be transported and through what areas and in what conditions?

Q3. Air Pollution monitoring.

Monitoring of incinerators has been unsatisfactory in the lack of rigor, the infrequency of monitoring, the small number of compounds measured, the levels deemed acceptable, and the absence of biological monitoring. Approval of new installations has depended on modelling data, supposed to be scientific measures of safety, even though the method used has no more than a 30% accuracy and ignores the important problem of secondary particulates.

Can you outline the monitoring regime that will be in place and the measures planned to deal with excessive emissions or those found to be above the safe limits for Dioxins and Furans bearing in mind the length of time to test the samples taken and provide results?

What community alert system will be in place to warn residents of breaches in real time?

Q4. Pops and Ireland’s Stockholm commitments.

The Stockholm Convention came into force on 17th May 2004 –

Ireland ratified the Stockholm Convention on 5th August 2010 –

The Stockholm Convention entered us into force in Ireland on 3rd November 2010.

There are a few elements of the treaty that are worth bearing in mind…..

Article 1 of Stockholm Convention


Mindful of the precautionary approach as set forth in Principle 15 of the Rio Declaration on Environment and Development, the objective of this Convention is to protect human health and the environment from persistent organic pollutants.

Article 5 of Stockholm Convention

Measures to reduce or eliminate releases from unintentional production.

Each Party shall at a minimum take the following measures to reduce the total releases derived from anthropogenic sources of each of the chemicals listed in Annex C, with the goal of their continuing minimization and, where feasible, ultimate elimination:


(c) Promote the development and, where it deems appropriate, require the use of substitute or modified materials, products and processes to prevent the formation and release of the chemicals listed in Annex C [dioxins and furans], taking into consideration the general guidance on prevention and release reduction measures in Annex C…

As our Government Commitment and policy since 2010 is to implement the Stockholm Convention and reduce POPs how does Dublin City Council’s plan to commit to 600,000 tonne per annum of waste to the Incinerator Company and hence cause extra POPs to be produced align with our obligations under the Stockholm Convention to give primary consideration to alternative process to deal with waste such as recycling and waste reduction which will not produce new POP sources?

What consideration of alternative methods has been taken?

Is this contract to supply 600,000 tonnes of waste to the incinerator not a failure to give primary consideration to substitute processes such as recycling that would avoid the release of POP’s from incinerators?

How can Dublin City Council’s plan to commit to waste incineration and hence produce new sources of POPs be compatible with our commitments under Stockholm?


Incinerators presently contravene basic human rights as stated by the United Nations Commission on Human Rights, in particular the Right to Life under the European Human Rights Convention, but also the Stockholm Convention and the Environmental Protection Act of 1990. The foetus, infant and child are most at risk from incinerator emissions: their rights are therefore being ignored and violated, which is not in keeping with the concept of a just society. Nor is the present policy of locating incinerators in deprived areas where their health effects will be maximal.

How can Dublin City Council comply with our obligations under the European Human Rights Convention?