The choice of thermal treatment is based on outdated, arbitrary criteria

Viz Originally it was given that all waste arising within Dublin City and County must be disposed of within the county border, because Dublin City and County was designated as one region for waste purposes (actually did these regions correspond to the regional borders for drawing down the EU6bn?). This designation was removed soon after the Waste Plan was adopted, with the whole country being one Waste Management region. So whereas originally the consultants discounted landfill of residual waste, saying there were no sites in Dublin, this became irrelevant.

Therefore a feasibility study of alternatives to thermal treatment was never conducted.

Specifically, the opportunity costs of landfill, or any of the other non-incineration technologies vs thermal treatment, was never carried out. A cost/benefit comparison was never made. Incineration is a very expensive technology whereas, even a high-spec landfill is cheaper. I always felt that the option of transport by rail, which would allow distributed collection along the track, instead of concentrating all the waste at one point, would be a good option for Dublin (it is done in the UK). Unlike Holland, Denmark, etc, we have plenty of land, cutaway bog, for example, which has no agricultural or ecological use, because it has been already stripped bare, would have been worth investigating.

Many Councillors were misled during ratification of Dublin Waste Plan

(a) Other Councillors (the Green Party voted against) thought that what they were voting for was to look at the feasibility of thermal treatment compared with the feasibility for other options - not to investigate if it was feasible to build an incinerator without just anyone stopping them through legal channels.

(b) Councillors were told that incineration was one of a number of thermal treatment options being examined. But in the small print of the engineering reports, it was clear that the other technologies had already been discounted, as the technology was unproven.

The site chosen is not most suitable

(a) Originally, the only criterion used to select a site was the zoning in the four Dublin Development Plans, although mass-burn incineration was not considered when those plans were being drawn up. All four plans had different criteria for deciding whether incineration was allowed. Thus Poolbeg was chosen because it was zoned for industrial use (actually, historically this zoning came from use as a port) and because, under Dublin City rules, incineration was allowed in industrial zoing. It was not chosen because it was the most suitable site for an incinerator.

(b) In the original Waste Plan Strategy reports, the Engineering volume recommended that  the incinerator be sited along the Orbital Motorway (M25?), because some heavy industry is located there and there is the potential for using the waste heat from incineration as process heat in industry.

(c) There was no analysis of the flows of bulk materials. For example, it makes sense to site sewage treatment at the Bay because the water is going into the sea. However the proposal is to move all the waste to Dublin Port, and then truck all the ash back out of Dublin Port. It would  make more sense to use the port for gathering materials like plastics that will be exported. An incinerator does not have to be in a port. [Also we don’t have any standards for use of bottom ash in construction]. Also why generate toxic waste (flyash/filtercake) if you don’t have to?

(c) There was no discussion of odour and heat pollution in Dublin Bay, which should have been given considered in light of the odour pollution caused by the waste water treatment plant.

Greenhouse gas emissions

(a) There is already an enormous amount of waste heat from the various power stations near the site, for which there is no market at present, and which could easily satisfy any requirement for district heating should Poolbeg be developed for domestic or commercial use.

(b) As a means of producing electricity, it must be the most carbon-intensive technology going. Ireland has loads of options for renewable energy and more efficient use.

(c) There are various clean Waste to-Energy technologies, notably anaerobic digestion of putriscible waste, and the use of tree and hedge trimmings in wood-burning stoves. A feasibility study of using refuse-derived fuel in peat-burning stations was not carried out.

(d) An incinerator with a fixed rate of  consumption, removes any incentive to further reduce waste volumes. Recycling is in its infancy here; it takes a few years to change the culture; Most households do not even have brown bins yet. There is absolutely no enforcement of source-segregation.. Recycling and reuse saves more energy than generating loads of unwanted expensive rubbish and burning it.

(e) With extensive recycling, possible anaerobic digestion as pre-treatment of waste and use of landfill gas to generate electricity at the landfill, the greenhouse-gas harm caused by old-style landfills can be avoided.

‘Centrally-located, for transport purposes’ - a nonsense

At one of the public consultation sessions I asked whether the Roads and Traffic Dept had been consulted in choosing the site and the answer was no. I do not believe that Poolbeg is a central location as regards road access. Sean Moore road and all the nearby roads have chronic traffic problems. In the Siting Study, there should have at least been some quantitative comparison of candidate sites, some measure of truck-miles, truck-hours or something, with and without baling stations. To choose a site on some vague statement that it is ‘central’ without such quantitative analysis is a thundering disgrace. Train freight would be much more sustainable, and this is an important consideration for the future. Also, it is very unlikely that the Eastern Bypass will ever be built, and so this should not come into the equation.

Human considerations

There is always the potential for accidents. Why site an incinerator in the middle of a population centre if it is not necessary? Even Dutch incinerators often exceed their target emission limits. In Holland, the municipality is responsible for monitoring. We have no culture of enforcing standards. If there is a problem with emissions it won’t be detected for a long time and then unlikely to be acted upon. No safe level of Dioxin emissions. Dioxins cause sterility,- a heartbreak. Dioxins accumulate in the food chain. Our Brent geese should be protected from the eventual poisioning of their food (top of food chain like extinct birds of prey)

Dublin Bay is the jewel in the crown of the environs of Dublin. It is where people go for a bit of wilderness, to get away from it all, enhanced by the Brent Geese. In Holland one of the incinerators we saw (both were absolutely enormous in size) was hidden by trees until we were beside. Dublin Bay is the focal point of many views and a whopper of a building here will change the scale of Dublin Bay and stick out like a sore thumb. A bit like storing your rubbish bins in the middle of your sitting-room.