Thursday, November 20, 2008

SUBMISSION TO AN BORD PLEANALA BY RATHCOOLE HERITAGE SOCIETY

The Rathcoole Heritage Society has many concerns regarding the proposed Waste Incinerator at Behan’s Quarry, Rathcoole. As we know, Heritage is an important part of people’s lives, giving individuals and communities a sense of identity and belonging and bestowing on them a sense of place to their surroundings. This heritage can easily be damaged by pollution – acid rain pollution, dust pollution, noise pollution, odour pollution and visual pollution.

The Windmill

The old windmill on Windmill Hill is situated only 35m from the perimeter of the proposed Waste Incinerator development site. As it is overlooking this site it is visible for many miles around. This Windmill is listed in the Record of Monuments and Places and The Record for Protected Structures (South Dublin County Council Development Plan 2004-2010).
Nobody knows exactly how old the Windmill is but it is of the same type of structure as of tower houses of the thirteenth and fourteenth centuries. As there were many mills built on the abundant number of rivers in the area, some historians suggest that the Windmill was used as a beacon by the settlers in The Pale to warn off possible raids from the native Irish.
Windmill Hill has figured in various records and stories throughout the years. The historian, Liam O’Broin found a reference that an execution took place there in 1641.
Speaking to local historian in Rathcoole, 87 year-old Mary Mc Nally, she told me that The Windmill building was used during the Penal Times by priests on the run to conduct Marriages and indeed, Baptisms. She speaks of one particular Jesuit priest, Fr. Warde who, after conducting a marriage ceremony there in 1743, was caught by ‘The Priest Catchers’ and hanged on the spot. The couple who were married were a Patrick Sheil from Valleymount , Co. Wicklow and a local young widow, Ms Bermingham. Patrick Sheil actually was Mary Mc Nally's Great Great Great Grandfather. It was unusual at the time for a man who lived so far away as Valleymount meeting and marrying a young lady from Rathcoole. Mary tells me that her ancestor, Patrick Sheil, grazed sheep on Ms Bermingham’s land during the Winter and this was how they met and got married. In 1916, people climbed Windmill Hill to see Dublin burning. Later locals to watch fireworks on the Liffey used it and to view air shows in The Phoenix Park and in Baldonnel.

So much for the History lesson…

Senior archeologist Gary Conboy prepared an Archeological and Cultural Heritage Assessment of Windmill Hill and the proposed site for a Waste Incinerator. He states that battering of the quarry face, approx. 40m from the Windmill will not damage the structure of the Monument. How does he know this? Surely this is a conclusion that can only be made by a qualified structural engineer? I studied archeology many years ago in UCD but I do not remember structural engineering to be part of the course. He continues, “In the opinion of the air emissions consultant, dust emissions from the stack will be insignificant and soiling of the building insignificant; the level of acid deposited on the structure is not ‘expected ‘ (in other words ,they do not know) to be significant due to the low concentrations.” Who is this air emission consultant? He does not give his name. Mr. Conboy states that Archeological monitoring and supervision of the windmill structure will be undertaken during all phases of construction. He does not say who is going to do it - nor is there any specification whatsoever included in the Report.

The Dublin Regional Authority's submission to the Bord includes very detailed information from their expert who travelled to Energy Answers sister Waste Incinerator plant in the USA. Their report has many disturbing and alarming facts including regular fires and explosions occurring there. Firefighters spent 18 hours extinguishing one fire there recently and photographs show massive clouds of black, toxic, poisonous clouds of smoke sprawling over a very large area. Chemicals and acids from such a fire would not be not be low density – the Windmill would suffer greatly - visually and structurally – not mentioning the fact that people would be evacuated from their homes and the nearby N7 would be closed for at least 24 hours.
This Archeological Report does not make one reference to The SDCC Development Plan 2004-2010. Mr. Conboy makes recommendations and proposals but nothing agreed re the Archeological Monitoring of Windmill. Monitoring of the Windmill site has never been carried out before - not even during blasting of quarry. There are no solid agreements in his report about who is going to do the monitoring.

There are 2 Peregrine Falcons nesting in the Quarry. They are the fastest animal in the world – can reach speeds of up to 200mph or 320 kmph. Peregrine populations were severely affected by the widespread use of pesticides like DDT in the 50’s and 60’s. Since 1970 the ban on these pesticides has allowed the peregrine falcons to slowly recover. They are now listed as an an endangered species. Although they have survived nesting in the quarry, Rosaleen Dwyer, Heritage Officer with the SDCC, told me that odours and dioxins will most likely force them to leave. This is apart from the battering of the quarry face where they nest. And of course if one of the frequent fires or explosions occur, (which is most likely) not alone are the peregrine falcons in danger but so are wild life for miles around. Regarding odours, The Dublin Authority report states that despite repeated complaints from neighbours of Energy Answers Plant in The USA and despite repeated efforts to subdue those odours, Energy Answers have not yet invented any method to do so. The odours persist. It must be noted that Peregrine Falcons mate for life and Irish Peregrines tend to nest in the same place year on year. An Incinerator in Behan’s Quarry would certainly be a big threat to this endangered species.

Finally, I wish to draw the attention of the Board to the fact that the proposed development is located within the catchment area of the River Griffeen. The source of the Griffeen river is high above in Rathcoole Hill. It flows alongside the Kilteel Road and then crosses under the N 7. A stream which flows alongside the proposed Waste Incinerator site empties into the Griffeen river at the N7 and then the river flows on to the centre of Lucan village where it joins up with the River Liffey. The submission from the Eastern Regional Fisheries Board states that the Griffeen system is exceptional among most urban river systems in the area, supporting migratory sea trout in the lower stretches and resident brown trout throughout.
Monitoring of the surface water after it has left the pond does not provide adequate safeguard to the receiving watercourse. Surface water from Truck wash will most likely contain detergents.
The Foul Water Treatment system is a pumped system. What happens if the pumps fail?
There is a strong suggestion here that waste water from the Waste Incinerator Site would contaminate the Griffeen River. The River Liffey is an established and well-known salmon fishing river – any contamination from a Waste Incinerator would be a disaster.
Our historian, Mary Mc Nally told me that when she was a young girl a special treat would be to be brought down to the Griffeen River and ‘Goodly’ the trout from the river, that is, catching them with their bare hands. I am afraid there would no more ‘Goodlying ‘ if a Waste Incinerator were built in Behan’s Quarry. Members of An Bord Pleanala, there are many reasons why Rathcoole is the worst possible site for a Waste Incinerator. And For the sake of our Heritage and Wild life alone, my plea is to reject this application.

Liam Mc Dermott
Chairperson, Rathcoole Heritage Society.
Also PRO for RAID
Ph: 087 6695390

1 comment:

The Galway Tent said...

Comments below apply to Rathcoole and to Poolbeg Waste-To-Toxins incinerators.

Incinerator to cost 100,000 man-years of life.
June 2008
It seems a Dublin Bay Incinerator at Poolbeg would cost at least 100,000 man-years of life.

This is for the first 15 years,
for Dublin's population of 1 million.

Basis: Estimates by British Society for Ecological Medicine
using World Health Organisation Air Quality Guidelines
_______________________

American's will live up to 2 years longer than Europeans,
- due to air quality standards.
Basis: European Respiratory Society.
_______________________


OPINION
An incinerator is basically a deadly particles generator. Dublin City Council has spent €19 million to promote its cynical one-sided case for the Dublin Bay Incinerator at Poolbeg. Apparently there has been a total omission of the health impacts - apart from spin such as 'you can not prove that'. This is the tobacco industry defence, an example of The Big Lie.

Below is an an extract about reduced life expectancy due to deadly particles - it's from a credible medical society. The full PDF file of 70 pages is at the indicated URL. Read it to make your own judgements. The Cork Harbour Alliance for a Safe Environment (CHASE) has other useful information. CHASE was given a legal bill of €50,000 today, in contrast to the €19,000,000 of your money given to DCC. George Bush would call that Fair & Balanced.
__________________________________________

SCIENCE
http://www.ecomed.org.uk/content/IncineratorReport_v2.pdf%20page%2015/16.


Assessment by the WHO and Other Authorities

Based on the World Health Organisation Air Quality Guidelines the British Society for Ecological Medicine has estimated that a 1μg per cubic metre increase in PM2.5 particulates (a very conservative estimate of the level of increase that would be expected around large incinerators) would lead to a reduced life expectancy of 40 days per person over 15 years (this equals a reduction of life expectancy of 1.1 years for each 10μg per cubic metre increase in PM2.5 particulates).

Although this figure appears small they note that the public health implications are large and the effect on a typical population of 250,000 surrounding an incinerator would be a loss of 27,500 years of life over a 15 year time period.

This figure gives an indication of the likely loss of life from any major source of PM2.5 particulates. In addition, incinerators normally operate for much longer periods than the 15 years quoted here. Note that the estimated loss of life here is likely to be an underestimate as it is from particulates alone and not from other toxic substances.

American's will live up to 2 years longer than Europeans [Heading Inserted here].
The European Respiratory Society has published its concern about the mismatch between European Union policy and the best scientific evidence. They state that a reduction in the yearly average PM2.5 particulates to 15μg per cubic metre(*) would result in life expectancy gains, at age 30, of between 1 month and 2 years.

They point out that the benefits of implementing stringent air pollution legislation would outweigh the costs. These recommendations are sensible and based on sound science. A programme of building incinerators would unfortunately achieve the opposite: they would increase particulate pollution, reduce life expectancy and would be at odds with the best science.

Statements by leading researchers include the following: “the magnitude of the association between fine particles and mortality suggests that controlling fine particles would result in saving thousands of early deaths each year” (Schwartz) and “there is consistent evidence that fine particulates are associated with increased all cause, cardiac and respiratory mortality. These findings strengthen the case for controlling the levels of respiratory particulates in outdoor air”
________________________________________________________

American's will live up to 2 years longer than Europeans.
Californians even longer.
Chart Submitted to EPA-Ireland Oral Hearing, April 2008.


* The National Ambient Air Quality Standard for PM 2.5 particulates was introduced into the USA in 1997 with a mean annual limit of 15μg per cubic metre. This had measurable health benefits.

An annual mean limit for PM 2.5 particulates is to be introduced into Scotland in 2010 and this will be 12μg per cubic metre. An annual mean target for PM 2.5 particulates is to be introduced into the UK in 2020 and this will be will be 25μg per cubic metre. Many will wonder why the difference is so vast when the science is the same.

http://galwaytent.blogspot.com/2008/11/incinerator-would-cost-at-least-27500.html