04 Dec

Platin Cement Burner- Skyfill is a bad idea.


Nov 2017 Submission to ABP Platin 

PLATIN: We’re concerned that this project will stop us recycling

Phosphorus and Nitrogen are needed to grow food , not burn as Fuel for Cement kilns.

Zero Waste Alliance Ireland (ZWAI) are very concerned at the use of recyclable materials as Refuse Derived Fuel (RDF). We know that this is a dangerous manner of turning Landfill materials into Skyfill pollution. Cement kilns are not designed to manage in an environmentally safe manner the pollutants that arise from the burning of a mix of recyclable and landfill bound materials. We have objected to An Bord Pleanala when such BAD IDEAS are proposed, most recently in Limerick and Duleek.

We made an additional Oral Submission to the Inspector of
An Board Pleanála  on the 22nd November 2017 in regard to  the  Platin Cement Proposal. It is a 10 year permission to facilitate further replacement of fossil fuel with alternative fuels  (RDF) and allow for introduction of alternative raw materials in the manufacturing of cement at Platin Works Platin, Duleek, Co Meath

ZWAI are an advocacy group promoting ways to recycle & recover materials and keep resources away from waste disposal so that they can be sustainably recycled. We are  particularly concerned about materials that are finite or are limited in their natural availability. So naturally, we question the wisdom of burning materials at the Platin Cement Kiln that in particular contain phosphorus and nitrogen.

You can read our Oral Hearing submission here.

Valuable Nutrients are lost.

The waste categories listed by Irish Cement  below are proposed to be incinerated in the cement kiln. Initially almost all of these originally required the use of Natural Gas or Coal to make the ammonia fraction of fertilizer for their growth. By burning in a cement kiln, Phosphorus will be wasted and will not be recovered. This is an essential element that is necessary for fertilizer to produce food.

Categories of waste that are proposed to be burned at Platin cement factory


02 01 02


animal-tissue waste

19 08 05

sludges from treatment of urban waste water

02 01 03

plant-tissue waste

02 01 06

animal faeces, urine and manure (including spoiled straw), effluent, collected separately and treated off-site

19 12 06

sludges from on-site effluent treatment other than those mentioned in 19 11 05

02 03 05

sludges from on-site effluent treatment

19 08 05

sludges from treatment of urban waste water

19 08 12

sludges from biological treatment of industrial waste water other than those mentioned in 19 08 11

19 08 14

sludges from other treatment of industrial waste water other than those mentioned in 19 08 13

Zero Waste Alliance Ireland(ZWAI) demands that Sewage Sludge or any of the other similar categories listed by “Irish Cement” that contain Nitrogen and Phosphorus should not be burned in the cement kiln for the following reasons:

  1. The Fossil Fuels (Natural Gas and Coal) that are used to make ammonia gas for fertilizer are finite and will eventually be depleted. We must reduce significantly the greenhouse gas emissions associated with the making of ammonia fertilizer. Any finite material must instead be recycled.
  2. The Burning of Nitrogen (Ammonia) and its loss to the atmosphere results in this resource being no longer available to farmers as part of the fertilizer to grow food.
  3. The emission of NOx will cause ozone in sunlight conditions. At ground levels ozone will cause ambient air pollution and should therefore be avoided.
  4. The energy of the Nitrogen (Ammonia) recovered in the Cement Kiln will not replace or be equal to the total energy required for its original manufacture, its processing as an NPK fertilizer, its transport around the world or the energy for its application on farms.
  5. Because the nitrogen is not being recycled locally to grow food it forces the continuation of this very wasteful energy intensive Harber & Bosch method that is depleting the remaining finite resources of natural gas. This failure to recycle nitrogenous waste as a fertilizer is not sustainable.
  6. The Green House gases that are generated by the manufacturing of Ammonia using the Haber & Bosch process contribute to climate change and must be reduced and eventually avoided.
  7. Phosphorus fertilizer is likely to become expensive in Europe, India and other parts of the world over the coming 20 to 40 years as the resources of the USA and China, two of the three remaining countries with phosphorus rock begin to protect their own national supplies. When “peak phosphorus” is upon us and world demand is greater than the supply then no nation will have cheap phosphorus to sell to Ireland. Unless we recycle nutrients of nitrogen and phosphorus, food prices in supermarkets that are based on fossil fuel and mined phosphorus fertilizer will become volatile, then more expensive, then affordable and eventually will not be for sale at all.
  8. Phosphorus is a finite resource that can be replaced by no other element. If burned in cement kilns this strategically important resource will be lost and wasted forever.
    We must therefore recycle Nitrogen and Phosphorus. We must avoid the possibility of a world population collapse.

We ask  An Board Pleanála to prioritize the long term public interest and put this above the private short term interests of a private business. It is not in the public interest that we should ignore the need for future food security.

23 May

Big burners – application is back for Ringaskiddy Incinerator


Ringaskiddy Incinerator Proposal – wrong place, wrong time, wrong solution.

There’s more than a whiff of toxic smoke from this project –

( Application to An Bord Pleanála by Indaver Ireland Limited for Planning Permission for a
Proposed  Incinerator at Ringaskiddy, County Cork An Bord Pleanála Reference PL04.PA0045) –

and the arrogance exhibited by both an Bord Pleanala, the EPA and the Co Co Council Executive Management.

Whiff of  suspicious smoke.

Firstly An Bord Pleanála refused to defer an oral hearing into a proposed €160 million (240,000 tonne  Hazardous and municipal waste) incinerator for Ringaskiddy, Cork Harbour which was needed to allow the opponents time to examine the large application and associated documents.

One of the 260 objectors, Cork Harbour Alliance for a Safe Environment (Chase) said Bord Pleanála had refused an extension to the oral hearing start date , leaving just 12 working days to prepare objecions against the proposed Ringaskiddy Incinerator.

This preparation period of just 12 working days was in stark contrast with the consultation period of over 3½ years which the applicant, Indaver,  have had with An Bord Pleanála to prepare this third planning application on the same site.

This must be the  shortest oral hearing notice and the longest consultation period on record for such a dangerous proposal.

Secondly, the haste at which the Ringaskiddy proposed Incinerator proceedings were transacted gave rise to concerns among the attendees that this might be a ‘foregone conclusion’ and the Board was merely paying lip service to the oral hearing and inspectors efforts to examine the proposal’s implications. A notable absentee was the EPA, normally a essential player in such applications.


Overwhelming support for opponents.

An Bord Pleanála received over 260 submissions objecting to the planned Ringaskiddy incinerator including objections from all four Cork South Central TDs including Minister for Agriculture, Simon Coveney, andFianna Fáil leader, Micheál Martin.

These submissions, among which Zero Waste Alliance Ireland, contributed a 28 page objection,  included objections because of site unsuitability, accident risk and hazard, health concerns and gross conflict with the regeneration of the surrounding area, include submissions from the Permanent Defence Force Other Ranks Representative Association (PDFORA) which represents 800 sailors based at nearby Haulbowline Naval Base. No project is in such direct conflict with the Circular Economy policy direction as this proposal, whih will be dependent on rising levels of waste generation to remain viable for a projected 30 year lifspan.

They also include submissions from CIT Students’ Union president on behalf of students attending the National Maritime College of Ireland , the Air Corps and submissions from the Teachers’ Union of Ireland (TUI) representing lecturers at the college.

Over 113 oral  presentations were contributed at the oral Hearing held in the Carrigaline Cour Hotel,  Co Cork which ended on  10th May 2016 after  4 weeks.

EU Complain looming.

A notable EIS omission during the hearing, in conflict with Art 5 of Stockholm Convention,  was pointed out by ZWAI in their closing statement, opening  the path to register a complaint to the compliance committee.

A decision is expected by the Board of An Bord Pleanala by mid July 2016.

12 May

Going on a Holiday to Majorca? Bring along your waste.

son-reus-wteIt now looks like Irish people might be able to bring their waste to Majorca when heading there on holiday. If they can’t do so directly, then a project proposed currently will do it for them indirectly, via waste exports from Derry. But don’t stuff rubbish in your rucksack just yet.  Reason may yet prevail.

From Bundoran to Bunyola, waste in haste.

Nestled on the North west coast of  Majorca, in the spurs of the Serra de Tramuntana, just 9 miles from Majorca’s Capital, Palma , lies the picturesque town of Bunyola.  It’s just 2,572 km from Bundoran, but unlike Bundoran its 5,475 inhabitants (double that of Bundoran)  have a serious concern.  They live near a large Incinerator that is operating below full capacity (like many others in Europe). But proposals currently before the Governing Council of Majorca will allow  the import of residual Irish waste for burning.  Problem solved you might think. They get money, we get rid of rubbish cheaply.

Maybe we’ve missed a vital piece of logic in the rationale used. For an island that survives on tourism  and that expounds the concept of clean open spaces, mountains, rural pursuits, crystal clear sea and bright sunshine it seems somewhat idiotic  to invite thousands of tons of residual rubbish along with holidaymakers every year. We certainly wouldent allow this to happen to our Green island. Would we?

Licence to burn in Majorca.

When the Son Reus burner was originally built  in 1992, near Bunyola, it handled 300,000 tons of waste. But guess what? Just like our own Carrinstown Indaver burner, its capacity was increased to 432,000 and then in 2011 to 736,000 tons. But why?  Since this is more waste than Majorca produces (Majorca creates about 540,000 tons of waste annually). Sounds familiar ? Sounds a bit like Poolbeg rationale?

Another similarity relates to the longevity of the licence granted to Tirme , the operator. It has a licence to waste treatment in Mallorca until 2041.

So in order to feed the capacity shortfall of the Incinerator waste must now be imported in increasing quantities for the next 27 years to match any drop in local Majorcan waste generation.

Ironically Bunyola,  has been a trailblazer for recycling waste and its local council is naturally indignant that piles of rubbish (ash) will in effect be dumped at its back door and pollute its air. The cruel outcome of increasing Eco awareness in Majorca , leading to less residual waste , means more rubbish imports will be needed to feed the burner. So there is no commercial reward for the Majorcan population to become greener!

When Irish eyes are smiling….something’s burning.

The reason why Irish waste could be exported to Mallorca is probably because the north west region is faced with a deficiency in waste management infrastructure and the Son Reus Incinerator needs more waste to fully utilise the burning capacity. (they previously tried to import Italian waste, unsuccessfully). So there is a commercial fit for these two needs  to meet.  We don’t need to invest in infrastructure and they fill a revenue gap.

Bunyola – A long way from Clare to here.

But do we know where the Irish waste will be generated — in Derry ?  Donegal ? Belfast ?  Clare? perhaps Dublin? In fact, it could come from any part of the country, transported quietly by truck to the Port of Derry, and loaded on a ship.  Derry Harbour Commissioners might be delighted of course, as the exports will increase tonnage throughput at one of Ireland’s smaller ports !
We all know that the waste industry is driven by the need to reduce costs at every stage, and one of the reasons why waste might be exported from Ireland to Mallorca is undoubtedly because it is cost effective. The landfill levy in the Republic has been steadily increased in Ireland (from €30/tonne to €50/tonne in 2011 to €65/tonne in 2012 and €75/tonne in 2013). This creates an opportunity for Irish waste exporters or brokers if they can find cheaper options.

The Zero Option.

Of course ,if we reduce our own waste in the first instance and use the latest Zero Waste technologies here there would be no waste to export. The local treatment of waste resources would provide new jobs here and help develop our own remanufacturing, re-cycling and re-use industries. This would keep money at home and put more of it (money not waste)  in people’s pockets (which they might spend on a  holiday to , well…Majorca?).

And if there was no waste to burn the Son Reus plant  might have to close down. Oops, that’s bad news for Tirme’s cashflow  – they’re expecting bumber revenues till 2041 remember- but great news for Majorca’s tourists and its hospitality industry and those 5,475 Eco aware Spaniards in Bunyola. Ole!

SangriaOnBeachSangria and soot?

So next time you’re lying on a sunny Santa Ponsa beach , pay attention to the wind direction. You might just get a whiff of your own waste, that’s followed you like a dog turd stuck to your sandals.

Discreetly check for traces of Soot in your Sangria as the turgid smoke wafts out in the night sky from the incinerator smoke stacks in the distance.

Cheers and …..Bon voyage !

05 Feb

Is Denmark leaving the dark age of Waste burning?

It  might seem unlikely but a recent apparent u-turn on waste management policy in Denmark could be in the offing. It’s all driven by the 2050 EU  goals of Emissions reduction.

Is the Sun setting for Denmark's Incinerators?

Is the Sun setting for Denmark’s Incinerators?

We applaud Denmark’s environment minister Ida Auken who recently announced a new strategy that changes the nation’s priority from incineration to recycling.  Make no mistake about it, this is a monumental shift for Europe’s biggest waste burner. Anyone visiting Denmark notices the Incinerator stacks too frequently and the bottom ash heaps in Copenhagen harbour are ugly indeed.

So why has the  world champion of waste incineration changed course?

Over 50% of Denmark’s household waste is burned at  incinerator plants that convert waste into energy for residential electricity and heat. However, C02 emission levels are exceeding the goals set by the Kyoto Protocol and sources of POPs need to be shut down.  The country aims at becoming independent from fossil fuel by 2050 and this means having to close down all polluting power plants by then, including of course the offending waste-to-energy incinerators.

This will not be an easy task given the extent of Incineration in Denmark today. The perverse economic incentives of Incineration run contrary to waste reduction, reuse and recycling .It also delays new cleaner electricity generation from taking hold, such as the Wind energy sector. Dumping incineration gives a double whammy – reduced Co2, POPs emissions, lower volumes of waste and the bonus – a waste recycling and re-use industry can develop, creating new jobs.

”In Denmark we have been incinerating almost 80 % of our household waste. Even though this has made an important contribution to green energy production, materials and resources have been lost which could otherwise have been recycled. Now, we are going to change this”said Auken.

Auken will drive a pro-recycling strategy that calls for households to sort their waste into several bins rather than sending the majority of it to the incinerator. ‘Recycling should be common sense and come to us naturally,’ the environment minister declared. ‘Danes will have to sort more of their waste. The goal is definitely to recycle more and incinerate less.’

Welcome to the 21 st Century, Denmark! Those dark , smoke filled days will be just a bad charred memory for the next generation of Danes.

The Government strategy is outlined in the published report ‘Denmark without Waste’. October 2013 , which has a tagline of ‘ recycle more – incinerate less’. You can Download the Danish Environment Ministry’s Report to read more.

24 Jan

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.


incinerator stack

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:


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 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 (such as Incinerators) of each of the chemicals listed in Annex C (Dioxins and Furans), 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 form Incinerators), taking into consideration the general
guidance on prevention and release reduction measures in Annex C (Dioxins and Furans
form Incinerators) .

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?