Letter from GAINS to Andrew Robertson, Chairman of Glasgow NHS, 12 Dec 2011, and his reply

Green Alternatives to Incineration in Scotland

33 Precinct Street

Coupar Angus

Perthshire

PH13 9DG

Tel/fax 01828 627124

Email: contact@gainscotland.org.uk

Andrew Robertson, Chairman of NHS Greater Glasgow and Clyde.

12 December 2011

Dear Mr Robertson

POLMADIE INCINERATOR – STOP CRAPPING ON POOR PEOPLE
I have sent the following information to all four of the Glasgow City Councillors for Southside Central, alerting them to the potential dangers from the proposed waste gasification incinerator proposed for Polmadie. I feel strongly that NHS Glasgow should make a firm stand against proposals for waste incinerators, as they are a danger to people's health.

Waste companies like to build incinerators in poor areas like Polmadie, because poor people are least able to articulate their opposition. Poor urban communities are also particularly vulnerable to health effects of waste incinerators, as they often have high pollution levels already. That is why Derby City Council rejected plans for a waste gasification incinerator last year, and why the company failed in its appeal.[i]

Don’t believe the slick marketing about how safe modern incinerators are. The Baldovie incinerator, built in 2000 in one of the poorest parts of Dundee, was caught emitting 102 times the legal limit for dioxins in 2008.[ii] Measurement of dioxins is only required twice a year[iii], normally organised by the plant management.

The type of incineration proposed, known as gasification, is still unproven.[iv] The only working example in the UK is on the Isle of Wight. In June this year the local Council announced that it was seeking alternative methods of waste management because it had proved so unreliable.[v]

No one wants incinerators near them. That is why Lancashire County Council has completely rejected all forms of waste incineration.[vi] San Francisco has done likewise, and is aiming for 100% recycling by 2020.[vii]

In addition to health concerns, there are many environmental reasons for rejecting incineration:

· Incineration/gasification recovers a tenth of the energy used to make the products in our rubbish[viii] (74% of greenhouse gas emissions come from energy[ix]).

· Recycling recovers 3-6 times more energy than incineration[x]

· Incineration represents the emission of 5 tonnes of CO2 from every tonne of waste that is burnt (3 tonnes from making the products in our rubbish and up to 2 tonnes from the combustion process).[xi]

· More and more things are being recycled, such as disposable nappies[xii] and Tetrapak drinks cartons.[xiii] If something can’t be recycled, we shouldn’t be making it.

To sum up, incineration is bad for human health and bad for the environment. Please do what you can to persuade colleagues in Glasgow City Council to reject the Polmadie waste gasifier proposal.

Yours sincerely,

Michael Gallagher, Secretary

[i] ‘Derby victor in Sinfin appeal’, 16 November 2010

[ii] SEPA – Emission breaches summary 2006-8, see foot of page 2, which mentions an elevated dioxin/furan result of 10.2ng/m3, compared to the emission limit of 0.1ng/m3

[iii] See section 5.6 of Waste Incineration (Scotland) Regulations 2003: Practical Guidance: Edition 2.

[iv] The Department of Energy & Climate Change described gasification as: “. . . emerging and unproven technologies for the treatment of waste biomass and mixed municipal waste where there are number of technical issues to resolve, for example, achieving intended throughput and air emission standards.” – see s12.2 of their report here (pdf file).

[v] Isle of Wight Council seeks to reduce use of 'unreliable' gasifier, 22 June 2011

[vi] Lancashire County Council Waste Management Strategy - page 14 states: "This Strategy confirms the Authorities stance regarding the alternatives to incineration. Accordingly, the County Council continues to oppose the siting of any proposal for mass burn incineration of municipal waste in any Lancashire District."

[vii] Toward zero waste: A look at San Francisco's model recycling policies

[viii] Morris, J. Garbage or Biomass Incineration/Combustion/Gasification Warning Labels, p1

[ix] From the website of ‘Good Energy’

[x] Up in smoke: Why Friends of the Earth opposes incineration, Friends of the Earth Briefing Note, p6

[xi] Petition to the Scottish Parliament, number 1379 ‘Green Alternatives to Incineration in Scotland’, page 2 (section headed ‘Global warming’)

[xii] Nappy days! Britain's mountain of disposables recycled into roof tiles in CO2-saving measure, 13 Sept 2011

[xiii] Tetra Pak Sustainability – UK and Ireland

Dear Mr Gallagher
re: Proposal for Incineration plant at Polmadie
Thank you for your email of 12 December in which you raised concerns regarding the proposal for a new incineration plant to be situated at Polmadie.
I have now had an opportunity to discuss this matter with the Board's Director of Public Health and I have received information from several of her colleagues, including some at Glasgow City Council. The Health Board and the Council work closely together on environmental issues that might have implications for public health, but as you may be aware, the principal responsibility of the Health Board is to ensure protection of the public health in the Board's area. The primary responsibility for the planning and implementation of the detailed proposal lies with Glasgow City Council. The overall planning of the plant is still in its relatively early stages and much of the detail has not yet been fully worked out. There will be a consultation phase in due course and it is at this stage that comments should be submitted by interested parties.
For this reason, I do not feel that I am currently in a position to respond to you in detail but I would like to take this opportunity to make some general points. Firstly, the proposal for the new plant should be seen not as an isolated development but in the context of an overall strategy for managing the large amounts of waste that are generated in the area of Glasgow City. Two of the most important general assumptions that underpin the strategy are that the use of landfill for disposing of waste should be minimised and that the recycling of waste materials should be maximised. In this context, the new plant would represent a possible means for disposal of residual waste that could not be recycled and which otherwise would have to be disposed of by landfill. The Council currently has a waste disposal facility on the site at Polmadie. This means of course, that the proposal is for development of an existing site rather than for creation of a new one.
Secondly, a new thermal technology will be utilised at the proposed facility. The details of the treatment are not yet available but the main processes will probably comprise pyrolysis and gasification. In these processes, waste material is subjected to thermal treatment but the process differs entirely from that of conventional single-chamber combustion. The main differences are that in the new thermal process, material is treated in the absence, or near-absence, of
oxygen so that the pattern of emissions is entirely different from that associated with ordinary combustion. The energy derived from the process is used to generate power. The last two points that I would like to make are that the proposal will be fully assessed in relation to environmental and health considerations as instructed by the planning authority and that the facility will need to be licensed by the Scottish Environmental Protection Authority (SEPA).
In summary, I am sorry that I am not currently in a position to give you a more definitive response but I hope that you will be reassured to some extent by the comments that I have made above. I hope that I will be able to respond in greater detail when the Council's plans become available. In the mean-time, please do not hesitate to contact me again if you have any queries about this response.
Yours sincerely
ANDREW O. ROBERTSON, OBE LLB
Chairman