Exhibition Hall Kingsley Village Penhale Fraddon
Town and Country Planning Act 1990
Appeal by SITA CORNWALL LTD against the decision of the
former Cornwall County Council (now Cornwall Council) to refuse
Planning Permission for the erection of an Energy-from-Waste
plant and ancillary development, including a bottom ash facility,
bulking up facility, chimney stack, administrative and visitor
facilities, gatehouse and weighbridge, vehicle efuelling area,
cooling units, parking and circulation areas, security fencing,
drainage and landscape woks, pipework for heat transfer to
existing china clay dryers, and other ancillary works, togetther
with site access road, private haul road and bridged river
crossing, junctions with the existing public highway and diversion
of footpath at Rostowrack Farm and land at Wheal Remfry, and
Goosevean and Parkadillick dryers, Saint Dennis, Saint Austell
Cornwall (Cf. Procedural Note : 14 JANUARY 2010 APPEAL
REF : APP/D0840/A/09/2113075)
courriel : [email protected]
“It is a popular misconception that the weight and volume of the raw waste are reduced during incineration. It is often quoted
that the volume of waste is reduced by about 90% during incineration. Even if only the residual ashes are considered, however,
the actual figure is closer to 45%. The weight of waste is supposedly reduced to about one third during incineration. However
this once again refers only to ashes and ignores other incineration emissions in the form of gases, which result in an increased
output in weight. In sum, if the mass of all the outputs from an incinerator, including the gaseous outputs, are added together,
then the output will exceed the waste input” Greenpeace Laboratories University of Exeter 2001 [1].
The above extract from a twenty-first century report would have made sense to Antoine Laurent Lavoisier
(1743-1794). One of the founding fathers of modern chemistry [2], he correctly identified the composition of
water, established the law of the conservation of mass, demonstrated the indestructibility of matter and was
the first to explain satisfactorily combustion in terms of oxidation. An example being the production of the
greenhouse gas carbon dioxide, when carbon is ignited : C+O2 = CO2 . He would probably turn in his
grave were he to witness the allegedly economic and scientific arguments advanced today to justify what
was at one time called “thermal” treatment then, just as euphemistically, “Energy from Waste” or “Waste to
Energy” ie techniques employed to process commercially an estimated 17% of municipal waste in the
European Union in 2004 and which rely essentially on subterfuge to gain public acceptance, since they are
as problematical in the long and medium term as the landfill sites they were supposed to replace.
The say-so of experts, with their questionable industrial credentials making them increasingly hostile to the
natural world, is pivotal to what passes for sound science and state-of-the-art technology today. Its
cornerstone is a novel kind of intellectual dishonesty which, protective of the acquisitive instinct and of the
consumer society, dissembles before the enquiring and truly inquisitive mind. It masquerades as
independence of thought whilst partaking of an iniquitous value system which engineers consensus,
requires an uncritical belief in artificial intelligence and a blind faith in would-be innovative but highly
technical answers to problems, whose best solutions as we shall see, are ultimately political and social.
To develop adequate understanding of the Appellant's proposals and to consider their full potential in terms
of pollution, environmental, health and social costs, the inquiry needs to examine established and emerging
policies, putting them into context against a background of geographical and historical data relevant to the
gestation of what has come to be dubbed Cornwall's Waste Management Crisis.
“No man is an island ...” First line of English poet John Donne's Meditation XVII.
The aim of this carefully researched and documented testimony is to dispel abiding fictions underpinning
the credo of so-called Energy from Waste facilities. Notably the political culture which produces all the hot
air and sales talk in the first place. Whether using mass-burn incineration or fluidised bed technologies,
combustion-led waste management is unsafe, unsustainable and provides neither recycling nor recovery as
ordinary mortals would normally understand the expressions. Moreover the modern EfW incinerator
provides no alternative to the waste tip, as if one option somehow displaced the need for the other.
A disproportionately lucrative sector of the private economy, the waste industry would be out of business
without landfills and other infrastructure developments, heavily subsidised by taxpayers, to accommodate
incinerator bottom ash disposal, plus a reliance on capital intensive movements of discards and sites to
absorb concentrates of fly and boiler ash, bag house filter dust, effluent and residual wastes. The same
'creative accountancy' methods, which has brought banks and financial institutions into such disrepute,
allows the public via the European Investment Bank (EIB) to underwrite exhorbitant and dubious Waste PFI
contracts such as one engineered by SITA UK and a previous incarnation of the Waste Planning Authority
whom shall be henceforth termed, more accurately, the Waste Disposal Authority (WDA).
The Appellant is a former subsidiary of Suez Lyonnaise des Eaux, which at the flourish of a pen and some
additional hyper activity on the stock market disappeared to be reborn as Suez Environnement in July 2008
ie one of the two main ramifications of a corporate merger that created GDF Suez, France. This company is
the world's second largest utilities conglomerate with a 260 000 strong workforce, reported revenues of
over $130 billon USD in 2007 and a total net income estimated in the region of EUR 3.6 billion [3].
Given the degree to which national sovereignty has been eroded by a globalised financial economy, with
legislative rules of engagement determined not so much by New County Hall, Whitehall or Westminster, as
by lobbyists in Brussels, and by international 'think tanks' like the World Trade Organisation and the World
Health Organisation, this means referring to the way SITA Cornwall Ltd operates as an affilate of SITA UK ie
of the tentacular Suez Environnement, active throughout Britain and elsewhere, notably in Europe.
The long and the short of what this submission will be demonstrating was revealed by the outcome of the
Cornwall Waste Local Plan inquiry in 2002. Namely that the UK planning system which came into existence
in 1947 now treats the public - ie the very people it was intended to serve - as a mere hindrance. It
desperately needs an overhaul, and not just the odd of tweaking to a fundamentally flawed Waste Local
Plan which is all that HM Inspectorate seemed empowered to propose in 2002. Where the following draft
testimony exceeds the 1500 word limit, an oral synthesis will be provided, with, time permitting, detailed
reference to the key areas of research in the presentation of proofs of evidence at the inquiry hearings.
[1] Incineration and Human Health : State of Knowledge of the Impacts of Waste Incinerators on Human Health
Michelle Allsop, Pat Costner and Paul Johnston. Greenpeace Research Laboratories March 2001. Any
acknowledgement for this particularly well researched document needs to be far extended beyond the three
authors themselves and their duly accredited advisers and proof readers : Wytze van de Naald of Greenpeace
International and Mark Strutt of Greenpeace UK, Andy Moore of Britain's Community Recycling Network – as well
as Alan Watson, of Public Interest Consultants Gower, Wales and Dr C Vyvyan Howard of Liverpool and Ulster
Universities and who have both further distinguished themselves with their recent work on respirable aerosols. (Cf.
An Bord Pleanála, Statement of Evidence, Particulate Emissions and Health, Proposed Ringaskiddy Waste-toEnergy Facility June 2009. Cf. Also Nanotechnology and nanoparticulate toxicity, a case for precaution, published
in Nanotechnology: Risk, Ethics and Law, Editors Hunt and Mehta, Earthscan pp 154-166. ISBN 1-84407-358-0).
Mention should also be made for example of Greenpeace International's groundbreaking 76 page report «Playing
with Fire» edited in 1999 by Lisa Finaldi in collaboration with Pat Costner and Joe Thornton.
Civil society salutes the courage of so many of the victims and campaigners speaking out to provide a living and
breathing indictment of the endless commercial violence which destroys so many lives in the name of profit and
progress. People like Billee Shoecraft, Bob McCray, Lois Gibbs, Marilyn Leinster, Carol von Strum, Val Barton,
Alan Dalton, plus Dominique Frey and Pierre Trolliet, co-présidents of ACALP in France, where le mythe
purificateur du feu and industrial hubris take their toll. It behoves us moreover to acknowledge the pioneering work
of Rachel Carson and the many others who came later to blaze the trail on hormone disruption along with WWF
scientist Theo Colborn co-author - with Dianne Dumanowski, John Peterson Myers - of Our Stolen Future.
One's mindful of the twenty-one signatories of the Wingspead Conference in July1991 and of the unstinting
commitment of other leading researchers like Paul Connett, Peter Montague, Lou Guillette, Frederick Vom Saal,
Chris Portier, Tom Webster, Richard Clapp, Barry Commoner, Arnold Shecter and the EPA's Linda Birnbaum,
many of them participating in the 'People's Dioxin Action Summit at Berkley University California in 2000.
Finally tribute must be paid to the priceless work of the unsung heroes of the grass roots network of public interest
organisations and colleagues too numerous to list. Personal thanks go to Rachel's Environmental News, Centro de
Acción Comunitaria y Justicia Ambiental (CACJA) alias the Center for Community Action and Environmental
Justice (CCAEJ), Environmental Health News, the stalwarts of associations like : APEL, AMIES, MDRGF,
RESEAU ENVIRONNEMENT SANTÉ–CNSME, CNIID : Maurice Sarazin, François Veillerette, Francis Glémet,
Claude Lesné, André Cicolella, André Picot – bravely standing up to France's unbelievably powerful waste and
chemical lobby, doubly dangerous in a country crippled by Jacobinist government, monarchical présidents,
reinforced by Pétainist laws. Hence la pensée unique of dinosaur-like institutions such as l'Académie des
Sciences. For in Paris, as in London. there is a dangerous conflation of the terms engineering and science.
Big environmental players such as FOE and Greenpeace provide many of the recruits. Battle hardened veterans
coming from all walks of life to provide the bedrock of popular resistance to financial empire builders fostering war,
famine, disease, debt, poverty and ecological destruction. Human dignity should not need such reasons to exist.
Yet the combat for social justice and civil rghts has become a fight to the death, imposed by a heinous ideology
responsible for unsafe, polluting waste treatment and disposal facilities. Opponents have names like the UK Zero
Waste Alliance, Michael Ryan and Dick van Steenis of UK Health Research, the British Society for Ecological
Medicine, Nottingham's NAIL 1 and Norfolk's NAIL 2, CAIR, BAN Waste, UKWIN. Thanks locally to Chris and
Chrissie Massie, Bob and Sally Turner, Elizabeth Hawken and, up country - last but not least - Ralph Ryder's
indomitable Community Against Toxics of Ellesmere Port which, founded in 1990, miraculously has been able to
survive on a shoe-string budget to enlighten the public and defend humanity's increasingly vulnerable offspring.
[2] Cf. Also the lives and works of other pioneers like Robert Boyle (1627-1691), Robert Hooke (1635-1703) Henry
Cavendish (1731-1810), Joseph Priestley (1733-1804), Carl Wilhelm Scheele (1742-1786).
[3] Cf.
PREAMBLE AND EXECUTIVE SUMMARY = Greenpeace, John Donne, Ron Whittle {three pages including acknowledgements}
CERC - GOVERNMENT ADVISERS = André Rico, Roy Harrison, Professor Dame Barbara Clayton {1½ pages} ELV ¼ page
CERC - THE UK HEALTH RESEARCH TEAM'S SMOKING GUN = BSEM reply to HPA {one page+six pages proof of evidence}
CERC - UNMONITORED AIRBORNE POLLUTANTS = Joel Schwartz & Michael Meacher{one page} + {one page of notes}
CERC - INVENTORY OF HISTORIC CONFLICTS OF INTEREST 1990-2010 = Maggie Thurgood {ten pages including notes}
CERC - A DEEP-ROOTED CULTURE OF DENIAL = CADAS {two pages including notes}
CERC - A CASE STUDY BYKER = Citizen Participation in Policy Setting by Lyn Woods & Bill Hopwood {three pages}
2ΞΥ6ΩΡΟΗΘ)ΞΩΞΥΗ {four pages including notes}
CERC - KEEPING THE LID ON A CAN OF WORMS = Ron Whittle {one page}
“Living beings are all protected against chemicals in the environment and every one of us is protected against low
concentrations. It is not for us to make decisions about the fate of unborn children ; future generations must fend for
themselves like everyone else”. André Rico former chairman, COMTOX – French equivalent of the UK Pesticide Safety
Committee and COT - Conférence Union des Industries de la Protection des Plantes (UIPP) 28 June 2001, Paris)
”[T]he other factor sir, which needs to be taken into account is the existing pollution in a locality and the incinerator will provide
an increment on top of that. A small increment would be more tolerable in an already heavily polluted location...” Evidence to a
House of Lords Select Committee Professor Roy Harrison, Birmingham University, London 1999 [Cf. infra]
“"Could I say the perception of incinerators varies in different parts of the country. In Birmingham it is splendid, but in
Hampshire and Dorset incinerators are a dirty word quite frankly because people's perceptions are very misguided (...) If you
look at the massive exposure of people to dioxins as a result of two major accidents, there is no evidence that the population
was harmed apart from developing severe chloracne which is a nasty skin complaint, but that was with massive exposure”.
Evidence to a House of Lords Select Committee Professor Dame Barbara Clayton London 1999 [Cf. infra]
As happened with asbestos, [1] if you trot out lies often enough, people start believing them. To brazenly affirm that
the worst possible effect of exposure to TCDD dioxin is a nasty skin complaint ranks alongside other acts of moral
insanity, such as Sir Richard Doll's well-paid whitewash of the effects of Agent Orange to disculpate Monsanto, Dow,
Bayer et al. Professor Dame Barbara Clayton is just one of many conduits through which industrial science has
relayed ad nauseum the 'received wisdom' of the 1994 CADAS Joint Report, emerging even in an entry for 'dioxins'
in Encyclopedia Britannica. Yet by 1992 the USEPA had acknowledged TCDD dioxin as a potent cancer promoter.
Like the drug thalidomide, this molecule had been identified as teratogenic by 1999 and there was already abundant
peer-reviewed scientific literature on the concerns over chemical trespass, which the WTO was invented to stifle.
Such testimony might seem irrelevant in 2010. It must be emphasised that, alongside the unstinting efforts of MEP
Caroline Jackson to promote incineration and weaken legislation supportive of environmental health safeguards, just
over a decade ago the findings of this House of Lords – European Communities – Sub-Committee were also to have
far-reaching effects as a formative influence on attitudes to waste management in the UK and elsewhere.
Like Professor Roy Harrison and André Rico's scurrilous dismissals of the human rights of, respectively, heavily
polluted communities and unborn populations, Professor Dame Barbara Clayton's observations have to be seen
against a background of European Commission proposals to include strict ELV [2] for dioxins and furans - then
introduced for the first time - for municipal waste incinerators. All three personify a culture of being 'economical with
the truth' which still informs reactionary and influential sections of the scientific and medical community as well as
government policy and conservative public opinion – as instanced by Cornwall Council's public statement that the
main hazardous property of fly ash is its alkaline nature and the Health Protection Agency's claim today that there's
little danger to health from incinerators and advising inspectors at public inquiries into planning applications for EfW
facilities - involving the combustion of a mixed waste stream - to ignore health impacts 'because there won't be any'.
Equally mischievous are Professor Dame Barbara Clayton's comments in1999 about the nuisance value of bonfires
as sources of dioxins comparable to waste incineration and the suggestion that improvements in air pollution control
would suffice to abate health impacts of "dirty old incinerators" – lines of argument which do not stand up to scrutiny,
but never cease to be wheeled out by senior waste industry operatives and a number of unscrupulous self-elected
oracles in Whitehall or at New County Hall to justify a new generation of MSW mass burn facilities. It should also be
noted that Professor Dame Barbara Clayton's unscientific approach to serious health and environmental issues was
already public knowledge, as she led the health advisory group which - in two reports in 1989 and1991 - had
airbrushed out the possible - and in time proven - adverse effects of the 1988 water poisoning incident at Camelford
Reservoir. As a past-president of the NSCA, this former president of the Royal College of Pathologists was clearly
in good company at the House of Lords, singing from the same hymnsheet as Gavin Tringham of Birmingham City
Council, Richard Mills, Lord Lewis of Newnham and the Earl of Cranbrook, all of them members of the NSCA .
The Environment Agency and the waste and chemical industries stressed their commercial interest in the approach
that consisted of BUILDING PUBLIC CONFIDENCE in waste incineration rather than introducing measures to
reduce waste at source. Despite testimony from Professor Stephen Holgate, who considered particulates to be the
most important issue relating to air pollution and health in general, the overall conclusion was that “the evidence
suggested that it was important to keep in perspective the relatively very small impact of incineration in terms of air
pollutants compared to other industrial and domestic sources”. One knock-on effect being the UK government's
guidelines set out in Waste Strategy 2000 with a pick'n'mix of four options all heavily weighted in favour of waste
incineration, mere compliance with formal EU requirements and a gutless approach to producer responsibility.
[1] "The evil effects of asbestos dust have also attracted my attention. A microscopic examination of this mineral
dust, which was made by HM Medical Inspector, clearly revealed the sharp, glass-like, jagged nature of the
particles, and where they allowed to rise and remain suspended in the air of a room, in any quantity, the effects
have been found to be injurious, as might be expected." Factory Inspector Lucy Deane's words appear in the1898
Annual Report of the Chief Inspector of Factories. She knew nothing about nanoparticulates but observed work
conditions and the sifting and carding operations, involving one of the four dusty occupations which came specially
under her remit. In the early 1900s researchers began to notice a large number of early deaths and lung problems
in asbestos mining towns.1909 and 1910 saw similar testimony from women factory inspectors ie lay competent
observers of occupational diseases and whose reports were then widely circulated among policy-makers and
politicians. The first documented death related to the mineral was in 1906, when Doctor Montague Murray
diagnosed a British worker as having died from asbestos disease - an event that was apparently reported to a
Government enquiry into compensation for industrial disease. In 1924 in Rochdale, home to a major asbestos
processor, later to become the multinational Turner & Newall, an inquest was held and a post mortem performed
on the body of Nellie Kershaw after her physician, Doctor Joss, had attributed her death to “asbestos poisoning”.
By the 1930s, the UK was regulating ventilation and had made asbestosis an excusable work related disease ie
about ten years sooner than the USA. On the other hand the Americans were to be slightly more pro-active than
Europeans when they banned the manufacture and some uses of PCB. The term Mesothelioma, to describe
fibrosis of the lungs associated with asbestos, was not employed in medical literature until 1931 and was not
directly linked with asbestos until sometime in the 1940s. Many governments and the asbestos industry have been
criticized for not acting quickly enough to inform the public of dangers and to reduce public exposure. In the late
1970s US court documents proved that asbestos industry officials knew of asbestos dangers since the 1930s and
had concealed them from the public. Kent, the first filtered cigarette on the market, used crocidolite asbestos in its
"Micronite" filter from 1952 to 1956. In 2005 the number of asbestos-related deaths in the UK was officially
estimated as 4000. (Cf. Environmental issue report No 22 Late lessons from early warnings: the precautionary
principle 1896-2000
Lucy Deane
[2] ELA = Exposure Level Values
Waste remains a growing problem in Europe, with only a few countries managing to stabilise or reduce the
amount of municipal waste produced, or to achieve high recycling and composting rates. During the last few
decades the EU has adopted a number of policies aimed at reducing waste generation and increasing recycling
and composting, including the Waste Framework Directive (the revision of which is currently being finalised) and
the Landfill Directive, aimed at reducing the amount of untreated organic waste going to landfill. A hierarchy of
preferred waste management options has been developed, which is now widely accepted, and stipulates that
reduction, re-use then recycling are preferred to energy recovery1 and then final disposal.
The European Investment Bank (EIB), the EU’s house bank, is mandated to promote EU policy with its project
investments and invested over EUR 1.5 billion in 33 waste management projects between 2000 and 2006, the
majority of which were in the EU. The EIB’s financing is essentially public money - although much of it is
borrowed on the financial markets it is guaranteed by EU governments and low-interest EIB loans represent a
political seal of approval, serving to encourage other investors to get involved. According to EU waste policy, the EIB
should support efforts to reduce, recycle and compost waste. However, this analysis shows that instead, in the
2000-2006 period, the majority of the EIB’s waste investments – 68 per cent - supported incineration, a waste
management method fraught with environmental and economic deficiencies.
If the EIB is to truly support the implementation of EU policy, this bias towards incineration investments must
be halted. The EIB needs to seize the opportunity of the Waste Framework Directive revision to review and
publish its waste lending policy, and to ensure that it promotes waste reduction and recycling in concrete
financial terms rather than continuing to lend financial support to incineration.
1 Energy recovery is often used as another name for incineration, however this is controversial as many argue that incineration’s primary purpose is the
disposal of waste, not energy generation. Energy recovery also includes less controversial technologies such as anaerobic digestion of organic waste
The 2006 Cornwall loan is for a Public-Private Partnership in which SITA has won a 30-year waste
management contract,46 which includes the construction of a a highly unpopular incineration plant. The location
for the plant has not yet been finalised due to fervent local opposition and therefore no environmental impact
assessment has so far been carried out. Yet the EIB, which claims to follow EU environmental legislation,
including requiring a full environmental impact assessment, signed a loan for EUR 120.2 million in October
2006, of which EUR 81.72 million is to be allocated for construction of the incinerator.47
It is questionable whether SITA’s record in delivering waste management services in the UK warrants Cornwall
County Council trusting it with its waste for the next 30 years. In 2001 the company’s contract was cancelled
in Brighton after it increased workloads to absurd levels to decrease costs and suspended workers who did not
manage to complete their rounds. The workers responded by going on strike and occupying the depot, and SITA
ended up having to pay GBP 3 million to be released from the contract since it could not deliver the services.48
The company has also been fined for several environmental offences during the last few years and has had two
of its incinerators temporarily closed as a result of technical problems and Enforcement Actions from the
Environment Agency.49 In 2002 a fatal incident at a SITA facility resulted in a GBP 80 000 fine for the
company for failure to implement adequate health and safety measures, plus GBP 20 505.41 costs.50
Ultimately it is the choice of Cornwall County Council and local people whether SITA is the best choice for the
County’s waste management, but it is another question whether the company should benefit from a public loan
that represents a seal of approval for SITA and the Cornwall waste contract. SITA/Suez and Veolia (formerly
Vivendi) are by far the largest waste management companies in Europe. In 2006 Suez had a net income of EUR
3.6 billion,51 and Suez Environnement, of which SITA forms a part, had a net income of EUR 562 million.52 It is
therefore far from clear why, if the company needed a loan, it had to come in the form of a low-interest public
loan and could not come from commercial sources.
46 EIB Press Release, 16.10.2006:
47 EIB Press Release, 16.10.2006:
48 Steve Davies: Sita in Brighton: humiliation by the sea, PSIRU, August 2001
49 Agency promises consultation before SITA can re-open tyre plant, 29.01.2001,, BBC website: Firm fined over landfill smell, 19.03.2004,, SITA UK: Environmental and social responsibility report 2004, p.17, ‘This is
Hampshire’ website: Firm fined GBP10k as smell gets up residents’ noses, 05.05.2005,, SITA
UK: Environmental and social responsibility report 2006, p.20; news: Boiler damage sees Kirklees incinerator out of action, 22.09.2006,
50 Health and Safety Executive website, case No. 2014466, heard on 13.12.04,
51 Suez website:
52 Suez Environnement website:
“The HPA have tried to skirt around the issue of synergistic effect by referring to the 2002 COT report. They have neglected to
say that, according to our information, the 17 members of the COT committee have 50 declared interests in the chemical
industry between them. It's hard to think of people less likely to acknowledge the existence of synergistic effects. However we
have produced ample evidence that synergistic effects do occur and will add to the danger of incineration, particularly in regard
to lung cancer”. Drs J Thompson and H Anthony - British Society for Ecological Medicine - Reply to Health Protection Agency.
Whether caused by the PM2.5 aerosols or the halogenated and heavy metal contents of flue gases, which add to
the intake of a wide range of toxics via the food chain, evidence of the significant effects of prenatal exposure to
modern incinerators exists. These are not the only sources of these harmful industrial PM2.5 emissions. There are
also cement kilns and in rural areas intensive agriculture means that pesticides/herbicides, dioxins and PAH are
also likely to impact on residents. UK Health Research is run by civil engineer Michael Ryan. Assisted by a retired
GP - Dick van Steenis – he has used unpublished Office for National Statistics birth certificate data and maps of the
London Authority's Electoral Wards to establish – beyond reasonable doubt - links between birth defects and high
infant mortality rates in populations downwind of EfW facilities. (Cf.
The principle UKHR researcher, who lives near a hospital incinerator in Shrewsbury, began to study the evidence
after losing two of his children : a daughter who died in 1985 aged 14 and his 19-year-old son, who succumbed to
leukaemia in 1999. After discovering the deaths of others in the area also from leukaemia, Michael Ryan learned
that radioactive waste was being incinerated in this clinical facility. Last year in his letter dated 9 June 2009 sent to
Michael Ryan, the Chief Executive of the Health Protection Agency, Justin McKracken admitted that the HPA had
not studied the rate of illness or premature deaths within electoral wards surrounding any incinerator.The absence
of such data begs the question as to how (a) the UK health authorities can refuse to recommend such studies and
(b) how Primary Care Trusts as statutory consultees to the Environment Agency can automatically conclude there
are no significant adverse health effects from granting an incinerator pollution permit and (c) HM Inspectors can
simply refuse to hear or consider data regarding health concerns in public inquiries merely on the grounds that
“incinerators are modern or well managed and the possible health effects are likely to be small”. An allegation which
is simply not borne out by the facts. On the contrary the numerous unauthorised emissions and pollution breaches
already recorded run counter to this suggestion. Indeed in the light of the all-too-frequent instances of “mediocre to
poor” duty of care ratings observed in the Environment Agency's performance, most ordinary mortels simply don't
realise the half of what goes on behind their backs, in the squalor beneath the polite facade of self-regulation.
Moreover the HPA's conclusions are drawn from the opinions of reviewers, as often as not reviewing the work of
other reviewers. Like those of Director of Enviros Consulting Ltd, Dr Mark Broomfield, Professor Roy Harrison and
Doctor Robert L Maynard of COMEAP in their 2004 Report to DEFRA. This possibly is also what persuaded Elliot
Morley MP - then Environment Minister, lately arraigned for fraud by the Crown Prosecution Service - to assert :
“Incinerating large quantities of household waste has no detrimental effect on health” (Cf. Guardian 7 May 2004).
The following table is a brief excerpt from a UKHR independent report analysing birth certificates from unpublished
ONS data, whose release was authorised by Health Minister Ruth Kelly: "Birth Defect Rates in England: 1995-2002"
INFANT DEATHS PER 1000 LIVE BIRTH Source of data : Office for National Statistics
According to the Health Protection Agency :”The Edmonton incinerator poses almost no threat to human health (Cf. 03 September 2009). Where they got the 'almost' from is a moot point. Published in
2007 a Memorandum - dated 2005 - was submitted by Michael Ryan (cf. infra) to the House of Commons –
Environment, Food and Rural Affairs Committee on the failure of Environment Agency (EAa) to regulate harmful
industrial PM2.5 emissions (Cf.
Re : Incinerators & infant mortality rates at electoral ward level
Michael Ryan 16/02/2008, 8:41 PM
Those who saw me at Costessey High School on 29 January 2007 for the incinerator public meeting, organised by
NAIL2 [1] and Norwich Evening News, might recall the overheads I showed of electoral wards around
incinerators and the fact that the "downwind" wards had higher infant death rates than the upwind wards.
I've updated the Coventry map as follows and if WRG can name any incinerator in England & Wales that does not
have higher rates of infant death in the downwind wards, would they please name them as I've got tired of looking
after examining data around twenty-eight incinerators.
When I looked again at the Coventry data to include the 2006 statistics, I wondered where the five electoral wards
with the highest infant mortality rates [2003-6 ONS data] were located and saw that instead of being randomly
scattered around Coventry, they were in a single group that "just happened to be" immediately downwind of the
incinerator in Bar Road. The odds against that occurring by chance are 1 in 8,568.
I also wondered where the two wards with the lowest infant mortality rates were located and saw that they were
also in a single group, but that group was immediately upwind of the Coventry incinerator & the odds against that
being a chance event are 1 in 78.
The odds against the five highest wards and the two lowest wards occurring in the pattern shown on the above
map is 1 in 668,304, which doesn't seem very likely to me.
Note that the two lowest infant mortality wards in Coventry had zero infant deaths in 2003-6 while there were
fifty infant deaths in the five "downwind" wards.
If WRG think "Oh, it's the poor people living in the high infant mortality wards", they'll have to change their tune
when trying to explain away the exceptionally high infant mortality rates in some of the London electral wards
which are not where "poor people" live but "just happen to be" downwind of incinerators.
I'll be happy to argue the case against their star witness, Professor Jim Bridges of Surrey University, who claimed
that incinerators pose no harm to health at the Belvedere incinerator public inquiry.
Jim Bridges will be keeping his head down after seeing my infant mortality maps of Kirklees, Coventry and
Edmonton incinerators that were printed in the Surrey Mirror and the Dorking Advertiser in January 2008 with
regard to the proposed Capel incinerator.
Many thanks to NAIL2 and Norwich Evening News for last year's meeting and special thanks to Rob Whittle for
making the above ward maps more professional-looking.
These are the London Boroughs with the five highest & five lowest infant mortality rates in 2006. It's really
strange that the ones which are exposed most to incinerator PM2.5emissions have the highest infant mortality
rates while the Boroughs with the least exposure to such emissions have the lowest rates.
Kind regards,
Michael Ryan,
[1] NAIL2 = Norfolk Against Incineration and Landfill
Waste Strategy for England 2007 - Environment, Food and Rural Affairs Committee
Environment, Transport and Rural Affairs
Select Committee on Environment, Food and Rural Affairs Written Evidence
Memorandum submitted by Michael Ryan
1.1 The EA's failure to regulate harmful PM2.5 (particles of 2.5 microns and below) emissions
from power stations, incinerators, cement works, brickworks and some other industrial processes has
caused a massive increase in sickness and premature death, which is likely to continue unless your
Parliamentary Committee takes early and effective action. These PM2.5s have increased
exponentially due to switch in fuel from coal to hazardous waste mixes.
1.2 The UK only monitor PM10s, ie particles of between four and 11 microns (a micron being one
millionth part of a metre), despite proof that the critical upper size of particles to enter the lungs is
PM2.5 and particles doing most harm are within the range PM1 to PM2.5.
1.3 There is no effective public health system in the UK to examine the patterns of sickness and
premature deaths resulting from industrial PM2.5 pollution despite there being considerable
published research on the subject by Dr Dick van Steenis and others.
1.4 If the UK adopted the US Clean Air Act of 1997 we could easily reduce the annual NHS bill by
£24 billion. The US saved $193 billion just from reduced hospital visits and days off work according
to the White House Office of Management and Budget report which was featured in the Washington
Post, 27 September 2003. HM Treasury failed to reply to Paul Marsden MP after he raised this issue
on my behalf in October 2004. My letter to Paul Marsden MP is at
1.5 The failure of the EA to regulate and reduce toxic airborne emissions can be proved and this
statement will make use of a case study in Shropshire and also my birth defect research at as only part of the proof.
1.6 The failure of public health professionals, whether in Primary Care Trusts (PCTs) or Health
Protection Agency (HPA) or elsewhere to study locations and causes of sickness and premature death
patterns and take effective remedial action shows a gross dereliction of duty.
1.7 There are two case studies with this report, the first is based in Shropshire and focuses on a
range of health parameters and a major unregulated source of PM2.5 pollution, which has caused and
is continuing to cause great loss of life. The second is based in Greater London and refers to
variations in rates of babies born with defects, a set of data that has been gathered by the government
since January 1964 with the aim of "providing early information of causal factors of congenital
malformation" (The Times, 6 January 1964, "Scheme to notify malformations"). The principles of
each case study apply elsewhere.
1.8 I've read and agree with Dr van Steenis' e-mailed submission (25 November 2005), having
discussed the matter with him. We both agree that the best solution would to replace the EA's failed
role as a regulator with an Environmental Police Force under the direction of HM Treasury, whose
money is at stake for the cost of failure of regulation and also because HM Treasury is the controlling
department of the Office of National Statistics (ONS), whose extensive data proves that what is
written here is correct and can be used in future to demonstrate that regulation is taking place, unlike
today. Such a new department should also be subject to external audit to prove effectiveness. Dr van
Steenis would be able to provide expert advice on setting up and auditing such an establishment.
2.1 Dr Dick van Steenis carried out a childhood asthma survey in West Wales [Lancet, 8 April
1995] and found 38% of four-to-five-year-olds in Whitland to be chronic asthmatics compared with
just 1% in Aberaeron and other locations upwind of the oil refinery/power station complex at Milford
Haven waterway. Dr van Steenis also obtained the cancer admission rates in high and low asthma
zones and found a 20-fold differential, ie the high asthma zone had a cancer admission rate that was
2,000% higher than the low asthma zone. Dr van Steenis also obtained the referral rates to consultant
psychiatrists for clinical depression in high and low asthma zones and found a nine-fold differential,
ie the high asthma zone had a referral rate that was 900% greater than the low asthma zone.
2.2 Dr van Steenis has shown that at least 20 illnesses/health parameters are caused by industrial
PM2.5s and the Shropshire Case Study, which started with childhood asthma, is detailing the
variation in rates of about half the list.
2.3 The devious role of the EA in public health was clarified during Prime Minister's Questions on
16 November 2005, when Tony Blair MP failed to confirm that the EA "must at all costs protect the
people . . ." in response to the question by Jim Dobbin MP. There is no protection from the EA, just
an illusion of protection to deceive the public.
3.1 I have replicated Dr van Steenis' asthma survey in Shropshire and obtained the percentage of
children in years 3 to 6 who bring inhalers to school for asthma. The highest was 100% in a school
immediately downwind of a brickworks. The lowest was 1.9% in a school that was upwind of both
the brickworks and also Ironbridge Power Station, the power station being a major source of
industrial PM2.5s in Shropshire. The asthma survey is reported at and the
variation in percentages of asthma inhalers brought to school can be seen to be higher downwind of
the power station, prevailing winds being mainly west-south-westerly, with north-westerly winds
being the second most common.
3.2 The rates of infant mortality by electoral ward were obtained and found to be higher downwind
of Ironbridge Power Station and the brickworks.
3.3 Telford & Wrekin PCT's 2004 report included ward maps showing highest premature death
rates due to both cancer and also coronary. These high death rate wards coincided with wards with
high infant mortality and were also in locations with high childhood asthma.
3.4 Dr Dick van Steenis and I met Michael Gwynne (Coroner for East Shropshire) on 27 June 2005
and showed him the above data and Dr van Steenis gave his opinion that suicides would be mostly
clustered in the same electoral wards with high rates of infant mortality etc. Mr Gwynne was
sceptical, but offered access to his register and subsequent examination has proved Dr van Steenis to
be correct.
3.5 Dr van Steenis had earlier spoken to Dr Catherine Woodward at Telford & Wrekin PCT
regarding Ironbridge Power Station and a meeting was due to be held, but was cancelled by the PCT.
The patterns of illness and premature deaths in Telford & Wrekin must, or should, have been known
to Dr Woodward whose own 2004 report referred to high rates of suicide and infant mortality.
3.6 I have requested data from Telford & Wrekin PCT under Freedom of Information; some has
been refused (suicide data by electoral ward) and some was false (infant death data by electoral ward
failed to match that obtained from the ONS). I also received a threat of a libel action by the Chief
Executive of Telford & Wrekin PCT for suggesting in my letter that Dr Woodward was responsible
(through her negligence) for more deaths than Dr Harold Shipman.
3.7 The health parameters in Telford & Wrekin PCT that have been studied so far include: infant
mortality, stillbirth, childhood asthma, diabetes, COPD, suicide, sudden unexplained deaths, age
standardised mortality rates (ie life expectancy), premature cancer deaths and premature death from
coronary disease. The correlation of high rates of the above (most by electoral ward, two by GP
practice and asthma by school catchment) in the same locations should have been apparent to Telford
& Wrekin PCT and their forebears years ago.
3.8 I first raised the issue of excess deaths downwind of Ironbridge Power Station with Michael
Gwynne (Coroner) on 2 December 2004. Beacon Radio interviewed me on 14 February 2004 and
broadcast several news items about emissions on 15 February 2005 and included statements by
Richard Pennells [manager of Ironbridge Power Station], who stated the following in the 10.00 am
broadcast: "We monitor our emissions on a minute-by-minute asis, 24 hours a day, 365 days a year.
We can categorically prove we are not a danger to public health." I wrote to Richard Pennells and
also the EA after the Beacon Radio broadcast requesting copies of any medical reports that backed up
Richard Pennell's claims. Both declined to send me any medical report and I later discovered
[through the asthma survey and other health research under Freedom of Information] that no such
report can possibly exist unless it is fraudulent, because the PCT refuse to analyse their own data.
3.9 I have raised concerns about the "Unlawful killing of Shropshire citizens" with Shrewsbury &
Atcham Borough Council (SABC), Shropshire County Council, Bridgnorth District Council and
Telford & Wrekin Unitary Authority by e-mail in October 2005 but all that has happened is that
SABC have referred the matter to public health professionals, having earlier claimed on 13 October
2005 to "have been advised that the (medical) evidence does not support (my) concerns". SABC
failed to send me a copy of the "evidence" that must also be false, just like that which Richard
Pennells referred to on Beacon Radio in the broadcast of 15 February 2005.
3.10 There's a possibility that excess rates of sickness and premature death downwind of Ironbridge
Power Station, and other industrial processes around the UK, are known about but covered up. If that
is so, it's reasonable to assume that there might be bribery of certain officials responsible for
monitoring of airborne emissions or public health to do nothing. If there have been financial
inducements to public servants to turn a blind eye to the effects of emissions from Ironbridge Power
Stations, such an action is little different to a police officer who, although aware of a Dr Shipman-like
character murdering patients, allowing it to proceed in exchange for some financial reward from the
murdering doctor.
3.11 Simon Conolly, Chief Executive of Telford & Wrekin PCT, wrote the following to me on 13
June 2005: "Whilst the PCT retains an open mind on this subject (excess premature deaths due to
Ironbridge Power Station emissions), I should explain that your views that there are adverse effects
from the emissions (from Ironbridge Power Station) is at odds with the professional advice that the
PCT has allegedly received from the EA and the HPA. Accordingly, in order to use NHS resources to
the best effect, I am not prepared to ask my staff to become engaged in a detailed investigation unless
a clear and justified case is put to us that there may be harmful effects associated with the power
station emissions."
Mr Conolly's letter had earlier invited me to write to the PCT in order to "explain the scientific case
that you (ie Michael Ryan) are alleging in respect of the power station emissions". The data now
gathered is such that his only course of action would be to sack Dr Catherine Woodward and then
resign in disgrace. The removal of Dr Woodward and Mr Conolly is overdue because Mr Conolly has
admitted reliance on "professional advice from the EA and HPA" instead of looking at the facts,
many of which are published in Dr Woodward's public health report of 2004. If Mr Conolly had been
an effective manager, he'd have studied my letter of 4 June 2005 very carefully—then asked Dr
Woodward to investigate the possibility that emissions from Ironbridge Power Station might be
causing excess premature deaths. They should have intwerviewed Dr van Steenis and myself. If Dr
Woodward carried out such an investigation, she'd have reached the same conclusion as me in much
less time and thereby saved many lives.
Number of times in top 10 for birth defect rates (out of maximum of 8)
Primary Care Trust
City and Hackney Teaching
Tower Hamlets
Hammersmith and Fulham
Sutton and Merton
Haringey Teaching
Richmond and Twickenham
Waltham Forest
(highest 1998 to 2002)
(highest in 1996 and 1997)
(third highest in 2000 and 2001)
(second highest in 1996,1997 and 1998)
(second highest in 1999)
(fourth highest 2000 and 2002; fifth in 2001)
(highest in 1995)
(second highest in 2001 and 2002)
(seventh highest in 1999)
(joint fourth highest in 2002)
(fifth highest in 2000)
(third highest in 1998)
A Greater London map showing point sources of industrial PM2.5s would explain variations of birth
defect rates and other health parameters. Bexley is also affected by emissions from SELCHP
(Lewisham) and Littlebrook D Power Station. I raised these issues in my statement to the recent
public inquiry using unpublished ONS birth defect data—yet my evidence was wrongly criticised by
pro-incinerator "expert" Professor Jim Bridges, whose seven page report on my statement was
erroneous as detailed in the South London Mercury, 23 November 2005. Professor Bridges stupidly
quoted from non-existent published birth defect data for Bexley and then, through Lovells (his
solicitors), refused to retract his erroneous report after I reminded Professor Bridges that I had access
to unpublished ONS data.
Michael Ryan
December 2005
«Who controls the past, controls the future. Who controls the present, controls the past». George Orwell (1903-1950)
It's called a Cornwall Energy Recovery Centre. The expression “recovery” is second from bottom on the waste
hierarchy. Any heat and electricity generated is offset by the destruction of energy reserves embedded in the
burnt products. Account must be taken of a finite world and the true environmental and social price to be paid :
such as additional NHS costs, burdening the UK economy. The only recyclates from this CERC would be poor
quality ferrous material, extracted magnetically from the slag, alias Incinerator Bottom Ash, and this allegedly
inert residual waste, abbreviated to IBA, used to make low grade aggregate, mostly as a base or sub-base for
road construction. It's current safety status arouses serious, widespread, legitimate concerns regarding long
term effects of heavy metal contamination and possibly organic pollutants leaching into the environment. Untold
pressure from the waste industry means that none of these questions are properly addressed today.
For instance studies of IBA have encountered List I substances, including furans and dioxins, amongst up to 31
toxic molecules or what are called Products of Incomplete Combustion (PIC). Also identified are a number of
heavy or so-called trace metal concentrates, notably Al, As, Cr, Cu, Mg, Mn, V (Cf. Van Buren et al 1985 Boegel
et al. 1987), with lixiviation giving rise to toxic leachates in even neutral pH conditions. In a February 2002
memorandum or brief status report provided for the CWLP public inquiry, Patrick Wheeler of AEA Technology
plc states that 50% of Britain's IBA is 'recycled' as 'low' grade' aggregate or roadstone.
He suggested that, despite 'marketing difficulties', the 'recycling' of IBA in the UK was increasing. At that time, of
an estimated 290 000 tonnes of illegally mixed fly and IBA, a 'significant proportion' were still unaccounted for in
the UK. Many were 'exported' from a SITA facility at Edmonton N18 3AG which had succeeded in 'reprocessing'
the entirety of the 150 kilotonnes of IBA produced there in 2001. Similar 'irregularities' were suspected of
arrangements between Ballast Phoenix and another site run by a subsidiary of SITA-Suez Lyonnaise des Eaux.
Cleveland Waste Management operate the EfW facility at Billingham TS23 1PY and argued for low-grade use
for IBA. Asked whether bottom ash was tested for dioxin before 'recycling' Jon Garvey, former regional manager
of SITA based at Teeside, seems to have responded with : “We haven't tested for dioxins, because they're
assumed not to be there”. (Cf. You and Yours 23 May 2000 BBC Radio Four). According to David York of Ballast
Phoenix all of the 80 kilotonnes of ash produced in 2001 from the Tyseley EfW plant - joint-owned by
Birmingham City Council and Onyx Aurora - were 'reprocessed'. Following the July 2001 BBC Newsnight report
on the fate of the contaminated residuals from Edmonton, 'reprocessing figures' for IBA from Onyx-Hanson,
concerning their Lewisham SELCHP site the amounts had dropped dramatically from 20 to only 4 kilotonnes.
Such developments might help to explain the official secrecy on so many 'unauthorised exemptions' from 'best
practice' at Edmonton and elsewhere and which appears designed to preserve the 'market value' of 'recycled
incinerator ash'. What price the unspecified quantities and categories of toxic waste which are alleged as having
been 'imported' from Edmonton for disposal as bituminous filler for the Dagenham Ford Works parking lots as
well as 'inert cover' at Cleanaway's 'controlled' land fill site at Pitsea, Basildon Essex SS16 4UW ?
Understandably alarmed at the effects on public opinion of these revelations, government and industry have
been desperate to present such usages as being 'not good practice'. Unfortunately bad habits always die hard
and the continual prospect of self-regulation leaves the door wide open to more abuses. Nothing can allay
public mistrust in the wake of so many of these allegedly discontinued examples of operators - including really
big names like Ballast Phoenix and SITA UK – notably at the Edmonton EfW incinerator - involved in mixing
illegally fly and bottom ash to sell concrete blocks and aggregate for road construction and car parks. In the
case of the Byker refuse derived fuel facility in Newcastle, highly toxic mixtures of APC residues, heat recovery
ash and IBA were spread on public footpaths and allotments. Paradoxically, children under 10 years of age
were removed from the parameters of the health impact assessment protocol for this seven year long 'pollution
incident' involving public thoroughfares and food producing areas dangerously contaminated with heavy metals
plus dioxins and furans with levels ranging from 0.02 to 9500ng/kg 1-TEQ (Cf. Pless-Muloli et al. 2001-2003).
A more detailed account of the circumstances and contamination ensuing from events at Byker and Edmonton
are provided in the notes and elsewhere in this submission. [1] As is a brief discussion of the toxicological status
and behaviour of TCDD dioxin and analogous PIC substances. Richard Clapp, a distinguished Professor of
Environmental Health at Boston University School of Public Health, describesTCDD dioxin - the most feared
member of a conspicuously stable and reactive family - as the Darth Vadar of man-made pollutants [2].
“Civil disobedience is not our problem. Our problem is civil obedience. Our problem is that numbers of people all over the
world have obeyed the dictates of the leaders of their government and have gone to war, and millions have been killed
because of this obedience.Our problem is that people are obedient all over the world in the face of poverty and starvation
and stupidity, and war, and cruelty. Our problem is that people are obedient while the jails are full of petty thieves, and all
the while the grand thieves are running and robbing the country. That's our problem” Failure to Quit by Howard Zinn (19222010) Professor of political science Boston University, historian, playwright, and social activist. Ex-bombardier in the 490th
USAF Bomb Group, participated in one of the first military uses of napalm, which was over Royan in France in April 1945.
Waste incineration is a political and cultural hangover from an outdated industrial era. It remains economically
feasible only if one accepts the hypothesis that unacceptable health and environmental costs are externalised ie
borne by the public purse, which thus carries the corporate can of worms and the long term knock-on effects of
chemical body burdens. APC requirements moreover contribute a major proportion to the expense of operating
heavy plant, be they cement kilns, MSW incinerators or landfills. Basically the SITA proposals redistribute and
concentrate the toxic charge dormant in Cornwall's waste. In other words the decades of combat necessary to
prevent fugitive and deliberate releases from incinerator dumpstacks was to focus most of the environmental
movement's publicity and the public's attention on airborne releases. This development intensified the toxicity of
incinerator residues about which government and industry are in denial. Because, contrary to what is stated
officially on the CERC by Cornwall's trusty self-elected mandarins within the WDA at New County Hall, the main
hazardous property of fly ash isn't its alkaline nature (Cf.
As Greenpeace have correctly pointed out most mass balance inventories gauge only dioxin output to the
atmosphere (Cf. National and regional dioxin and furan inventories H. Fiedler H 1999). Dioxin content in the
incinerator fly ash or slag and thence in the entirety of the biosphere is barely considered. (Cf. T. Webster and P.
Connett, Dioxin emission inventories and trends: the importance of large point sources, Chemosphere 37 1998).
It would seem therefore a fallacy to suggest that the total releases of dioxins, whether adhering to respiratory
aerosols or entering the environment and food chain have declined. Firstly because, even if emissions air via
stack gases may have decreased because of improvements in air pollution abatement technology– although the
health and safety implications of this assertion are based essentially on hearsay and are debatable, given the
reliance on spot checks, programmed as calendar events, the absence of continuous monitoring and a refusal
to admit independent health study data around existing incinerator facilities, as well as combustion upsets and
pollution from other technical hiccoughs – releases of dioxin to the environment with the ashes could have, in all
probability, just as easily increased. Moreover the bigger the facilities the wider the potential margin for error.
The specious arguments are perpetuated by well oiled corporate spin funded from the proceeds of an extremely
lucrative industry. Despite appearances ie the cosmetic and illusory effects of atténuateurs de fumée and plant
silhouettes fastidiously designed by architects and engineers to lull people into a false sense of security, the
current disposal methods use parallel routes or pathways to arrive in the end at the same environmental fate.
Understandably PR fails to allay the well founded fears of host communities. Efforts to 'build public confidence'
continue nonetheless unabated as the mistrust reflects the failure of APC systems to abate the release of lethal
nanoparticulates in flue gases and the contaminants in the 'reprocessed ash residuals'. Like baubles distributed
to the suspicious natives, the emphasis is on gadgetry, 'state-of-the art palliatives' , deployed to sweeten the
bitter pill by producing marginal amounts of so-called energy from waste. The net result is trashed environments
and unremitting sources of persistant organic pollution - made tolerable - only if we dispense with the idea of
considering people and other life forms as viable biological entities, but treat them too as disposable objects.
Britain and other EU member states may have stopped the barbarous practice of dumping sewage in the sea.
Governments in Europe and a certain Waste Disposal Authority in Cornwall contemplate with equanimity the
prospective use of the air we breathe, food and water we consume, our own persons and our children's bodies
as repositories for the poisons manufactured by groups such as SITA UK and their rivals Onyx-Veolia, TIRUEDF and the Waste Recycling Group. The latter, now like Fosca, part of a vast Spanish construction and
services empire, FFC alias Fomento de Construcciones y Contratas, run the macabre Eastcroft facility.
In February 2009 Hazel Blears quashed Nottingham City Council's planning decision to refuse WRG permission
to expand. “Nottingham Against Incineration and Landfill” hit the nail on the head when they say: “Incinerators
do not destroy waste. Our rubbish still exists. We just see less of it. We end up inhaling and eating it”.
“The magnitude of the association between fine particulates and mortality suggests that controlling fine particulates would
result in saving thousands of lives each year”. Joel Schwartz, Francine Laden and Antonella Zanobetti : “ConcentrationResponse Relation between PM2.5 and Daily Deaths” : Enviromental Health Perspectives Vol 110 Number 10 October
2002 (Cf.
“Incinerator plants are the source of serious toxic pollutants : dioxins, furans, acid gases, particulates, heavy metals and
they all need to be treated very seriously. There must be absolute prioritisation given to human health requirements … and
the protection of the environment ... I repeat that the emissions from incinerator processes are extremely toxic. Some of
the emissions are carcinogenic. We know scientifically that there is no safe threshold below which one can allow such
emissions. We must use every reasonable instrument to eliminate then altogether. It is the overall impact, deposition of
substances of different kinds on the environment and the cumulative impact that we do need to be convinced about”.
Evidence from Michael Meacher MP, House of Lords inquiry into Waste Incineration 14 April 1999 (HL Paper 71 p 108).
It is a question of preventing avoidable diseases and numerous early or premature deaths and there is every
reason to believe the sincerity of the above testimony from the former Secretary of State for the Environment.
The UK incinerator building programme – including Cornwall's facility - increases particulate pollution, axes life
expectancy and is at odds with the best science. Present Air Pollution Control (APC) regulations were a belated
response to decades of public concern, regarding the dumpstacks of literally scores of EU and UK incinerators
uninhibitedly spewing out dioxins and dioxin-like substances into the environment and entering the food chain.
We now realise the extent to which this concession to public health falls short of basic industrial hygiene. The
US National Ambient Air Quality Standard for PM 2.5 particulates was introduced into the USA in 1997
with a mean annual limit of 15g 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 12g 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 25g per cubic metre. Many will wonder why the difference is so vast when the science is the same.
Moreover while the EC directive sets no enforcable limits either on either PM10 or more appropriately PM2.5
particulate emissions, developments in so-called innovative technology mean that the contents of mixed waste
streams produce molecules which are not recorded in the original regulatory protocols and which are not
incorporated in would-be presciptive anti-pollution measures. Certain chemicals exhibit behaviour similar to
those listed under Annex C of the Stockholm Convention : for example : polychlorinated napthalenes (PCN),
polybrominated dioxins and furans (PBDD/F and PCBDD/F), polyaromatic hydrocarbons (PAH).
Listed by Greenpeace [3] the Products of incomplete combustion which legally may be released unabated from
incinerators are too numerous to mention. The pervasive use if brominated flame retardants (PBDE and HBCD)
suggest these also should feature in Annex B of the Stockholm Convention [4]. Very few incinerators are tested
under their normal operating conditions for different reasons : spot checks organised as calendar events,
absence of continuous monitoring. [5] Advising operators of time and dates of routine visits, as permitted or
stipulated by current EC legislation, allows them to accordingly adjust the MSW feedstock.
Laboratories delegated to analyse data have in the past actually proven to be subsidiaries of the companies
being 'controlled'. The system is further flawed by numerous examples of demonstrable complicity or negligence
on the part of the Environment Agency – like their predecessors at HMIP. No account is taken of combustion
upsets, multiple technical hitches involving emergency shut downs and start ups, turbo-alternator incidents
necessitating the bypassing of APC systems. This has occurred with SITA on 26 June 2002 at the Ocreal plant
at Lunel-Viel, operated by their subsidiary Novergie (Cf.
In the unlikely event of a successful prosecution, penalties for operators of EfW sites have no deterrent value.
The £5000 fine for Contract Heat and Power (CHP) at Byker being typical, with Dame Barbara Young herself
describing the sum as “piffling”. What the head of the Environment Agency didn't say was that her Executive
Non-departmental Public Body is accused of doing a deal with the culprits, withdrawing seventeen of the
criminal charges and witholding vital evidence. As the late Alan Dalton showed when quizzing HSE officials at a
press conference, ordinary citizens could serve a gaol sentence for nonpayment of a TV licence, yet no
employer had ever been jailed after a worker's death. At the time the construction industry alone was killing 150
workers a year. The trade-unionist alias veteran safety and environmental campaigner was to be later fired by
Sir John Harman, his immediate boss at the Environment Agency, for publishing a scathing report, highlighting
apathy, inefficiency, backbiting and bullying in an organisation supposedly protecting the UK environment [6].
[1] For details of Byker cf. Chapter : CERC - A CASE STUDY BYKER. For details of Edmonton and Phoenix
[2] Dioxins and dioxin-like compounds are persistent organic pollutants. Polychlorinated dibenzodioxins - alias
PCDD or dioxins - are nominally derivatives of dibenzodioxin and polychlorinated dibenzofurans - alias PCDF
or furans - nominally a derivative of dibenzofuran. The latter, strictly speaking are not dioxins. But they have
dioxin-like properties. The family of these oxygenated molecules numbers all told 210. The difference between
75 PCDD dioxins and 35 PCDF furans is the structural assymetry of the latter which lack an oxygen bridge.
The most poisonous isomer – described by Sandemann et al. 1957 - is the 2,3,7,8-TCDD. It is extremely
stable chemically, insoluble in water and, as with most organic compounds, soluble in oils. These attributes
permit dioxins in soils to resist dilution with rainwater, causing them to seek and enter the fatty tissues in the
body. Toxicity derives from the compounds' ability to bind or bond with a particular type of receptor protein in
the body. Equivalents are calculated in relation to the TCDD dioxin, classified as a class I carcinogen, the
highest category of the IARC (International Agency of Research in Cancer). Only 17 of the 210 congeners
possess a chlorine atom in the position 2,3,7,8.This renders them strongly toxic, expressed as Toxicity
Equivalent. 1 ng TEQ signifies a PCDD/PCDF mixture corresponding to I nanogram of 2,3,7.8-TCDD dioxin.
[3] Cf. Individual compounds identified in the air emissions of a municipal waste incineration plant. Appendix B
Incineration and Human Health : State of Knowledge of the Impacts of Waste Incinerators on Human Health,
Michelle Allsop, Pat Costner and Paul Johnston. Greenpeace Research Laboratories Exeter University 2001
Dioxins and furans are Products of Incomplete Combustion (PIC). Other examples in MSWI exhaust fumes :
Polyaromatic hydrocarbons (PAH)
Polychlorinated naphtalenes (PCN)
Polybrominated diphenyl ethers (PBDE) aka Polybrominated biphenyl ethers (PBBE)
Halogenated phenols
Brominated and mixed halogenated dioxins (HBCD)
Polychlorinated dibenzothiophenes (PCDBT)
[4] The Stockholm Convention on Persistent Organic Pollutants is an international environmental treaty that
aims to eliminate or restrict the production and use of persistant organic pollutants (POPs).The convention, of
which the UK is a signatory, entered into force on 17 May 2004, with ratification by an initial 128 parties and
151 signatories. Co-signatories agree to outlaw nine of the dirty dozen chemicals, limit the use of DDT to
malaria control, and curtail inadvertent production of dioxins and furans. As of December 2008, there are 168
parties to the Convention, who agree to a process by which persistent toxic compounds can be reviewed and
added to the convention, if they meet certain criteria for persistence and transboundary threat. The first set of
new chemicals to be added to the Convention were agreed at a conference in Geneva on 8 May 2009.
[5] Spot checks carried out once or twice a year in accordance with regulatory prescriptions, do not give an
accurate estimate of incinerator emissions during start-up, shut-down or in combustion upset conditions, that
can be thousands of times higher than during steady-state operation ie when dumpstack testing is typically
accomplished. The work by R. De Fré, M. Wevers (Cf. Underestimation in dioxin emission inventories, 1998.
Organohalogen Cpds. 36:17-20) shows that a standard incinerator emission measurement according to the
European Standard Method EN1948, during a period of six hours resulted in an emission concentration of
0.25 ng TEQ/Nm³, while the average over two weeks in the same period, using the GFA AMESA method, was
8.2 to 12.9 ng TEQ/Nm³. This demonstrates that the standard measurement may underestimate the average
emission by a factor 30-50. All UK spot sample data are likely to underestimate true incinerator emissions.
[6] “Alan Dalton became a workplace safety and environmental campaigner for the British Society for Social
Responsibility in Science (BSSRS). While there, he was one of a small group behind a new grassroots safety
magazine, Hazards Bulletin, created as unions, for the first time, were given legal rights to participate in
workplace safety. Leading the BSSRS asbestos campaign through the 1970s, Dalton knew the asbestos
industry had money and influence and had resisted successfully attempts to impose stricter, more protective
workplace exposure standards. The industry was also doing a pretty good job of putting a healthy gloss on
what was already emerging as the most effective industrial killer of all times - responsible for more lost lives
than the Black Death. From the mid-1970s the UK's national newspapers were carrying full page adverts
telling us "We need asbestos," a claim criticised even then by the Advertising Standards Authority. The
industry campaign was aided by the co-option of its scientific and medical critics. Many ended their careers
hundreds of thousands of pounds richer as a result. Standing up to the asbestos industry could, by contrast,
be costly. Asbestos killer dust, Dalton's 1979 campaigning book on the industry's charm offensive, landed him
in court when he was sued for libel by Dr Robert Murray OBE, a doctor, one-time Manchester University
lecturer and government medical inspector criticised in the book for his pro-industry views and advocacy of
asbestos "safe use." Dalton lost, although more as a result of England's generous libel laws than any errors of
fact, and Murray was awarded £500. Murray's £30,000 legal bill, however, left Dalton and Hazards Bulletin
bankrupt. Murray, later to become a paid asbestos industry consultant, is now dead and discredited and
Dalton's charges have been repeated as fact in leading, peer-reviewed medical journals. This moral victory
was not much comfort to Dalton ...” Obituary : Alan Dalton (1946-2003) Cf.
“From its unmanned, automated weighbridge to its public access website with its daily emissions readings, it is a state-ofthe art facility. There's no self-effacement here : its award-winning design has a striking 70-metre stack ressembling a
Viking ship's sail, while the main building's curved roof line echoes the rolling hills behind it. An oil burner has been
installed simply to heat the gases to prevent them condensing in the atmosphere, in response to local concerns about a
visible plume (even though it is water vapour and poses no environmental threat).” (Cf. Waste Management March 2005)
The above prose is Maggie Thurgood, in a 21st century edition of the CIWM magazine [1], extolling the virtues
of the 60 000 tpa Manx incinerator run by SITA on a 25 year contract. Their EfW correspondent omits to feature
ultrafine PM 2.5 m respirable aerosols (10-9) released in flue gases. Presumably these do not show up in the
«daily emissions readings» from this moving grate appliance's dumpstack, nor in print-outs of the «continuous
monitoring data» for an 'Energy Recovery Facility' at Chineham, Basingstoke : one of Hampshire's three Onyx
plants with a joint capacity of 450 000 tpa and mentioned in the same article. SITA's scandinavian piece of
“cutting edge technology” on the Isle-of Man also has an automated weighbridge. Little scope for job creation
there. A fact which might seem to belie what is asserted on about an estimated 48 new
full-time jobs for the CERC. On the contrary once installed, with recycling levels falling, modern EfW facilities
generally require a maximum of four people to operate them during the day and just two on the night shift.
Any serious misrepresentation of the truth about a major industrial undertaking - already cloaked in secrecy albeit allegedly on the grounds of commercial sensitivity - is not conducive to health and democracy. The only
obtacles to this flow of misinformation and the retention of swaths of often vital information are the concerted
efforts of dedicated and mostly unpaid members of the public and not-for-profit organisations to brief fellow
citizens on dubious financial arrangements detrimental to the public good and damaging ecosystems in ways
which neither industry nor various levels of so-called sovereign government are prepared to acknowledge.
Largely concerned with their own economic survival, bigger environmental institutions like Friends of the Earth
or Greenpeace tend to distance themselves from day to day problems affecting communities hosting obvious
sources of pollution and with little access to the media. It is left to small grass roots campaigners who are, as a
rule, no match for the well-paid army of spin doctors, opposing them : be they drawn from academia, or elected
and unelected officials, accredited journalists and PR consultancies like Maggie Thurgood's. What effectively
constitutes a permanently mobilised propaganda machine helps drive a coach and horses through all attempts
to establish and enforce policies on genuine waste reduction in keeping with the wider public interest.
Not easy to recognise, their organisations and their members can be identified by their business associates,
committee membership, focus groups, press contacts, public interventions, media savoir-faire, enabling them to
portray themselves as possessing invaluable technical or scientific expertise, when what distinguishes them in
fact from ordinary citizens are undeclared or declared interests in a sector of the economy, whose corporate
aims and agenda they serve to the exclusion of most other considerations. Unaccountable to taxpayers directly
or indirectly financing their activities, rarely exposed to public scrutiny, these people use professional skills and
connections to routinely negotiate revolving doors between government and industry and are part and parcel of
a vast political and social experiment dating from the birth of the public relations industry - founded by 'father of
spin' Edward Bernays [2] among others - and which manipulates public opinion and manufactures consent to
the extent of removing any semblance of impartiality or rational objectivity from decision making processes.
The idea that key policy decisions on core issues can be derailed by what might be termed a caucus of snakeoil salesmen and women may seem preposterous to the unitiated. Yet given the quality of what is marketed as
planning, there is no other way of describing this blend of social engineering and political corruption. Listed
below in no particular order are the case histories of some architects of Cornwall's Waste Management Crisis.
Chris Maltbaek Linked to United Mines liaison group, 'options appraisal multi-disciplinary consultants' Fichter,
while employed by WDA as Integrated Waste Management Contract Manager, in November 2007 replacing
Niranjan Patel. First surfaced in March 1999 at Truro's Hall for Cornwall Public Meeting of Cornwall Waste
Forum as WDA Special Projects Manager. Two years prior to CWLP inquiry, he announces publicly LAWDC's
intention to build an EfW plant, that a site had been selected and the purchase to be completed before end of
summer. Ex-Veolia, AEA Technology, Babtie Group employee and panel guest on “Communication Forum” with
for theme “Changing public attitudes about Energy from Waste”. Part of Symposium at the Hilton London
Metropole entitled “Driving forward Waste Derived Energy, Heat and Fuel” dated 24-26 February 2010.
Howard Rose DMS Dip TP MRTP MIWM Planning Inspector Cornwall Waste Local Plan public inquiry MarchApril 2002, Truro, appointed - by the Secretary of State for Transport, Local Government and the Regions - to
'consider all uresolved objections to the First Deposit Draft and Revised Deposit Draft'. These numbered, all
told,1768, opposing 243 statements of support. By October 2001 only 66 objections had been withdrawn. At the
inquiry there were 571 oral and 895 written representations. The conduct of proceedings at Alverton Manor
Hotel and the Examining Officer's Final Report were impaired by a suspicion of bias. Fatal flaws of AEA's BEO
and BPEO studies were unequivocally substantiated by objectors. It was repeatedly demonstrated to the Local
Plan Inspector that Cornwall County Council had deliberately put the cart before the horse and were intent on
finalising an unreliable planning document before the basis of a viable Municipal Waste Management Strategy
(MWMS) had been formulated. Moreover this was their statutory obligation in line with guidance laid down in
Waste Strategy 2000 ie to define notably the Waste Planning Authority's recycling and composting objectives. A
brief, barely audible, declaration of interest – from Howard Rose announcing his membership of the Institute of
Wastes Management - at the onset of the hearings – neither absolves HM Inspectorate of their duty of care nor
makes this absence of impartiality any less suspect, both regarding the WPA's unashamedly corporate agenda
and the failure to consider objectively the views of a broad spectrum of objectors to both, fatally flawed, CWLP
drafts. Objectors mounted a robust defence of the wider public interest and were more numerous than those
producing statements of support. Redubbed the Chartered Institution of Wastes Management, the Institute of
Wastes Management was soon subject to a Memorandum of Understanding with the pro-incineration lobby
represented by the merged Environmental Services Association and the Energy from Waste Association. The
fudge at this stage of the planning process forged the knock-on effects responsible for the current impasse.
Niranjan Patel To appreciate the crucial part played by this Svengali-like personage, one has to be mindful of
the conspiratorial - not to say clandestine - way policy decisions were made within the WPA and the LAWDC to
slant the CWLP in favour of incineration. At fault firstly was the abiding, almost willful, ignorance of most County
Councillors and, secondly, the undue influence enjoyed by their technical advisers which prevailed through the
power wielded by unelected council officers, notably David Owens, to whom publicly the Chair of Planning Pat
Rowe was heard deferring at a plenary vote on the Revised Deposit Draft in May 2001 at New County Hall. It
was AEA Technology plc that produced the key “restricted-commercial” documents supposedly assessing the
Best Environmental Option (BEO November 1999), plus the Best Practical Environmental Option (BPEO) in
February and June 2001, the latter co-signed and reviewed by Niranjan Patel. Dismissive of alternative
technology, such as Anaerobic Digestion and separated at source kerbside collection, the flawed BPEO study,
taken as gospel, was designed to slant planning from the start in favour of a large centrally situated burner.
It should be recalled that CCC as the former WPA was the sole owner of an “arm's length” Local Authority
Waste Disposal Company - County Environmental Services and their subsidiaries Sid Knowles Waste Ltd,
Dave Peat Waste Ltd and Rag and Bone 2000. It came thereby to exercise near exclusive control of options
governing waste management and the environmental fate of many associated pollutants, notably arsenic. In
essence CES operated a monopoly and had a long history of discriminating against best practice, infringing the
human rights of the communities hosting their waste facilities notably at United Mines. CCC's resolve to impose
EfW as a synonym of incineration is evidenced by a confidential Executive Board Meeting of 12 July 2000,
convened to consider analysis of options for the procurement of an EfW plant for Cornwall, over 18 months
prior to the CWLP public inquiry in February-March 2002. County Solicitor Ian Kennaway apparently
recommended for agreement a Corporate Policy Option [2] including a retainer of up to £40 000 for financial
consultants Pricewaterhouse Cooper, a submission to the DETR developing an Outline Business Case for PFI
credits, a joint venture with a private company, invited to buy out 80% of the LAWDC, in exchange for a 25 year
waste disposal contract. The quid pro quo of this secretly arranged marriage was providing the bride with a
dowry ie inflating artificially the LAWDC's market value. Allegedly legal loopholes and an Environment Agency
not fit for purpose – allowed CCC to extend unlawfully - via an Environmental Impact Assessment Study of
insufficient quality and thoroughness - the lifespan of the United Mines waste repository, so as to deposit there
bulky, low grade IBA. By now Niranjan Patel was employed by CCC as their Integrated Waste Management
Contract Manager. Resigning in 2009, he appears to have been seconded temporarily to DEFRA and was last
reported - ploughing fresh pastures with his promotional EfW/PFI furrow - as part of PUK (Partnerships UK) for
“IEA BIOENERGY Task 36 : Integrating Energy Recovery into Solid Waste Management Systems”.
John Gummer MP Tory Environment Minister (1993-1997) Environmental Director of General Utilities, then
owned by Vivendi Universal, formerly Compagnie des Eaux, now ESA member Veolia Environment and Suez
SITA's big French rival. Its subsidiaries - formerly called Onyx Total Waste Management and Onyx Aurora Ltd.,
now in their present incarnations own, run or manage as joint venture companies several MSW facilities notably
in Sheffield, Tyseley in Birmingham, Lewisham in London and Hampshire including Winchester. Samples from
the latter in 1989 and 1991 - allegedly kept secret for four years by regulatory officials - reveal figures close to
those exceptionally high dioxin levels found in cow's milk (up to 1.9 pg TEQ/g whole milk, equivalent to 48
pgTEQ/gfat) sampled in dairy herds from farms in the vicinity of an incinerator at Coalite Chemicals Bolsover
Derbyshire, closed down in November 1991 (Cf. MAFF 1992, EA 1997, Sandells et al. 1997). At this time or
soon after - to accommodate operators of incinerators liable for prosecution for unauthorised emissions and
pollution breaches – the COT at HMG's behest - raises at the stroke of a pen – unproven, 'allegedly safe',
thresholds from 1 pg WHO-TEQ /kg/bw a day to 10 pg WHO-TEQ/kg/bw a day. The father of the Landfill Tax
was also chairman of, spun off quango, Producers Responsibility Group. This multi-layer
conflict of interest has a Minister of the Crown, linked to financial interests producing mountains of packaging
waste of high calorific value, on the payroll of another company burning the stuff and in office at a time when
UK incinerators were being closed down for non compliance with EU Directives even as the waste industry is
planning to restock Britain with a new generation of waste incineration facilities. As evinced by Waste Strategy
2000, proposing up to 128 incinerators and singing the praises of WRG's Eastcroft CHP plant in Nottingham
with special mention too for Onyx - Sheffield and SELCHP Lewisham – as well as Newcastle's Byker facility.
Earl of Cranbrook Chair 1999 House of Lords Select Committee on European Communities–Sub-Committee
C (Environment, Public Health and Consumer Protection ie a remit parallel to one vouchsafed Conservative
MEP Caroline Jackson in Brussels q.v.). Chairman ENTRUST (quango regulating environmental trusts under
the Landfill Regulations). Former Chair of Shanks & McKewan aka Rechem, past operator of more than 80 UK
waste treatment sites, now mostly hived off to one of three other major companies : SITA, Veolia, WRG. It
operated, at one point in time, three notorious hazardous waste incinerators ; Fawley in Hampshire, Pontypool
in Gwent and a third 'high temperature incineration site' was at Bonnybridge 4 miles west of Falkirk. This was
inaugurated in 1975 and very soon became subject to a high profile protest, studies of poor animal and human
health, a government report, legal action by a farmer and national exposure in the media. It was closed in 1984
officially for 'financial reasons', after a workforce walk-out on health and safety grounds. Ian Craig (haulage)
then bought the land. Until at least 2002 the Shanks group was also running two MSW incinerators : at Sutton
Coldfield in the West Midlands and at Stewartby, Bedfordshire. They also ran the 'clay-lined' specialist landfill
site at Pen-y-Bont, near Wrexham. Approved in 1992 by the then Secretary of State for Wales Sir David Hunt,
the facility's located 50 yards from a source of municipal water abstraction - the River Dee - supplying two
million people in Clwyd, Chester, Merseyside and the Wirral. (Cf. TOXCAT VOL.2 NO.15). Lord Cranbrook in
1999 was also Vice-President National Society for Clean Air and Environmental Protection (NSCA), Honorary
Fellow, Institute of Wastes Management - now the Chartered Institution of Wastes Management, Honorary
Fellow, Chartered Institute of Water and Environmental Management. In December 2009, Carlyle, the US
private equity group, made a bid for the Shanks Group plc, said to operate in the Netherlands and Belgium and
the UK, where they purportedly employ 4500 staff in Argyll, Milton Keynes, Southampton, Essex and Glasgow.
Lord Derek Ezra of Horsham Chair of Dalkia plc, previously a division of Vivendi Universal, the former parent
company of Onyx, running EfW incinerators in Brest, North Finistère, Rennes, East Brittany, Sheffield and
South Yorkshire. Today the affiliate is controlled by Veolia and EDF and is accredited with 4200 facilities worldwide. The Combustion Engineering Association has bestowed upon the LibDem life peer an award for services
to industry. The former National Coal Board chairman was registered as chair of Sheffield Heat and Power Ltd,
located on one of thirteen Mass Burn Combustion sites listed as operational in1998 in Waste Strategy 2000.
Lord Chris Patten Director Energy Power Resources, an EfW company in 1999 applying for planning for a 400
000 tpa incinerator for Goole in the East Riding of Yorkshire. As Minister of the Environment in 1989 he set a
'non-statutory' recycling target of 25% for the year 2000. In 2002 the national average was still barely 9%.
Simon Charles Henry Rufus Isaacs Marquess of Reading, consultant UK Waste Management Ltd.
Earl of Arran Parliamentary Adviser Institute of Wastes Management.
Baron Hugh Cavendish of Furness Conservative life peer and director since 1993 of Nirex, referred to as the
independent nuclear waste agency or the 'firm' tasked with the 'disposal' of nuclear waste. Six years ago an
anonymous source at this Nuclear Decommissioning Authority described the situation of Britain's nuclear waste
storage as 'outrageous' (Cf. London Observer 30 June 2002). The news came with the findings of a report from
the Radioactive Waste Management Committee, which suggested that 88% of the stockpiled – intermediatelevel radioactive waste in Britain – 'equivalent in mass to 725 double-decker buses' - is stored in such
hazardous conditions at up to 24 UK locations - that it could explode or leak with devastating results at any
time. Given the failure to detect for a period of nine months a massive leak at Sellafield in April 2005 - involving
tens of thousands of highly radioactive liquid from a ruptured pipe at BNFL's controversial Thorp reprocessing
plant – and whose closure - when the time comes - will cost taxpayers billions of pounds, the UK clearly has
one of the worst-designed and thought-through systems of nuclear power production in the world.
Lord Lewis of Newnham In 1999 this Vice-President of NSCA was, like Lord Cranbrook, an Honorary Fellow,
Chartered Institute of Water and Environmental Management. Chairman of the Environmental Services
Association Research Trust, this self-same ESA is now merged with the Energy from Waste Association (EWA)
and subject to a Memorandum of Understanding with the Institute of Wastes Management, rebaptised the
Chartered Institution of Wastes Management. At the 1999 House of Lords hearings EWA's Ray Palin 'stressed
the importance of building public confidence'. He declared: “As more plants are built, so the uncertainties and
perhaps the fears in the abstract are seen to be misplaced”. Nothing today could be further from the truth.
Professor James Bridges Today a purportedly retired professor of toxicology at Surrey University, Guildford,
UK, with apparently no medical background, testified during US Occupational Safety and Health Administration
hearings in 1995 on the issue of indoor air quality and passive smoking. He there questioned the findings of
what was then a recent Royal College of Physicians study linking tobacco smoke inhalation to lung cancer.
Has sufficiently strong views to suggest that releases from waste incinerators pose no threat to human health
and that an estimate for a TDI of any chemical in the diet of a developing foetus would be possible, a task that
no credible scientist would undertake, if the cocktail effect is taken into account. Former chairman of the EU
Scientific Advisory Committee on Toxicity, Ecotoxicity and the Environment, he now chairs the EU Scientific
Committee on Emerging and Newly Identified Health risks. In a newspaper article dated 5 October 2009 he is
described by Neal Hall of the Vancouver Sun as a 'pro-incineration expert'. According to Port Moody resident
Elaine Gold - who holds a PhD in biochemistry : “He seems to be an apologist for industry” and spoke at a
series of public forums for a company - Metro Vancouver - aiming to build a 400,000 tpa plant in a region then
enjoying a waste diversion rate of 55 per cent. Britain's waste industry appears able to call upon his services
regularly as a 'risk assessment expert' to testify at inquiries concerning planning applications for incinerators. A
speaker on risk assessment methodology, health risks involved in waste management, he is a member of a UK
Advisory Committee on Toxic Substances, Air, Soil, Water Contaminants, Novel and Irradiated Foods and
chairs the Veterinary Residues Committee. At the House of Lords 1999 European Communities sub-committee
hearings - chaired by Lord Cranbrook of Shanks plc - he responded to a question about the USEPA's cautious
linear dose approach to setting acceptable standards for genotoxic carcinogens such as dioxins. Professor
James Bridges and Dr Robert Maynard (q.v.) both felt that whilst this attempted to extrapolate to low doses, the
resulting numbers were difficult to justify ; both supported the alternative business friendly European threshold
dose approach (Q 399). He is listed as heading the Environmental Advisory Board of Shanks Group plc.
Professor Roy Harrison Head of Division of Environmental Health and Risk Management at Birmingham
University since 1991. Like Professor Bridges, this consultant - who provides advice to the Health Protection
Agency - seems endowed with a kleptomaniac's capacity for collecting positions of trust and authority on
influential committees, like DEFRA's Expert Panel on Air Quality Standards and Air Quality Expert Group. The
latest HPA guidance appears heavily dependent on reviews from the Committee on the Medical Effects of Air
Pollutants (COMEAP) to which this Royal Society of Chemistry member was appointed 1st December 2006. It
had input from the Department of Environment's Quality of Urban Air Review Group (QUARG), of which this
'professional adviser' is a past chair, from his DETR Airborne Particles Expert Group, from his DEFRA funded
Advisory Committee on Hazardous Substances and his 2004 DEFRA-University of Birmingham-Enviros
“Review of Health and Environmental Effects of Waste Management : Municipal Solid Waste and similar
Wastes” : also nurtured by Maggie Thurgood, damned with faint praise by the Royal Society's peer review.
Dr Robert L Maynard UK Government's senior air quality health advisor, COMEAP member of the DoH funded
HPA. Toxicology expert with OPP (organophosphate poisoning) background and a special interest in respiratory
issues. So what links pesticides, acting like nerve gases, to pulmonary disorders or other diseases induced by a
miasma of exhaust fumes ? With just the whiff of a multidisciplinary approach, COMEAP, in their March 2001
report finally agreed that the total impact of airborne particulates is comparable to that of passive smoking, ie a
'substantial public health hazard'. The same COMEAP had likened 24 000 yearly air pollution deaths to an
'early harvesting' of people close to death anyway. Something Joel Schwartz (2000) disproved. As did the great
London Smog (Cf. Bates 1995 - doubling of infant and perinatal mortality). HPA quibbles about the possible size
of health effects around incinerators, permitting HM government and the waste industry to stonewall and stall
on remedial action. Such 'expertise' begs the question of why taxpayers should invest in the efforts of feckless
souls who fail to serve the wider public interest. For example the 2009 Health Protection Agency refusal (q.v.)
to recommend public health studies around modern incinerators, on the grounds that such facilities are well
managed : ergo any possible health effects are likely to be very small. The premise remains unproven and the
reasoning flawed. Not only is this plainly opinion based science, rather than science based opinion. Chemical
hygiene which relies exclusively on risk assessment and self-regulation does not stack up. Especially when the
aim of the exercise is public relations, dilatory policies, perfunctory monitoring and reckless management.
Professor Dame Barbara Clayton Honorary President of the British Dietetic Association. Former president
Royal College of Pathologists, past president of National Society for Clean Air and Environmental Protection.
NSCA Land Quality Committee. All told NSCA fielded five players at the House of Lords 1999 hearings.
Gev Edulgee, former ERM consultant, [4] with experience in hazardous waste treatment, joined SITA UK in
2001 as Technical Director. Now their External Affairs Director, he is guest speaker at a 27 March 2010 Waste
Management Conference organised by the Royal Town Planning Institute at Hatton Gardens, Central London.
Officially the guest list includes waste and environmental planners, waste managers, contractors, suppliers and
consultants plus, yes, environmental groups. But only top drawer people with industry sponsorship could
possibly afford the entrance fee of GB £489 +VAT. A move to deter grass roots activists and not-for-profit
organisations, ie the only ones with a financially disinterested approach to high profile public interest concerns.
Significantly the panel also includes Stephen Pratt, Principal Planning Officer, Planning Inspectorate and Chris
Saville, Policy Advisor, Waste and Resources Management, Environment Agency. [5] Their apparent remit :
how to counter or obstruct sustained public opposition to infrastructure proposals from an industry sector
lobbying Brussels to obtain a blanket system of 'integrated waste management'. Alias their incineration-led
policies which are the root cause of the antagonism they arouse. Greedy for an ever bigger slice of the cake of
a world in recession, facing the prospect of diminishing returns, dissatisfied with the speed of even the current
top down planning processes - driven by an exclusively commercial agenda and which tries to discount the will
of the people – multinationals of the size of GDF Suez and their affiliates are now clearly going for the jugular.
Journalists often accuse governments and industry of being in bed together. As bedfellows, money and politics
provide a contentious and complex subject area, notoriously difficult to pin down. It was Lord Acton who said
that all power corrupts and absolute power corrupts absolutely. Waste industry troubleshooters penetrate vital
organs of the body politic. Hand in glove with the efforts of MEP Caroline Jackson (q.v,) they seriously influence
'policy decisions' and infiltrate 'option appraisal' procedures. Cornwall's 'strategic policy' is skewed by talk of
targets designed to comfort purely market criteria. A new breed of private/public sector apparatchik operates via
the echelons of this 'waste hierarchy'. To consolidate an incestuous relationship between private and public
sector interests with a 'discretionary sense of public accountability' and absolutely no financial liability, such
operatives are legally permitted to jump from engineering consultancies or waste company directorships to jobs
in local government, as can be seen by the key appointments of serial 'movers and shakers' like Chris Maltbaek
– AEA/CES/CCC/United Mines liaison group/Managing Director Veolia Environmental Services/Onyx South
Downs Ltd/Divisional Director Babtie Group/Fichtner Consulting Engineers – like Niranjan Patel –
AEA/CCC/DEFRA/PUK etc. ; like Maggie Thurgood – temporary WDA appointee in Cornwall, a NSCA and PPS
Group consultant. The latter “a company of talented people working in the tougher areas of communications
consultancy. If you need an advocate to explain a complex issue in a coherent and compelling manner, then
PPS is for you ...”(Cf. Maggie Thurgood, similar to Niranjan Patel, an “AEA Technology
consultant, funded by DEFRA to assist Cornwall County Council 'communicate' on its PFI process...”
Such activity may be considered officially as perfectly legitimate freelance business. Yet the chameleon-like
trajectory of such 'checkered careers', bespeaks speculative planning driven by tyrannical business concerns.
Public distrust is natural given the way waste contractors and council delegates collude and conspire to
override or simply sidestep hostile public opinion, subverting consultation processes and the true public interest
by what smacks of an amalgam of sleaze and corporate osmosis, So-called free trade, reliant on a drip feed of
public money and captive markets to maintain otherwise unsustainable growth patterns, tampers dangerously
with public health, safety and welfare, undermines wholesome economies and is incompatible with democracy
Maggie Thurgood, has “worked in the waste sector since 1983, when she helped to establish The Warmer
Campaign and edited the Warmer Bulletin”. From June 2000 to May 2001- in the wake of the House of Lords
1999 hearings - she undertook research on behalf of the National Society for Clean Air and Environmental
Protection (NSCA), in 'partnership' with a group of 'interested organisations'. Published under the title “The
Public Acceptability of Incineration” (Cf., the
60 page report was part of a wider project which had been largely 'industry financed' – Cory Environmental and
SITA Environmental Trust, S Grundon (Waste) with contributions from the Environment Agency, Surrey CC,
East Sussex CC and Kent CC (Cf. http://www.imagespace,“She has over 10
years experience as a consultant, focusing on public engagement and the wider communication aspects of
waste management. She has worked for several waste disposal authorities as well as conducting research for
bodies such as the Welsh Assembly, and producing waste guides for DTI and DEFRA. She joined PPS at the
end of 2007 and helps to manage their private and public sector waste projects”.(http://www.futuresourceuk.
com/FUTURESOURCE/Conference/SpeakerBiographies/Maggie_Thurgood.aspx. On the Staff of the PPS
Group - employed or sub-contracted - she provides 'PA consultancy services' (cf.
index.php/PPS_Group_UK_Clients_and_Staff_1.12.07_-_29.02.08). “Maggie Thurgood, an AEA Technology
consultant, funded by Defra to assist Cornwall County Council communicate on its PFI process, writes in this
month’s Wastes Management on “The Politics of Incineration” quoting how, in Aberdeen, planning failure for
EfW was attributed to “uncertainty of the region’s evolving waste strategy giving no clear policy steer to the
council”. It should be noted that Fosca and Sita also have expensive stalled incineration projects in Hereford
and Worcester and Surrey respectively, which have caused major problems with their contracts as a whole and
ongoing delays and missed targets. The problems are not going to go away simply by appointing a PFI
contractor to take responsibility for Cornwall’s waste ...” (Cf. As NSCA
Project Consultant Maggie Thurgood said that the public are unaware of what happens to their waste, but that
the more informed they are "the more likely they are to support the use of waste incineration as one part of an
overall waste strategy". Adding that the concerns over incineration come in the form of : emissions and health,
conflict with recycling, where contractual ties may require waste to be incinerated in preference to an expansion
of recycling and Local Authorities may take the ‘easy’ option of incineration ; local impacts, including impacts
on property values and aesthetic concerns ; the importing of waste from other communities, which is seen as
unacceptable ; and the transport of waste to the incinerator, causing noise, dust and congestion. Her NSCA
paper suggests that to increase public acceptance of incinerators, several factors should be considered :
incineration must reinforce and not jeopardise other waste strategies ; the public must be involved at the
earliest stage of decision-making ; information, such as on environmental impacts and emissions should be
available, honest and trustworthy ; and developers must be sensitive to community concerns, for example a
small incinerator may be acceptable where a larger one would not be. Friends of the Earth (FOE) slammed this
NSCA report as "poorly written, un-referenced, and grossly misleading". (Cf.
Maggie Thurgood
Maggie Thurgood helped conduct a 'focus group' study in 2005 which polled 'overwhelming' support for EfW –
97% - at 27 locations in Cornwall. ( It would seem that such survey
results depended somewhat on the form and content of questions asked and how they were put to the public.
Caroline Jackson
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Caroline Jackson, MEP
Caroline Jackson (born 5 November 1946, Penzance, Cornwall) has been a British Conservative
MEP and a Member of the Parliament's Committee on Environment, Consumer Protection and
Public Health since 1984. She was Chair of the Committee (1999-2004), Conservative spokesman
on the Committee (1984-1999), and continues to be Conservative Party Environment
From 1999 to June 2004 she was chairman of the Parliament's committee on the Environment,
Consumer Protection and Public Health.
Member, Committee on the Environment, Public Health and Food Safety
Substitute, Committee on Transport and Tourism
Substitute, Delegation for relations with the People's Republic of China
Record and Controversies
Declaration of Financial Interests
Professional Activities:
• Chairman, Institute of European Environment Policy, London (non remunerated)
Paid Functions or Activities:
• Member of the Environmental Advisory Board of Shanks plc. (remunerated)
• Member of the Advisory Board of SITA UK (since September 2008) (remunerated)
Further Information:
• I have two assistants working in my Brussels office. The senior receives a salary in the £3040,000 band and the junior one receives a salary in the £20-30,000 band.
• I have a secretary working part time in Swindon who receives a salary in the £10-20,000
band. Their salary payments , PAYE etc are handled by a Swindon firm of accountants.
• I have a service provider contract with my part-time press agent who works out of
Okehampton. The sum he receives is in the £10-20,000 band.
• In 2006-7 I made three consultancy fee payments to my husband (each in the band £010,000) for his assistance in writing my pamphlet on waste management, and my report and
associated speeches and articles on the waste framework directive on which I am the
Parliament's rapporteur. There are and have been no other payments to family members or to
private companies.[3]
Background of Conflicts
Between 1984 and 1999, Jackson was responsible for Committee reports on landfill policy, product
safety, food additives, better protection for package tourists, and on the use of live animals in
experiments. In the mid-nineties, she was also a member of the board of car company Peugeot
Talbot (UK) Ltd, and a paid consultant with food giant Mars, the PR company Market Access
International, and the Brewers' Society.[4][5] Jackson argued that there was no conflict of interest
between these commercial posts and her role as an MEP.
When she became Chair of the Environment Committee Jackson resigned her Peugeot directorship
and declared: “Anyone who thinks I take instructions easily should ask my mother.”[6] Her critics
though point out that Jackson was still a consultant to Mars (UK) at the same time as being a
Member of the Environment Committee, which was dealing with issues such as the level of sugar
permitted in sweets and food additives.[7]
Register of Interests
• Ex-member of the board, Peugeot Talbot (UK) Ltd ( - Car
• Ex-consultant, Mars ( - Food Company
• Ex-consultant, Market Access International ( - PR
• Ex-consultant, Brewers' Society ( - Society representing interests of
independent brewing companies in UK
Conflicts of Interest
More recently Jackson acted as Rapporteur on the Environment Committee for the revision of the
waste framework directive – her draft report was published in June 2006 and final report in
December 2006.[8]
At the same time Jackson was a paid advisor to Shanks, an independent waste company based in the
UK and the Netherlands. Jackson is paid £6000 as a member of the company’s environmental
advisory board (EAB), a position she still holds.[9][10][11]
The head of the EAB, Professor James Bridges, acknowledges that Jackson’s views, including her
“wide knowledge of European legislation”, have “been a benefit to our work”.[12] In the company’s
2005/06 report, Shanks acknowledges that “plans to revise the EC Waste Framework Directive and
the revision of the Waste Strategy for England are just two examples testament to the continuing
changing face of waste management within Europe.”[13] A year later Professor Bridges wrote: “The
EC waste framework directive is also being revised and as the MEP within the European Parliament
responsible for the revision of the Directive, EAB member Caroline Jackson was able to keep us
updated on progress during the year. This will have far-reaching implications for waste management
and the EAB will consider its impacts on Shanks activities in the UK and mainland Europe.”[14]
So there is a complicated situation that the Rapporteur for a report on waste is a consultant to a
company that could be impacted by that report.
Moreover, the Chief Executive of Shanks, Michael Averill is also the President of the European
Federation of Waste Management and Environmental Services (FEAD), which represents the
European waste management industry. FEAD ran a ‘consultancy group’ that looked at Jackson’s
report as well as lobbying Jackson herself three times. So the Rapporteur of a report on the waste
framework directive has been lobbied by the industry group headed by the boss of a waste company
where she is a consultant.[15]
Jackson maintains that there is no conflict of interest as Shanks has no interest in incinerating waste,
which was the main subject of her report. “There is no conflict of interest because Shanks is not
really involved in the kind of waste treatment activities that are touched on by the waste framework
directive,” she argues.[16] But Shanks does have some incineration interests. On its website it says
that it “remediates PCB and pesticide contaminated soil through high temperature incineration at
dedicated facilities in the UK and the Netherlands.”[17] In her defence, Jackson also argues: “I have
never received any instruction or advice from Shanks.”[18]
Record of Parliamentary Votes
• Voted against the directive on "establishing a framework for Community action in the field
of water policy" (A5-0027/2000). The directive covers all water management aspects in
order to achieve a 'good status' of all waters by 2015.[19]
• Voted in favour of the directive on "national emission ceilings for certain atmospheric
pollutants" (A5-0063/2000). The amendment allows setting less ambitious national emission
ceilings for sulphur dioxide (SO2), nitrogen oxides (NOx), ammonia (NH3) and volatile
organic compounds (VOC), which would result in more damage to human health and the
Voted against the directive on "waste electrical and electronic equipment" (A5-0100/2002).
The amendment sets higher reuse and recycling rates for IT and telecommunication
equipment.[21] Rejected due to lack of absolute majority.
Voted in favour of the report on "Community guidelines for the development of the transEuropean transport network" (A5-0135/2002). The Trans-European Network of Transport
(TEN-T) is a network of so-called 'transport corridors' through Europe. This amendment
calls for a full Strategic Environmental Assessment of these transport corridors and calls on
the Commission to improve methods for analysing the environmental and economic impact
of the TEN-T.[22]
Voted against the regulation concerning "traceability and labelling of genetically modified
organisms and traceability of food and feed products produced from genetically modified
organisms" (A5-0229/2002). The amendment allows customers the right to choose GM free
Voted against the report towards a "thematic strategy on the sustainable use of pesticides"
(A5-0061/2003). The amendment proposes to ban or severely restrict use of pesticides in
areas around sources of drinking water and nature protected zones.[24]
Voted against the directive on "environmental liability with regard to the prevention and
remedying of environmental damage" (A5-0145/2003). According to the amendment,
polluters have to pay for environmental clean-up, and it supports an EU-wide regime which
makes polluters liable for the damage they cause to wildlife, water and land.[25]
Voted against the directive on restructuring the "Community framework for the taxation of
energy products and electricity" (A5-0302/2003). The amendment aims at giving tax benefits
to environmentally friendly sources of energy, which would make them cheaper and more
competitive to conventional (more polluting) sources of energy. It also gives tax benefits to
environmentally friendly uses of energy for transport, for instance trains.[26] Rejected due to
lack of absolute majority.
Personal Information
Curriculum Vitae
• MA (1969).
• D.Phil. (1979).
• Member of the European Parliament (since 1984).
• In the European Parliament: Chairwoman of the Committee on the Environment, Public
Health and Consumer Policy (1999-2004).
Parlement européen
Bât. Altiero Spinelli
60, rue Wiertz / Wiertzstraat 60
B-1047 Bruxelles/Brussel
+32 (0)2 28 45255
[email protected]
Bounds, Andrew, "MEP on waste company payroll," Financial Times, 13 June 2008, accessed 11
November 2008.
• Caroline Jackson, About Caroline Jackson, Dr., accessed 11 November 2008.
• European Federation of Waste Management and Environmental Services, FEAD Bulletin, 21 June –
10 November, N°15, 2006, accessed 11 November 2008.
• European Parliament, Committee on the Environment, Public Health and Food Safety, Draft
Report on the Proposal for a Directive of the European Parliament and of the Council on
Waste, 15 December 2006, accessed 11 November 2008.
European Parliament, Declaration of Member’s Financial Interests: Caroline Jackson, 04 March
2008, accessed 11 November 2008.
European Parliament, Declaration of Members' Financial Interests: Caroline Jackson, 23
September 2008, accessed 10 February 2009.
European Parliament, MEP Directory: Caroline Jackson, accessed 11 November 2008.
European Parliament, MEP Directory: Caroline Jackson, accessed 10 February 2009.
Friends of the Earth, EU Vote Watch, accessed 10 February 2009.
Rowell, Andy, "Too Close for Comfort?" Spinwatch, July 2008.
Shanks Group plc, Background, accessed 11 November 2008.
Shanks Group plc, Remediation, accessed 11 November 2008.
Shanks Group plc, "Safety, Health and Environment Report 2005/2006," accessed 11 November
Shanks Group plc, "Safety, Health and Environment Report 2006/2007," accessed 11 November
[1] Chartered Institute of Wastes Management. “The CIWM Journal is distributed monthly to waste
professionals all around the UK and abroad. With a print run of over 7,000 and a readership of almost
20,000, you can be sure your advert will be seen by key players in the industry”
[2] Edward Louis Bernays (November 22, 1891 – March 9, 1995) was an American pioneer in the field of
public relations along with Ivy Lee, referred to in his obituary as "the father of public relations". Combining the
ideas of Gustave Le Bon and Wilfred Trotter on crowd psychology with the psychoanalytical ideas of his
uncle, Dr. Sigmund Freud, Bernays was one of the first to attempt to manipulate public opinion using the
subconscious. To learn more The Century of the Self is a British television documentary film by Adam
Curtis. It was first screened in the UK in four parts in 2002. "This series is about how those in power have
used Freud's theories to try and control the dangerous crowd in an age of mass democracy," says Adam
Curtis in his introduction to the first episode. Cf.
[3] The relevant four pages of this Confidential Report Reference No. RPR 0006 to Executive Committee and
dated 12 July 2000 can be accessed on
[4] Environmental Resources Management consultants (ERM) are believed to have sold - WRATE (Waste
and Resources Assessment Tool for the Environment) - their life cycle assessment (LCA) software system or
engineers modelling kit to both SITA and the Environment Agency. The latter relinquishing Wisard, kindred
weaponry, used in the AEA Technology 'BPEO options appraisal' for CCC. All of which would seem to confirm
suspicions of an unhealthy, overtechnical and incestuous liaison between planners, regulators and their main
clients, begging the question of reliability and independence, of 'revolving doors' between government and
industry, in the development of planning criteria for infrastructure needed to protect the public interest.
[5] “The waste agenda continues to change. Brussels is about to adopt a new Waste Framework Directive
that will introduce new targets and reinforce the requirement for a comprehensive framework of waste
management plans in the UK. Whilst planning authorities are struggling with the new planning system in
bringing forward plan. Meanwhile infrastructure proposals are coming forward from industry, but there is no
relaxation in public opposition to these. This conference will provide delegates with the opportunity to discuss
these challenges with key government officials and players from the Environment Agency, the waste industry
and local planning sectors”. 27 March 2010 Waste Management Conference organised by the Royal Town
Planning Institute at 51-53 Hatton Gardens, London, EC1N 8HN Chancery Lane, Farringdon. GB £489 +VAT.
Conference chair : Richard Read, Head of Planning and Development, Hampshire County Council. Speakers
: Gev Edulgee, External Affairs Director SITA UK ; Rod Bull, Eversheds, Lester Hicks, Consultant ; Simon
Goldsmith, Technical Director, Environmental Planning and Sustainability, Mouchel ; Stephen Pratt, Principal
Planning Officer, Planning Inspectorate ; Mark Plummer, Team Leader Minerals, Waste and Pollution Control,
Communities and Local Government ; Chris Saville, Policy Advisor, Waste and Resources Management,
Environment Agency. (Cf.
“In conclusion, it seems, in the light of current knowledge and in view of the small quantities involved, that we have the means
to identify and control the risks associated with dioxins, and that these substances do not pose a major public health problem
(…) Rather than imposing predetermined, unnecessarily restrictive regulations, we recommend progress contracts, between
the State and municipalities or intermunicipal organisations, that would encourage the adoption of the most efficient and best
adapted technologies”. Dioxin and its analogues CADAS- Académie des Sciences Joint Report N°4 dated September 1994
DEFRA in 2004 and the HPA in 2009 minimise the biological impacts of incineration. They preach risk management
or cure rather than prevention or the removal of obvious sources of danger. Singing from the same hymn sheet, the
above quotation embodies the conclusions and recommendations of a treatise from the Comité des Applications de
l'Académie des Sciences. Beneath a scientific veneer, the paper conceals the toxicity of TCDD dioxin and dioxin-like
substances and is designed to protect the turnover of groups like Veolia, SITA ,TIRU-EDF, or their predecessors, in
France running, between them in 2000, the biggest number of Europe's MSW incinerators : a massive total of 210.
Its armchair audit dismisses in a tiny paragraph, “de novo” synthesis – the formation or reformation of dioxins “from
their constituent elements : carbon, oxygen, chlorine”, known to occur in the gases cooling within the electrostatic
precipitators (EPC) - ie the very units supposed to cleanse or purify dumpstack emissions. It then justifies a refusal
to investigate further this phenomenon of chlorination or electrophilic dechlorination, on the grounds of “the extreme
complexity of reaction conditions in real environments (sic)”. The sleight of hand recalls similar repeated professions
of faith and spoof chemical trials. For example “The Trace Chemistries of Fire”, to wit the Dow Chemical Company's
1978 attempt to debunk Rachel Carson's wake-up call on organochlorines and organophosphates, to regild their
tarnished image and cloud the issue on the pollution of the Tittabawasse River skirting their vast industrial complex
in Michigan. Their experiments using pure dioxin applied directly to the skin of US prisoners in Pennsylvania seem
to have inspired Professor Dame Barbara Clayton's lugubrious and sinister contribution to the House of Lords [1].
The waste and chemical industries are forever anxious to see off moves to regulate more effectively their lucrative
but highly dangerous sources of income. The CADAS working party comprised names from Atochem, Dow Europ
and Rhône-Poulenc. Moreover this sleek 110 page document was a direct response to USEPA funded research
which had acknowledged and confirmed TCDD dioxin as a potent cancer enhancer or promoter. Thumbing their
noses at the Americans, the French team were telling colleagues in the field of chemical engineering exactly what
many of them would have wanted to hear. Indeed the work of one initial contributor, CNRS toxicologist André Picot,
was so out of tune with this rosy picture, that either he withdrew or had his name excised from the final draft.
Evidence of spurious science from Paris in1994 and Professor Dame Barbara Clayton's amateurish and misleading
comments on the subject five years later in London, [2] provoked Dr Linda Birnbaum, a leading USEPA authority on
dioxin and dioxin-like compounds, to make her research more familiar to the public. She is on record as saying : “We
know that in animals in prenatal exposure, or should I say perinatal exposure actually, both prior to and shortly after
birth in animals, leads to permanent suppression of the immune system and this never goes away. We have
followed the animal up to 18 months of age and their immune system still doesn't function properly”. Her words at
'The People's Dioxin Action Summit, University of Berkeley California 10-13 August 2000 ought to have reached the
ears of the people who needed it most, like those exposed for years to the plume of facilities like Gilly-sur-Isère, or
to the mixed ash from Byker and Edmonton. Part of a government team, this highly respected senior American
scientist had studied the health impact of TCDD dioxin for a decade or more. Two years after declaring TCDD dioxin
to be 'much more toxic than previously known' in September 1994 the USEPA, for whom she worked, described the
molecule as 'a serious public health threat'. This laboratory work, conducted under their auspices, had led USEPA to
slash the recommended TDI for TCDD dioxin to 0,0064 pg/kg/day. A decision which elicited. in turn, this desktop
analysis from the CADAS and in character with the reactions in 1999 of Professor James Bridges and Dr Robert
Maynard supporting the alternative - more corporate friendly - European threshold dose approach.
Incinerator and landfill operators exploit uncertainties about their pollution levels. Given what is known regarding the
nature of chemical body burdens comprising up to 400 man-made substances - heavy metal compounds, dioxins,
PCB, DDT and other pesticides, the official talk of remedial action and Tolerable Daily Intake shows the degree of
contempt with which host communities are held. Since 1992 much has been learnt about transplacental hormone
disruption. The detection of so many xenobiotic molecules in the stools of newborn babies [3] should constitute an
unequivocal hazard warning. Instead the official line seems to be that postpartum meconium analysis is a relatively
new and sensitive tool to detect foetal exposure to environmental toxins. Its clinical use awaits further investigation.
Human and environmental health are treated as if they were mere commodities or a simple question of amenity,
rather than irreplacable assets, notably in beings with patently immature endocrine, immune and nervous systems.
[1] “Dow Chemical Company produced the herbicides 2,4,5-T and Agent Orange, the defoliant that was sprayed
on the jungles of Vietnam. Both herbicides are contaminated with dioxin during the manufacturing process.
In 1965, Dow conducted a series of experiments to evaluate the toxicity of dioxin on inmates at Holmesburg prison
in Pennsylvania. Under the direction of Dow researchers, pure dioxin was applied to the skin of prisoners.
According to Dow, these men developed chloracne but no other health problems. But no health records are
available to confirm these findings, and no follow-up was done on the prisoners, even after several went to the
EPA after they were released seeking help because they were sick. EPA did not help them (Casten, 1995) …
In 1976, Dow began studies to evaluate whether animals exposed to dioxin would develop cancer. Dow chose
very low exposure levels, perhaps anticipating that the studies would show no toxic effects at low levels. Much to
their surprise, they found cancer at very low levels, the lowest being 210 parts per trillion (Kociba, 1978) ...
In November 1978, after an intense four and one half month effort that cost the company $1,8 million, Dow
released a report called the "Trace Chemistries of Fire," (Rawls, 1979) which introduced the idea that dioxin was
present everywhere and that its source was combustion and any and all forms burning (Dow, 1978). Dow released
the report at a press conference rather than in the scientific literature, which is the standard procedure with
scientific studies. The report concluded that dioxin in the Tittabawassee and Saginaw rivers came not from Dow,
but from "normal combustion processes that occur everywhere." A Dow scientist stated at the time that, "We now
think dioxin have been with us since the advent of fire. Subsequent studies have proven the "combustion theory"
claims to be more public relations myth than scientific fact. Measurements of dioxin in lake sediments show that
dioxin levels dramatically increased after 1940, (Czuczwa, 1984, 1985, 1986) when chemical companies such as
Dow began to make products contaminated with dioxin”. (Cf.
[2] Professor Dame Barbara Clayton's testimony as Past-President of the NSCA, included remarks to the effect
that many of the public's perceptions of the health risks from incineration were misguided—particularly in relation
to dioxins. She declared “Animal studies showed a wide range of reactions in different species to dioxin exposure.
Human epidemiological studies largely related to "dirty old incinerators", two-thirds of which had since been closed
as a result of tightening standards”. (QQ 267-9,291). However Our Stolen Future had been available since 1996
and the contents more than suggested that, at a cellular or hormonal level, mammalian or vertebrate organisms
betray a disconcerting capacity for shared experiences in terms of adverse effects, even if the dose-effect might
vary considerably. Developments in molecular biology change our view daily of the living world. Thus research by
Australian scientist David Miller indicate that the DNA of reef building coral Acropora millepora contains genetic
sequences corresponding to genes that guide the patterning of the incredibly complex human nervous system. Cf.
Science News, Jan 24, 2004 by John Travis Cf.
Since Rachel Carson's Silent Spring in 1962, data on possible foetal effects of exposure to chemicals – PCB,
pesticides, dioxins has come to light. Published in July 1999, the conclusions of the House of Lords Select
Committee Eleventh Report on the European Communities Sessions 1998-1999 (Waste Incineration) set an
unhealthy precedent, molding thought patterns, further entrenching attitudes, reinforcing an elitist template, which
still drives the mindset of so many planners and decision makers. Two committee members had declared - but
nonetheless flagrant - conflicts of interests. Namely : the chair the Fifth Earl of Cranbrook (crucial quango landfill
regulator Entrust, Shanks & McKewan, IWM, NSCA) and a member Lord Lewis of Newnham (NSCA, ESA).
Asked by the committee to describe the situation [ie the position of an incinerator] in general terms, Mr Gavin
Tringham (Birmingham City Council and NSCA) declared "Our incinerator is in an inner city area. It has always
been an incinerator site for perhaps the last 100 years. It is surrounded by a mixture of old industrial units and
older housing units, typically occupied by people of the lower socio-economic groups" (!) In his evidence to the
aforementioned august body a Mr Richard Mills - of the NSCA then appears to have remarked : "I think perhaps a
footnote ought to be added in relation to the fact that clearly those inner city areas are likely to have potentially the
biggest impact because they will be already in some cases air polluted areas, so that will be a factor …”
[3] Alongside Linda Birnbaum's research on dioxins, an abundance of scientific literature is available on Hormone
Disruption. A brief selection of references is provided elsewhere to keep the scope of this document to within the
confines of inquiry procedures. As to proof of perinatal chemical exposure, here are references to three studies :
Cf. Environmental pollutants in meconium in Townsville, Australia. Deuble L, Whitehall JF, Bolisetty S, Patole SK,
Ostrea EM* and Whitehall, JS.Department of Neonatology, Kirwan Hospital for Women, Townsville. *Department of
Pediatrics, Wayne State University, Michigan. 1999. (Unpublished research document).
Cf. Measurement of organophosphate metabolites in postpartum meconium as a potential biomarker of prenatal
exposure: a validation study. R M Whyatt and D B Barr Columbia Center for Children's Environmental Health,
Division of Environmental Health Sciences, Mailman School of Public Health, Columbia University, New York, New
York 10032, USA. [email protected] (Cf.
Cf. Prevalence of Fetal Exposure to Environmental Toxins as Determined by Meconium Analysis Enrique .M.
Ostrea, Jr. Victor Morales, Etienne Ngoumgna, Randy Prescilla, Edwina Tan, Emilio Hernandez, Gloria Baens
Ramirez, Herminia L. Cifra, Maria Luisa Manlapaz (
“ABSTRACT It is widely acknowledged that the poorest sections of society bear a disproportionate burden of poor
environmental quality, including toxicity and pollution. The struggles to address environmental injustice instigated at
grassroots level also place the burden of righting the injustice on those who often have the least resources in terms
of time, money and access to decision makers. The unfolding story of BAN Waste’s sophisticated challenge to the
proposed building of a replacement incinerator in a working-class area of Newcastle demonstrates many of the
issues and stages common to struggles for environmental justice. The struggle became proactive and built wider
alliances and a broad coalition across the city for change. The eventual success in preventing the incinerator being
built and in producing a superior waste strategy counters the popular belief that environmental concerns are
predominantly those of the middle class” … EXTRACT : “The Byker incinerator had operated since 1979 but by the
late 1990s was near the end of its life due to tightening safety regulations and old age. The city’s level of recycling
had run at 3–6%, well below even the poor British average. In the late 1990s a new waste strategy was prepared
with a new incinerator in Byker as a central feature. As residents discovered these plans in summer 1999,
Campaign Against Incinerating Refuse (CAIR) was established … and pushed Newcastle Council, with discussions
facilitated by Newcastle Healthy City Project, to organize a public meeting in Byker in January 2000 ... Both the
Environment Agency representative and the Director of Public Health sat on the Council side of the top-table and
appeared to be supporting the incinerator proposal, giving general reassurances about safety. The public, however,
was overwhelmingly opposed, with people relating stories of the unpleasant smells, ‘black snow’ (soot from the
chimney) covering windows, cars and washing hung out to dry, noise, concerns about poor health in the area, what
was burnt and a host of other issues”. Source : BAN Waste, Environmental Justice and Citizen Participation in
Policy Setting by Lyn Woods & Bill Hopwood Sustainable Cities Research Institute, Newcastle upon Tyne, UK.
Pica behaviour is an eating disorder typically defined as the persistent ingestion of non-nutritive substances for a
period of at least one month at an age at which this behaviour is considered inappropriate. It is estimated that
between 4% and 26% of individuals with a learning disability show signs of pica behaviour with the suggestion that
the more severe the individual’s learning disability the greater the chance that they will develop patterns of pica
behaviour. The phenomenon was displayed in youngsters living under the pall of the Byker incinerator where, for
seven years, mixed ash was dumped systematically on allotments, footpaths and bridleways. Moreover what price
the advice to wash and peel fruit and vegetables, when dioxins can bioaccumulate in Cucurbitaceae, for example ?
The Evening Chronicle Newcastle 5th January 2002 Source :
Gagging orders stopped ash probe
A top Government insider today revealed how he was barred from investigating the Byker toxic ash scandal.
Former Environment Agency board member Alan Dalton, who represented the North East, claims the agency silenced him over
the affair.
He told how he tried to make his own inquiries into cancer-causing dioxins from the Byker incinerator but was told by EA
chiefs to `keep his nose out'.
Mr Dalton, a board member for three years, spoke out after Newcastle City Council was fined £25,000 for dumping 2,000
tonnes of toxic ash on allotments across Newcastle.
The owner of the incinerator, Contract Heat Power, was also fined £5,000 at Newcastle Crown Court yesterday. Both were
ordered to share court costs of £35,000.
Protesters immediately called for changes in the law to protect the public from future health scares.
But today Mr Dalton claimed he tried to reveal his own concerns about the ash which was spread on allotments and paths
across Newcastle, but was thwarted by his own bosses.
He said: "I was told in no uncertain manner to keep my nose out. Yet good public health practice requires that, wherever
possible, human populations be protected from exposure to dioxins."
Mr Dalton was appointed as an EA board member for the North East region on January 1, 1999.
He said: "For the first year things were fine, but when I started to ask a few questions I found the EA more and more
Mr Dalton was asked to investigate a landfill site at Wakefield, West Yorks.
During a six month investigation he raised concerns about the site, but his report was rejected.
Mr Dalton's spell as a board member ended last month after talks with Environment Secretary Michael Meacher over his
He said: "On the basis of my experience we do not need an Environment Agency. The EA is clearly a rubber-stamping outfit
for the Department of Environment, Food and Rural Affairs."
A spokeswoman for the Environment Agency said: "We are aware of Mr Dalton's comments.
"The agency is satisfied that the Byker ash incident was investigated fully. More than 1,000 office hours were spent on the
"We are happy that we have brought a successful prosecution and are happy with the result. We are also aware that this case
has highlighted that lessons need to be learned and the Agency is confident of doing this."
But protesters today slammed the court sentence on the council as a slap on the wrist. Campaigners insisted that a Newcastle
Crown Court judge's fines on the shamed city council and a waste burning firm were deplorable and said the legal process was
a whitewash. They vowed to continue their fight demanding a public inquiry and a change in waste management law.
Val Barton, spokesman for the Campaign Against Incinerated Refuse, said: "A fine of £5,000 against the incineration
company is no deterrent at all. It is a deplorable amount.
"They knew for years what was in the waste and didn't tell the council.
"I don't believe the judge was told the full story about the risks. There are still many unanswered questions about how this
happened and the risk to public health. The whole thing is a whitewash.
"We are going to demand a public inquiry. The Environment Agency failed to monitor the ash situation and is now trying to
cover its tracks.
"Its monitoring and prosecuting duties are a clash of interest. The agency must be overhauled."
She was speaking after Judge Esmond Faulks fined Newcastle City Council a total of £25,000 for two breaches of waste
management law.
Judge Faulks also fined Contract Heat and Power (CHP), which runs Byker Reclamation plant, £5,000 and ordered the two to
pay a total of £35,000 costs.
The court had earlier heard how the city council had unlawfully spread ash containing some of the world's most poisonous
man-made chemicals on city allotments while trying to boost its green policy.
And for four years between 1994 and 1998 while this was going on, CHP bosses failed to tell Cityworks the ash contained
deadly dioxins and heavy metals.
The court also heard how Alan Tweedale, CHP managing director, knew in the mid-1990s that ash from the Byker incinerator
was not being disposed of properly. Newcastle City Council admitted two specimen charges of breaking the Environmental
Protection Act 1990 and asked for another 11 offences to be taken into account. CHP admitted one count.
Judge Faulks said: "When all this became known there was a high level of public anxiety and parents were advised to keep
children off the land.
"I accept there was no attempt to flout the law and the council has bent over backwards to try to rectify the problem. I therefore
see their culpability as low. But a public authority has a duty to take care of health risks."
The court also heard the council had so far spent £577,622 of public cash sorting out the mess.
Barry Rowland, the council's director of Cityworks, said: "The council pleaded guilty to the charges and accepted its
responsibility. We have apologised for any concerns caused by our actions which were clearly not malicious in intent.
"We have spared no expense to rectify our mistake.
"We will not rest until we are satisfied we have done everything possible to repair the damage done to people's confidence."
Long road to court for council officials
Key dates in the Byker ash scandal:
September 12, 1999: Council admits 2,000 tonnes of ash were spread on 28 allotments across Newcastle. The authority agrees
to have the ash tested.
April 12, 2000: Workers begin to remove ash from allotments after it is found to contain high levels of dioxins.
September 24: Environment expert Keith Collins warns dioxins from the ash could have killed up to 36 people a year.
December 14: Environment Agency announces it is to charge the council and incinerator owners with breaching public health
August 7, 2001: Council bosses today plead guilty to breaching health rules over the Byker incinerator toxic ash scandal.
November 5: Protesters lodge an application with the High Court in an effort to get a judicial review of the affair.
January 3 2002: High Court rejects demand for judicial review.
January 4: Council and incinerator owners fined a total of £35,000 plus £35,000 costs at Newcastle Crown Court.
Top adviser on health issues
Alan Dalton is currently the Health and Safety Co-ordinator for the Transport and General Workers' Union.
He is also a part-time Senior Environmental Adviser, Centre for Environmental Quality, at the University of East London.
As an expert in his field he is sought after as a consultant on health and safety for firms and organisations across the country.
Mr Dalton is also an authority on hazardous materials and a member of the National Society of Clean Air Environmental
Protection's Commission on Industrial Regulation and Sustainable Development.
He is also the author of Safety, Health and Environmental Hazards at the Workplace published in 1998.
Legally, the Environment Agency Board is directly responsible to Government ministers for all aspects of the Agency's
organisation and performance.
The Board consists of 15 members including the Chairman and Chief Executive.
The board meets six times per year - once in London, once in Bristol (where the Agency's Head Office is located) and four
times in the English Regions and Wales. Mr Dalton is responsible for an area stretching from the Scottish Borders to Redcar.
It includes the Northumberland National Park and the three main rivers, The Tyne, The Wear and The Tees as well as the major
urban areas in Tyne and Wear.
The Evening Chronicle, Newcastle
What was ditched on the paths and Blucher allotments and transported via soiled shoes into some residents' houses ?
“One of the remaining and and presently operating incinerators that was deemed to comply with the EC directives
was the Byker incinerator, sited in Newcastle. From 1994 to 1999, a mixture of fly ash and bottom ash has been
used on allotments and on paths. Concern by local residents about possible toxic substances in the ash prompted
the local health authority and council to organise an analysis of dioxins and heavy metals in the ash. Initial results
showed high levels of dioxins in the ash and residents were advised that children under two years of age should
not play on the allotments, eggs and animal produce from the allotments should not be consumed, and all
vegetables should be washed or peeled before eating. The final results of the analysis showed that levels of
several heavy metals in the ash and dioxins were far higher than usual background levels. The average
concentration concentration of dioxin was very high, 1373 ng TEQ/kg, with a maximum concentration of 4224
ngTEQ/kg. These levels exceed the relevant German regulatory guidelines for dioxins. For instance, restrictions on
growing of agricultural crops are recommended above 40 ng TEQ/kg and it is recommended that remediation
should be carried out if playgrounds exceed 10 ng TEQ/kg and if residential areas exceed 1000 ng TEQ/kg. With
the exception of mercury, all the other heavy metals tested exceeded the Dutch trigger levels for soils, as shown in
table 5.6. The Dutch guidelines are used by planning authorities in Britain. As a consequence of the high levels of
toxic substances in the ash, all of it had to be removed. This was at a cost to the local council of £50-70 000. It is of
great concern that the use of this ash for paths and allotments was permitted to happen by the regulatory
authorities and begs the question whether similar incidences have occurred but remained unnoticed in the UK or in
other countries”. Cf. Incineration and Human Health : State of Knowledge of the Impacts of Waste Incinerators on
Human Health Michelle Allsop, Pat Costner and Paul Johnston. Greenpeace March 2001.
Table 5.6 Levels of metals (mg/kg) and dioxins and furans (ng/kg) in 16 Byker ash samples compared with Dutch Trigger Values
Mean (mg/kg)
Range (mg/kg)
Dutch Trigger Value (mg/kg)
1,373 ngTEQ/kg
11-4223 ng TEQ/kg
Source : Bucholz and Landberger (1995)
"Hormones are exceptionally potent chemicals that operate at concentrations so low that they can be measured only by
the most sensitive analytical methods. When considering hormones such as estradiol, the most potent estrogen, forget
parts per million or parts per billion. The concentrations are typically parts per trillion, one thousand timesa 'lower' than
parts per billion. One can begin to imagine a quantity so infinitesimally small by thinking of a drop of gin in a train of tank
cars full of tonic. One drop in 660 tank cars would be one part in a trillion; such a train would be six miles long." Page 40 :
Our Stolen Future Theo Colborn, Dianne Dumanoski, John Peterson Myers 1996 Dutton New York
Living organisms need to communicate with and respond to their environment. Rachel Carson first highlighted
the subtle biological impacts of industry upon animals with her work on DDT in the 1950’s and 1960’s. Later,
during the 1990s, alarm bells began to ring, firstly in the USA then elsewhere, with the discovery that man-made
compounds were interfering with the endocrine system of different species, including humans. Hormones are
natural chemicals acting as powerful messengers which circulate in the blood stream and in the vascular system
of plants [1] at very low dose levels – parts per billion and, in some cases, parts per trillion – operating like
switches, turning on and off bodily processes. From the moment of conception throughout the remainder of life,
growth patterns, cognitive development, reproductive capacity, individual and social behaviour will be controlled
by the way hormones have been allowed to operate in the womb. These secretions will guide key functions like
a baby’s nervous and immune systems. They will "program" organs and tissues such as those of the liver, blood,
kidneys and muscles, so they work properly. The performance of the brain and gonads, or primary sexual
glands, in later life would appear to be determined at various, critical stages of embryonic or foetal development.
Extraneous cocktails of endocrine disruptive chemicals and minerals in the food chain and body burdens are
now officially acknowledged by even COT advisory committee reports on human diet. What is disputed are the
causal links existing between them and massive increases in ill health, such as the clinical obesity and cancer
epidemics, discernible in industrial countries or regions benefitting from so-called highly developed economies. A
reasoned precautionary approach suggests that material data [2] extant in independent peer-reviewed studies is
sufficient to prove that only fools or knaves may now talk of safe thresholds for heavy metal compounds, dioxin
and other products of incomplete combustion with a capacity to disrupt hormones. This unpalatable fact is bad
news for the chemical, mining and waste industries, doing their level best to obstruct any moves which enhance
public awareness to curtail or remove this concealed, but nonetheless dangerous, threat to our existence.
It is not only a lack of 'firewalls' or efficient checks and balances in allegedly lawful societies which favours cosy
relationships between private contractors, like SITA UK, and WDA officers, which in turn permits this unhealthy
state of affairs to prevail. It is also due to public apathy, fostered by the opinion-based, commercially motivated
science of industrial apologists to justify multiple, diffuse sources of a pollution that is invisible but frequently
bioaccumulative. Names like Roy Harrison and James Bridges spring readily to mind. But there are so many
others who partake of this culture of denial. Mostly because regulation is tied to the toxicology of Paracelsus [3],
and the concept of the median lethal dose. [4] Numerous documented instances of historic conflicts of interest,
declared or otherwise, likewise play their part. Neither is this region exempt from the globally regimented market
forces that tend to induce the habit of a dumbed down, ostrich-like, political consensus, resulting in an unspoken
censorship of current affairs and a dearth of published, high quality, investigative journalism. This peninsula is
distinctly subject to mass media manipulation and control, local conservatism being due to the fact that major
daily or weekly, regional newspapers are owned by one press group, Cornwall and Devon Media Ltd. Editors
and reporters are vulnerable to corporate spin when, for reasons of professional expediency or constraints, like
work and peer group pressure, staff may take government and industry press briefings and handouts for gospel.
The upshot being that both sides of the story seldom get told before crucial planning decisions have been made.
Five examples should suffice to suggest ways a veritable conspiracy of silence has impacted upon probative,
compelling and demonstrable prima facie evidence, relating to hormone disruption and fundamental cancer
research, now in the public domain, but sequestered from public view by socially regressive local government.
(a) As the authors of the BSEM reply to the HPA [5] state unequivocally “Science is continually evolving and
research studies are revealing toxicity at progressively lower exposures for many toxic substances.This trend is
certain to continue. There is the historical fact that regulators have consistently and repeatedly underestimated
the risk of pollutants and toxic chemicals. This has been true for asbestos, lead, DDT, PCBs, dioxins, amd
CFCs. Often it has taken decades for regulators to acknowledge these risks and ban these substances”.
(b) The harmful effects of numerous exemptions introduced by Brussels at the behest of industrialists and their
political clients to dilute the form and contents of the REACH [6] regulation enforceabIe since the 1st June 2007.
(c) The general public ignores or remains obstinately silent about the multiple implications of local and national
government's failure or refusal to implement the Stockholm Convention, which entered into force on the 17 May
2004 (Cf. and which the procurement of the current CERC technology will similarly flout.
(d) In biochemistry and pharmacology, a ligand (Latin ligare = to bind) is a substance that is able to bind to and
form a complex with a biomolecule to serve a biological purpose. In a narrower sense, it is a signal triggering
molecule, binding to a site on a target protein. Exposure to pesticides, dioxins and certain industrial solvants has
long been considered a high risk factor for cancer. Environmental factors in particular have been suspected as
causing non-Hodgkin lymphomas (NHL). But scientists have so far lacked the biological proof of a link. Follicular
lymphoma is a B cell cancer, characterized by a translocation event or exchange of genetic material that occurs
as activated B cells undergo AID-driven diversification of their antibody genes in germinal centers (GCs). This
translocation involving ligands connects specifically to two chromosomes, referred to as t(14;18), linking the
gene encoding the pro-survival protein BCL2 to the heavy chain locus (IgH) resulting in aberrant BCL2
expression and cell survival. Such translocations can also be found in healthy individuals, a fact indicating that
additional cancer-causing events are required to cause disease. In a ten year long cohort study involving 128
French farmers, a team of researchers from Marseilles, Caen and Rouen found the frequency of translocation
in the blood of farmers were up to one thousand times higher than normal. Molecular analysis of these suggests
that some could constitute real tumoural precursors and initiate the first stage in the development of a cancer.
Cf. Agricultural pesticide exposure and the molecular connection to lymphomagenesis © 2009 Agopian et al.
The Journal of Experimental Medicine
(e) A Greenwire bulletin ( published on the New York Times website 15 October 2009, highlights the waste
and chemical industries incommensurable lobbying power to hamstring a crucial White House OMB policy
statement. At issue a USEPA Endocrine Disruptor Screening Programme, created by the 1998 Food Quality
Protection Act to identify chemicals that can disrupt reproductive systems. The Office of Management and
Budget directive, said to contain unusually strong language, was hailed by corporate interests concerned about
prospects for expensive testing mandates. "We've held the position that the information collected under FIFRA
includes enough detailed information on reproductive and developmental toxicity," said Eric Janus, director of
human health policy for CropLife America, a pesticide industry group." Dating from 1947 and later amended,
notably in 1972 and 1998, the Federal Insecticide, Fungicide and Rodenticide Act has been repeatedly criticised
for watering down public health and environmental protection to safeguard commercial secrecy.
[1] All multicellular organisms, belonging to the Plant and Animal Kingdoms, secrete hormones.
[2] Cf. Other data available
[3] Renaissance physician, botanist, alchemist, astrologer and general occultist, Paracelsus, (1493-1541) is
often called the father of toxicology. When he wrote in : “Alle Ding' sind Gift, und nichts ohn' Gift; allein die
Dosis macht, daß ein Ding kein Gift ist“ - literally "All things are poison and nothing is without poison, only the
dose permits something not to be poisonous." Little did he realise that he was formulating a dogma which
industrial society uses to both measure the effects of a poison and to justify a source of pollution. The fact is
the Paracelsian formula of the dose making the poison no longer stands the test of time. Because for the
purposes of evaluating the subtle impacts chronic or subchronic exposure different tools are required.
[4] In toxicology, the median lethal dose, LD50 (“Lethal Dose, 50%”), LC50 (Lethal Concentration, 50%) or
LCt50 (Lethal Concentration and Time) of a toxic substance or radiation is the dose required to kill half the
members of a tested population after a specified test duration. Frequently LD50 figures are used as a general
indicator of a product's acute toxicity. Created by J.W. Trevan in 1927, the test is being phased out in some
jurisdictions, for reasons of animal welfare in favour of tests like the Fixed Dose Procedure. However the
concept and calculation of the median lethal dose is still widely used for comparison purposes.
[5] 'The Health Effects of Waste Incinerators' A report - moderated by Drs J Thompson and HM Anthony - by
the British Society for Ecological Medicine (BSEM) February 11, 2009 is a more than just a rebuttal of the
HPA's deplorable stance (Cf infra for contents of the document). With full charitable status and officially dating
from 2005 the BSEM was formerly known as the British Society for Allergy, Environmental and Nutritional
Medicine. This in turn was formed in 1993 from a merger of the British Society for Allergy and Environmental
Medicine and the British Society for Nutritional Medicine, founded respectively in 1983 and 1984.
[6] At issue in REACH have been the 100,106 chemicals in use within the EU in 1981, when the last survey
was performed. Of these only 3,000 have been tested and over 800 are known to be carcinogenic, mutagenic
or toxic to reproduction. These are listed in the Annex 1 of the Dangerous Substances Directive (now
Annex 3 of the CLP Regulation: Classification, Labelling and Packaging). REACH stands for Registration,
Evaluation, Authorisation and restriction of CHemicals (REACH). It is a European Union Regulation
of 18 December 2006 and entered into force in June 2007, with a phased implementation spread over the
next decade.
Executive summary
1. Introduction
2. Emissions from incinerators and other combustion sources
2.1 Particulates
2.2 Heavy metals
2.3 Nitrogen oxides
2.4 Organic pollutants
3. Health effects of pollutants
3.1 Particulates
3.2 Heavy metals
3.3 Nitrogen oxides and ozone
3.4 Organic toxicants
3.5 Effects on genetic material
3.6 Effects on the immune system
3.7 Synergistic effects
4. Increased morbidity and mortality near incinerators
4.1 Cancer
4.2 Birth defects
4.3 Ischemic heart disease
4.4 Comment
5. Disease incidence and pollution
5.1 Cancer
5.2 Neurological disease
5.3 Mental diseases
5.4 Violence and crime
6. High-risk groups
• 6.1The foetus
• 6.2 The breast-fed infant
• 6.3 Children
• 6.4 The chemically sensitive
7. Past mistakes and the precautionary principle
• 7.1 The precautionary principle
• 7.2 Learning from past mistakes
8. Alternative waste technologies
• 8.1 Mechanical biological treatment
• 8.2 Gasification methods
• 8.3 Recycling
9. Other considerations of importance
9.1 The costs of incineration
9.2 The problem of ash
9.3 Radioactivity
9.4 Spread of pollutants
10. Cement kilns
11. Monitoring
12. Risk assessment
13. Public rights and international treaties
14. Conclusions
15. Recommendations
The GMC and Dr Andrew Wakefield
About the Society
• Contact the BSEM
• Ecological medicine
• Membership
• Responsive conditions
Training, accreditation and validation
List of registered practitioners
• Journal of Nutritional and Environmental Medicine (JNEM)
• Environmental Medicine in Clinical Practice
• Reports
• Chronic Fatigue Syndrome and Mitochondrial Dysfunction
• Effective Allergy Practice
• Effective Nutritional Medicine
• Multiple Chemical Sensitivity
• The Health Effects of Waste Incinerators
• Log in
“The main hazardous property of fly ash is its alkaline nature, but as a precaution it is treated as if it was hazardous”.
The above declaration features on Cornwall's WDA website ( and provides an indication of
the banality of the lies, deceit and faulty supervision characterising the waste industry's biggest operators under
today's regulatory climate. One instance are the fines imposed on Newcastle City Council which were derisory
relative to the gravity of this municipal crime. In any civilised society such conduct would rate as grievous bodily
harm. The violence inflicted on the host population was tolerated by the regulator and begs the question as to
whether similar 'unnoticed pollution breaches and unauthorised emissions' may not still occur elsewhere.
The judicial imbroglio of Gilly-sur-Isère in France and Novergie-Centre-Est, a SITA-Suez subsidiary - with limited
liability and apparently claiming diminished responsibility– suggests what could lie in store for Saint Dennis and
nearby villages at the hands of the Appellant and the Environment Agency. To 'facilitate' combustion, the burner
polluted 26 communes and 40 000 people - en Haute Savoie - operating frequently 'en torchère', ie with APC
equipment deactivated. Caught red-handed, the parent company of Novergie-Centre-Est is still in denial. For
over nine years the victims have been endeavouring to prevent the French courts and the government from
burying the scandal. This incinerator released levels of dioxins 17 000 times the permitted norm. Yet the SITASuez website refuses to acknowledge the true cause and origin of 78 cancer cases – with 24 in one street of 80
households – Rue Louis Berthot - in the municipality most exposed to the plume : Grignon, with a population of
1400. Nothing can compensate for the livelihoods wrecked, the family lives devastated, the 3500 farm animals
destroyed, the 7000 tonnes of dangerously contaminated hay, the eradication of 13 000 litres of milk a day.
An attempt to have the investigating magistrate removed from the case reveals the top level degree of trafic
d'influence or undue influence peddling [1] distinguishing this affair. The merger between the banking group Suez
and Lyonnaise des Eaux occurred in 1997. As an affiliate of this outfit, Novergie as well as the dilatory officials including two préfets - one a leading adviser to the ex-French premier Jean-Pierre Raffarin and who probably
should have been prosecuted – benefit from friends in high places. Links exist between the alleged offenders,
influential members of the business community and high ranking politicians, notably two former ministers.
Michel Barnier - ex-Agriculture Minister, ex-European Commissioner, ex-président du Conseil Général and now
an MEP - is reported to be close to Albert Gibello, Mayor of Albertville, once detained under investigation, now
free as a bird with the abandonment of the case against him on 26 October 2007. According to the Guardian 17
May 2005 - quoting another national newspaper, the French daily Libération – the Savoyard ex-Environment
Minister is accused - by one of the suspects - of persuading regulators to ease off on waste incinerator pollution
in the run-up to the 1995 local elections. For the following fifteen years these emissions went unrecorded.
A fellow Savoyard politician – ex- Agriculture, Economy and Health minister Hervé Gaymard - is married to Clara
née Lajeune. An 'empowered businesswoman' in her own right, she's reputedly an adept of Opus Dei, a potent
lobbying group, commanding compliance among the clergy and in European secular society. The couple are
thought to exert considerable pressure in government and business circles. Jérôme Monod joined the Lyonnaise
des Eaux management team in 1979, becoming later a chairman and general director. A personal friend of
Jacques Chirac, as his political adviser (2000-2007), he had an office in le salon d'Argent at the Élysée palace.
As with Edmonton and other UK sites, Gilly-sur-Isère is not an isolated case and at least 41 French incinerators
operated under an identical régime. Neither can this tragic saga be dismissed as past history. Novergie runs an
insanitary 'Energy Recovery Facility' at Lunel-Viel, 20km from Montpellier in the department of l'Hérault. This
Ocréal plant, operational since1999, is fitted with an atténuateur de fumée like the one on SITA's Manx facility. It
has hosted major pollution incidents, catching fire on 26 June 2002, when a cloud of thick black smoke was
released from parts other than the dumpstack. (Cf. www.greenpeace,fr/incinerateurs/detail.php?d=lunel).
To protect their turbo-alternator and the APC system, the operator had bypassed the air filtering devices. When a
much bigger fire finally forced closure of the huge TIRU-EDF incinerator at Issy-les Moulineaux near Paris, the
response has been to construct an even bigger unit on another site ! A doctor's association AMIES has monitored
huge increases in prescriptions and sales for antibiotics in the Lunel-Viel region, testifying to an epidemic of ear,
nose and throat infections. Novergie has been declared in breach of the law, due to poor storage and treatment
of allegedly inert IBA at Lunel-Viel. Ordered to close on 18 February 2007 by an administrative tribunal, France's
'decentralised authorities' permit the notoriously dirty incinerator to continue operating (
"Particulate matter consists of a combination of non-combustible fractions of waste combined with Products of Incomplete
Combustion, often carbon. In addition high molecular weight compounds, like dioxins, are usually present as they condense
on the surface of particles, mainly carbon". House of Commons Research Paper 09 May 2002
It is a fact firstly that every summer Cornwall's population explodes with the arrival of the seasonal visitors. In
2006/2007 Cornish households were saddled with the bill for treating the County's 327 000 tonnes of municipal
waste, of which only an estimated 10% arises from schools and offices, litter and street sweepings. Of this total
31% was recycled, leaving 220 000 tonnes for disposal in landfill. By 2012, with an anticipated recycling rate of
40%, total waste arisings are predicted to be 360 000 tonnes or more. In funding the new CERC with a 240 000
tpa capacity and authorised to accept commercial waste, Cornish taxpayers can be seen to fund the treatment of
much more waste than they are producing. This tendency is reflected in national figures. For example in 2002,
total waste arisings were 400 million tpa, of which only 28 million tpa could be classed as municipal.
To imagine what the potential for pollution could be, were the CERC EfW plant to obtain a permit, reference must
be made to the way compliance is policed and to an increasing lack of public confidence in the enforcement of
environmental protection through the self-regulatory regime under which the waste industry operates. According
to the Environment Agency only 546 breaches of the 'authorised pollution levels' were 'self-reported' during the
1999-2000 period, from which a single prosecution resulted. This was Sheffield's facility, operated by Onyx Total
Waste Management and owned by Sheffield City Council. They were fined £18 000 in December 1999 for
"persistently" failing to ensure their incinerator complied with legal emission limits. Analysis of this quasi-lawless
situation - widespread under the Integrated Pollution Prevention and Control system and a woefully underfunded
Environment Agency - features in a paper (Cf. presented at
the Symposium on Law and Economics of Environmental Policy, University College London in September 2001.
It is entitled “Pollution and Penalties” by Anthony Ogus, Professor of Law, University of Manchester, Research
Professor, Maastricht University and Carolyn Abbot, Lecturer in Law, Manchester University. According to figures
published by the Environment Agency Annual Report and Accounts for the period 1999-2000, a record 17,592
'waste incidents' investigated by the Environment Agency led to the conclusion of a mere 342 prosecutions.
Or again : of all the companies that the Environment Agency did prosecute in 1999, only 32 businesses were
fined over £10,000. The average fine for prosecuted businesses and individuals was £6,800 and £1,000
respectively. In a number of cases, including illegal waste disposal, the level of fines is reported as actually
falling. The Parliamentary Select Committee on Environment, Transport and the Regions, in its report on the
Environment Agency, expressed concern at the consistently low level of court fines for environmental offences. A
perception shared by respondents to the consultation paper - including the Environment Agency – whose staff
have also publicly drawn attention to what they regard as a failing on the part of the criminal courts.
From a document signed A. Mehta and K. Hawkins - “Integrated Pollution Control and Its Impact: Perspectives
from Industry” (1998) 10(1) Journal of Environmental Law 61, 69 – we learn more about this disturbing trend :
prosecutions relating to Integrated Pollution Control are the lowest with a mere 22 resulting from the total of
599 substantiated pollution incidents. The Environment Agency can threaten to invoke loss of a licence as an
alternative to the criminal process, but clearly there must be evidence that it is willing to initiate proceedings if the
threat is to be credible and, as we have seen, this public body is known to be very reluctant to do this.
It seems not unreasonable to suppose these statistics to be an inaccurate reflection of the reality today : given
human nature ie corporate greed and regulatory officials' reluctance to release compromising data especially in
the wake of the revelations on Newsnight in July 2001, regarding what effectively amounts to the 'fly-tipping' of
dioxins and heavy metals by incorporating them in construction blocks manufactured for building purposes.
The management of this particular breach of 'authorised pollution levels' is instructive, as the Environmental
Services Association was then boasting of the £4 billion contributed by its members to the UK economy – ie
purportedly 5% of GDP. While others were counting the real social and environmental cost of this apparent
bonanza. When interrogated about the character of mixed ash from Edmonton, Environment Minister Michael
Meacher MP was on record as saying that the Environment Agency had no information on the toxicity of dioxin
concentration in ash mixed before August 2000. Yet a fax dated 24 July 1996 was to be produced as evidence
during the court action by North London Waste Ltd against Greenpeace activists. It was sent by Henry Cheung to
Peter Montgomery, Environment Agency inspector responsible for regulating Edmonton's plant since 1996.
It showed laboratory analysis of dioxins and furans levels in fly ash samples from the plant's ESP (Electrostatic
Precipitator) dust. These contained large amounts ie as much as from 3 600ng/kg 1-TEQ to 10 800ng/kg 1-TEQ
(nanogrammes per kilogramme international toxic equivalent). A hand written document apparently also reports a
14 to 1 ratio of bottom ash to fly ash produced with a set of calculations indicating final levels in the mixed ash as
having 771 ng/kg 1-TEQ. These concentrations are clearly much higher than the 'background levels' spoken of
by the Secretary of State when he declared that the Agency had been informed by the operator that test results
showed dioxin levels of mixed ash to be close to background levels ie those found in normal urban soil.
Results of four analyses of manufactured blocks show a range 117-390ng/kg 1-TEQ. Tests conducted by the
BBC 2 Newsnight programme on a sample block made from 30% of Edmonton mixed ash yielded 343ng/kg 1TEQ. By comparison, blocks containing only IBA from Edmonton, with no ESP residues, would be expected to
hold no more than 4ng/kg 1-TEQ. In conclusion, levels of dioxin concentration in the unprocessed mixed ash
would be in excess of 1100ng/kg 1-TEQ, significantly higher than the 200ng/kg1-TEQ – peaking to 900ng/kg 1TEQ – left after Operation Ranch Hand in Vietnam, where birth defects and elevated dioxin levels in human
tissues are being reported still 35 years after spraying of the ultra toxic defoliant Agent Orange had ceased [2].
With all this knowledge the Environment Agency didn't intervene to stop the practice. On the contrary, Ballast
Phoenix, the company using the mixed ash was granted a waste licence exemption. In May 2000 a seminar
promoting 'ash recycling' hosted by Ballast Phoenix was held at Edmonton incinerator by Aggregate Industries owners of Bardon Aggregates, who allegedly publicised the event. In an apparent damage limitation exercise, a
DETR official was reported as showing the guests around the ash storage facilities announcing that ash was also
available from the SELCHP plant at Lewisham, plus Stoke-on-Trent,Tysley and Dudley in the West Midlands.
When Waste Strategy 2000 was compiled there were just twelve UK Energy from Waste - Mass Burn Incineration
sites : Wolverhampton, Nottingham, Cleveland, Bolton, Coventry, Dudley, Sheffield, Tyseley-Birmingham, Stokeon-Trent, Edmonton-North London Waste, SELCHP-Lewisham, Dundee. According to journalist Paul Brown they
were required to report on 165 different pollutants. From 1999 until 2001 the ten plants in England had breached
their licences 553 times between them. (Cf.
Other facilities were listed as proposed, approved or not yet constructed, or burning Tyres, Secondary Liquid
Fuels or Refuse Derived Fuels. Added to this were three infamous merchant hazardous waste burners :
Cleanaway : Ellesmere Port, 75 000 tpa, commissioned in 1990 ; Rechem : Fawley-Southampton with a 35 000
tpa commission in 1990; Shanks : Pontypool, commissioned for 24 000 tpa in 1972 ; giving them a total
combined annual capacity of 134 000 tpa. Plus the cement kilns, with their statutory limit on particulate emissions
(between 30-50mg/m³) which is invariably superior to the statutory limit set for the MSW- EfW plants (10mg/m³).
Depending on the type of fuel burned, the volume of emissions per second can be up to seven times higher than
waste incinerators. The result being that the quantity of particulates released can be over 30 times greater. From
1996 to 2002 there were 'officially' just 1276 breaches of emission limits for Britain's MSWI. Based on data from
Environment Agency pollution registers, the table below shows pollution offences for the period 1999-2000.
Name of incinerator
Number of offences
Edmonton North London
Lewisham South London
These statistics would appear to suggest that Nottingham's CHP facility's 'pollution performance' would be about
average in the above league table. But what does average mean today and have the pollution figures improved ?
Built in 1972 the WRG installation comprises two 'open grate models' which 'process' two mixed waste streams
at a rate of 11.5 tonnes/hour, giving a total of 100 000 tpa, with an additional 100 000 tpa proposed to bring this
figure up to 250 000 tpa. The industrial component of the plant's MSW waste stream contains reject cigarettes –
containing up to 599 additives of which 69 are carcinogenic – plastics, chemicals, tyres, PVC, animal tissues,
food waste containing common table salt, sodium chloride, lead and tin capsules on wine bottles, ie a magma of
oxygen, carbon, chlorine and heavy metals – including highly poisonous antimony - custom-built to enrich the
PIC with dioxin and metallic compound releases in unmonitored respirable fractions of the PM2.5 m particulates.
An audit of which is not plainly visible in the official published figures for the Eastcroft facilty. Despite WRG's poor
track record (Cf. infra), in February 2009, Heather Blears, Secretary of State for Communities and Local
Government (2007-2009), overruled a Planning Decision by Nottingham City Council and awarded the operator
permission to expand, subject to no further appeal. Their Eastcroft CHP incinerator already costs NCC
approximately £1 million per annum. As the two tables below reveal taxpayers are neither getting value for
money, nor are their families' health prospects likely to improve (Source :
Unauthorised emissions and pollution breaches Nottingham's Eastcroft EfW facility 2001-2008
2 **
* Dioxin=0.9ng/m³ Annual check by EA Cause not known. Breach could have gone undetected for several months.
**Enforcement notice issued by EA ; Formal warning issued by EA.
Unauthorised emissions and pollution breaches Nottingham's Eastcroft EfW facility 2007
18 December
Excess carbon in bottom ash
(indicates inadequate combustion) possible cause : use of oil burners
21-22 November
Hydrogen Fluoride
The EA has required a report on any irregular waste by end of 2008
Carbon Monoxide
Boiler tube leak
Carbon Monoxide
'sudden release of a hydro-carbon substance… resulted in depletion
of the excess oxygen’ (i.e. probably explosion of a gas canister)
10 November
14 October
July to September No compliance of monitoring
Measurements for cadmium, thallium, mercury and other heavy metals
not carried out correctly so no valid data for whole quarter
- failure to provide valid data for cadmium, thallium, mercury and other
heavy metals for third quarter of 2007
- failure to provide valid data for particilates, PCB and PAH for the
whole of Jul-Dec
failure to provide valid data for chemical oxygen demand discharged
to sewer in the fourth quarter
- failure to provide data on emissions to air and sewer due in January
2008 until March.
A final word in this doleful chapter should be reserved for the performance of SITA-Suez Environment at their UK
installation in North London and which, at 540 000 tpa, is appreciably larger than Veolia Environmental Service's
420 000 tpa/35MW SELCHP facility in Lewisham. The Edmonton site is now called the LondonWaste EcoPark
and is run by LondonWaste, a joint venture company [3]. The discards from seven London Boroughs are officially
converted into electricity, IBA, air pollution control residue and flue gases. 55 megawatts (MW) of electricity are
generated, sufficient power to meet the needs of 24,000 households. In early 2002, plans were rejected for a
large expansion of the incinerator, which would have made it the largest household waste incinerator in Europe.
Permissions had been granted by both the Environment Agency and Enfield Council. But on 23 May 2002, UK
Energy Minister Brian Wilson refused the plans on the basis of Waste Strategy 2000. Trials are being carried out
to use the River Lee Navigation in transporting materials to the incinerator. A large composting facility opened on
the site in 2006, allowing green and kitchen waste from local homes to be converted into compost.
Chingford Green (373 hectares, pop. 9479, census 2001) is a Tory stronghold and electoral council ward of
Waltham Forest, (pop. 223 200) also comprising Walthamstow, Leyton and Leytonstone. It has the smallest ward
population in the entire borough and, directly downwind of SITA UK's big London moneyspinner at Edmonton,
today boasts the second largest number of child deaths relative to its population in the whole of the capital.
[1] In France where all political parties are funded by waste industry 'donations', influence peddling is rife. This
involves often enough the illegal practice of using one's influence in government or connections with persons in
authority to procure favours or preferential treatment, usually in return for payment. But not necessarily in the
most direct sense. It is also called traffic of influence and is not automatically illegal, as the OECD often uses
the term "undue influence peddling" presumably so as to refer to more blatantly illegal acts of lobbying.
Lobbying is of course applied mostly to legislators. Who determine 'rules of engagement' ... Leaving regulators
and the judiciary to interpret what ensues in terms of health and environmental protection 'guidelines'.
Cf. After Incineration The Toxic Waste Problem, Jindich Petrlík M.S. and Ralph Anthony April 2005 ;
Ryder R 2001 : No Smoke Without a Liar The Ecologist Vol 31 No 8 October 2001.
[3] Edmonton incinerator's owner-operator is called London Waste Ltd. The latter is a joint venture company
between the North London Waste Authority and the private sector firm SITA-Suez-Environment alias GDF
Suez. The North London Waste Authority consists of the London Boroughs of Barnet, Enfield, Haringey,
Waltham Forest, Camden, Hackney, and Islington. Owned by: NLWA/SITA. Waste burnt: A wide variety of
material including domestic, commercial, clinical and industrial waste. Capacity: 540 000 tonnes per year.
Edmonton Self reported breaches 1997-2001 specifying date of unauthorised release and reason given
01.03.01 CO Jammed grates on boiler 2
26.02.01 CO Fault in air system of FGT plant
26.02.01 HCl Fault in air system of FGT plant
19.02.01 ? no details on register
18.02.01 ? no details on register
08.02.01 ? no details on register
29.02.01 ? no details on register
18.01.01 CO Sudden reduction in load, no 1 unit
21/22.11.00 CO Defective riddling screw
09.10.00 ? no details on register
25.09.00 Fly ash (FGT residue) Corroded steel plate no. 2 conveyor. 0.5 - 0.75 tonnes fine powder released
14.08.00 Fly ash (FGT residue) Corroded steel plate no. 4 conveyor. 1-2 tonnes of fine powder released
9/10.08.00 CO Feeder ram failure
28.07.00 CO None given. Described as "an unavoidable breach"
20.06.00 CO Grate drive failure causing loss of fuel to fire bed and drop in burn temp.
21.05.00 CO Large material in feedstock blocked quench bath
21.11.99 HCl Feedstock contaminated with an unknown quantity of chlorinated products
03.11.99 HCl Feedstock contaminated with an unknown quantity of chlorinated products
03.11.99 HCl Feedstock contaminated with an unknown quantity of chlorinated products
04.10.99 ? no details on register
27.07.99 HCl incineration of a large quantity of vinyl wallpaper
21.07.99 HCl Unknown quantity of chlorinated product present in feedstock
21.07.99 HCl Unknown quantity of chlorinated product present in feedstock
04.04.99 CO Quench bath flap unexpectedly came adrift
30.03.99 HCl System unable to cope with large quantity of PVC (1.1 tonnes)
20.03.99 CO Blocked feed chute
17.02.99 SOx Possibility of high sulphur content in waste stream
17.02.99 CO Control failure of the FD Damper Vane
21.12.98 ? no details on register
21.09.98 HCl Unknown source of chlorinated products present in waste
21.09.98 SOx High HCl levels mopped up lime dosing
16.04.98 HCl Contaminated feedstock from 14.4.98
14.04.98 HCl Unknown source of chlorinated products present in waste
29.11.97 HCl Incineration of PVC credit cards
Self-reported releases to air for 2000:
Cadmium & thallium 8.92kg
Carbon monoxide 191 t
Dioxin 0.08 g
Hydrogen chloride 36.7 t
Total metals 653 kg
Oxides of Nitrogen (as NO2) 1080 t
Particulate matter 25.6 t
Sulphur dioxide
“Environment Agency pollution registers are often kept in a state of extreme disorder and this can sometimes result in
researchers under-estimating the actual number of breaches that have occurred. The breaches listed above are not
necessarily all those known to the Environment Agency (...) London Waste has never been prosecuted for exceeding
autorisation limits to air.” Source :
“It illustrates under ASA scrutiny how far, and to what lengths, SITA has been 'bending' reports, wording, words like
sustainable, safe, 'airbrushing' pictures in its propaganda to massage public perception of its grubby technology”.
Rob Whittle – Norfolk Against Incineration and Landfill 27 July 2009 (Cf.
Whether by senior waste planning officers or industry officials, combustion based technologies are imposed by
devious means. SITA UK appointed Terence O'Rourke on 25 October 2006 to advise or assist on planning and
environment. In 2009 this PR consultancy published, on behalf of SITA Cornwall, a brochure designed for public
consumption - libraries, schools and colleges - vaunting the merits of their CERC bid. Already Saint Dennis had
heard David Buckle, Project Director for SITA Cornwall, speaking of the 'strict guidelines' to which his employer and
other big waste industry players supposedly adhere. A complaint was made to the Advertising Standards Agency.
On 8th July 2009 the ASA adjudicated that the booklet failed to comply with ASA guidelines and, on 3rd August 2009,
ordered the pamphlet to be withdrawn. This ASA landmark decision followed an investigation which upheld five of the
fifteen separate points at issue. These included SITA UK's claim that the HPA considered incinerators “safe” and
which was found to be incorrect. Allegations – relative to the 'environmental benefits' and 'sustainability' of the plant
deemed 'unbelievable' - were also rejected by the ASA as “likely to be meaningless to consumers and could
mislead”. Moreover the literature's photomontages were rated 'misleading', lorry numbers 'understated' and a claim
on job creation 'unverifiable'. Apparently the Waste Planning Authority saw nothing untoward in this piece of spin.
But then there is a sense of déjà vu in this latest shot fired in a propaganda war where truth suffers heavy casualties.
As June 2003 saw another crude and shameless attempt to mold public opinion on Energy from Waste when New
County Hall employed CAG consultants to target a 2500 person strong 'focus group' or 'survey' with an 'inadequately
researched' – some said overtly - 'disingenuous' - questionnaire on renewable energy options and AONB. The straw
poll's bias was tailor-made to garner support for a projected EfW plant, fed by a mixed waste stream and virtually
identical to one, for which their wholly owned LAWDC – CES - had applied for planning permission at Roche.
“Incinerators are the most strictly monitored section of UK industry” is another line fed routinely to the media by ESA
members' press officers. For four years the Environment Agency and an 'independent' consultancy, AEA Technology
plc, failed to notice that SITA/LondonWaste Ltd were submitting miscalculated data on dioxin emissions form the
Edmonton facility - despite being told initially they were both getting their sums wrong.
From parliamentary questions on routine testing to Environment Minister Michael Meacher (Cf. Hansard 26 March
2001) we learn how the ash of the plant at Teeside, operated by SITA, is tested by EUS Laboratories Ltd and AES
Ltd. Airborne emissions are analysed by AES Ltd, then a subsidiary of Suez – SITA. Due to energy efficiency
measures carried out by Nottingham City Council local ratepayers were reported to be paying in 2002 a monthly
£100 000 in fixed penalties to WRG plc operating the Eastcroft Waste to Energy facility on Incinerator Road off
Meadow Lane in Nottingham NG2 3AF (Cf. Waste Strategy 2000 page 81). Local Councillor John Hartshorne is on
record as saying “We've been environmentally responsible, but shot ourself in the foot commercially”. In the light of
current market uncertainties, no-one can predict Imerys' future energy requirements or the effects of a seemingly
acutely dysfunctional business acumen among Cornwall County Council's elected and unelected officers. So what's
to prevent a similarly expensive blunder occurring with respect to the sustainability of the CHP plant at the CERC ?
Calling incinerators something more pleasant-sounding, like Energy-from-Waste facilities, may help politicians and
their professional advisers feel better about them. Local residents, too often from so-called dysfunctional families and
communities, know them for what they really are and are less and less prepared to pay the price. But thanks to the
discourse of consultants from Britain's top drawer academia, like Professor Roy Harrison, Professor James Bridges
and Professor Dame Barbara Clayton, socially deprived areas are increasingly saddled with these unacceptable
sources of pollution. This despite the endless reports about the way illness and health hazards are intimately linked.
Indeed the Environment Agency produced a study in Spring 2004, written by researchers from Stafford and Leeds
universities.(Cf Public Health News 20 September 2004), Its findings included a suggestion that wards in the most
deprived tenth of the UK were five times more likely to contain hazardous waste sites and that these too were
clustered together in the poorest regions. Curiously such places had consistently lower air quality and higher
concentrations of pollutants, like carbon monoxide and benzene, plus elevated levels of carcinogenic emissions.
They identified 'pollution-poverty hot spots' in cities like Manchester, Sheffield, Nottingham,and London. The problem
also is that major food producers in rural areas are now targeted by the likes of SITA, Veolia, S Grundon, WRG,
TIRU-EDF. Saint Dennis' CERC is a case in point. A 120 metres high dumpstack and EU regulations limiting
'theoretically' dust emissions to1.4kg/hour or 12.2tonnes/year will do precious little for the image of clotted cream.
Professor Roy Harrison claims risks from incinerators are "negligible" (Buckingham Today, 20 March 2008)
The expression 'landfills in the sky' was suggested by a 'concerned member of the public'. Lawrence G Cooper lives
in the village of Quainton ie near a place where Buckinghamshire County Council have been considering a proposal
from the infamous Spanish-owned company, Waste Recycling Group (WRG), to build a mass-burn incinerator. (Cf. 'Chemical
cloud could hang over Aylesbury Vale's villages' The Bucks Herald 14 July 2009 Johnston Press plc).Not all doctors
and scientists s are prepared to provide government and industry with the alibi and feel-good factor that enable them
to poison and pollute the 'less articulate sections of the public'. People like Dr Catherine Woodward at Telford and
Wrekin PCT or Professor Roy Harrison who, as Michael Ryan would say, are responsible - via their public utterances
or bureaucratic negligence - for more deaths than Dr Harold Shipman. Listed below are just some of the studies that
have helped to raise public awareness about so many large sources of avoidable disease and premature death.
Silent Spring Rachel Carson Houghton Miffin Co ISBN 0395-68328-7 (pbk) 1962.
1978 Frederick vom Saal, Cyproterone acetate exposure during gestation in mice retards foetal growth. Physiol. Behav. 21:515-517.
1985 Yamashita F, Hayashi M Foestal PCB syndrome : clinical features, intra uterine growth retardation and possible alteration in calcium
metabolism. Environmental Health Perspectives 59:41-45
1988 Rogan WJ, Gladen KL, Hung SL, Koong SL, Shih LY, Taylor JS et al. Congenital poisoning by polychlorinated biphenyls and their
contaminants in Taiwan. Science 241:334-336.
1988 Grocock CA, Charlton HM Pike MC : Rôle of foetal pituitary in cryptochordism induced by exogenous maternal oestrogen during
pregnancy in mice. Journal Reproductive Fertility 83:295-300
Manz A et al. 1991 Cancer Mortality among workers employed in the production of chemicals contaminated with dioxin. Lancet No 8773.
Fingerhaut M A et al. Mortality among workers employed in the production of chemicals contaminated wit h2,3,7,8 tetrachlorodibenzo-pdioxin (TCDD). Final Report, January 1991, US Department of Health and Human Services.
'Chemically induced alterations in Sexual and Functional development -The Wildlife Connection' Wingspread Conference, Racine, Wisconsin
USA, 25th-28th July 1991. Since1991, there have been numerous examples of adverse effects of EDCs in fish, wildlife, domestic animals,
and humans. Endocrine systems have been disrupted by anthropogenic chemicals including antiandrogens, androgens, estrogens, AhR
agonists, inhibitors of steroid hormone synthesis, antithyroidal compounds, and retinoid agonists. In addition, potential pathways and targets
for endocrine disruption extend beyond the traditional EAT receptor–mediated reproductive and developmental systems ...
1991 D'Itri. Mercury contamination: what we have learned since Minamata. Environmental Monitoring and Assessment 19 : 165-182.
1992 Chen YC, Guo YL, Hsu CC, Rogan WJ Cognitive development of Yucheng ('oil disease') children prenatally exposed to heat degraded
PCBs.Journal of the American Medical Association 268:3213-3218.
17th February 1992 USEPA Scientific Reassessment of Dioxin : A Status Briefing for the Administrator Office of Research and Development.
This followed a Memorandum from Cate Jenkins Ph.D of the USEPA, intitiating on 15th November 1990 'A Criminal Investigation of
Monsanto Corporation - Cover-up of Dioxin Contamination in Products - Falsification of Dioxin Health Studies' by Dr Raymond Suskind at
Monsanto's Nitro factory In West Virginia. The studies were used to lobby to help slacken FIFRA legislation. Although found guilty, the firm's
subsequent vendetta against Cate Jenkins was to force her into early retirement. (Cf.
9th October 1992 USEPA's analysis of dioxin incorporates issues that could be relevant to analysis of ETS (Environmental Tobacco Smoke).
Erich W Bretthauer, Assistant Administrator for Research and Development at USEPA, received a memorandum from William K. Reilly,
USEPA Administrator, advising of the need to update the USEPA's dioxin risk assessment due to recent developments then, including
publication of a new epidemiology study. Reilly had emphasized that USEPA's efforts to reduce risk must be based on the best available
scientific information. It was as a result imperative to follow-up new scientific developments, assess what can be learnt from them, act upon
them to improve the programmes, and draw implications from them for USEPA's priorities.This approach was in contrast to USEPA's then
current approach then to its ETS draft risk assessment, which had not included three recent epidemiological studies. THE OCCUPATIONAL
SAFETY AND HEALTH ADMINISTRATION (OSHA). This memorandum marks the beginning of a long battle to get ETS classed as a Group
A carcinogen. Indeed three years later, UK Professor James Bridges was testifying at OSHA hearings to affirm that there was insufficient
evidence to link passive smoking and cancer. Cf.
PVC A Primary Contributor to the U.S. Dioxin Burden by Pat Costner, Charlie Cray, Gail Martin, Bonnie Rice, David Santillo, Ruth Stringer,
Paul Johnston and Allan Vincent, published in conjunction with the Greenpeace International Science Unit Greenpeace, February 1995. The
organisation launched a broad investigation of the PVC industry in 1994, specifically targeting U.S. chemical companies that manufacture
the key chemicals for PVC production: ethylene dichloride (EDC) is converted into vinyl chloride monomer (VCM) which is then polymerized
to form polyvinyl chloride, also known PVC or vinyl. Cf.
1994 Goyer RA, Epstein S, Battacharyya M, Korach KS, Pounds J, Environmental Risk Factors for Osteoporosis. EHP 102, 4: 390-394.
1994 Schwartz J Air pollution and daily mortality : a review and meta analysis. Environmental Research 64 : 36-62).
III. [EPA/600/BP-92/001c] (Cincinnati, Ohio: U.S. Environmental Protection Agency, August, 1994.) This is the official draft of "Chapter 9" of
the EPA dioxin reassessment, also known as the "risk characterization chapter." Linda Birnbaum, director of research at the US EPA Health
Effects Laboratory in Research Triangle Park, N.C., was the leader of EPA scientific team reassessing dioxin. She says, "Dioxin appears to
be a carcinogen in fish, rodents, and other mammals, including humans. But dioxin can also modulate [modify] the immune system resulting
in an inability to fight disease. It is a very powerful immunosuppressant. But it can also upregulate [excite] the immune system so that you
start becoming hypersensitive, developing autoimmunity and allergies. Depending upon the stage [of growth] of the animal and the species,
sometimes you observe immunosuppression and in other cases you observe upregulation." (Cf.
1994 Schwartz J Air pollution and daily mortality : a review and meta analysis. Environmental Research 64 : 36-62).
1995 Pope III CA, Dockery DW, Schwartz Review of epidemiological evidence of health effects of particulate air pollution. Inhal.Tech 7: 1-18.
Our Stolen Future Theo Colborn, John Peterson Myers, Dianne Duomanoski Dutton Press 1996 ISBN 0 3168756 5
“Endocrine Disruptors” Collaborative work from Peter de Fur (Virginia Commonwealth University) and Caroline Raffensberger (Director
Science and Environmental Health Network). Rewritten for 'Takng Action' Strategy Recommendations from the Third Citizens' Conference on
Dioxin and Other Synthetic Hormone Disruptors, Baton Rouge, Louisiana, USA 15-17 March 1996.
Dr C Vyvyan Howard. Foetal and Infant Toxico-Pathology, Liverpool University. First UK public presentation of the work of Peter de Fur and
Caroline Raffensberger, “Endocrine Disruptors” CATs and Green peace Conference, Ellesmere Port, Cheshire June 2006. “Although
exposure took place in the womb, sometimes the effects don't appear until puberty or afterwards, sometimes even in the next generstion”.
1996 Goyer RA Toxic effects of metals. In Casarett & Doull's Toxicology. The Basic Science of Poisons. Magraw-Hill ISBN 0071054766.
1997-2000 In Wales, the chances of birth defects were doubled among families living near the Nant-y-Gwyddon landfill Cf. Fielder HMP,
Poon-King CM, Palmer SR, Moss N, Coleman G. Assessment of impact on health of residents living near the Nant-y-Gwyddon landfill site:
retrospective analysis. [Commentary by Dolk H.] BMJ. 2000;320:19–22 [Additional commentary Roberts D, Dockerty J, Redfearn A].The first
EUROHAZCON study (1997, 1998) "Dolk Report" Much publicised in the UK was a preliminary report in 1997 by Dr Helen Dolk and others
of the London School of Hygiene and Tropical Medicine. They found a statistically significant 33% increased chance of a birth defect
occurring in babies born to families living within 3 kilometres (1.9 miles) of any of 21 landfills in 10 European countries.The researchers
reviewed 46 studies of the human health effects of landfills for the Environment Agency. They concluded, "Landfill sites may represent real
risks in certain circumstances." Air or water pollution ? The exact mechanism of the hazard is unknown. But the evidence about the dangers
of living near a landfill is overwhelming in a society addicted to chlorine chemistry and other sources of organohalogen compounds.
1998 There is more than anecdotal evidence from the Carharrack Residents Action Group of a high incidence of asthma, cancers, infant
mortalities and still births occurring near to the United Mines landfill site at Redruth, Cornwall. The incidence is higher than the Cornish or
national averages. Cf. Health Implications of United Mines Landraising Site (Cf. The unlined tip was licensed for the disposal of waste categories A -F, ie
including most putrescibles, food, some special waste and asbestos. Data analysis by Dr Derek Pheby, formerly of a SWPHO team, reveals
observable increments of several cancer types and statistically significant increases in the incidence of lung cancer and non-melanoma
cancer within the TR16 postcode district. None of these findings were taken into consideration by the relevant PCT statutory consultees and
the Environment Agency reissued a permit for United Mines.
Maynard RL and Howard CV (1999). (Eds) Particulate Matter: Properties and effects upon health. Bios Oxford. ISBN 1 85996 172X.
Dr Linda Birnbaum (USEPA), Chris Portier US National Institute for Environmental health Sciences. Testimony at 'The People's Dioxin Action
Summit' University of California Berkeley CA 10-13 August 2000 Toxcat ISSN 1355-5707 Vol 3 No 12 November/December 2001
2000 Viel J-F, Arveux P, Baverel LJ, Cahn J-Y. Soft-tissue sarcoma and non-Hodgkin's lymphoma clusters around a municipal solid waste
incinerator with high dioxin emission levels. American Journal of Epidemiology 152 :13-19.
A. Curnow, F. Kendall, D. Gould and L. Salter. Arsenic inhibits single strand DNA repair in cultured human cells. British Society for
Investigative Dermatology, Edinburgh, 07/04/2000 (Cf.
A Preliminary investigation of the effects of arsenate on irradiation induced DNA damage in cultured human lung fibroblastes. A Curnow et al.
Journal of Toxicology and Environmental Health Part A pp. 605-616 13th February 2001.
Incineration and Human Health : State of Knowledge of the Impacts of Waste Incinerators on Human Health Michelle Allsop, Pat Costner
and Paul Johnston. Greenpeace Research Laboratories, Exeter University. March 2001. Appendix A 'Health Effects of Specific Pollutants
released from incinerators' provides numerous bibliographical references and detailed discussion of their relevance to MSW incinerators.
The second EUROHAZCON study (Lancet 26 January 2002) 245 cases of chromosomal anomalies were studied along with 2412 controls
who lived near 23 hazardous waste landfills in Europe. After adjustment for confounding by maternal age and socio-economic status, a
higher risk of chromosomal anomalies was noted in people who lived close to sites (0-3 km) than those who lived further away (3-7 km).
Results suggest an increased risk of chromosomal anomalies similar to that found foe non-chromosomal anomalies.
D. Gould, A. Curnow, N. Morley and L. Salter. Synergy between pollutants and ultraviolet radiation: a comet assay investigation. British
Association of Dermatologists, Brighton, 01/07/2003 (Cf.
EG Knox Childhood cancers and atmospheric carcinogens.J Epidemiol Community Health 2005;59:101–105. doi:10.1136/jech.2004.021675.
Distribution of PCDDs/PCDFs and Co-PCBs in human maternal blood, cord blood, placenta, milk, and adipose tissue : Dioxins showing high
toxic equivalency factor accumulate in the placenta Biosci Biotechnol Biochem. 2005 ; 2005 ; 69 (190); 1836-1847 January 5th, 2006 . G.
Suzuki and colleagues working with Rakuno Gakuen...Analysis of PCDDs/PCDFs and Co-PCBs indicates toxic dioxin levels accumulate in
Body Burdens of Polychlorinated Dibenzo-p-dioxins, Dibenzofurans, and Biphenyls and Their Relations to Estrogen Metabolism in
Pregnant Women Shu-Li Wang,Yu-Chen Chang,How-Ran Chao, Chien-Ming Li, Lih-Ann Li, Long-Yau Lin, and Olaf Päpke. 2006 study
suggests that dioxin exposure significantly affects oestrogen metabolism. Cf.
“We think that it would be wrong to discount public concern about the health implications of incineration products (especially
dioxins) on the grounds that it is derived from the experience of an older generation of municipal incinerators which the 1989
Directives have essentially done away with. Although considerable progress has been made in understanding the toxicology and
exposure effects of many of the key pollutants, continued epidemiological work will be needed. We consider there are well
established grounds for caution, justifying the general approach of the draft Directive. We feel that the collection and study of
data on the potential health risks, from combustion products should continue to be a priority”. 11 Report HL Paper 71, 15th June 1999
Featuring in the record of proceedings for the 1999 hearings of the House of Lords Select Committee Inquiry into
'Waste Incineration', the above comments would appear to echo the doubts and misgivings expressed by Dr Dick van
Steenis, Communities Against Toxics and Friends of the Earth. Almost predictably however, in the summary and
conclusions, they carry so much less weight than the waste industry's commercial interests. As with other public
consultations, lip service is paid to ordinary people's concerns. To draw an analogy, one has only to consider how, in
the face of all the medical evidence, tobacco manufacturers were allowed by law to hide the list of toxic ingredients in
cigarettes, tailormade to poison people and keep them addicted, or the decades of official secrecy over the serious
illness and the annual 4000 premature deaths, directly attributable to the activities of the asbestos industry.
The list of 599 additives approved by the Food and Drug Administration for use in mass-produced cigarettes is
something every smoker should see. Submitted by five major cigarette companies to the US Department of Health
and Human Services in April of 1994, this catalogue of ingredients - including known carcinogenic substances - had
long been kept a secret. Often approved as additives for foods, none were tested by igniting them. It is combustion
of many of these substances which changes their properties, often for the worse. Over 4000 chemical compounds
have been identified in the smoke of a burning cigarette – 69 of them are known to cause cancer. Carbon monoxide,
nitrogen oxides, hydrogen cyanides and ammonia are all present in cigarette smoke. 43 known carcinogens are in
mainstream smoke, sidestream smoke or both. Smokers not only poison themselves, they expose others who may
breathe in the secondhand smoke. Relatively draconian and legally enforcable measures have been introduced in
recent times to protect the public. Smoking cigarettes and becoming addicted to an alkaloid, like nicotine, and other
metabolites is a matter of personal choice. Surely the host communities of waste-to-energy incineration facilities
should be offered the possibility of not to passively smoke the fumes to which industry and government at all levels
connive to expose them, making nonsense of the right to prior informed consent. Especially when the 'filter tips' on
incinerator dumpstacks are about as effective as a plaster on a wooden leg and as useful as a hip pocket in a shirt.
Tobacco companies reporting this information were:
American Tobacco Company
Brown and Williamson
Liggett Group, Inc.
Philip Morris Inc.
R.J. Reynolds Tobacco Company.
Source :
Council accused over Sita links
Western Morning News Monday, February 08, 2010, 10:00
Comment on this story
CORNWALL Council has been accused of harbouring a "culture of collusion" over the controversial strategy for a £117
million waste incinerator.
Documents released under the Freedom of Information Act show officials have advised waste contractor Sita UK on how to
handle councillors, the media and on the timing of sensitive announcements.
The e-mail correspondence about the proposed energy-from-waste plant at St Dennis, Mid Cornwall, was unearthed by
opponent Stephen Gilbert, who claimed it suggested a "culture of collusion".
"I expected to see no more than a dozen e-mail exchanges between the council and Sita around each of the milestones of the
process," said the Lib-Dem prospective Parliamentary candidate for St Austell and Newquay.
"I was shocked and horrified to see more than 400 pages of material. It has to bring into question whether the council is an
independent adjudicator of the planning process."
French-owned Sita UK was awarded a 30-year, £427 million waste management contract by the county council in 2006.
The company had planned a single incinerator, with a 390ft chimney, to burn 240,000 tonnes of waste a year, converting it
into electricity and heat to power 21,000 homes.
Those proposals were rejected by the former Cornwall County Council in March last year, leaving the future strategy for
managing Cornwall's waste in disarray. Sita announced its appeal last September.
But Mr Gilbert claimed the documents revealed that the "client/contractor" and "planning authority and applicant"
relationship had become confused, with officers "overstepping the mark".
"It is all very well to open a relationship with a private company and contractor but behind the scenes, the council should
have enough firewalls in place to prevent what seems to be a far too cosy relationship," he added.
"You might expect council officers to work with Sita but in my view, that should be limited to strategic issues, not the way
information is presented to members."
One e-mail from an unnamed Sita official was sent to County Hall a week before the plans went before the planning
committee on March 26.
"We feel we should send a letter to the members in advance of the planning meeting to ensure they are fully informed," it
said. "The first draft is attached. This will also be the basis of my presentation on the day. Comments would be welcome."
An officer from County Hall responded by offering advice on the presentation and tips on what else to include.
"I agree with (name redacted) that the tone is good and that the first para (graph) should be modified as she suggests.
"Electricity and heat: I would also add some more on the heat use by Goonvean and Imerys reducing significantly the use
of gas, a fossil fuel, and helping to secure the future of those driers and associated jobs.
"Nature conservation: Make the point that the enhanced clean up and higher stack will make this the cleanest plant the
country, as befits Cornwall.
"Health impacts: Should include a quote from the Food Standards Agency. Employment: Could also include the
employment of Cormac – 40 on the road construction for a year."
Two days before the planning decision, someone else at Cornwall Council said the private briefing of councillors "went
well" adding that the "heat use" by the driers "could make several members vote in favour if it is presented in the right
Despite the advice, councillors rejected Sita's planning application – to the joy of campaigners from St Dennis.
Behind the scenes, discussions between council officials and Sita then turned to the likelihood – and timing – of an appeal.
One note from the council on April 28 cynically suggested that the appeal could have been made during the county election
"purdah period" – a political move designed to frustrate debate as councillors would have been unable to comment.
Another telling exchange came in August 2009 – two weeks before Sita made public its intention to appeal.
A letter from a council official laid out concerns about the company's ability to manage media inquiries, while Sita was
asking for a delay.
The response from Sita warned: "As we learnt from the previous planning process, management of media interaction,
development of a positive argument and above all access to members is critical."
Officials in the council's legal department were also not afraid of having a flippant swipe at local campaigners, after Sita
was rebuked by the Advertising Standards Agency over one of its leaflets.
"I trust they will be looking at some of Stig's (St Dennis Anti Incinerator Group) literature too," said the council e-mail.
Mr Gilbert said he had been "consistently opposed" to the incinerator even though it put him at odds with his own party,
when the Lib-Dems controlled the county council.
"My view is that it is the wrong technology," he said. "Do we really want to send 250,000 tonnes of waste to be burnt, yearon-year for 30 years? I am 33 now, and I will be 63 when we stop paying for this PFI contract.
"I'd like the council to look at anaerobic digestion and gasification, in particular, to have four or five smaller sites, near to
the major centres of population in Cornwall."
Campaigners are currently working to prepare for the planning inquiry, which is due to start on March 16 and last for more
than 20 days.
Pat Blanchard, chairman of the St Dennis Anti Incinerator Group, said she was "hugely disappointed" by the content of the
"Clearly, we have got one group of officers and councillors who believe this is a bad application and should be refused,"
she said.
"Then we have got another group of people who seem to be more interested in saving face and their reputation and looking
after Sita's interests. They need to be reminded that they serve the people of Cornwall, not Sita."
Matthew Taylor, MP for Truro and St Austell, said the e-mails were "clearly unacceptable".
"They clearly overstep the mark," the Lib-Dem MP added. "It can't be right that officers are telling Sita how to influence
councillors' opinions."
A spokesman for Cornwall Council said its relationship with Sita was "professional and robust" and that the council had
"endeavoured to be as open as possible" over the incinerator. "Cornwall Council has a long-term contract worth over £400
million with Sita for the provision of waste management services throughout Cornwall.
"The relationship between the council and Sita is professional and robust and it is entirely understandable that there has
been, and will continue to be, extensive contact between the two organisations on all levels.
"The contract has already delivered significant improvements to the network of household waste recycling centres, transfer
stations and the two materials recycling facilities with more recycling centres and transfer stations on the way.
"Cornwall Council has endeavoured to be as open as possible with the public when dealing with the emotive issue of the
Cornwall Energy Recovery Centre given that some items, as in all business matters, have to be treated as confidential."
A spokesman for Sita said: "Sita Cornwall is a major supplier to Cornwall Council, with a 30-year contract to supply vital
services on behalf of every household in the county.
"It is only right and proper that we should communicate with the council to ensure we offer the quality services they expect.
"It is also important that we agree how our activities should be communicated, so that the public is given accurate and
consistent information.
"Regarding the delivery of new waste infrastructure, including the CERC, it is crucial that we talk to the council regularly,
as this represents a series of extremely important decisions, which must be made following an open dialogue."