Levy on Incineration: letter to Minister Hogan

Full text of letter to Minister Hogan
Ref: Levy on Incineration
Dear Minister Hogan,
It must be stated from the outset that the Environmental Pillar is opposed to the use of mass burn incineration as a part of the waste management strategy.  This opposition is based on the many impacts that incineration will have on the health and well-being of the public, and the damage it will do to the agri-food, tourism, blood-stock and green industries and their capacity to provide jobs and sustainable employment.  The impact on the economy is discussed further in appendix 1 below.
In the short-term, given the current circumstances where incineration has already become part of the waste management infrastructure, the Pillar asserts the urgent necessity for an incineration levy to recover at least some of the costs, to society and the economy, of the pollutants released in the process.  That said, it is clear that no levy could ever compensate for the long-term health impacts resultant from incineration.
The EU waste hierarchy, as adopted into Irish law earlier this year obliges Irish waste management, legislation and policy to prioritise the prevention of waste over other management strategies. The absence of a levy on incineration would appear to be in conflict with this requirement.  There is also the need be consistent in legislating in order to reduce waste production rather than create a market demand in order to feed the incineration industry.
Without a levy, incineration would gain undue market share simply by ‘free riding’ its pollution costs. This is the principle reason the ESRI and Eunomia reports, both completed with the last two years, recommended an incineration levy.  A review of their findings and a discussion of the possible levy rates to be applied are to be found in Appendix 2 below.
The pollutants released during incineration include arsenic, cadmium, chromium, lead, mercury, dioxins, and furans among others. Although a levy is likely to only reduce the impact from the release of these highly toxic substances on those receiving the fallout from incinerators, any failure to charge for these pollutants would run counter to a core principle in European and Irish waste management – that the polluter pays.
The urgent need to establish a clear regulatory infrastructure that protects the environment, the economy and the tax-payer is brought into focus by the imminent commissioning of the Carranstown incinerator, located close to Duleek in Co Meath, and the on-going discussions regarding the proposed incinerator at Poolbeg in Dublin.  This infrastructure must include the immediate introduction of a levy set at a rate that will maintain the push to reduce, reuse or as a last option to recycle.
I hope you find this letter of assistance and look forward to working with you to bring about a situation where incinerator operators have a real incentive to minimise the release of what are highly toxic pollutants, and moreover, that the toxins and other harmful chemicals which are released carry a financial burden for the plant operator.
The Environmental Pillar stresses again its willingness and dedication to work with you on this and other environmental matters.
Kind regards,
Michael Ewing
Coordinator, Environmental Pillar of Social Partnership
Knockvicar, Boyle, Co Roscommon, Rep of Ireland
Tel: +353 71 9667373
Mob: +353 86 8672153
Email: michael@environmentalpillar.ie
web: www.environmentalpillar.ie
Letter to Minister Hogan on Levy Incinerators 31st August 2011 – with appendices