The promoters's Air Quality report was proven in public at the Bord Pleanala hearing in 2007 to be fundamentally flawed. Ten percent of an orange plus ten percent of an apple does not give you 20 percent of a banana. The lack of peer review and quality control for that report is disturbing. Can the promoters be trusted with our health?
Following that 2007 fiasco the promoters seem to be arrogantly following the same organisational methodology for the Irish EPA oral hearing in 2008. As highlighted on the first page of the promoter's brief, the specialised hired-help who created the brief is very connected to Irish government construction contracts and to commissions from pharmaceutical companies. With this overwhelming dependence it is fair to strongly question the credibility of the promoter's brief across multiple dimensions.
For example the promoter's Air Quality brief-of-evidence omitted:
- risks from accidents,
- explosions,
- uncontrolled bypasses of the pollution control equipment or
- similar problems that can and do occur at incineration facilities.
These serious omissions seem to follow a curious pattern of information disclosure. What is hidden from the public?
The wordings are curiously similar to those used by San Joaquin Valley Air Pollution Control District when promoting a Covanta incinerator at Fresno California.
The Health Risk Assessment (for Covanta-Stanislaus-Inc Incinerator at Fresno, California) incorrectly claims that the assumptions used in the study are "designed to be conservative." At the December 3rd hearing the Air District confirmed that the Risk Assessment did not assess risks from accidents, explosions, uncontrolled bypasses of the pollution control equipment or similar problems that can and do occur at incineration facilities.
Based only on "maximum allowable emissions," the Health Risk Assessment thus lacks an accurate, real-life evaluation of what happens during violations, accidents, uncontrolled bypasses of pollution control equipment and other breakdowns. It lacks a realistic worst case scenario. This omission is a huge defect in the Health Risk Assessment and is a fatal flaw in the permit review and approval process. A permit must not and cannot be approved based on this inaccurate and flawed Health Risk Assessment.
Covanta Stanislaus, Inc at Fresno, California: Assessment of Health Risk Assessment Study prepared by the San Joaquin Valley Air Pollution Control District [Source: http://www.greenaction.org/stanislaus/covantacomments121602.shtml ]
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Do the promoters have a cynical attitude to the public? Do the promoters provide the truth and the whole truth? What does the following curious pattern of wordings say?
“ ... A conservative approach has been adopted ... “
Covanta Dublin Bay Incinerator: Extract from EdwardPorterAirQualityF01.pdf wrt Covanta Dublin Bay Incinerator.
'assumptions used in the study are "designed to be conservative." '
Covanta Stanislaus, Inc at Fresno, California: Extract from Health Risk Assessment prepared by the San Joaquin Valley Air Pollution Control District
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“ ... emissions ... were assumed to be operating at their maximum emission level ...”
Covanta Dublin Bay Incinerator: Extract from EdwardPorterAirQualityF01.pdf
" ... maximum allowable emissions ... ”
Covanta Stanislaus, Inc at Fresno, California: Extract from Health Risk Assessment prepared by the San Joaquin Valley Air Pollution Control District.
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All comments are allegations believed to be correct and are subject to correction.
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