Indaver submit starving man and grossly understated vertical plume risk zone to Bord Pleanala

CHASE have submitted forensic analysis of Indaver’s new material to Bord Pleanala which reveals a starving model man on under 1,000 calories a day in order to meet EU dioxin intake limits, a gross underestimation by over 57metres of the vertical emissions dispersal and associated risk zone to helicopters, comparisons with a helicopter landing base near a UK Naval base that fails to mention that helicopter operations there ceased in 2012, three years before the nearby incinerator commenced operation in 2015, as well as ongoing dioxin discrepancies. The submission period for observations on Indaver’s new material closed on Friday last, 21 July at 5.30pm.

The material submitted by Indaver in May 2017 at the invitation of Bord Pleanala refers to further information on flight paths around the incinerator stack and information regarding the incorrect dioxin information submitted on the final day of the 2016 Oral hearing.

RISK TO HELICOPTERS AND SAFE OPERATIONS AT HAULBOWLINE NAVAL BASE

• Indaver consultants, Irish based Graham Liddy and UK based DBS Consulting, have misinterpreted reports carried out on behalf of Indaver to present a 3.5m high-risk plume zone in both horizontal and vertical directions when the true high-risk plume segment models to a vertical height of 61m.
  
• Modelling carried out for CHASE in response to Indaver’s new material (modeled using AERMOD, taking incinerator specifications provided by Indaver in their EIS and real weather data from the Roches Point weather station) shows the danger zone for helicopters from the incinerator plume extends 61m vertically above the stack (430ft above ground level), not the 3.5m distance submitted by Indaver. The modelling was carried out by Plume Plotter and a video animation ( https://youtu.be/sghB1jcDgC8 )can be viewed at https://youtu.be/sghB1jcDgC8.
  
• Applying the Department of Defence recommended “standard obstacle clearance height of 500ft”, the minimum safe height for helicopters is 930ft, which is consistent with the Department of Defence conclusion that a 1,000ft avoidance zone is required and the statement of the Department of Defence at the 2016 Oral Hearing that it would be reckless to operate an aircraft anywhere close to that high-risk zone.
  
• Indaver mislead in their failure to mention that a helicopter landing site which they reference at Devonport Naval Base in the UK closed in 2012 BEFORE an incinerator opened nearby in 2015, instead stating “The waste to energy plant has been operating since 2015 without interfering with the operations of the Naval base in any way as we believe would be the case for Haulbowline”. This statement was made despite Indaver having carried out a site visit in 2017 along with their consultants.
  

DIOXIN MODELLING

• Indaver have starved the MARI man, allocating a calorie intake below 1,000 calorie a day diet in order to meet EU limits of acceptable daily dioxin intake. The MARI (most at risk individual) is a theoretical subsistance farming family living in the vicinity on whom the effects of dioxin and dioxin like compounds are modelled over a lifetime. If the MARI man had been fed a subsistance farmers typical diet, the MARI adult’s dioxin/furan intake rises well above the EU “tolerable intake” and the MARI child’s dioxin-like intake rises to over 30 times as high as the figure submitted by Indaver and 4 times the EU “tolerable intake”.
  
• Predicted levels of dioxins/furans still do not link consistently with dioxin/furan intake in certain tables.
  
• Modelling documents reviewed and reported on by Dr Paul Johnston for Indaver do not appear to be the same documents as those which have been made available to the public via the Indaver owned website ringaskiddyrrc.ie, and presumably also submitted to An Bord Pleanala.
  
• No robust explanation has been offered by Indaver for the original errors, instead claiming ‘transcription error’ which is not credible.
  

Dioxin expert, Dr Gordon Reid, who exposed the irregularities on the final day of the hearing said “In view of the fundamental unreliability of the data we have already been given, and its only partial improvement in the further information now submitted to the Board, I would suggest that the Board cannot accept at face value the dioxin deposition values”.

CHASE Chairperson Mary O’Leary said “The shameful inaccuracies, manipulation and omission of critical information are an attempt to gain planning at all costs, including misleading the planning authority and the community that an application is safe when it is not. It is a cornerstone of the entire planning system that the information submitted by a developer must be true. That cornerstone has been shattered in this case and it would be outrageous to grant permission or scope for any further clarification in these circumstances.

It is time to reject this application once and for all, allow Cork Harbour to reach its full potential and to get in line with current EU Circular Economy recommendations.”

The Bord Pleanala website currently states a decision date is currently unavailable. The decision was originally due in July 2016 in order to meet Strategic Infrastructure statutory guidelines.

Links
Link to Plume dispersal animation video
https://youtu.be/sghB1jcDgC8
Plume Plotter ringaskiddy modelling page
http://plumeplotter.com/news/ringaskiddy/plume.html
Dr Gordon Reid dioxin submission for CHASE
http://chasecorkharbour.com/wp-content/uploads/2017/07/Response-to-Indaver-further-information-dioxins-Dr-Gordon-Reid-19.07.2017.pdf
Dr Gordon Reid illustration and basis for calculations
http://chasecorkharbour.com/wp-content/uploads/2017/07/Reference-document-and-illustrations-for-Dr-Gordon-Reid-analysis.pdf
Helicopter Risk submission from Mike Griew, Pilot
http://chasecorkharbour.com/wp-content/uploads/2016/01/PL04_PA0045_MGriewComments.pdf
Bord Pleanala application page
http://www.pleanala.ie/casenum/PA0045.htm