Jersey’s Save Our Shoreline (SOS) group has been active in raising the alarm over incinerator proposals for the island.

Save Our Shoreline have now submitted a substantive dossier to the Environment Scrutiny Panel containing strong and expert evidence that the Planning Consent for the ‘Energy from Waste’ plant is seriously flawed in several aspects.

The Environmental Scrutiny Panel have agreed to conduct a full review on the basis of the evidence so far submitted, and SOS has joined other campaigners in calling for a halt of the construction until the evidence has been heard and judged by the Panel.

Recent evidence has been sent to SOS by Dr. Stephan Funk Phd MSc MsC, a respected expert on EIA methodology, together with evidence regarding Planning Law infringements from Mrs Lara Luke who has a Bsc (Honours) degree in Environmental Studies and holds a diploma in Pollution Control. Both parties have concluded that the EIS is not compliant with current Planning Laws.

Some of this evidence can be downloaded from the Jersey in Peril website. Concerns include:

1. AIR POLLUTION
The chimney will be re-used for the incinerator as will the culvert. The chimney and culvert are exempt from current emission laws, which may be convenient for TTS and Planning but is contrary to currently declared policy and will not conform to EU standards. The Planning department have said that there was no need for any EIA with regard to airborne emissions relating to the Ramsar area. Why not? Dr. Funk is clear that marine organisms react differently to human organisms and this has been ignored.

In Dr. Funks’ words:

It is a well established fact that levels of toxicity of chemicals is not identical for all organisms and varies greatly. Bio-accumulations of pollutants through the food chain is well documented and can cause disease. What might pose no risk for humans might be highly toxic to other organisms and vice versa…the EIS did not provide evidence that there is NO rise to noticeable impacts on the ecology of an adjacent marine system.

Yet the basic requirements have not been carried out – no baseline samples have been taken. No account has been taken of the fact that there are shellfish farms to the east within the Ramsar area.

Babtie Fichtner commissioned Ambios Environmental Consultants to carry out a baseline ecological assessment of land at the La Collette reclamation site. The report does not include any survey or scientific data on the Ramsar site and did not assess any potential risk to the Ramsar Site. The report states that “There will be no impact on the adjacent RAMSAR Site.” Ambios were tasked only with looking at the inert waste upon which the incinerator will be built, yet for some reason made conclusions about the adjacent area. This conclusion is not substantiated by any data or evidence.

2. WATER POLLUTION
Heated ‘cooling’ which will be piped into the Ramsar area through a culvert previously used by the JEC Power station, again under old permits and therefore not subject to more stringent modern environment legislation. These effects have not been properly addressed in the Babtie FIchtner EIS or at all in the Ambios EIA. The same culvert will be used, emerging this time further into the Ramsar area as can be judged from the second photo. This marine intrusion is not recognised as being significant and other probable effects upon the Ramsar area, such as chemical leachates from the porous base of the incinerator or wind borne surface material (including toxic fly ash) are not considered by the Planning or TTS as worth addressing. They rely solely on the contractor’s good will in this area. SOS does not.

With regard to cooling water, the EIS states “It is therefore expected that any impact on coastal habitat would continue as currently i.e. extremely localised and of minor significance.”

Dr. Funk responds:

The EIS fails to present data substantiating the statement of minor significance. It mentions a previous assessment but without citing data or evidence the report contains the word ‘cooling’ 21 times yet no underpinning data.) Thus the Babtie Fichtner EIS did not conduct an independent impact assessment on this issue.

3. PLANNING CONSENTS AND THE LAW
Old out of date consents are to be used on both the chimney and the culvert. SOS believes this contravenes not only our Planning Laws and EU legislation, but the ‘Wise Use’ policy of Ramsar.

4. FURTHER EROSION OF RAMSAR AREA
A new Emergency Road is to be constructed to the east of the plant. It will necessitate the demolition of shoreline rocks along the perimeter and within the Marine Protection Zone and the Ramsar area, and we contend that this will contravenes the Planning Law relating to SSIs (copy & notes attached) unless consent is granted with specific conditions.

5. EU INCINERATION PRACTICE
The ‘EfW’ plant will be burning Jersey’s waste which is not currently separated, Therefore nickel and cadmium batteries and electronic parts etc will all be burned, releasing heavy metals into the atmosphere. The chimney emissions fallout radius will be is very close to the most densely populated and school intensive areas of the Island, St. Helier when the wind is in the south and east , and close to the General Hospital where the most at risk and elderly residents of the island will be. When the wind is in the west, the emissions will fall on the Ramsar area. This release of emissions containing heavy metals is not allowed in the EU, yet Senator Cohen has confirmed that local standards must replicate EU standards.

6. RAMSAR ORGANISATION & DEFRA IGNORED
Finally but no less important. Up until 6th December 2008 not one letter or communication from the States of Jersey, Planning or TTS informing the Ramsar Organisation in Switzerland, or DEFRA in the UK, of their intentions to build a massive incinerator on porous ground only yards from a wetland of International importance was sent. Nor was advice on how best to conduct an EIA on the possible effects of this incinerator sought.

This is in contravention of our International Obligations, and at the least totally discourteous to the Ramsar Organisation, who have arranged for a web page to be displayed on a partner site (Wetlands.org) in support of our case. If the Ramsar Organisation support us, then we feel that our case is strong.

For more details, visit the SOS Press Release of 17th February, 2009. You can also read Stephan Funk’s Report and SOS’ comments on relevant Planning and Building Laws and much more!