Dear Mr. Fadi Aboud
We, at the Green Party in Lebanon, would like to thank you for sharing with us the specifications of the incinerator that is planned to be installed in Dhour Chweir. Also, we appreciate very much your transparency in communicating to the public some useful information about the incinerator.
Yet, we are writing to express our concern over the proposed incinerator. In general, we found it outrageous that such an environmentally harmful venture would be considered, while most local and national efforts are directed towards finding and adopting more sustainable solutions. We believe that promoting waste incinerators (either as local or national solutions to the waste crisis), while the pressure of the waste scene on the streets of Lebanon is not fair.
In general, we heard in many occasions how relevant companies and firms tell communities how safe and good modern incinerators would be, only then to learn that known carcinogens would be released daily into the air.
Like any other project with possible impact on the environment, this project will require by Law the preparation of a credible environmental impact assessment (EIA). Have you had the chance to conduct any EIA prior to the establishment of the incinerator? Is this project coordinated with the Ministry of Environment?
Your public interventions stated that the plant is only designed to deal with sorted waste. Then who is going to control the process of sorting and feeding the incinerator with the right type of wastes? Was this incinerator tested for the specificity of the waste in Lebanon? What kind of and which portion of waste will be burned? We all know that the largest portion of our wastes is composed of organic material, and another important fraction can be recycled, then why do we need to burn the inert material while it can be dealt with in many different environmental friendly and less costly ways.
Looking at the firm’s catalogue of incinerator, one should be reassured that certain emissions from the incinerator will be within ‘legal limits’, however we need to be clear that there will be always the risk that incinerator chimneys emit organic substances such as dioxins, heavy metals such as cadmium and mercury, dust particles and acid gases such as sulphur dioxide and hydrochloric acid. All these emissions have a detrimental effect on public health. How are you going to ensure that the incinerator will be maintained to fulfill all conditions for destroying harmful emissions such as dioxins and furans? Who is going to control and monitor that? What about the emissions of nanoparticles? We draw your attention that many of tiny particles do not have any air quality standards or regulations attached to them which basically gives incinerator companies freedom to emit without consequence. That is why many of these were not initially indicated in the emissions data table of the incinerator A8000. Besides, do we have in Lebanon laboratories, research centers, and advanced equipment to detect and monitor the emissions of these highly toxic gases? Who will control and supervise works for sorting, monitoring, and safely disposing toxic ashes, especially that some tests cannot be performed in Lebanon? Who will operate the incinerator? What are the experiences of the operator?
The permissible limits for emission of many of substances that could be emitted by an incinerator have been continuously tightened by the European Directives aiming to prevent and limit negative environmental effects by emissions into air, soil, surface and ground-water, and the resulting risks to human health, from the incineration and co-incineration of waste. Accordingly, manufacturers of incinerators have been trying to comply to some sort of emission standards, however, this does not mean that the “safe” emissions per annum are safe and will have no adverse effect on local communities and their health – it just means they will be within legal limits. Given the extreme toxicity of dioxins among others, any extra burden on human health would be unacceptable, so the ‘precautionary principle’ should be applied and no more avoidable pollutants should be added to the environment (i.e., through incineration).
Maintenance, emissions control, and monitoring are of concerns with the lack of expertise and technical know-how. For example, who is going to ensure that the incinerator is maintaining throughout time a homogeneous high temperature (>850 degree), and excess of oxygen (>6 %), among other factors to efficiently destroy dioxins, furans, and similar gaseous components?
Modern incinerators such as the A8000 (Inciner 8) are supposed to use filters and processes to remove many of the harmful particulates and toxins produced as a result of the incineration process. However, such incinerators still do not filter out the smallest particles. These ultrafine tiny particles are not captured through air pollution control measures and may pose a threat to human health.
With regard to bottom and flue ash – it is not apparent that efforts have been made to secure a safe option to re-use or landfill generated bottom and flue ash – it should be a requirement that bottom and flue ash be safely dealt with as extremely toxic material. Toxic emissions and dangerous substances are concentrated in fly ash and pose a problem – they will require inertization before the disposal in controlled and special landfills which are not available in Lebanon. What will be done with the remaining ashes and how will it be handled and transported? Are the right inertization procedures secured?
One of the main thrusts behind the type of plant suggested is that it resolves the wastes problem at the local level – however this does not respond to the strategic objectives of managing municipal solid wastes in Lebanon. No one wants to see in the future an incinerator for every group of municipalities. In the potential presence of many incinerators and the lack of control, Lebanon will enter the worst health threat time until present, and accordingly, risk of cancer and other chronic diseases will multiply to remarkable levels. Instead, we shall be aiming at more sustainable and healthier coordinated solutions for municipal solid waste management.
Last, but not least, the proposed incinerator is expected to burn 70 liters of oil per hour (in reference to your intervention at Manar TV on the 29-10-2015). This is expected to generate 1490 tons of CO2 every year locking the plant into generating a big quantity of dangerous greenhouse gases in addition to other pollutants for burning fossil fuels at least for the next 10 years (or over the entire life span of the incinerator) at a time we need to be urgently reducing emissions of greenhouse gases and other pollutant gases. This has been clearly reflected in Lebanon’s national strategies and plans for climate change mitigation and adaption, and it was also reflected in the recently published Intended Nationally Determined Contributions (INDC) report which Lebanon submitted to the United Nations Framework Convention on Climate Change (UNFCCC), and which will be considered among all other INDCs in the crucial negotiations that are expected to take place during the 21st Conference of Parties to the Convention on Climate change to be held in Paris next month.
Overall, why are we encouraging investments in costly and probably polluting technologies and not pushing towards adopting good practices for reducing wastes, recycling material, composting organics, and properly processing inert material? Do we really want from this pilot project to push towards incineration at the National level (with all its drawbacks on the environmental and public health) that is expected to involve an expenditure over 1 billion and two hundred thousand dollars for 4 incinerators (excluding the high operational costs), and a minimum of four years for implementation, while sorting and recycling needs only very few millions of dollars and a much shorter time for implementation?
In brief, we believe that a sustainable future, a future where sound science and logic prevails, will count on recovering of resources from waste through sorting, recycling and processing organic material whether at the local, regional, or national level. Only this will allow the adoption of the highest
standards of environmentally hygienic safety methods and approaches with very reasonable cost that is expected to be reduced by the values retrieved from waste, exactly like in many other countries.
Your Excellency, based on the extensively presented arguments above, we highly object to the proposed incinerator. It is hoped that you seriously re-consider the use of the incinerator and together, hand by hand will work towards a better vision of the future, one in which we tap into the different opportunities for properly managing our resources.
Green Party of Lebanon