10. Comments on the Environmental Impact
Assessment (EIA) study on the Proposed Waste
to Energy (WTE) Plant at La Chaumière.

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10.8 Socio Economic Impacts

The EIA report contains a section supposedly to review the Potential Social, Cultural and Socio economic issues. The report even suggests that in the absence of local guidance on how to carry an impact assessment on the social, cultural and economic issues, it has made use of the latest IFC guidance notes57.

IFC Performance standards on social and environmental assessment establish the importance of:

(i) Integrated assessment to identify the social and environmental impacts, risks, and opportunities of project;
(ii) Effective community engagement through disclosure of project-related information and consultation with local communities on matters that directly affect them; and
(iii) The Client’s management of social and environmental performance throughout the life of the project.

Unfortunately neither the identification of social and economic impacts as elaborated in the said IFC document is addressed in the review section of the EIA report nor the output expected from the said assessment.

To illustrate the misuse of the IFC document, two examples are given below:

o It is stated in the IFC document that the assessment will be an adequate, accurate and objective evaluation and presentation of the issues, prepared by qualified and experienced persons58.

o As part of the assessment, the Client will identify individuals and groups that may be differentially or disproportionately affected by the project because of their disadvantaged or vulnerable status.

The EIA report has not even identified the economic activities and social vulnerability of the persons associated with these economic activities.

Hence one would have expected that the EIA report, in conformity to the requirements of the IFC document, provides a detailed of agricultural and farming activities in the immediate vicinity of the Site. The vegetable growers and pig breeders are the most vulnerable groups and the following details are reported by Carl Bro:

• To the immediate north of the site is the new St. Martin Wastewater Treatment Plant (Lot no. 5), designed for a population equivalent of about 150,000 and expected to come into operation in 2004;
• Lot no. 2 is 25 acres of land vested in the Ministry of Commerce and Co- Operatives for a piggery relocation project and occupied by 50 illegal squatters;
• Lot no. 1 is land under the control of Ministry of Agriculture, Food Technology and Natural Resources and part of it is also occupied by illegal squatters;
• Lot no. 3. is 10 acres of land leased to the Plaisance Pig Credit and Marketing Cooperative Society Ltd for a pig farm;
• Lot no. 4 is the Regional Co-operative Office of the Ministry of Commerce and Co-Operatives;
• Further north are the sugar cane plantations of the Medine Sugar Estate and some private planters;
• To the immediate northeast of the site is a mixed residential/agricultural land use area (Lot no. 6). This Lot is leased by the Ministry of Commerce and Co- Operatives to small-scale vegetable growers forming part of the St. Martin Cooperative Society. There are also some pig breeding activities. According to a site survey in October 2003 there are about 40 plots of land, 17 of which had buildings erected on them. Most of the buildings seemed to be used for residential purposes and a few for storage purposes ;
• On the eastern boundary of the site is private property land belonging to SODIA used for cattle breeding and poultry rearing;
• Bordering the site on the western and southern boundary (Lot no. 7) is land leased to SODIA for cattle grazing;
• About 1 km south east of the site is the La Chaumiere agricultural site where significant vegetable production is carried out.

Despite the claims of the EIA report that gaseous emissions will have no impact on the environment, it is well known that areas underneath the emission plumes of a MSW incineration plant are more impacted because pollutants from the stack are more likely to reach the ground closer to the MSW Incinerator. The impacts on the agricultural and farming activities should have been evaluated as the livelihood of the small farmers and vegetable growers is at stake.

Furthermore the EIA report should have also addressed socio economic impacts on a regional and national basis. The economic development that has started in the region viz. construction of Club Med, aquaculture project, IRS Projects at Bambous and Albion, commercial centre at Canot, etc. The tourism sector at large as it will be difficult to allay the fears of tourists that the food they are consuming are not contaminated with the highly toxic compounds that emanate from a waste incinerator.

It is not surprising that in view of the shortcomings of the EIA report on the identification of the socio economic impacts of the proposed WTE Plant on the immediate vicinity of the Site, mobilisation of public opinion against the Project has been gathering momentum in recent weeks.

10.9 Conclusions

10.9.1 The EIA report is based on two main uncertainties, namely:
• The characteristics of the waste still need to be confirmed;
• The characteristics and quantities of the various pollutants in the gaseous, liquid and solid waste streams generated by the proposed WTE Plant are unknown and these are strongly dependent on the waste characteristics and nature of the solid waste.

10.9.2 Impact assessment depends in general on identifying releases of significance, assessing the exposure of the general population/ecosystems and specific subgroups thereof and then using these data to assess the risks of a negative impact or health impact. If the data used in any of the steps are inadequate, then inevitably the risk assessment is flawed.

For example, the EIA report has attempted to assess the impacts of gaseous emissions, waste by products and release to the water environment. The data used to carry out such assessment are not based on the actual waste characteristics but as in the case of gaseous emissions on the maximum gaseous emission standards as per EU Directive.

10.9.3 Furthermore it is shown that many statements in the EIA report that purportedly tried to demonstrate the no/minimal impact of a particular activity have been undermined by the information already published and freely available in the academic and scientific literature.

10.9.4 The EIA report has failed to demonstrate that:
• The risks of air pollution can be satisfactorily mitigated although the EIA report has adopted stricter air emission as per EU Directive and intends to use state of the art air pollution control systems. The EIA fails to recognise that proper control of air emissions requires more than the presence of state of the art air pollution control technologies.
• There are no risks, as claimed in the report, of pollution of the underground water as well as surface waters. This is because the EIA does not consider that the residues from a WTE Plant as toxic despite reports on the contrary.
• The EIA report also fails to report that the local aquifer already provide potable water for the local vicinity as well as supplementing the Port Louis water supply network at a rate of 5000m3/d. Water is becoming a scarce resource in Mauritius and once contaminated by the toxic substances and compounds from the residues, the underground and surface waters cannot be exploited either for potable or irrigation uses.
• The small planters of the western coast, the pig growers of St Martin, the vegetable growers, the poultry farms, the cattle feedlots as well as other agricultural and meat producers of the region will not be affected directly.
• The economic development that has started in the region viz. construction of Club Med, aquaculture project, IRS Projects at Bambous and Albion, commercial centre at Canot, and the tourism sector will not be affected. The report fails to allay the fears of tourists and the population at large that the food will not be contaminated with the highly toxic compounds that emanate from a waste incinerator.

10.9.5 The EIA report on account of its major shortcomings cannot be used as a decision making tool by the Authorities. Hence on the basis of the precautionary principle, the application for the EIA licence must be rejected.

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57 IFC Guidance Notes: International Finance Corporation (IFC) Performance Standards on Social & Environmental Sustainability (April 30, 2006)
58 Paragraph (7) of Performance Standard 1: Social and Environmental Assessment and Management Systems. IFC

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