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10.1 Introduction

The purpose of the EIA study is not only to assess the environmental sustainability but also to confirm the economic and social sustainability of the Project.

The EIA report has attempted to allay the environmental and health concerns of the nearby community residents likely to be impacted by the proposed WTE Plant operation. However the uncertainties, shortcomings and omissions of the report have provoked the contrary.

The EIA report is based on two main uncertainties, namely:

o The characteristics of the waste still need to be confirmed;
o 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.

Impact assessment depends in general 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.

Furthermore it will be 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.

The EIA report makes extensive reference to the Carl Bro report and actually uses some of the conclusions of the said report to justify several aspects pertaining to the Project namely the siting of the proposed WTE Project, issues of Mare Chicose Landfill, waste characteristics, etc. Yet the EIA report fails to assess the various reservations that Carl Bro made on solid waste incineration.

The comments made in this section on the EIA report for the proposed waste to energy (WTE) plant will focus on the fundamental issues, namely:

• The characteristics of the solid waste;
• The generation of by products of waste incineration and their characteristics;
• Lack of rigor in risk assessment of water pollution (underground and surface)
with far reaching consequences;
• Socio Economic Impacts

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