Protect us from our Protectors The Story of against Pollution so far

Making the Invisible Visible

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LIT Raheen Cratloe Coonagh Bunlicky Caherdavin Dooradoyle Ballinacurra Limerick City Hospital (UHL) UL andThomond Mary I Park Mungret CollegeCastlemungret Limerick Leader 1905-current, 09.11.1940, page 7 LAP LimerickLimerick AgainstAgainst PollutionPollution

From its first meeting in May 2016, Limerick Against Pollution has grown into a citizen- led, civil society organisation concerned with analysing the risks to public health, to community well-being and to the environment.

We are particularly concerned with a risk known as an Incremental Lifetime Cancer Risk (ILCR), where the chances of becoming seriously ill increase in proportion to the amounts of toxic particles and substances that are ingested into our bodies over a long period.

We believe that the health risks arising from the change of use of the Mungret Cement plant have not been disclosed in a socially responsible way. Furthermore, the public bodies that are charged with protecting our well-being and the health of our environment in trust for future generations are failing us, as they failed women over the cervical smear The decision to form Limerick Against checks. Pollution (LAP) arose from a lack of trust in the mechanisms that are supposed to protect As we see it, the air is a shared resource and public health and the well-being of the the dangers involved in CRH/ICL’s plans to residents and the environment of the Shannon incinerate toxic waste and to emit potentially Estuary, including Counties Limerick and Clare. lethal doses of cancerous toxins into the atmosphere threatens the fundamental life When CRH plc (Cement Roadstone Holdings) – force of our community. Ireland’s most profitable multinational and the holding company of Irish Cement Limerick (ICL) We speak for the thousands of citizens across – announced that they intended to incinerate this city and region who have supported our waste in their old kiln in Castlemungret, we campaigns. were alerted to the possible risks and dangers. In the following pages we map our story so CRH/ICL claimed that they had concluded far … it is your story too. a positively-received public consultation with local communities and had secured the support of councillors.

Residents in Raheen and Dooradoyle knew this wasn’t true and started to ask questions … EIGHTY YEARS POLLUTING THE PEOPLE

Saturday 21 October 2006 – Irish Examiner reports: ‘A huge dust emission from a Limerick factory damaged hundreds of cars in a number of city suburbs on Thursday night (19 October). The incident at the Irish Cement Ltd factory in Mungret sparked a major health scare and local hospitals were put on alert … Parts of Raheen and Dorradoyle were blanketed by gritty dust which spewed from the cement factory at around 10.30.’

In the report, residents claimed that there had been three similar incidents that year.

15 June 2007 – ICL pleads guilty to the charge relating to the unauthorised emission of dust to the atmosphere on 19 October 2006. Judge O’Donnell imposed a fine of €1,250 and EPA costs of €11,555. [EPA website – Enforcement section]

Environmental Protection Agency: Cement kilns can emit large volumes of dust, which in addition to being a respiratory hazard, can act as a medium for the transport of other air pollutants. It is noted that the emission limit value for dust from cement kilns co-incinerating waste is higher than for conventional incinerators. Environmental( Report [2007] relating to the Strategic Environmental Assessment of the Proposed National Hazardous Waste Management Plan 2008-2012), p. 72.

1938 EIGHTY YEARS POLLUTING THE PEOPLE

CRH plc is the biggest company in Ireland with a worldwide turnover of €18 billion. Its history since the 1930s has been clouded by conspiracies, scandals and corruption, together with repeated allegations of its involvement in criminal price-fixing and market-sharing. All of these activities continue up to today. [Michael Smith, The Village, ‘A History of Scandal’, 2 November 2012)

CRH was accused in 2002 of the illegal dumping of 100,000 tons of toxic waste on land in Blessington, Co. Wicklow over a 10-year period. The company denied all knowledge of illegal dumping and no DPP investigation was initiated. [Michael Smith, The Village, ‘A History of Scandal’, 2 November 2012).

Irish Examiner 21 October 2006 •

2019 FAULT LINES IN THE CEMENT: July 2015 to November 2016

4 am 25th July 2015 – Incident at Irish Cement caused by a blockage in a pre-heater tower. EPA notified at 11 a.m.

27 July – Inspectors from EPA visit site and report that ‘Irish Cement was non-compliant with Conditions 5.1 & 5.2 of their licence.

September – Irish Cement distribute a brochure ‘Investing in our future’ where they attempt to convince the residents living in the immediate vicinity of the cement works that they intend changing their source of fuel from petcoke and burning ‘alternative fuels’.

It would later emerge that in a list of 114 different substances, this list of “alternative fuels” would include extremely hazardous materials: over 3,500 tyres/day, industrial solvents, animal carcasses, dessicated sewage, and red mud from the alumina plant at Aughinish.

During 2015, the EPA was notified of 6 different incidents relating to non- compliance of CRH/ICL Licence P0029-03.

25 April 2016 – EPA notified of fugitive dust emissions.

23 May 2016: Concerned locals convene a meeting in the South Court Hotel. They ask a simple question: ‘Are you concerned about Irish Cement burning hazardous waste?’ The group starts to organise and communicate using the name Limerick Against Pollution. The names of the original group included: Ivor Casey, Luisa & Eric Araujo, Ken Moran, Trish Talty.

30 May – Public meeting held at St. Paul’s school.

18 June – Action Day – T.D.s and councillors turn up to sign petition in support of LAP at the South Court Hotel. There is the first drop of leaflets across the city alerting citizens to the dangers.

October – Growing annoyance among councillors that there has been a lack of transparency and public consultation over the waste management strategy. ‘Public Consultation needed over Irish Cement and Mr Binman’s plans’ (Limerick Post, 15 Oct. 2016)

23 November: Public meeting at St. Paul’s school.

During 2016, CRH/ICL were found non-compliant on three separate occasions.

A CAMPAIGN takes shape November 2016 to 8 March 2017

28 November: 22 February – Silent Protest Cllr. Cian Prendi- outside the ville writes a long council buildings opinion piece in Limerick Life: in Dooradoyle ‘A campaign of prior to the de- non-violent civil cision by LCCC disobedience executive to may be need- grant planning ed here to stop permission. LAP tyre-burning at member, Angus Irish Cement.’ Mitchell makes a 24 February – statement in the Public Health council chamber. Policy expert, He lists the risks Professor An- to health and safety, the environment and the thony Staines addresses a meeting organised reputation of the mid-west region if the ICL/ by LAP at St Paul’s school. He draws attention CRH plans get the go ahead. All council officials to the ‘appalling’ record of Irish Cement and the and some of the councillors refuse to listen and lack of HSE data that would be necessary to leave the chamber, but other councillors show produce an accurate health risk register. The meeting is attended by Deputies Willie O’Dea their support. and , Senator Kieran O’Don- 17 January – Public meeting in St. Paul’s school nell and several city councillors. 28 February – Senator Maria Byrne asks a T.D., a former chief economist with CRH, an- question in the Seanad: ‘There is a fear factor swers on behalf of the Minister for Communi- in regard to air quality, in particular as there are cations, Climate Action and Environment, De- quite a few farmers in the area and very strong nis Naughten. odours from the cement factory have been experienced in the past. Given this fear fac- 8 March – Senator Kieran O’Donnell asks a tor, more than 1,000 submissions went to the question in the Seanad, this time Minister EPA, with a similar number having been made Naughten responds. against the planning application. It is an issue 8 March – Despite the opposition of 90% of that is very much to the forefront of people’s the elected Limerick City and County to CRH/ minds in the Mungret, Raheen and Dooradoyle ICL’s plans, the chief executive of LCCC, Conn areas, and it affects roughly 30,000 people liv- Murray grants conditional planning permission ing in the vicinity.’ to CRH/Irish Cement. The announcement 7 March – Deputy Willie O’Dea T.D. asks a is made 48 hours before LAP’s first protest question in the Dail highlighting the concerns through the city. The timing is clearly intended of the 20,000 residents living in the immediate to unsettle LAP’s plans to build a groundswell vicinity of the cement works. of bottom up support. FAMILY PROTEST MARCH:11 MARCH 2017

11 March – LAP organises a Family Protest • Risks to the food chain, local agriculture March from City Hall, Merchants Quay to and the dairy industry resulting from The People’s Park. The sun shines and an increased dioxin and levels of heavy metal estimated thousand concerned citizens turn up particulates; to participate in what is a positive and peaceful occasion. • The reputational risks for a rapidly-changing Limerick; A good attendance of local politicians, including Deputies Willie O’Dea, Maurice Quinlivan, Jan • The traffic and infrastructure risks; O’Sullivan plus Senators Maria Byrne, Paul Gavan and Kieran O’Donnell. They were joined • Noise contamination and odour risks; by Cllrs Malachy McCreesh, James Collins, Daniel Butler, Cian Prendiville, Elenora Hogan, Other issues raised include the need for John Loftus, John Gilligan, and others. • Independent, monitoring within the city and region of air quality and contamination Limerick set out some of the principal risks levels; a proper council-led plan should at stake in this confrontation between big have been discussed before planning had business and community well-being. They ask been issued. for a proper assessment of • A clear strategy on how comprehensive • The human health risks this incineration mitigations and safeguards on air quality process will introduce; current research might be implemented going forward; shows that co-incineration processes increase levels of cancer, pulmonary disease • A community-involved response to regional and heart problems for people residing near waste management. the incineration plants. [See Dr. Gary Fuller, The Invisible Killer]. 31 March – Clare Cllr Cathal Crowe submitted a motion at a meeting of asking the council to lodge an appeal to An Bord Pleanála over the CRH/ICL proposal. However, an amendment made on the day resulted in the Council making a submission to the EPA rather than An Bord Pleanála. In a statement, Cllr Cathal Crowe said that ‘airborne pollutants know no boundaries’ and the particles coming from the chimney stacks in Limerick could conceivably travel not just into the nearby communities of Meelick, Cratloe, Shannon, Bunratty and Sixmilebridge, but also into parts of north and west Clare.

FAMILY PROTEST MARCH:11 MARCH 2017 1-2 April – Technical 26 April – The Limerick Leader May Day concert – Love Our problems at the Irish Cement runs a front-page story Air – LAP organise a concert plant; hundreds of adjoining detailing the EPA’s report at St Michael’s Church, beside properties and cars are confirming that the sample the People’s Park, Pery Square. covered with a sticky, grey dust taken on 6 April most Young musicians include an and gritty substance. The EPA likely emanated from Irish ensemble of harpists. is bombarded with complaints Cement. Irish Cement offer from concerned residents. free car washes at a special car 6 May – An editorial piece in Fugitive dust-storms continue wash on the Dock Road. the Limerick Leader says that for several days during an ‘Confidence in Irish Cement is unusually dry spring. 27 April – Irish Examiner carries Evaporating’ a story ‘EPA investigates 3 April – LAP hand-deliver their cement plant over city dust 19 May – Limerick Post reports objection to An Bord Pleanála. cloud’. that there are 18,443 people with asthma in Limerick. 6 April – EPA visits Irish April / May EPA and LCCC Complaints made locally that a Cement plant and the effected establish ‘a network of dust strong smell of burning rubber surrounding area. Irish Cement monitoring units in four is reported in the Mungret area, deny all culpability. locations in Limerick City that including the new playground are providing information on facility. 8 April – Limerick Leader run a dust levels.’ And order a ‘formal story ‘Irish Cement strongly compliance investigation’ of 22 May – Sinn Féin organise a denies dust emission from the dust emissions from the meeting where Ireland South factory’. Mungret plant. The monitors MEP, Liadh Ní Riada outlines would breakdown in 2018. strategies for opposing Irish Cement at a European level that ‘Congenital anomaly the Strand Hotel. It is attended and says that she will meet with surveillance is not in place by several hundred concerned the European Environment for HSE Mid-West despite a citizens and residents. He Agency about the matter. recommendation having been points to the shortfalls in made in the Askeaton Report regulation, monitoring and 31 May – Joint statement by in 1998 that this should enforcement threatening the EPA, LCCC and HSE executive. be implemented – this is public and environmental LAP meet with Dr Mai Mannix, because the establishment of health of the region. Tom Boland and Tessa Grealy a national congenital anomaly to articulate their concerns surveillance system has 11 June – LAP organises about the health risks. been held up by the need to a nationwide Zero Waste introduce enabling legislation workshop at Cloughjordan 31 May – Ireland bans fracking. through the Health Information eco-village. Indaver granted permission by and Patient Safety Bill which ABP to build an incinerator in has not yet become law.’ 17 June – Dr Paul Connett Ringaskiddy. calls for an independent review 9 June – Dr Paul Connett of Aughinish Alumina’s plans to 2 June – In a letter answering a leading Environmental blast rock adjacent to the red LAP’s concerns about the Chemist gives a lecture on mud ponds, calling it ‘reckless’ lack of baseline health ‘The Problems, Dangers and planning. status data, Dr Mannix said Alternatives to Incineration’ at An Bord Pleanála Oral Hearing: 29 August to 1 September 2017

29 August – Start of the ABP Oral Hearing at the THIRD PARTIES South Court Hotel. Philanthropist J.P. McManus sits through the entire four days of proceedings • Mr. Kevin Feeney supported by the former county state solicitor, • Mr. Tim Hourigan John Power. • Mr. Jack O’Sullivan, Environmental Manage- ment Services. LAP is represented by leading environmental consultant, Jack O’Sullivan. After ABP refuse to • Dr. Paul Connett, Executive Director AEHSP. allow environmental scientist Dr Paul Connett to • Dr. Gordon Reid, Physiologist. speak via a video conferencing call, LAP pays for • Dr. Angus Mitchell, Historian and Lecturer in him to fly in from the U.S. as an expert witness. Corporate Social Responsibility and Business The following politicians and residents made Ethics. statements or gave presentations during the four • Mr. Derek O’Dwyer. day hearing. • Mr. Joseph Burke. • Ms. Tara Robinson. ELECTED REPRESENTATIVES • Mr. Martin Gleeson, Dooradoyle Estate and St. Nessan’s Park Residents Association. • Cllr. Daniel Butler. • Ms. Trish Talty. • Ms. Liadh Ní Riada, MEP. • Mr. Colin Moran (on behalf of his father Mr. • Cllr. Malachy McCreesh. Ken Moran). • Cllr. Séighin Ó Ceallaigh. • Ms. Margaret McMahon. • Cllr. James Collins. • Mr. Ivor Casey. • Senator Kieran O’Donnell. • Cllr. Malachy McCreesh (on behalf of Ms. • Senator Maria Byrne. Sabrina Begoin & Mr. Jason Doherty). • Deputy Jan O’Sullivan. • Mr. Denis Ryan, Gouldavoher Residents • Cllr. Cian Prendiville. Association. • Cllr. John Gilligan. • Ms. Luisa Araujo. • Cllr. Paul Keller. • Mr. Tim Hourigan (on behalf of Educate To- • Cllr. John Costelloe gether Limerick East, Parents Association). • Cllr. Cathal Crowe. • Mr. James Tuohy (on behalf of Educate To- • Deputy Willie O’Dea. gether Limerick East, Board of Management). • Cllr. John Loftus. • Mr. Martin Corcoran, Inis Lua Residents Association. • Ms. Claire Keating, Slí na Manach Residents Association. • Ms. Nuala Geoghegan. An Bord OBSERVERS • Ms. Mary Hamill. • Ms. Helen McGee. Pleanála • Mr. Derek O’Dwyer (on behalf of Ms. Elsie McGee). Oral Hearing: In the cross examination LCCC were forced to 29 August to 1 September 2017 acknowledge that they did not carry out the necessary due diligence regarding the planning application at the oral hearing. In his summing up their barrister stated that “should the infor- mation that LAP presented have been available to them at the time there very well could have been a different outcome”. 7 September – Residents complain of another ‘dust incident’ on residences near to the cement plant. DECEMBER – After delays, the EPA opens legal ABP approve plans & proceedings against Irish Cement over the more dust blow outs: spillage. September 2017 to May 2018 JANUARY – Irish Cement placed on National Priority List because of pending non- compliance cases and their persistent breach of environmental standards. SEPTEMBER – Uplift – Ireland’s multi-issue campaign organisation promoting people FEBRUARY – The Limerick City and County powered action – raises €1800 for LAP through Council executive ignore local concerns and grant crowd-funding donations. permission for the alumina refinery at Aughinish to blast rock in a borrow pit beside two red mud OCTOBER – Plans announced by LCCC for a ponds storing approximately 40 million tonnes suburban housing scheme ‘the size of a small of toxic red mud waste at Aughinish Island (LP, town’ consisting of 850 homes to be built in the 10.2.2018). A report in the Limerick Leader calls Mungret College grounds. this the ‘death knell for the Shannon Estuary’. 3 NOVEMBER – A spike of particulate matter on 27 FEBRUARY – EPA inspection of cement the recently installed monitors is played down by plant notes that the licensee’s Environmental the local authorities. Guidelines Booklet failed to address dust NOVEMBER: Mayor James Collins spearheads emissions from all relevant areas, e.g., quarry a special meeting of the city councillors which roads and the limestone intake area, and this passes multiple notices to block any further omission was in breach of Condition 6.12.2 of the plans to develop incineration in Limerick city and licence. county. FRIDAY 13 APRIL – An Bord Pleanála grant 3 DECEMBER – 21 complaints received by planning permission to Irish Cement with ten the EPA describing a ‘glue-like’ limestone dust conditions. Fifty-one toxic substances are crossed covering cars and properties across Limerick City. from the list of 114 coded materials leaving 63 Maria Lenihan of the EPA states that 2.5 tonnes categories of waste material. CRH/ICL claim of material had fallen across the city shortly incorrectly that their incineration plan ‘is essential after 10.15am. to ensure the long-term viability of the Mungret factory.’ 23 APRIL – Pat Robinson of Irish Cement Mungret signs a letter with ‘facts’ about ICL’s plans for burning ‘alternative fuels’. The letter is distributed to households in the immediate vicinity of the cement plant but does very little to alleviate concerns among residents.

The EPA remove CRH/ICL from a ‘watchlist’ for their non-compliance in spite of the fact that there are two court cases pending for non- compliance.

27 APRIL – LAP organise meeting at South Court Hotel.

9 MAY – Dr Kevin Kelleher, the assistant national Director – public health/childhealth strategic planning and transformation, writes a letter in response to a question from Deputy T.D. Kelleher identifies the shortfalls and insufficiencies of the HSE in protecting 600 the public. In several ways, this position was a 500 climb down from the emphatic confidence of the HSE Environmental Officers who had rubber 400 stamped Irish Cement’s Environmental Impact 300 Statement back in June 2016. In their submission �g/m� report, they admitted that ‘no risk assessment 200 for Tolerable Daily Intake of dioxins, furans and 100 dioxin-like PCBs has been undertaken’. In other words, they have no idea if our daily dose of 0 29. Oct 30. Oct 31. Oct 1. Nov 2. Nov 3. Nov 4. Nov 5. Nov dioxins will impact our wellbeing? Total particles PM10 particles PM2.5 particles PM1 particles FAMILY PROTEST MARCH13 MAY II:2018

13 MAY 2018 – LAP organise a Family Protest Metropolitan councillors and Limerick City March II through the centre of Limerick city. Councillors, led by Cllr James Collins, approved Over 1000 people march in an orderly fashion plans for a joint submission to the EPA opposing from the Potato Market to the People’s Park. Irish Cement’s incineration plans. ‘If a motion Within days the EPA delay their decision over goes to the EPA from us collectively, it will send granting a licence. a very strong message we do not want and we will not tolerate industrial incineration in our community.’ (LL, 2.6.2018) FAMILY PROTEST MARCH13 MAY II:2018

23 MAY 2018 – Willie O’Dea asks the Minister for 26 MAY – LAP identify a clear ‘governance gap’ in Communications, Climate Action and Environment the protection of public health in a letter to the about his plans to remove the immunity from Limerick Leader: prosecution provided to the Environmental Protection Agency (EPA) in section 15 of the EPA ‘How safe is safe?’ act of 1992 as recommended by the ombudsman in 2011. GUILTY of non-compliance (twice in six months): July to December 2018

6 July – CRH/ICL are found guilty in the district court of ‘environmental pollution’ and for allowing ‘fugitive dust’ to cover cars and properties. Judge Marian O’Leary fines the multinational €1,250 and grants them two months to pay. 20 September – LCCC submit a letter to EPA stating their concerns that: ‘Current operations do not consider emissions of Dioxins, Metals, Ammonia, Hydrogen Chloride and Hydrogen Fluoride so there will be a net overall increase in ground level concentrations downwind of the facility as 22 October – In a letter to the Limerick a result of these emissions.’ In other words, Leader and Limerick Post, ‘Who is dust escaping from the plant will blow protecting public health?’, LAP state that ‘If across this city, bringing with it all manner of the license is granted without the necessary unknown toxic cocktails. protective measures and due regard to the precautionary principle, we will have October – Former CRH plc economist, no choice but to challenge the Southern Richard Bruton T.D. is appointed Minister Environs Local Area Plan. Further residential of Communications, Climate Action and expansion in the Mungret/Raheen area Environment. and industrial incineration are mutually exclusive.’ October – Based upon a report by the and a ‘very isolated incident’. In delivering consultancy group RPS – (Irish Cement the sentence, Judge O’Leary dismissed Limerick P0029-06 – Licence Application) Spence’s inaccurate excuses and said that – the EPA requests further information this was the third time that people living in from ICL/CRH. Among a substantial list of the Raheen/Mungret area ‘have suffered’ serious issues in respect to the licence, in recent years. (Limerick Leader, 10 Dec. the report challenges CRH/ICL’s modelling 2018). CRH/ICL were also required to pay and forecasting. It also draws attention costs. to the fact that the cement plant has 64 ‘minor emission’ points which discharge particulates into the atmosphere, and that these points have not been incorporated into their modelling. There is also a request for a Health Risk Assessment. 23 November – A ‘Plastic Waste Conference’ is hosted by Sean Kelly MEP at the South Court Hotel. The meeting is a PR fiasco. Activists from ‘Future Proof Clare’ and the London-based ‘Extinction Rebellion’ interrupt proceedings and accuse Kelly of cynical appropriation of a critical contemporary concern. 7 December – CRH/ICL plead guilty and are given the maximum fine of €4000 by Judge Marian O’Leary in the Limerick District Court for the spillage of 2.5 tonnes of ‘raw meal’. Solicitor Deborah Spence, representing the accused, claimed that this ‘was a once off, very unusual occurrence’ Does our health matter? December 2018 to March 2019 2019 18 December – The Mungret air quality January 2019 – Over 4000 individual monitors cease operating. The unit is sent objections have now been registered to the UK for repair. Anne Goggin, senior with the EPA expressing multiple concerns executive engineer LCCC, admits there about the for-profit incinerations plans. were problems with the other monitors Objections come from local businesses, and consequently no collection of any householders, hospital staff and those data for over two months. When asked involved in the hospitality sector. by LAP why she failed to notify the public, Goggin responded that she ‘was unaware Campaign by LAP is included on the of the level of public interest in these Environmental Justice Atlas as part of a monitors’. worldwide movement for environmental protection. 20 December – Dr Martin Hogan, a medical executive of the occupational 5 February – Thomas Boland, health provider CHI, (who served as Environmental Health officer with the an expert witness for CRH/ICL at the HSE, writes to EPA with a cover letter ABP oral hearing), assembles a Health from Public Health England (PHE) giving Risk Assessment on behalf of CRH/ICL the all clear to ICL’s incineration plans. in the week before Christmas. Hogan Boland and PHE are the same ‘expert’ highlights the ‘considerable difficulties’ in bodies, who had given the all clear undertaking such an assessment due to back in 2016 to the original list of toxic the lack of baseline data and the absence waste codes that had been dramatically of health risk registers. Nevertheless, he cut back as a result of the oral hearing. submits an assessment based upon a Boland, however, failed to turn up to partial analysis of the research literature, the August 2017 oral hearing and fails in which unequivocally states that “No every respect to address the concerns of ambient air quality standards for ultra- thousands of Limerick residents. fine particles are in place.” LAP has the report independently assessed and Hogan’s report is criticised for being superficial. 9 February 2019 – LAP publishes a letter 21 February – ‘LAP urge Irish Cement in both the Limerick Post and Limerick to withdraw EPA application’ (Limerick Leader ‘One-Sided Study’ high-lightingthe Leader, 21 February 2019). evident fault lines and partial conclusions of the Health Risk Assessment carried out 25 February – At a special meeting of by Dr Hogan on behalf of CRH/ICL. LCCC Cllr Malachy McCreesh (SF) seeks to ban the burning of rubbish as part of 14 February – Dissatisfied with CRH/ICL’s the new regional strategy. The motion response to their further information that will form part of the Regional Spatial and “does not adequately identify, describe Economic Strategy and will be decided and assess the direct and indirect effects upon by the Southern Regional Assembly. of the proposed development on the environment,” the EPA request additional 21 March – LAP convenes a public ‘further information’ from CRH/ICL and meeting in the South Court Hotel to up- gives them until the 11 April 2019 to date the public and local councillors in respond. anticipation of the local elections in May. 17 February – The challenge by Friends 11 April – Deadline for CRH/ICL to of the Irish Environment and Future provide further information. Proof Clare opposing the plans to build a terminal at Ballylongford to store U.S. Dr Gordon Reid: It is therefore fracked gas or LNG (Liquid Natural Gas) is misleading to assess the use of alternative referred to the European Court of Justice fuels as free of risk to human health, (ECJ). Making the referral, High Court based on a limited set of only 15 articles Judge Garrett Simons told the developers studying a limited set of alternative fuels, that work cannot begin on the proposed and omitting the entire literature on the gas terminal on the Shannon Estuary until health effects of burning the very varied the ECJ decides whether the project must waste stream intended in the present be assessed under the Habitats Directive. application. Given that the proposal is to Legal sources say the referral to the ECJ burn a full range of municipal waste, the could take between one and two years. relevant literature must encompass the health effects of burning mixed municipal waste. (Analysis of Martin Hogan’s Health Risk Assessment, 13 Feb. 2019). after if things go wrong with these incineration plans of CRH/Irish Cement. (Speech at Family What the People say... Protest March, 13 May 2018) SENATOR KIERAN O’DONNELL: ‘The Minister should be aware of the concern among the public. A march is being organised by people in Limerick city this Saturday. These people have genuine concerns. They are reasonable people with young families living in Dooradoyle, Raheen, the Mungret area where the Irish Cement plant is located and other areas. JIM LONG: ‘It is very sad to write that we are (Seanad Éireann, 8 March 2017) standing alone against the very system put in place to protect us.’ (Letter to Limerick Post, 28 NICK RABBITTS: As the march progressed, April 2018) demonstrators chanted: “Limerick City, full of grace; County Council, your disgrace”, in KATE BROUDER: (Laurel Hill student) ‘I reference to the grant of planning permission. can’t believe that Irish Cement are going to “Smog and poison everywhere, Irish Cement we be allowed to burn all sorts of toxic industrial despair,” also followed. The crowd – including waste so close to the city centre. How can they many children – were also given masks covering pretend to us that this is okay? I’m only 13 years their mouths to wear. (Limerick Leader, 11 of age, and even I know burning things like tyres March 2017) and plastics is not good for my health.’ (Speech at Family Protest March, 13 May 2018) NUALA & PAT GEOGHEGAN: the Government needs to have this immunity/ WILLIE O’DEA TO DR MAI MANNIX: protection in place for the EPA, when they are ‘I have spoken to hundreds of Limerick people forcing through risky issues like incineration. A who have genuine concerns about the potential key part of the decision-making process is that health implications if Irish Cement are given no one in the EPA is held accountable once permission to burn toxic materials in their the licence is granted, and there is no long- Mungret plant. As a public representative, I term responsibility for damage caused to the would like to encourage you to follow through environment or human health. Essentially, this on all the commitments you have given to divests the state of any liability should a decision Limerick against Pollution.’ Willie O’Dea T.D. in prove to be a bad one. (Letter to Limerick Limerick Leader a letter to Dr Mai Mannix, ( , 7, Leader, 8 April 2017). Oct. 2017) LIADH NÍ RIADH: I will use my networks MARY HAMMILL: The HSE have not looked in Europe to advocate on your behalf. Having after the women of Ireland and I am referring to a clean and safe environment to live in is one the recent Cervical Check scandal. And do not of the most fundamental human rights we for one moment believe that you will be looked enjoy. Being able to breathe without inhaling MARY HAMMILL: Exposure to the chemicals damaging and carcinogenic toxins is such an is bad for all of us but it is the children in obvious and basic necessity of life. (Limerick particular that I worry about and the reason Post, 27, May 2017). I am involved in this campaign. I do not wish them to grow up looking forward to hormonal ANGUS MITCHELL: Mr Gilmore argued that disturbances, fertility problems, heart & lung the for-profit incineration of rubbish is vital for problems and cancer. As adults we owe them the ‘future of the plant’; but what about the more than this. (Love our Air, 1 May 2017) future of the planet? What about the future of Limerick? Being paid to burn industrial waste Metropolitan mayor may be a profitable plan for Irish Cement, but DANIEL BUTLER commented that the latest request for more at what cost to the health and reputation of this information highlights the casual and haphazard city? (Limerick Leader, 22 April 2017). work practices of Irish Cement. I am satisfied to see that the EPA has drilled down on its City mayor JAMES COLLINS: We can’t sit submission in relation to the Bunlicky lake and back and allow Irish Cement to proceed with water quality related issues as highlighted by its incineration proposals when clearly there LAP. Also, the further information in relation to are huge public concerns about emissions from greenhouse gases and the noise is of particular the Irish Cement plant in Mungret carrying on importance to our community. This reinforces the wind for a radius of 20km. We are literally our stance on the issue from the very beginning. talking about the health of thousands of people The numerous concerns we expressed are being in Limerick. We’ve had an oral hearing on the borne out in the questions from the EPA and the planning issues surrounding Irish Cement, shortcomings they too are highlighting,” he said. but we haven’t had an oral hearing dealing (Limerick Leader, 19 Feb. 2019) specifically with the health implications of allowing incineration at the Mungret plant. The DR KEVIN KELLEHER, Assistant National HSE didn’t even give testimony to the last oral Director of Public Health/childhealth Strategic hearing. Surely now, they can see this is a public Planning & Transformation has recently said in health issue of major concern.” (Limerick Post, a letter “there is no environmental or planning 14 Dec. 2018). legislation that obliges the HSE to assess and monitor on an ongoing basis the risk to Sinn Féin councillor MALACHY MCCREESH human health from a particular site specific also voiced his anger at An Bord Pleanála’s development following the granting of planning decision. He believes that allowing “hazardous permission”. (Letter to Niall Collins T.D., 9 May waste to be incinerated” at the Mungret facility, 2018) will present future generations with possible far reaching health impacts, “due to likely emission of dioxins and furans”. (Limerick Post, 19 April 2018). they managed to put 11 people in hospital in its first month of operation in 2017. How can anyone honestly say the CRH/ICL change of use What the People say... is zero risk. (ABP Oral Hearing, 30 August, 2017) TIM HOURIGAN: we have to express to the Inspector our deepest concerns for impact on the health of the children, the staff who teach and assist them, the environment that surrounds them, and even the reputation of the school as a desirable community for others to join in, if this planning permission is granted. CLAIRE KEATING: Regarding this latest (Statement at ABP Oral Hearing, August 2017) request for further information once again, it’s clear that Irish Cement Ltd are still not providing DEIRDRE MACMAHON: If the incinerator relevant answers to the questions put to them goes ahead any threat of dioxins being released by the EPA. Further information was already into the atmosphere will affect the reputation sought by the EPA on foot of the RPS report of small organic farmers in the region. The and the response from Irish Cement Ltd was Urban Co-Op is making a submission to the not adequate. We feel the EPA should reject EPA on behalf of our 800 members and 53 local this application to alter their current emissions suppliers. licence. (Limerick Leader, 23 February 2019) SEÓNAIDH NÍ SHÍOMÓIN: The local DEREK O’DWYER: The cement kiln community has made their feelings very is 35 years old; it will undergo simple clear. People are infuriated and worried at modifications to accept whole tyres and pre- the thoughts of this toxic monstrosity in their processed industrial waste. The staff have backyard … On the assumption that the EPA will no special expertise in dealing with waste grant Irish Cement a licence then the only action incineration. They’ve had no special training to which will stop the toxic incinerator is a direct deal with industrial waste incineration. Contrast community campaign. [Limerick Post, 09, March this with Covanta, a specialist global company 2019] operating the brand-new facility in Poolbeg. With brand new hardware, fully qualified staff, specialist training and the latest fail-safe hardware and software that, despite training, MARIA CORBETT: I refer to the on- going cervical check scandal: you can almost substitute the word “cement “ for “cervical” and so much would overlap. We trusted our health to those in public office and assumed that our health was the priority and in the event of a cause for concern that we would be monitored and informed should the need arise. One key difference is that the cervical check scandal physically impacts on those with a cervix, whilst the proposed incinerator at the Irish Cement factory at Mungret is not as selective and will affect cervix owners and non-cervix owners alike!

JAMES TUOHY: Greta Thunberg’s call for strikes and school walkouts inspired school children around the world and is a critical and meaningful response to the crisis posed by climate change. Just like LAP’s struggle against CRH/ICL, nobody is coming to save us. We must organise our communities to face down the slow violence of polluting industries and protect the generations to come. Everything is dependent upon the provision that ‘the process is effectively managed’. Yet, the evidence suggests that this entire matter is being very badly managed. CRH/ICL has lost confidence RISK with the people. A standard definition of “risk” is the the first three years of the systematic process of evaluating the We feel that LAP campaign potential risks that may be involved in shows that, based upon past performance, the community has a projected activity or undertaking. Any every reason to be seriously concerned process of evaluation is partly based upon with the change of use of the cement the past performance of the entity being kiln to incinerate municipal and industrial assessed. For instance, when someone wastes. seeks car insurance, the insurer looks at the history of the driver: how many Dr Paul Connett, who was brought accidents have they had? Do they have to Limerick on two occasions stated points on their licence? How old is the his profound concern at the lack of driver? How old is the car? regulation, monitoring and enforcement protecting Limerick and the mid-west What the LAP campaign has clearly community revealed is that the cement works in Mungret has a long history of blow outs, If the pre-existing risks to public health fugitive dust storms, noise pollution, non- are so widespread and, at the same time, compliance and denial stretching back so poorly understood, how can any of to the very foundations of Cement Ltd. us, in good conscience, stand by while a in 1938. The worrying factor is that ICL’s light-touch EPA lets a private company history of ‘getting it wrong’ has not been significantly increase these risks for no factored into the modelling of the risk other reason than to increase profits? involved in the intended change of use by the plant. THE PRECAUTIONARY PRINCIPLE

The precautionary principle might be defined as follows: “When an activity raises threats of harm to human health or the environment,precautionary measures should be taken even if some cause and effect relationships are not fully established scientifically.”

Limerick has a very high register of asthma and pulmonary disease. According to the Limerick Post, there are over 18,000 medicated asthma sufferers in the city. While some of this might be attributed to socio-economic factors, there is a case to be made that eighty years of streaming dirty, gritty emissions across this city has contributed to such high numbers. Quite simply, Irish Cement don’t have the control systems, safety fail-safes and expert staff to maintain the consistently high temperatures to manage an incinerator of this scale without increased risk of contaminating nearby farms and residential areas. Their ‘appalling’ track record of regular dust storms and blowouts makes a precautionary approach absolutely necessary. The importance of air quality to community well-being was highlighted in the EPA’s recent State of the Environment Report (2016). While Ireland may enjoy relatively clean air, this general statement cannot be applied to specific local situations. The fact that the cement works is up-wind of Limerick City and the emissions blow directly across densely populated areas of Limerick city and county makes it even more important to apply the precautionary principle. We ask

• What precautionary measures, if any, should parents, teachers and school principals take? • What happens when a spike coincides with school breaks when kids are in the playground? • Who is responsible for assessing the health risks of dangerous variability in emissions levels, as opposed to the averages that might mask real hazards? • Who is responsible for determining risk thresholds and providing guidance and warnings (or reassurance if appropriate) to the public? As the narrative in this pamphlet clearly demonstrates, LAP has legitimate concerns supported by current research into air quality and the potential health harms and risks that bad air brings. The actions of ABP, the EPA and the Courts have in different ways supported our concerns, and yet these same bodies are ruling in the favour of the socially irresponsible and convicted multinational. Yet we, and by inference the people who support us, are treated with contempt by the HSE, LCCC and CRH/ICL.

We’re not politicians and we’ve no political agenda, but we will make public-health an issue in local, mayoral, general and European elections until our concerns are understood by those who can deliver change. We demand that

1. The EPA should temporarily suspend the licence of CRH/Irish Cement.

2. We are seeking funding for an independent review of the RPS report and their request for a Health Risk Assessment. The responses from the HSE and Public Health England and Dr Martin Hogan are utterly unsatisfactory and merely reinforce the concerns expressed at the August 2017 oral hearing by residents and experts.

3. We continue to support the need for the Multi-Party Actions Bill 2017, which provides that proceedings which involve multiple parties, whether as plaintiffs or defendants, can be certified by the Court and will be signed into law.

4. We will continue to support efforts to bring about an end to the EPA’s immunity that is presently before the Dail.

5. We support strategies for improving monitoring in the city and we demand that LCCC replace or repair the monitors installed in 2017 and that they recognise that air quality is a matter that the people of this city take very seriously.

6. We campaign for a commensurate punishment for polluters so that polluters really do pay. Fining CRH/ICL a few thousand euro for scattering tonnes of toxic dust across properties throughout this city makes a mockery of the law and enforcement. Fines should be registered in the millions and be proportionate with the massive profits of CRH.

7. If necessary, we will challenge the Southern Environs Local Area Plan. Since we are steadfast in our view that further residential expansion in the Mungret/Raheen area and industrial incineration are mutually exclusive.

8. Implement a community-led Zero Waste policy to reduce the consumption of plastic and encourage alternative forms of recycling and up-cycling. This will require the positive involvement and support of LCCC. What you can do! STEP 1. Object to the EPA – the process is still ongoing so object while you can, there are already over 4,000 objections! https://action.uplift.ie/campaigns/stop-irish-cement-burning-tyres

STEP 2. Explain the information in this pamphlet to friends and family, buy more copies and give them out. Help spread the word.

STEP 3. Get involved with Limerick Against Pollution: Visit our Facebook page or text join to ‘085 1509684’ and we will be in touch on how you can help.

STEP 4. Write letters and contact the HSE, the EPA, and LCCC and your public representatives and explain that you are actively concerned! When they arrive on your doorstep to ask for your vote tell them wny you are worried.

STEP 5. Check the air quality in your area and report unusual activity to LAP and to LCCC. Follow this link to access https://www.airqweb.com/

STEP 6. Support us through our on-line crowd-funding link https://www.gofundme.com/limerick-against-pollution

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Limerick Against Pollution: Pamphlet I / 2019