More Comments on the Alutrint EIA
Tuesday October 10th 2006
The Corporate Secretary
Environmental Management Authority,
8, Elizabeth Street, St Clair,
Port of Spain
Dear Madam,
We are pleased to submit the following comments in respect of the EIA Supplementary Report for ALUTRINT, August 2006.
Dr Peter Vine
Dr Wayne Kublalsingh
Comments on the EIA Supplementary Report for ALUTRINT
August 2006
5.1
It is unacceptable that ALUTRINT failed to meet the regulatory bodies, Town and Country planning and the Ministry of Energy and Energy Industries. Even the meeting with the Ministry of Labour, according to the minutes, did not lead to adequate arrangements for ensuring the safety of workers.
5.2
ALUTRINT’S response to the EMA’s question is flawed. An invitation to a member of PSAEL, private unpublished consultations with selected members of the La Brea community, and an ALUTRINT newsletter are no substitute for a public consultation as stipulated by law. Additionally, the applicant is under the misapprehension that a public consultation need involve only members of the La Brea community; any national of Trinidad and Tobago is legally entitled to attend and make comments. The applicant misunderstands the definition of consultation; questions and comments are expected to be answered. This did not occur in the public consultations. Second, a consultation must include the possibility that the majority of the participants reject the proposal to build a smelter; it is not meant to simply quiet the fears of participants and mollify opinion in favour of the applicant. The open rejection of the smelter by “a recently formed anti-smelter group” is not illegitimate and must be taken into account. The applicant’s notion that the so called “anti-smelter protest group had the sole intention of disrupting the proceedings” is unfounded; these persons sought genuine answers to questions, and desired that the applicant take note of their comments. Far from this intervention defeating the full potential of the community consultation process, it constitutes the very essence of consultation.
6.1
The EMA commented that the risk assessment did not address the long-term human and ecological health risks. The EMA also required a human health risk assessment. The applicant’s responses are unacceptable. It is incomprehensible that the applicant ignored the request from the public for health data from similar smelter plants in China. The idea of waiting for twenty-five years to know whether there will be any health risks is immoral and unacceptable. The applicant claims to have adjusted the emissions to be equal to the maximum allowable levels; this is unreliable, since any minimal positive deviation will send the pollution over the limit.
It is unacceptable to state that “the La Brea area is not an agricultural community and thus the need to protect food crops and farm animals with a stringent HF standard does not arise.” This statement implies that residents may not raise any type of farm animals or food crops in the La Brea community. This indicates intolerable living conditions.
If the pollution limits are now to be measured at the outer periphery of the buffer zone the idea of a buffer zone is defeated. One must not redefine the boundary in order for the pollution levels at the boundary to appear more favourable. Redefining the boundaries is an attempt to make the pollution figures appear favourable, without actually reducing the pollution.
7.5
ALUTRINT has not adequately answered the EMA’s comment on SPL disposal. Even though a hazardous waste disposal facility may become available, the EMA has not sanctioned its use for SPL.
9
No plus or minus accuracy limits have been supplied for the air emission maps. This was specifically requested by members of the public.
9.2
Merely citing the names of technical organizations involved is not a scientific method of assuring us of the adequacy of the analysis.
Micro climate factors have been disregarded but these cannot be disregarded especially in relation to emissions from the eaves and windows of the plant and in relation to turbulence near ground level.
10
It is estimated that 1572 foreign workers would be hired for the construction phase and 410 locals. However, the hiring company concerned has not given a guarantee on these figures, and there could be considerably fewer locals. This seriously diminishes the economic benefit of the project to Trinidad and Tobago.
Dr Peter Vine
Dr Wayne Kublalsingh
The University of the West Indies
St Augustine
The Corporate Secretary
Environmental Management Authority,
8, Elizabeth Street, St Clair,
Port of Spain
Dear Madam,
We are pleased to submit the following comments in respect of the EIA Supplementary Report for ALUTRINT, August 2006.
Dr Peter Vine
Dr Wayne Kublalsingh
Comments on the EIA Supplementary Report for ALUTRINT
August 2006
5.1
It is unacceptable that ALUTRINT failed to meet the regulatory bodies, Town and Country planning and the Ministry of Energy and Energy Industries. Even the meeting with the Ministry of Labour, according to the minutes, did not lead to adequate arrangements for ensuring the safety of workers.
5.2
ALUTRINT’S response to the EMA’s question is flawed. An invitation to a member of PSAEL, private unpublished consultations with selected members of the La Brea community, and an ALUTRINT newsletter are no substitute for a public consultation as stipulated by law. Additionally, the applicant is under the misapprehension that a public consultation need involve only members of the La Brea community; any national of Trinidad and Tobago is legally entitled to attend and make comments. The applicant misunderstands the definition of consultation; questions and comments are expected to be answered. This did not occur in the public consultations. Second, a consultation must include the possibility that the majority of the participants reject the proposal to build a smelter; it is not meant to simply quiet the fears of participants and mollify opinion in favour of the applicant. The open rejection of the smelter by “a recently formed anti-smelter group” is not illegitimate and must be taken into account. The applicant’s notion that the so called “anti-smelter protest group had the sole intention of disrupting the proceedings” is unfounded; these persons sought genuine answers to questions, and desired that the applicant take note of their comments. Far from this intervention defeating the full potential of the community consultation process, it constitutes the very essence of consultation.
6.1
The EMA commented that the risk assessment did not address the long-term human and ecological health risks. The EMA also required a human health risk assessment. The applicant’s responses are unacceptable. It is incomprehensible that the applicant ignored the request from the public for health data from similar smelter plants in China. The idea of waiting for twenty-five years to know whether there will be any health risks is immoral and unacceptable. The applicant claims to have adjusted the emissions to be equal to the maximum allowable levels; this is unreliable, since any minimal positive deviation will send the pollution over the limit.
It is unacceptable to state that “the La Brea area is not an agricultural community and thus the need to protect food crops and farm animals with a stringent HF standard does not arise.” This statement implies that residents may not raise any type of farm animals or food crops in the La Brea community. This indicates intolerable living conditions.
If the pollution limits are now to be measured at the outer periphery of the buffer zone the idea of a buffer zone is defeated. One must not redefine the boundary in order for the pollution levels at the boundary to appear more favourable. Redefining the boundaries is an attempt to make the pollution figures appear favourable, without actually reducing the pollution.
7.5
ALUTRINT has not adequately answered the EMA’s comment on SPL disposal. Even though a hazardous waste disposal facility may become available, the EMA has not sanctioned its use for SPL.
9
No plus or minus accuracy limits have been supplied for the air emission maps. This was specifically requested by members of the public.
9.2
Merely citing the names of technical organizations involved is not a scientific method of assuring us of the adequacy of the analysis.
Micro climate factors have been disregarded but these cannot be disregarded especially in relation to emissions from the eaves and windows of the plant and in relation to turbulence near ground level.
10
It is estimated that 1572 foreign workers would be hired for the construction phase and 410 locals. However, the hiring company concerned has not given a guarantee on these figures, and there could be considerably fewer locals. This seriously diminishes the economic benefit of the project to Trinidad and Tobago.
Dr Peter Vine
Dr Wayne Kublalsingh
The University of the West Indies
St Augustine
posted by Attillah at 8:45 PM
0 Comments:
Post a Comment
<< Home