Wednesday, November 08, 2006


Dr Dave McIntosh

CEO – Environmental Management Authority (EMA)

St. Clair


Dear Dr. McIntosh,

While Dr. Ahmed Khan of Rapid Environmental Assessment Limited (REAL) - engaged by ALUTRINT to conduct an Environmental Impact Assessment (EIA) for their proposed aluminium smelter plant at Union Industrial Estate (UIE) - has made some effort to answer your basic concerns laid out in the ‘Deficiency Report’ prepared by EMA on the draft EIA, he still fails in his Supplemental Report to provide any actual performance data for air pollution control equipment. Why is it imprudent for him to obtain this from the Chinese smelter similar to the one proposed by ALUTRINT?

The results of the air pollution model used by REAL indicate that the EMA’s draft Air Pollution Standards for Fluoride (F) - among the most dangerous pollutants known - are exceeded at the edge of the smelter buffer zone. REAL has asked you to relax your Standards and at the same time propose to meet them if they ‘flip’ the plant around and use European air pollution control technology instead.

The question is can you be sure about the credibility of his air pollution model given that it has already marginally exceeded your Standard using hypothetical data?

Furthermore, what remain inadequately assessed in the Supplemental Report are the cumulative health impacts on surrounding communities from the whole estate when operational. We remain unsatisfied how this aspect of the EIA was handled. There are about 10,000 persons residing within 5km of UIE. The most predictable thing about climate and atmospheric conditions is that they are growing more unpredictable - this renders the air modeling even less credible. You need not be a sage to know that the age of heavy gas based industrialization in ‘developed nation states’ is closing for well documented reasons. But, based on ALUTRINT’s ‘philosophical’ reasoning for the reduction of the EMA’s proposed ‘Standards’ - based on an ‘economic benefits’ argument - this age should be dawning in T&T.

In all seriousness, since your Terms of Reference (TOR) for the EIA failed to require an ‘economic’ impact assessment of the smelter (despite this being mandatory according to the “Energy” clause of the current National Environmental Policy (NEP), how can ALUTRINT pose ‘economic’ logic to convince you to relax the environmental Standard you have yet to introduce? If the economic benefits argument is going to hold, then the question becomes: what about the economic costs? They remain sadly in the dark.

I believe that Dr. Khan is over playing the ‘techo-speak’ to give the impression that a hazardous industry of this notoriety for terminal cancer can be satisfactorily managed now in T&T - at the infancy stage of our regulatory instruments to ensure sustainable development. Who would have thought that at the last minute, with a flip of a plant and a trip over to Europe that the well being of Vessigny children would be assured against cancer from Fluoride poisoning over the next 20 years! Wonders never cease.

Despite these late antics by REAL, if you are not completely assured of the safety of these children, as we on the outside are not, then you are obliged to invoke the “Precautionary Principle” established by the Environmental Act 2000, as the grounds to deny ALUTRINT a Certificate of Environmental Clearance (CEC).

Moreover, if modern air pollution control technology is actually being successfully operated by the Chinese, it still confounds most of us out here why it is not possible for ALUTRINT to secure any actual data on their employee health surveillance records. ALUTRINT promised to translate these and make them available to you (see verbatim transcript of Public Consultation). Similarly, if the newly proposed “European” technology is really as good as they say, how has it actually performed and where? In other words, the only proof is in eating the pudding.

ALUTRINT has argued that you should relax your 24hour F standards because they cannot be consistently met. You need to be very cautious here. The human health information provided for F by REAL/ALUTRINT is not consistent with research on F from other sources. We strongly urge you to become familiar with a host of readily available peer reviewed research on the dangers of F at very low concentrations, and compare this to the data selectively introduced by REAL/ALUTRINT – before you capitulate to their argument for you to relax your intended Standard.

We are also wondering if, after reading their Supplemental Report, you feel that REAL is assessing ALUTRINT’s smelter in a truly professional unbiased manner. Did you ever get the feeling that REAL may be wishing with all their heart that they can deliver the CEC to ALUTRINT? Did you ever get the sense that REAL is equally moved by concern for the well-being and health security of surrounding residents?

I need not remind you that the environmental – social – economic justice movement in T&T is somewhat frustrated by what it sees as an intentionally flawed CEC process, and sees the EMA but a rubber stamp for ‘done’ political ‘deals’ which, as history teaches, are never based on “social” and “environmental” values but on the narrow economic interests of a privileged elite. A Doomsday recipe!

Why is it not possible to know through the CEC process whether a smelter run on hydropower in Guyana or Venezuela, with down stream aluminium industry in UIE, Trinidad, is not far better socially, environmentally and economically for all? Or perhaps equally valid, how can we be sure that we would all not be better off to replant UIE with high commercial value organic food crops for export?

Please be assured that we are deeply committed to helping the EMA to evolve the CEC process towards a sustainable T&T.

In your moment of decision whether to award a CEC to ALUTRINT- or not - I wish the light of Christ to be with you.


Cathal Healy-Singh

Environmental Engineer


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