Dear Secretary of An Bord Pleanála,

With this letter I appeal to An Bord Pleanála to reconsider the permission granted by Meath County Council on July 31st, 2001 towards Indaver Ireland to build an incinerator at Carranstown, Duleek (file number 01-4014).

I have the following three observations for reconsidering this permission:

1. The possibility exists that the Indaver incinerator near the Boyne Valley is able to stimulate the formation of clouds and thus obstructing the sunlight coming inside Newgrange around winter solstice.
2. The Boyne Valley is on the World Heritage list and the Indaver incinerator is 3 km from this unique area. I miss an explicit approval from UNESCO (or Dúchas/State Party) to build the incinerator at this precious location.
3. The ground level concentrations in the EIS (section 4) are determined by using a flat ground. The question is if this is allowed knowing that Donore is 2.5 km from the incinerator and at the same level as the top of the incinerator's chimney.

In my opinion these observations provide reasons to reconsider the permission granted. If more information is needed, I am of course willing to provide that. Furthermore I keep my web-site continuously updated with new information on the above observations.
 

Yours sincerely,
 
 
 

Victor Reijs

E-mail: remove underscore
Web site: http://www.iol.ie/~geniet/eng/indaver.htm

Details concerning the observations:

1. The possibility exists that the Indaver incinerator near the Boyne Valley is able to stimulate the formation of clouds and thus obstructing the sunlight coming inside Newgrange around winter solstice.

In the original Meath County Council Planning report (file 01/4014, dated 9/3/2001, approved 13/3/2001) the following text is found (section 3.6 page 28):
“Visible plume formation associated with the emission stack particularly in the periods of cold weather will be reduced as it is proposed to heat exhaust gases to 100°C.”
This statement is left out in the final version of the Planning report (July 31st, 2001)!
The terms reduced and proposed need more body, certainly because the visible plume (clouds) could block the winter solstice sun which goes into Newgrange. It is recommended that a study will be performed to determine cloud formation due to the Indaver incinerator and if these clouds could block the sun light presumed to go into Newgrange.
Clouds are not permitted to be formed around winter solstice at the following sky window:

(Height = 0m is the height of the incinerator's chimney outlet)

Useful models could be Seasonal/Annual Cooling Tower Impact (SACTI: http://www.ead.anl.gov/ead/who/section/ats.cfm) and Combustion Stack Visible Plume (CSVP).

Prof. Perry J. Samson, University of Michigan states:
“If the relative humidity is relatively high then there is a reasonable change the plume will persist for some distance downwind.  Qualitatively the higher the relative humidity the long the plume will persist and effect sunlight.”

2. The Boyne Valley is on the World Heritage list and the Indaver incinerator is 3 km from this unique area. I miss an explicit approval from UNESCO (or Dúchas/States Party) to build the incinerator at this precious location.

Dúchas has mentioned this already in their reaction towards Meath County Council on July 23rd, 2001:
"... in relation to the visual impact of the 40m chimney stack. We would ask that its potential visual impact on the Boyne Valley area site included in the UNESCO World Heritage list, be taken into consideration in the decision on weather or not planning should be granted for this development."
I have not seen official feedback or to Dúchas or within the final Meath County Council Planning report (July 31st, 2001). An official investigation if UNESCO (http://www.unesco.org/whc/archive/opguide99.pdf) approves this building, is recommended.
3. The ground level concentrations in the EIS (section 4) are determined by using a flat ground. The question is if this is allowed knowing that e.g. Donore is 2.5 km from the incinerator and at the same level as the incinerator's chimney outlet.

Donore is 2.5 km from the Indaver incinerator and at a height of 70 m above sea level (so almost at the same height as the chimney outlet, see also View 22 of EIS attachments). The model used by Indaver Ireland (Industrial Source Complex Short Term, ISC3 ST) supports a more complex terrain than a flat ground (called Terrain Grid pathway, see ISC3 User’s Guide, Volume 1: http://www.epa.gov/scram001/userg/regmod/isc3v1.pdf  section 3.6). A recalculation of the ground level concentrations including this Terrain Grid pathway is recommended.

Continuously updated information on these observations can be found at: http://www.iol.ie/~geniet/eng/indaver.htm