Concerning file number: 01-4014
Location of development: Indaver, Carranstown
Skerries, September 27th, 2001
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:
The above observations are elaborated in the appendix.
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.
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.
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
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.
E-mail: remove underscore
Web site: http://www.iol.ie/~geniet/eng/indaver.htm
Details concerning the observations:
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:
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
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
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.
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
© V. Reijs, 2001