Cement and the Climate Crisis

Earlier this week the Irish Environmental Protection Agency granted a licence to Irish Cement to commence burning tyres, medical waste, animal waste, plastics and other toxic substances at its facility in Limerick.

The decision comes despite more than 4,000 people submitting formal complaints against the proposal to the EPA, and more than 4,500 people turning out on the streets of Limerick in 2019 to protest the plans.

Today we look at the EPA’s decision to approve this plan in the context of the Climate Crisis, and look at the emissions from the cement industry as a whole – one of the largest emitters on the planet, and one that gets little media attention.

Irish Cement Limerick

Irish Cement is planning to burn 90,000 tonnes of waste annually at its facility in Limerick. While it has repeatedly used the term “alternative energy”, the reality is that the vast majority of what the business plans to burn is highly toxic waste that poses a major threat to both human and animal life, as well as to the climate.

The burning of this toxic waste material – which will include 1 million tyres per year – not only produces harmful carbon dioxide emissions, but also emits nitrous oxide – which has a greenhouse effect 298 times more powerful than carbon dioxide – as well as sulphur oxides.

Particularly given the company’s poor history of meeting environmental standards.

In 2006 the business was fined €1,250 by the EPA for dust emissions that damaged hundreds of cars in Limerick, and resulted in the city’s hospitals being placed on high alert for patients being emitted with respiratory illnesses.

A decade later in 2016, an EPA study found that Irish Cement in Limerick had nitrous oxide emissions that were 20% above the legal limits set out by the European Union, for which it did not receive any fine. The same year, Irish Cement issued a public threat to cut jobs unless the permit to burn toxic materials was granted.

This threat was issued just four years after the company refused to pay the salaries of 50 workers unless they accepted an 18% wage cut, despite Irish Cement’s parent company, CRH, recording €700 million in profits the previous year, a year-on-year rise of 35%.

Just two years later, in 2018, Irish Cement was fined again – this time a total of €4,000 – for further dust expulsions that affected homes, cars and local infrastructure.

Yet, in response to the widespread protests against their planned expansion, Irish Cement’s only public response was to state to the Limerick Leader: “We’re part of the local community too.”

With over 850 new homes planned for the Mungret area around the cement factory in the next decade, there are serious concerns that the burning of toxic materials will lead to health threats to more and more people in the near future.

Health Threats

The fight to oppose Irish Cement’s plans in Limerick has been led by citizen activist group Limerick Against Pollution, which has been active since 2015.

We spoke with Claire Keating of Limerick Against Pollution to find out more about their mission: “The decision to form Limerick Against Pollution arose from a lack of trust in the mechanisms that are supposed to protect public health and the well-being of the residents and the environment of the Shannon Estuary, including Counties Limerick and Clare.”

“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,” continues Keating. “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 checks.”

Climate Threat

Despite the Irish Government declaring a Climate Emergency in May 2019, the EPA’s decision to grant Irish Cement’s licence to burn toxic materials demonstrates that this was little more than a PR exercise.

This is particularly troubling given that the cement industry is responsible for around 8% of the world’s total carbon dioxide emissions – totalling some 2.8bn tonnes, according to Chatham House.

Around half of the CO2 emissions from cement come from the production of clinker, a binding agent in concrete, which requires heats in excess of 1,450°C to produce. These high temperatures are used to change the chemical composition of limestone to produce clinker, which releases a vast amount of CO2 in the process as a by-product.

A further 40% of the emissions from cement production come from the burning of fuels to heat kilns to the temperatures needed for this process to take place.

In fact, the European Parliament has urged member nations to minimise garbage inceration due to the high levels of CO2 emissions, as this reduces recycling and increases demand for oil extraction through the creation of virgin plastics and other products.

Ireland could take a leaf from the books of Denmark, where their government has legislated to reduce its incineration capacity by 30% in a decade, with the closure of seven incinerators while also dramatically expanding its recycling capacity.

“It’s time to stop importing plastic waste from abroad to fill empty incinerators and burn it to the detriment of the climate,” said Dan Jørgensen, Danish Climate Minister.

Sadly the EPA’s decision leaves Irish people and the Irish environment vulnerable to corporate exploitation once more.

A contest in the European courts is currently being considered against the EPA’s decision to grant the licence to Irish Cement.

EPA Response

While the EPA issued a broad statement when it announced that it was granting the license to Irish Cement, there was a considerable lack of transparency about the due diligence that had been undertaken in the approval process – and why the concerns of over 4,000 people had been overlooked.

As a result, IrishEVs contacted the EPA to seek answers to why the licence had been granted, especially in the wake of the Climate Emergency declared in 2019.

The questions submitted – and the answers provided by the EPA – are printed in full below. We’ll leave it up to our readers to determine whether you think their responses address the specific and important questions that we posed, or whether these are stock PR responses that avoid answering the questions we asked:

How can the EPA justify the burning of such toxic materials in the wake of the Climate Emergency that was declared in 2019?

The documents that support the decision of the Agency in relation to the co-incineration of waste at this installation (Irish Cement Ltd, Limerick) are all available on the EPA website and include the Inspectors Report and the Oral Hearing Report. In particular, National policy, particularly the Waste Action Plan for a Circular Economy 2020[1] and the Climate Action Plan 2019[2] are considered in the Circular Economy section of the Oral Hearing report (section 2.4). Also section 2.3.5 Climate Emergency/Carbon Dioxide Emission Savings provides a consideration of issues raised by Objectors in relation to Climate Emergency and there is further detail in other sections of the Oral Hearing Report such as section 2.5 Alternative fuels and alternative raw materials, section 2.5.1 refers to co-incineration and section 2.5.2 refers to waste acceptance.

All documentation associated with this licence application are made available and can be accessed from the EPA website. Further information on how the licensing process works can be found on the  EPA website.

Given that more than 3,000 people objected to the proposal, and more than 4,500 marched in Limerick against Irish Cement's plans, why is there so little transparency about why the EPA made its decision to approve the plan?

The EPA Industrial Emissions Licensing process is open to public participation at all stages in the process and all documentation is made available on-line from the earliest stage of receipt of the licence application through the assessment phase. The documents that support the decision are all available on the EPA website and include the Inspectors Report and the Oral Hearing Report.

Section 1.2.2 of the Oral Hearing report deals specifically with public engagement during the licence review process. All documentation associated with this licence application are made available and can be accessed from the EPA website. Further information on how the licensing process works can be found on the  EPA website.

Does the EPA believe that charging €126 per complaint is a fair charge for concerned citizens, and does it recognise that such an unaffordable expense is a barrier against social justice where corporations are concerned?

When a Proposed Determination issues the fee to make an objection is set in legislation (S.I. No. 284/2013 Environmental Protection Agency (Licensing Fees) Regulations, 2013) and is €126.

The public can engage in the licence application process from the date that an application is made and can make a Submission without any fee until such time as the Proposed Determination (draft licence) issues. 4,180 Submissions were received on this licence application and all are available to view on the EPA website. Following the issuing of the Proposed Determination the Agency received 18  Objections on this Licence Application including 6 requests for an Oral Hearing. In addition, 39 written submissions were received to the oral hearing for which there is no fee and 35 people presented their submissions to the oral hearing over five and half days.