Sheila Healy
Interim Chief Executive
Shropshire Council,
Shirehall,
Abbey Foregate,
Shrewsbury, SY2 6DN

27 April 2009

Special Delivery Package Number ZU 4587 9702 3GB

Dear Ms Healy,

Planning Application for incinerator at Harlescott. (Ref: SC/MS2009/0125/SY)

I object to the above planning application for an incinerator at Harlescott because:

1. PM2.5 emissions from the incinerator will harm health and cause premature deaths at all ages, and
2. “plasma gasification” is a safer and cheaper alternative method of waste disposal as explained to the Inspector at the Shropshire Waste Plan Public Inquiry on 15 January 2004 by Dr Dick van Steenis MBBS who was my “expert witness”. If health damage costs are included in a comparison between incineration and plasma gasification, then plasma gasification has a nett cost that’s around one hundred pounds per tonne cheaper than incineration, i.e. a potential saving of £9 million per annum at Harlescott. There’s an article about plasma gasification in the New Scientist, 25 April 2009.


Health damage due to incineration

PM2.5 emissions from the proposed Harlescott incinerator will cause increases in the rates of illness and premature deaths at all ages, and will also cause both NHS and Social Security costs to soar in Shropshire as more people become chronically sick and unfit to work.

Unlike here in the UK, the US government further reduced industrial PM2.5 emissions in their 1997 Clean Air Act and made nett savings (i.e. after retrofitting abatement) of up to $193 Billion from October 1992 to September 2002 due to fewer hospital visits and less days off work. I’ve enclosed a copy of “Study finds net gain from pollution rules” (Washington Post, 27 September 2003). No UK paper bothered to report the above study by the White House Office of Management and Budget, otherwise the UK might have copied the US clean air strategy and started to save lives and money instead of increasing industrial PM2.5 emissions with incinerators.

I’ve enclosed a copy of the Shropshire Star article “Council accused of breaching rights” (16 January 2004) which reports that my “objections were health-related” and that “by ignoring health implications (of waste disposal) at this critical early stage, Shropshire County Council has breached the human rights of every citizen”.

The above Shropshire Star article of 16 January 2004 mentions my research into birth defects, which are known to be a major cause of infant mortality and which have since been proved to be caused by industrial PM2.5 emissions by researchers at McMaster University, Canada (Science, 14 May 2004).

I’ve enclosed a copy of the Norwich Evening News article of 27 March 2006 about my research: “Incinerator and birth defects are linked” because that article states: “Earlier this year, the Evening News reported how an investigation by the Health Protection Agency had not found any links between incinerators and ill health.” which suggests that the Health Protection Agency has examined rates of illness and premature deaths around incinerators and compared upwind zones-v-downwind zones.

Your Council will take “expert” advice from the Health Protection Agency (HPA) on health effects of airborne emissions from incinerators - either directly or via Shropshire County Primary Care Trust. Unfortunately, the HPA have failed to examine relevant data around incinerators as admitted in Justin McCracken’s letter to me dated 1 May 2008 which I’ve enclosed together with a copy of my letter to Dr Pat Troop, Chief Executive of the HPA, dated 31 March 2008. The enclosed copy of the Western Daily Press article “Chemical danger testing” (6 August 2003) reported the intention of the HPA to examine whether or not there was any harm to health of residents near landfill sites or incinerators. It was this article which prompted me to ask the last question in my Freedom of Information letter to Dr Pat Troop, dated 31 March 2008.

Norman Baker MP asked the following Parliamentary Question: “To ask the Secretary of State for Health what assessment he has made of the correlation between the presence of a functioning incinerator and the incidence of infant mortality in that area.”. You can see from the enclosed Hansard written reply dated 17 September 2007 that “In November 2005 the Health Protection Agency issued advice on the public health impact of Municipal Solid Waste Incineration…..”, but that “advice” is worthless and invalid because the HPA have failed to examine any relevant data.

Two Surrey newspapers reported the HPA’s failure to examine relevant health/mortality data around incinerators and I’ve enclosed copies of “Incinerator fury as bosses admit to no health checks: Protestors say agency is failing to protect public from illness” (Dorking Advertiser, 22 May 2008) and “Chill wind over fumes risk from incinerator” (Surrey Mirror, 22 May 2008). I’ve also enclosed a copy of “Incinerator could kill our children” (Dorking Advertiser, 10 January 2008) which features copies of infant mortality maps I prepared for an incinerator lecture at Norwich in January 2007, which was jointly hosted at Costessey High School by the Norwich Evening News and the local action group NAIL2. Dr Dick van Steenis was also a speaker at that meeting.

If infant mortality rates (IMRs) are examined at electoral ward level around industrial sources of PM2.5 pollution, there’s a consistent pattern of high rates in the downwind zone compared with the upwind zone.

Wolverhampton has an incinerator in Crown Street and the electoral ward with the highest IMR in Wolverhampton is Fallings Park, which is downwind of the incinerator with south-west wind where the 2003-2007 IMR is 15.3 per 1,000 live births, i.e. three times the average rate for England & Wales. The next wards downwind from Fallings Park are Essington (IMR=9.5), Great Wyrley Landywood (IMR=24.4), and Great Wyrley Town (IMR=12.4) and these last three wards have the highest 2003-2007 infant mortality rates in South Staffordshire. If the above four wards are treated as a single group, they have an average infant mortality rate of 15.3 per 1,000 live births (22 infant deaths, 1440 live births).

Only one of Wolverhampton’s electoral wards had zero infant deaths in the 5-year period 2003-2007 and that was Tettenhall Wightwick, which is upwind of the incinerator and adjacent to a group of nine South Staffs electoral wards which also had zero infant deaths in 2003-2007 as seen on the enclosed ward map of Wolverhampton and South Staffordshire.

Shropshire County Council’s December 2000 report “A Review and Assessment of Air Quality in Shropshire” has the following sentence at the top of page 59: “The predominant wind direction over Shropshire is South Westerly, bringing clean air from the Atlantic and over Wales.”. If the air from the Atlantic is “clean”, then rates of asthma will be very low in non-polluted zones as found by Dr Dick van Steenis in his West Wales survey of childhood asthma rates (The Lancet, 8 April 1995). Dr van Steenis found very low asthma rates upwind of the oil refinery/power station complex at Milford Haven waterway and very high rates in the fallout zones downwind of those polluting sources.

I’ve enclosed an electoral ward map of Shropshire, Stafford and South Staffs showing different bands of 2003-2007 infant mortality rates which shows that the South West sector [ie the one with most “clean air from the Atlantic and over Wales” has a larger area of wards with zero infant deaths than either of the other three sectors. You can see that the wards in the North East sector of the map, which are downwind of Ironbridge power station, have an average infant mortality rate that’s four times greater than the ten-mile wide upwind zone. If the downwind zone had the same infant mortality rate as the upwind zone, there would have been 88 fewer infant deaths recorded by ONS during 2003-2007, ie 30 instead of 118.

Living in an urban area doesn’t automatically mean high infant death rates as one of the London electoral wards had 1539 live births recorded and zero infant deaths during the seven-year period 2001-2007. This particular London ward is well away from all incinerators.

I’ve enclosed the abstract of the 2004 Japanese study of infant deaths around 63 incinerators: “Risk of adverse reproductive outcomes associated with proximity to municipal solid waste incinerators with high dioxin emission levels in Japan” (J Epidemiol. 2004 May; 14(3): 83-93) which has the following sentence at the beginning of the conclusion: “Our study shows a peak-decline in risk with distance from municipal solid waste incinerators for infant deaths and infant deaths with all congenital malformations combined.” I’ve also enclosed the abstract of the 2007 Italian study which also found high infant death rates associated with 27 incinerators.

I’ve examined infant mortality rates at electoral ward level around 28 incinerators and have always found elevated rates in the downwind zones compared with upwind. The nine “zero infant death wards” upwind of Wolverhampton incinerator can be extended to a group of 180 electoral wards by including electoral wards in Shropshire, Powys, Ceredigion, Carmarthenshire and Pembrokeshire.

Medical researchers and doctors in 1944 should have realised that airborne pollution was likely to be a major causal factor in infant mortality as can be seen from the enclosed page 471 of the 1944 edition of Black’s Medical Dictionary which states that infant mortality rates are “as a general rule lowest in agricultural districts, higher in thickly populated mining and manufacturing regions, and highest in large towns where textile industries are carried on and where female labour is largely employed”.

London has 625 electoral wards (if City of London counted as a single ward) and sixteen wards had very high infant death rates during the 6-year period 2002-2007, ie IMRs of 11.0 per 1,000 live births and above. Eleven of these 16 high infant death wards were either wholly or partially within two miles of an incinerator. There were fourteen electoral wards in London which all had zero infant deaths recorded in same 6-year period and none of these wards were within 2 miles of an incinerator. The largest group of zero infant death wards in London are three wards that are seven miles upwind (ie to the west) of the nearest incinerator.

I’ve enclosed a copy of the South London Press article “Health risk: worries of more infant deaths and heart disease found near incinerators” (4 May 2007) which has the following statement attributed to Chris Smith, now Lord Smith and Chairman of the Environment Agency: “no permit would be issued to an incinerator operator if a health risk was likely”. The Environment Agency don’t bother to check any health or mortality data around any incinerator and neither do the Primary Care Trusts who rely on the Health Protection Agency for advice.

I’ve mentioned the Newham infant mortality rate rising after the SELCHP incinerator started in December 1993 and have enclosed the graph of IMRs in Newham and London from Jacqui Barker’s report “Health inequalities in Newham perspective”, 22 January 2004. Also enclosed is the graph of coronary heart disease mortality in persons under 75 for Newham, London and England & Wales. Note that the mortality rate for coronary heart disease rose in Newham after 1993. Note that SELCHP is owned by Veolia.

Several London papers have reported my infant mortality/incinerator research and I’ve enclosed copies of the Enfield Advertiser: “THE BABY KILLER?” (25 April 2007) and the Harrow Observer: “BABY KILLER?” (3 May 2007) plus the Sunday Express article “Incinerator fumes link to hundreds of infant deaths” (29 April 2007).

Professor Richard Weisler, of University of North Carolina, found suicides and cancers clustered around sources of industrial PM2.5 emissions, ie an asphalt plant and also an incinerator. Professor Weisler, who is a medically-qualified doctor [psychiatrist), suggests a link between certain chemicals and child abuse which should have been of interest to all Social Services departments in the UK, especially in Birmingham, Haringey, Doncaster, Kirklees and Sheffield – all of which are subject to PM2.5 emissions from incinerators and all of which have electoral wards with high infant death rates.

The increased rate of suicides in Neath Port Talbot and Bridgend coincides with the increase in industrial PM2.5 emissions in that area due to the Crymlyn Burrows incinerator.

The enclosed Western Mail article “Experts puzzled at rise in babies born with defects” (19 March 2005) failed to consider that PM2.5 emissions from the Crymlyn Burrows incinerator which started operating in 2002 might be linked to “the seven cases of gastroschisis in babies in Bridgend”.

Your Officers and Councillors cannot be expected to make a correct decision on the Harlescott incinerator unless relevant health and mortality data is carefully examined and understood. The Council has opted for an unsafe and expensive method of waste disposal when they knew about the safer alternative of plasma gasification over five years ago in January 2004.

Yours sincerely,




Michael Ryan BSc, C Eng, MICE