It will be too costly to run.
The published running cost is already higher than the cost of landfill. The published costs are also underestimated.
The development will become a White Elephant as a burden on the citizens of Dublin for the next 30 years. There is likely to be a drastic correction to our production of greenhouse gases as a result of policy changes by Government when it recognises the urgency of the global warming crisis.
Since Elsam have been given guaranteed deliveries of waste under the Put or Pay clauses of the contract we will then be left paying for this incinerator for the remainder of the term without receiving any benefit for the expenditure.
Costs published in the EIS
The costs for the proposed incinerator can be derived from the figures presented on page 2 of Appendix 13.2:
Waste to Energy Environmental impact Statement – Community Gain Proposals
Proposed Scale of the Community Gain Fund
Dublin City Council is proposing that the fund should comprise a once-off capital contribution of 3% of the capital cost of the facility and an annual revenue contribution of 0.5% of the amount of revenue generated by gate fees at the facility during its lifetime, subject to maximum annual contribution of €500,000. Based on the estimated construction cost of €266m, the capital contribution will be of the order of €8m. Based on a throughput of 600,000 tonnes per annum, the annual revenue contribution will be of the order of €265,000.
From the above paragraph we extract the following costs:
Construction cost: € 266 million
Gate fee: € 265,000 is 0.5% of the gate fee for 600,000 tonnes per annum.
Total gate fee is therefore € 53 million per annum
Gate fee is therefore € 88.33 per tonne.
Omitted from the published costs are several items which should have been included in the pricing model for this incinerator. These additional costs are:
- Transport costs
Original site selection was based on having the South-Eastern Motorway running across Sandymount strand to the M50. This roadway is not in place causing all traffic for the incinerator to run through Ringsend / Irishtown. It now means that all trucks from the baling stations arriving at the site will incur an East Link toll fee twice – one arriving and one departing and a portion will also incur West Link toll fees on the M50. These costs have not been assessed.
- CO2 emission costs
The Kyoto carbon credits are currently running at some € 17 per tonne (Irish Times 25th July 2006). The excess CO2 tonnage emitted by this plant should be costed.
- Cost of bottom ash disposal
The applicant is proposing that bottom ash be exported abroad by sea from Dublin Port. This is an unsustainable proposal since reuse of bottom ash in other countries such as Denmark and the UK is only feasible due to Government policy interventions in those markets.
The bottom ash cannot be exported until testing of leachate proves it is not hazardous. The applicant has not stated where this testing is to take place. Section 10.5.3 on page 10-6 states that the bottom ash pre-treatment will not be undertaken at the Dublin WtE facility. Aging of bottom ash takes some 6 to 8 weeks to complete and during this period substantial changes occur in the chemical composition of the ash. The classification of the ash as hazardous or non-hazardous is unknown until pre-treatment is completed.
This means that the ash cannot be exported directly to another country contrary to the statement by the applicant. The consequences are that the bottom ash must be disposed of in Ireland entailing a considerable increase in traffic and additional costs for transport and for landfill fees. These costs have not been assessed.
- Cost of baling of waste at the three baling stations were omitted.
- Revenue from sale of heat is assumed with no proven demand.
It is notable that DCC has approved the Fabrizia application for 737 apartments within 500 metres of the incinerator site but have not specified any planning condition requiring use of the heat from the proposed incinerator.
- The original BATNEEC decision was based on a 19% difference in NPV of the four scenarios. The NPVs were derived using an incorrect cost of money at 6.5%.
Euribor is currently 3.53%.
Please see the attached Submission (August 2004) by J McCarthy to the Waste Management Plan Review by Dublin City Council for worked details of these omitted costs. The submission shows an additional € 45.9 million per annum in omitted costs from the original MCCK Technical Studies and Dublin Waste Model (1997).
The gate fee of € 88.33 per tonne proposed is at the same level as current landfill fees in Leinster and, when the above factors are priced into the project, may be much higher than landfill fees. The additional costs are likely to double the gate fee.
Such a high fee is unsustainable for the people and businesses of Dublin.
Such high fees might also encourage illegal dumping to avoid fees.
Affordability for the Developer
Indaver Ireland stated on 19th September 2006 at a conference at the Radisson – St Helens that their proposed incinerator in Carranstown, Co Meath will be uneconomical at a gate fee € 90 per tonne.
They have demanded that Government intervene in the market by imposing a tax on landfill to bring the gate fee for landfill up to € 120 per tonne before they are willing to proceed with their € 100 million investment.
This begs the question of commercial interests dictating national policy in waste management.
If Indaver cannot run an incinerator with a gate fee € 90 per tonne how can DCC afford to do so at € 88.33 per tonne?
We suggest that the development is unsustainable on cost grounds.