OPEN LETTER IN RESPONSE TO MINISTER BRITTO FROM THE ESG 27/10/03
We are very grateful for Mr. Britto’s answers to our public letter. We however feel that we have to clarify some points. We cannot agree with the reason given for the long delay (8 years and counting) in complying with EU directives on air monitoring. He claimed that this was because newer directives were coming up and they were waiting for these to come up to comply with them. This is a fundamentally flawed argument since it is clear that new directives are implemented to improve upon, and tighten existing legislation in order to improve environmental conditions. If we follow the minister’s argument through to its conclusion then we would never have to pass EU legislation because newer ones will eventually come along to replace existing ones. This is clearly not the manner in which EU legislation is expected to be implemented.
We also do not believe in alarming or scaring the public but neither do we believe in allowing a false sense of security. The minister claimed that even though there was no continuous monitoring that this did not mean the air quality was bad and in fact mentioned the “Study of Air Quality in Gibraltar” of Dec 1998. Indicating that the levels were okay. We would like to quote from the Conclusions and Recommendations from this same report.
For Nitrogen Dioxide it concludes the following,
“2. The EC directive limits for NO2, to come into force shortly, specify a value of 21 ppb as an annual mean, for protection of human health. Three sites (Devils Tower Road, Glacis Road, and Rosia road near the electricity generating stations) had six-month means above this value (although within the 50%>margin of tolerance). It is therefore likely that this new Directive limit will be exceeded at some town sites near busy roads. In addition, four sites (Lime Kiln Steps, Queensway, Sandpits and South Barrack Road). Had six-month means above the upper assessment threshold; and a further three (George Don House, Watergardens, and new Harbour views) had six-month means above the lower assessment threshold.
“4. The 1995 WHO guideline for NO2 is that the annual mean should not exceed 20 to 30 ppb. Four sites (Devil Tower’s Road, Glacis Road, Rosia Road and South Barrack Road) had six-month means over 20 ppb but below the 30ppb limit. These sites were also at the side of busy major roads. We could carry on quoting from this report on levels of other substances like ozone and on levels of Benzene and other organic compounds but we do not wish to be alarmist. We believe it is not prudent for the minister to give the impression that Government is not monitoring, but complying, with the air quality standards if this is not always the case.
We were forced into writing the public letter because even though we have met as the minister rightly said to discuss many issues of concern and in particular power stations, we were not informed in an open manner of what the plans for the power stations were, and that there was in fact an expansion of the OESCO power station planned. This regrettable lack of openness and clarity on the part of the minister, in what we thought were completely frank and open discussions, prompted us to issue a public letter to him requesting a full and public explanation. So far the minister in his statements has mentioned the noise issue and how he will deal with it, but of more concern to us are the emissions from the power stations and their effects on health. It is clear from the “Study of Air Quality in Gibraltar” that the power stations are contributing to our ambient air pollution and as in point 2 of its conclusions and recommendations it already mentions the power stations near Rosia road as a source of pollution exceeding recommendations as of 1998. If the proposed expansion of OESCO goes ahead then this will aggravate a bad situation that could have grave health issues with residents of the South District.
The minister explains that the economic growth and expansion of Gibraltar depends on the generation of electricity and we totally agree with him. However we do not believe that the alternatives are,
1) The production of electricity at any cost without regard to noise or emission monitoring and control because electricity is essential, Or,
2) Power cuts.
It is clear that electricity can be and should be produced in a manner that does not adversely affect the health of residents near the installations or indeed breaks EU laws. We urge the minister to explain since he has not yet done so, how he intends to deal with the pollution problem from the power stations and in particular how he intends to comply with the Air standards required under EU law without addressing the power stations issue. It is simply not good enough to claim that this is justified because electricity is essential, especially since there are technologies available today to eliminate the problem of emissions from our existing power stations.
There are clearly better ways to produce electricity than with old reconditioned diesel engines using dated technology without any emissions controls or arresting equipment to reduce pollution. We could in Gibraltar invest a relatively small amount of money to produce perhaps ten or fifteen percent of our peak capacity with renewable sources, which would place us as the leader in Europe of renewable energy use. At worst if this not possible the very least we demand is air that is fit for breathing.
Now that these matters have been publicly cleared albeit pending the minister’s response, we also hope to be able in the future to resume our meetings with Mr. Britto, or whoever takes over the ministry of the environment. The ESG as a serious environmental group will want to continue meeting and discussing important environmental matters with all decision makers and most importantly with Government.
Sincerely,
ESG COMMITTEE
