Select Committee on Environment, Transport and Regional Affairs Fifth Report


Energy from Waste

88. Although the phrase 'energy from waste' encompasses a number of techniques, in practice it is used as shorthand for the process of deriving energy from waste incineration. The future role of energy from waste incineration was a central preoccupation of our inquiry and witnesses were sharply divided in their views. Some argued that incineration should be encouraged as a vital part of a more sustainable waste strategy and that it was the only technique which could deliver the targets resulting from the Landfill Directive. But others believed that incineration of municipal waste represented a lost opportunity to re-use, recycle and compost, that the technique should be seen as no better than landfill and markedly less desirable than the other techniques for recovery and that it posed a real risk to human health. Indeed, for a variety of reasons, the public have developed a deep distrust of incineration and generally object strongly to planning applications for new incinerators in their neighbourhood.[146]

89. Incineration with energy recovery is currently used to dispose of 8% of municipal waste and incineration is also used to deal with large amounts of particular streams such as clinical waste. The Government's attitude to incineration is both blurred and changeable. The draft waste strategy A Way with Waste appeared bullish, suggesting that up to 165 new incineration facilities of capacity up to 200,000 tonnes per year would be needed to meet the aims of the Landfill Directive.[147] However, by the time Waste Strategy 2000 was published, this bold declaration had become rather shy, retreating into an Annex at the back of Part 2 of the Strategy. As acknowledged by officials from the DETR, this shift indicated a "change of tone" by the Government on incineration. By piecing togther the statements from several witnesses, it seems clear that the DETR are generally opposed to a big role for incineration, the DTI are very keen, and the Treasury are cooler but still in favour. These mixed attitudes seem likely to be the cause of the ambivalent tone in the final Strategy. Nevertheless, witnesses thought that one of the main weaknesses of the Waste Strategy 2000 was its over-reliance on incineration as a means of reducing dependence on landfill[148] and Public Interest Consultants even dubbed it a "Charter for Incineration."[149]

90. Concerns about incineration focused on two main areas: the health effects of incineration, and the impact that the construction of incinerators has on the prospects for other techniques such as recycling, re-use and minimisation. We deal with these matters below before considering funding and planning issues, and finally outlining the role which incineration should play in the waste strategy.


91. There is real public concern about the impacts of emissions from incinerators upon human health. These emissions include pollutants with known toxic properties such as dioxins and nitrous oxides. But the health concerns do not centre solely on the gaseous emissions; there are also worries about the content and treatment of the fly ash (which is taken from the filters in the flues and tends to have higher concentrations of toxics) and the bottom ash which is left after combustion of the materials. The quantities of ash are sizeable, at around 30% of the weight of the material which was incinerated.[150]

92. We received much evidence on the impacts of the air pollutants emitted from incinerators. Inevitably, the subject is a complex one and there are many epidemiological studies which the two sides of the argument selectively quote to 'prove' their case. As part of the Regulatory Impact Assessment of the Waste Incineration Directive, the Government employed a consultancy, Entec, to consider the health impacts of incineration. The results were published and using these figures, Public Interest Consultants calculated that the incineration of 1 million tonnes of waste would bring forward 20 deaths and 41 hospitalisations.[151] In subsequent questioning of Mr Meacher, it emerged that an error had been made in the calculations by Entec and that this would have resulted in an over-estimation of the number of deaths being brought forward. Indeed, the 'over-estimation' appears to be almost of an order of magnitude.[152] As a result, the Environment Agency estimate that, "of the estimated 24,000 deaths brought forward annually by all sources of air pollution, fewer than three of these may be attributed to the pollutants from the ten operating municipal waste incinerators."[153] Entec's error is more than unfortunate: where such a study should have brought clarity to the health effects of incineration, instead it has contributed directly to the confusion which surrounds this complex topic.

93. There is a significant body of epidemiological evidence which shows health effects resulting from older incinerators. Even today's exponents of incineration accept that the older incinerators were relatively dirty and probably did have direct health effects. But those exponents go on to make the case that a distinction must be drawn between 'new' incinerators which meet modern emissions standards and 'old' plants which were built before meaningful emissions standards were introduced. Many of these older incinerators were closed down in the mid-1990s as new standards were introduced. Certainly, there is good evidence that the emissions standards have driven down the actual emissions from incinerators and this will continue with the implementation of the Waste Incineration Directive. But it is also generally accepted that emissions standards are still based on what can be measured and what is technologically achievable, rather than what is safe.[154] Inevitably, this simple fact undermines the safety case which can be made from an incinerator meeting modern emissions standards. In particular, the scientific evidence and consensus about the health risk posed by dioxins is not fully developed and the US Environmental Protection Agency have recently published for consultation a review which concludes that dioxins could be some 1000 times more toxic than previously thought.[155] The Environment Agency told us, more generally, that our understanding of the health effects of air pollution is "at an early stage."[156]

94. The subjects of risk and perception of risk are extremely complex ones. Indeed, this point was emphasised during the course of our inquiry with the publication of Lord Phillips' report on the BSE crisis. There are risks associated with any industrial process and any waste management option. Dr Martin Whitworth of the Environment Agency told us: "I cannot give any categoric answer that any waste management option is safe."[157]With the messages from the BSE inquiry still fresh, we were astonished to be told by the Energy from Waste Association that "there is no risk" from incineration.[158] Such bald statements do not help rational analysis of the subject, any more than those which exaggerate the risks of incineration to create undue public concern.

95. No consideration of the health risks of incineration would be complete without reference to the Byker incinerator in Newcastle. The story is a sobering one: poor operating practices went on for many years and this culminated in the spreading of mixed bottom and fly ash on allotments, footpaths and play areas. This ash was untested but now appears to have had elevated levels of many heavy metals and very high dioxin concentrations.[159] Beyond the direct impact on the local community, this experience has scarred the public's perception of incineration.

96. If the public is to believe that incineration is safe, it must be convinced that the regulation and inspection regime is adequate and sufficiently thorough to ensure that an incinerator will be well run. When the Environment Agency came before us, they did not make a convincing case that they could persuade a sceptical public that incineration was safe, nor that the regulatory regime would ensure an incinerator continued to operate as it should.[160] These problems were graphically illustrated by the Capel Action Group who commented that:

    "The public are told they are safe, they then find the monitoring is done by the operator, then they find a lot of the monitoring does not apply except once or twice a year to particulates and so on. ... When you have enforcement notices being ignored at Edmonton, where clinical waste continued to be burned when emission limits were being exceeded, and they were taken to court and fined a paltry sum, it shows the system is not working and no wonder the public are concerned."[161]

97. Following technical guidelines is only one part of regulation. The other is making it transparent and ensuring that the public believe in it. It seems inevitable that incinerators will require more frequent inspection if the public's confidence is to be gained and that this must encompass all aspects of the incinerator's operation, including what happens to the ash. Whatever the quality of emissions regulation and emissions reduction equipment, poor management, poor regulation and poor operating practices can produce a real health risk from an incinerator. The arguments about the health effects from incinerators are complex and are based on incomplete knowledge. There are, however, some truths which can be drawn from the debate over the health impacts of incineration. Firstly, that the health effects which result from an incinerator's emissions are not yet fully known. Secondly, that the regulation of incineration to date has been rather poor and that this has resulted in poor practices developing in some incinerators. This, in turn, has raised the levels of anxiety amongst the public. Regulation must encompass emissions, the handling of the ash and all other aspects of the operation. Lastly, the lack of pre-separation of potentially hazardous materials, such as PVC, treated wood and batteries, increases the risk of emission limit values being exceeded.

98. The Environment Agency must provide a better standard of inspection of incinerators if the public's confidence is to be regained. The Agency will also need to examine its strategy for communicating the risks from incineration to the public. In addition, continuous monitoring of the emissions from all incinerator stacks should be carried out and the data made freely and easily available to the public. Where recurrent breaches of limit values are found to occur, the operator should be fined. If breaches continue to occur, the plant should be closed down. Only with the combination of better, more rigorous regulation and greater transparency will it be possible to convince a sceptical public that incinerators need not pose a major risk to human health.


99. Some witnesses were concerned that an expansion of capacity for incineration would 'crowd out' recycling[162] and this possibility is acknowledged by the DETR.[163] Because building an incinerator is a capital-intensive project, incinerators require a guaranteed waste-stream (with a reasonably high calorific value) over many years for their construction to be cost-effective. Contracts often specify a given amount of waste for a period of up to thirty years. In addition to the construction of new incinerators, there is also a danger that large amounts of waste could be diverted for use as a fuel in cement kilns. By taking a large amount of material out of the waste stream (and also diverting away from landfill, thereby helping to meet the landfill diversion targets based on the EU Landfill Directive), it is argued that efforts to recycle and re-use will be lessened.[164] As such, some have dubbed incineration the "slob" solution to meeting the Landfill Directive targets.[165]

100. Against this, if we are to lessen our dependence on landfill (as we must), it is difficult to see how this will be achieved without increasing the amount of waste which is incinerated. Many witnesses made the point that the legal requirements for diversion of biodegradable waste from landfill would not be met without recourse to incineration.[166] Peter Jones of Biffa wrote that "common sense" would suggest a doubling of incineration capacity.[167] Similarly, the National Association of Waste Disposal Officers noted the need for a "secure" option to deal with the residual waste after recycling and composting.[168] Certainly, in the short- to medium-term, it will not be possible to maximise the levels of waste reduction, re-use and recycling such that the levels of waste left over are relatively small and can continue to be landfilled.

101. The argument about incineration 'crowding out' recycling really comes down to the scale and number of individual incinerators which will be built. The discussion of these numbers produced much disagreement. Part 2 of the Waste Strategy 2000 indicates that up to 166 new incinerators (of average 250,000 tonnes/year capacity) could be required by 2020 to meet the landfill diversion targets. The Government is, however, keen to distance itself from any specification of how many should be built - the DETR told us that:

    "The number of incinerators which will appear will not be a matter which we decide. They will be the outcome of local decisions made by local authorities with responsibility for managing waste in consultation with their local communities ... There is no Government plan for the number of incinerators. We have illustrated what will happen if people do not get on and make plans and increase recycling."[169]

However, perception is skewed in that the gap between the recycling and recovery targets is often taken as the 'requirement' for energy from waste. As such, it seems likely that higher recycling and composting targets would probably reduce the planned incineration capacity.

102. In a slightly curious situation, those who argue for more incineration project fewer numbers of smaller incinerators whilst those who are opposed to the technique told us that there would be large numbers of high-capacity incinerators built. Robin Murray told us that:

    "The most likely one that fits the model is 112 incinerators. If you think that there are just over 130 waste disposal authorities, from my experience of disposal authorities ... the great majority are going for plans that are reflected in the Strategy, which are incineration centred."[170]

Peter Jones of Biffa Waste Services Ltd also suggested that around 100 incinerators would be built.[171] Against these figures, the Energy from Waste Association described the projection of up to 166 new incinerators as a "gross exaggeration"[172] and went on to suggest that a maximum of 40-50 plants would be constructed by 2015.[173]

103. The Energy from Waste Association stated that there is no optimum size of incinerator since the appropriate scale will vary according to local conditions.[174] However, many witnesses argued that incinerators above a certain size were inimical to prospects for recycling[175] and it seems to be common sense that smaller plants are less likely to reduce the potential for recycling since they take a smaller portion of the waste stream.[176] The Government has signalled (albeit rather weakly) that it does not want to see very large incinerators being built. Mr Ward from the DETR noted the scale of the Edmonton incinerator (which has an annual input of 600,000 tonnes) and that it burns all materials without sorting. He went on to say that "we are signalling that that sort of style is not what it is all about. That is not what we regard as integrated waste management for the future."[177]

104. But amongst those incinerators which have recently received planning permission are those at Slough (440,000 tonnes per annum) and Maidstone (500,000 tonnes per annum).[178] The average size of new incinerators is smaller, at around 200,000 tonnes per annum, but even at this size, incinerators must still be considered inimical to the prospects for recycling and composting.

105. The scale of an incinerator is, obviously, linked to how much material is to be burned. One of the arguments against mass-burn incineration is that around 30% of the material included is inert and does not burn.[179] Not only does some of the material not ignite but unsorted mixed waste will also contain many components from which value could be gained through recycling or composting. Quite simply, incinerators would be smaller if they were only used to burn waste from which materials for recycling and composting had been source-separated.

106. The nature of incineration is such that it can 'crowd out' recycling: if a significant number of large incinerators, operating on long contracts, are allowed to be built, the long-term prospects for recycling will be diminished. The real challenge, then, is to keep the contribution of incineration to a reasonable level. For this reason, the Government should consider how to ensure that incineration is used only for sorted waste from which materials of value have been reclaimed. Further, the average size of incinerator currently planned is too large and the Government must offer a clear signal that the building of incinerators above a capacity of 100,000 tonnes per annum is unlikely to be approved.


107. It can be argued that planning for new incineration is heading towards crisis-point. Some witnesses expressed concern that the current timescale for planning and constructing incinerators was such that energy from waste would not make a much greater contribution to waste management before 2010.[180] The primary problem is the public's complete lack of acceptance of incineration. There are many reasons for this - the health issues (as discussed above), worries over the amount and type of traffic which an incinerator will bring and a general reluctance to see an industrial facility in their neighbourhood. Indeed, the public appear to have reservations about any waste facility being built: a subject we consider later in this Report.

108. However, we were left in no doubt that it is incineration and incinerators which people object to most: there are now many protest groups set up around the country to oppose the construction of incinerators. By their proposed scale, many incinerators must be considered to be of regional significance - that is, they will handle not only local waste but also that from the surrounding region. Such facilities will often attract greater opposition because of the perception that one neighbourhood is being forced to deal with the waste from elsewhere. This tends to breed further resentment. We have already noted that smaller incinerators could make incineration less of a threat to the prospects for recycling. It may also be that the public find smaller incinerators less objectionable.[181]

109. Seeking planning approval for incineration at present can also be considered to be handicapped by the Government's equivocal level of commitment to incineration as part of the future waste strategy. Indeed, the Planning Officers Society told us just this:

    "the bottom line is the determination of a planning application for an incinerator facility which may be the subject of a public inquiry, through call-in or whatever. Whilst the planning officers may seek to support that proposal, they may well not be able to bring in defence of that support, firm Government guidance which states categorically that incineration is supported"[182]

It is estimated that it takes around 7 years to gain planning permission for and build a new incinerator at present.[183]The Energy from Waste Association argued that "rigorous revision of the planning process" would be necessary to meet the targets in the Landfill Directive. Although the planning system can be slow and cumbersome, it is surely the best check on what is built and ensures that the public must be consulted (at least indirectly) about waste management facilities to be built. We consider the planning of waste management facilities more fully later in this Report.

110. Although the planning system is currently delaying the construction of new incinerators, it can be considered to be one of the few factors which is restraining the growth of incineration. Given our severe reservations about the future role of incineration, we are not unduly concerned by these delays. The most worrying aspect of the siting of new incinerators is that they may end up in those areas where it is anticipated that resistance will be least. In practice, this is likely to be poorer areas[184] and there are already indications that the Energy from Waste Association are recognising the need to offer something to the local community where an incinerator is to be sited.[185] We are concerned that incinerators may end up being built according to the 'path of least resistance' rule. If allowed to happen, this may mean that poorer areas of towns and cities are left effectively blighted by the presence of a large incinerator. This must not be allowed to happen. If incineration is safe then a sceptical public must be convinced and incinerators should then be sited in the most appropriate places which could be out-of-town shopping centres or adjacent to town-halls and other offices, rather than the poorest areas. When siting incinerators, the main factor should be the existence of a suitable local demand for the hot water and electricity produced.

111. The problems of planning for incineration will not be easily remedied and it may be that authorities should make use of this situation to motivate and involve the public in waste planning more generally. Several witnesses noted the benefits of producing a draft waste plan which includes the construction of new incineration capacity. Although such a plan is likely to attract protest on the basis of the siting of the new incinerators (if nothing else), it is then possible to engage in a public debate about what should be done with the neighbourhood's waste. Essex Waste Disposal Authority told us of the success of this approach, noting that it had resulted in "the most fantastic debate" about waste management in the county.[186]

112. Some have suggested that this approach be taken one step further and that a local authority could 'shadow plan' for an incinerator.[187] In effect, the authority would develop plans for new incineration capacity but only proceed with construction if attempts to minimise, re-use and recycle left a shortfall from the diversion targets. In most cases this technique is likely to promote greater involvement from the public in waste planning. However, a formalised arrangement of 'shadow planning' for incineration could be considered to have a whiff of bullying about it. Such veiled threats should be used with caution and should only follow after the failure of other efforts to engage the public in the local waste plan. Shadow planning of facilities which the public may oppose must not be used as a short-cut to public engagement.

113. One other issue about planning for incinerators was brought to our attention by Colin Pickthall, Member of Parliament for West Lancashire. There appears to be a possible 'back door' by which any industrial facility may be able to convert to become an incineration plant for BSE-infected cattle without having to go through a full application for planning permission. By applying for a Lawful Development Certificate, the firm avoids any planning considerations being taken into account: the only question to be answered is whether the development in question is lawful for planning purposes. This is wrong: it is vital that facilities which provoke public anxiety such as incinerators are required to go through the full planning route so that those concerns can be aired and considered before a decision over planning permission is given. An increase in incineration must not be allowed to be imposed by any 'back door' route, such as Lawful Development Certificates. In particular, the conversion of existing industrial facilities to incinerators to deal with the remains of BSE-infected cattle should only be allowed if sought through a full application for planning permission.


114. Many witnesses claimed that incineration had been, and continues to be, in receipt of large amounts of public money which are either not available to other options or are more difficult to attract.[188] Robin Murray told us that the existing instruments available to fund new incineration capacity were "like financing an abacus development programme when we have an electronic revolution around the corner."[189] Public Interest Consultants detailed the incentives available:

    "the NFFO support; the issue of Packaging Recovery Notes; Private Finance Initiative grants - which are being used almost exclusively for incineration centred projects; rate relief on incinerators; the classification of bottom ash as inactive for landfill tax; and possibly still the Climate Change Levy exemption."[190]

This point was explicitly acknowledged by officials from the DETR who said, simply, that "we recognise that the level of support for incineration is greater than the level of support for recycling."[191] Robin Murray told us that the net effect of these schemes for the Kidderminster incinerator was that it received £100 million of public money out of the total cost of £500 million.[192]

115. As we have already noted, incineration is a capital-intensive technique and many witnesses argued that, as a result, it was effectively more eligible for Private Finance Initiative funding than other, less capital-intensive techniques. This point too was effectively acknowledged by officials from the DETR who noted that the PFI rules had now been "tightened up" to ensure that an incinerator forms "a properly balanced part of the overall package."[193] The DTI memorandum lists the new criteria, the relevant one being that the PFI bid must:

     "reinforce the central place of recycling and composting in waste PFI applications. Proposals for incinerators must demonstrate that all opportunities for recycling have been considered first, and should include proposals for combined heat and power where possible."[194]

Although this is clearly an improvement, the Minister told us that "most, if not all" of the eight PFI projects which have been approved since the change of rules have still involved incineration.[195] Nevertheless, Mr Timms was confident that the new criteria would be reflected in future bids. The nature of the PFI system is such that it will continue to end up funding large-scale incineration or large Materials Reclamation Facilities, rather than the incremental building-up of kerbside recycling facilities.[196]

116. We welcome the Government's amendments to the rules for Private Finance Initiative funding and expect these to be fully enforced to ensure that incineration plays only a moderate role in most bids. Further, the Government should examine whether the PFI rules can be changed so that long-term improvements in recycling and composting facilities can be funded from this source. If not, we recommend that the role of PFI funding for waste management be progressively reduced.

117. A further aspect of PFI funding raised concerns: in many cases, PFI funding has been approved before planning permission for an incinerator has been granted. Not surprisingly, this has provoked resentment from local communities who feel that they are being presented with a fait accompli and are being bounced into accepting a facility without true or full consultation. Consultation must be pursued before seeking PFI funding.[197] We recommend that PFI approval not be given until planning permission has been granted for the facilities required.

118. The other aspects of subsidy to incineration rest largely upon its classification as a source of renewable energy. Proponents argue that energy from waste is renewable on the basis that it displaces fossil fuels, thereby producing a net reduction in emissions of carbon dioxide, the principal greenhouse gas. Critics argue that the net reduction in emissions is not large: for example, Greenpeace stated that energy from waste incineration produced 80% of the emissions produced by a fossil-fuel power station.[198] Leaving aside the question of emissions, Ms Hewitt, the DTI Minister told us that a renewable source of energy is one which is "continuously and sustainably available"[199] and this point was echoed by Stephen Timms, the Treasury Minister. Mr Meacher seemed less convinced, noting that "there is still the question about the conceptualisation of energy from waste and whether that is renewable."[200] Certainly, it is difficult to feel comfortable with a system of renewables classification which categorises energy from waste alongside solar, wind and wave power. Some witnesses argued that by classifying energy from waste as 'renewable', these other sources were being deprived of funding.[201]

119. This confusion over whether energy from waste can be classified as "renewable" seems to extend into the different schemes of taxation, funding and targets. At present, energy from waste incineration is being counted towards the Government's target of generating 10% of electricity from renewable sources by 2010 and the DTI estimate that it will fulfil around one-quarter of the target.[202] Indeed, we strongly suspect that the discrepancy in attitude towards incineration between DETR and the DTI which we have noted elsewhere is the result of DTI's need for incineration if it is to achieve its target on renewable energy.

120. Energy from waste will be exempt from the Climate Change Levy when it is introduced in April of this year on the basis of its classification as 'renewable'. Incineration has also qualified for subsidy under the Non-Fossil Fuel Obligation, receiving some £420 million under this scheme.[203] However, it is now proposed that it is excluded from the successor scheme, the Renewable Energy Obligation, on the grounds that:

     "... inclusion within the Renewables Obligation would have high dead weight costs for any new projects it would bring forward, but that inclusion within the climate change levy definition could produce a small but worthwhile stimulation effect..."[204]

On the other hand, the Energy from Waste Association told us that it was "absolutely vital" that energy from waste qualified for the Renewable Energy Obligation. However, David Tuthill from the Essex Waste Disposal Authority commented that:

    "Because of the number of subsidies which have in the past brought down the gate fees of incinerators the industry has the view now that the level at which they have to bid is now so low that it is a commercial enterprises and the number of subsidies could disappear without affecting the market."[205]

121. There is a real question about establishing the right balance of encouragement for energy from waste so that it does form a limited component part of the waste strategy. But we do not accept that energy from waste incineration is a renewable form of energy. Even if one considers that it meets the technical definition of renewable energy, it utterly fails to meet what might be called a 'common-sense' interpretation. A waste stream is only 'sustainable' in the most twisted definition of the word since sustainable waste management has as its cornerstone the minimisation of waste, and the explicit maintenance of waste streams for the purposes of incineration is in complete contradiction of this principle. By classifying energy from waste as renewable energy, a signal is sent to the public and business that it is acceptable to continue producing waste because 'renewable energy' is generated from it. We therefore recommend that:

  • energy from waste incineration be excluded from counting towards the target for 10% of electricity to be generated from renewable sources;

  • the Government's exclusion of energy from waste incineration from the Renewable Energy Obligation proposals be maintained;

  • the exemption of energy from waste incineration from the Climate Change Levy be withdrawn.

122. Despite some changes to the various measures, we are very concerned that incineration may be being favoured by the structure and nature of fiscal instruments. There must be no subsidy to the growth of incineration. If fiscal instruments favour the development of incineration, then the result in 20 years time could be a large and overbearing incineration industry which effectively crowds out the more attractive options of minimisation, re-use, recycling and composting.

146   Ev p160 (HC 36-II) Back

147   A Way with Waste: A Draft Waste Strategy for England and Wales, July 1999, Paragraph 3.19 Back

148   Ev p23, p128 (HC 903-II) Back

149   Ev p149 (HC 903-II) Back

150   Ev p92 (HC 903-II). Around 25% is made up by the bottom ash, with the remaining 5% from fly ash. Back

151   Ev p153 (HC 903-II) Back

152   Reference to answer to Parliamentary Question on 14 November 2000 [136098-136100]: "It [the Entec study] concluded that the proposed NOx limit would prevent 46 deaths being brought forward and prevent or delay 91 respiratory hospital admissions as a result of the formation of ozone. Entec UK have very recently recognised a mathematical error ... The correct figures for health effects of NOx are in fact significantly lower - 0.7 deaths not brought forward and 0.9 respiratory hospital admissions not brought forward as a result of the formation of ozone." Back

153   Letter from Environment Agency to The Guardian, 5 December 2000, (DSW 94(a) (Ev not published)) Back

154   This point was put forward by the Capel Action Group (Q149) and accepted by the Environment Agency (Q896) Back

155   Draft Exposure and Human Health Reassessment of 2,3,7,8-Tetrachlorodibenzo-p-Dioxin (TCDD) and Related Compounds, US Environmental Protection Agency Website ( Back

156   Q914 Back

157   Q906 Back

158   Q106 Back

159   Memorandum from Communities Against Toxics (Ev not printed) Back

160   QQ892-906 Back

161   Q147 Back

162   Ev p15, p43, p150 (HC 903-II) and Ev p201 (HC 36-II) Back

163   Ev p31 (HC 903-II) Back

164   Ev p15 (HC 903-II) Back

165   Ev p15 (HC 903-II) Back

166   See, for example, Ev p1, p49, p52, p106 (HC 903-II) and Ev p226 (HC 36-II) Back

167   Ev p102 (HC 903-II) Back

168   Q388 Back

169   Q61 Back

170   Q11 Back

171   Q33 Back

172   Ev p91 (HC 903-II) Back

173   Q92 Back

174   Ev p91 (HC 903-II) Back

175   Ev p73 (HC 903-II) Back

176   Ev p65 (HC 903-II) Back

177   Q66 Back

178   Ev p160 (HC 36-II) Back

179   Ev p102 (HC 903-II) Back

180   Ev p55 (HC 903-II) Back

181   Q428 Back

182   Q168 Back

183   Q96 Back

184   Memorandum from Communities Against Toxics (Ev not published)  Back

185   Ev p151 (HC 903-II) Back

186   Q522 Back

187   Q535 Back

188   Ev p15 (HC 903-II) Back

189   Q15 Back

190   Ev p149 (HC 903-II) Back

191   Q64 Back

192   Q15 Back

193   Q64 Back

194   Ev p211 (HC 36-II) Back

195   Q981 Back

196   Ev p36 (HC 903-II) Back

197   Ev p36, p206 (HC 903-II) Back

198   Q367 Back

199   Q966 Back

200   Q1185 Back

201   Ev p37, p164 (HC 903-II) Back

202   Q1029; Ev p207 (HC 36-II) Back

203   Q372 Back

204   Ev p212 (HC 36-II) Back

205   Q536 Back

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