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Minister Michael Woods T.D., Minister for the Marine & Natural Resources, Department of the Marine & Natural Resources, Leeson Lane, Dublin 2. 17th July 1998
RE: Ministerial Meeting of the OSPAR Commission 1998 Dear Minister, I am writing with regard to the 1998 Ministerial Meeting of the OSPAR Commission. Radioactive Substances On behalf of VOICE I would like to express serious disappointment with the Irish Draft OSPAR Recommendation 98 on Radioactive Discharges from Nuclear Fuel Reprocessing Plants. Whilst it is vital that technetium-99 discharges are eliminated from the Irish Sea, the elimination of all radioactive discharges must be the overall goal. By simply calling for an immediate reduction of the current discharges of technetium-99, the Irish recommendation to OSPAR is totally inadequate and represents a serious weakening of Ireland's traditional position in opposing radioactive discharges from nuclear reprocessing plants. VOICE calls on you to ensure that every effort is made to strengthen the Draft Sintra Statement so that the continuation of nuclear reprocessing plants such as Sellafield is no longer viable. In particular VOICE calls on you to support the Norwegian and Danish suggestion (15B): Alternative 2: WE REINFORCE the objective to prevent pollution of the maritime area by continuing to reduce anthropogenic discharges, emissions and losses of radioactive substances, including wastes, with the ultimate objective of achieving concentrations in the marine environment which are near background values for naturally-occurring radioactive substances and close to zero for man-made radioactive substances. VOICE further calls on you to do everything possible to ensure that the following sentence is added to the above paragraph: "We shall make every endeavour to move towards such concentrations by 2020" Hazardous Substances I refer to the Draft OSPAR Strategy with regard to Hazardous Substances, resulting from the Meeting of Heads of Delegation in London : 9-10 June 1998. VOICE is very disappointed that Ireland has expressed reservation at committing "to prevent and/or reduce and/or eliminate" the emissions, discharges and losses of hazardous substances which reach, or could reach, the marine environment (Section 3.1). VOICE calls on you to ensure that the Commission will develop programmes and measures to ELIMINATE the emissions, discharges and losses of hazardous substances which reach, or could reach, the marine environment. We further call on you to support the proposed timeframe of "...making every endeavour to move towards the target of the cessation of discharges, emissions and losses of hazardous substances by the year 2020" as per Section 4.1. With regard to Hazardous substances in the Draft Sintra Statement, VOICE calls on you to ensure also that the timeframe of 2020 is adopted as the target for endeavouring to cease discharges, emissions and losses of hazardous substances. I trust that Ireland supports the emphasis on the precautionary approach/ principle and that Ireland will not allow this to be undermined by calls for the inclusion of emphasis on the scientific assessment of risk. With regard to Section 12 of the Draft Sintra Statement VOICE calls on you to support the timeframes of 2002 for the control of discharges, emissions and losses of substances on the OSPAR List of Chemicals for Priority Action. Given that Ireland has only recently begun to identify discharges, emissions and losses of a limited number of hazardous substances through the Pollution Emission Register required by the EPA in Integrated Pollution Control licences, VOICE calls on you to support the suggestion that Paragraph 12 should include a bullet point "adopt measures to avoid the release of new hazardous chemicals into the marine environment". Apart from reducing further pollution of the seas, these measures would obviously help reduce the future workload involved in eliminating discharges, emissions and losses of hazardous substances. Eutrophication With regard to the section dealing with Eutrophication in the Draft Sintra Statement VOICE urges you to ensure that emphasis is placed on reducing nutrient inputs into the maritime environment and not simply tackling the elimination of eutrophication where it already occurs. Offshore Oil & Gas VOICE hopes that Ireland will retain its position of supporting a ban on the disposal of disused oil platforms at sea. Involvement of NGOs in OSPAR VOICE welcomes the decision to allow the greater involvement of NGOs in the work of the Commission and trusts that Ireland supports this decision especially in light of the Department of the Environment's commitment to sponsor the involvement of environmental NGOs at other international Fora. I trust that you will give serious consideration to VOICE's suggestions. Yours sincerely,
Iva Pocock, Campaign Co-ordinator.
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