Distinguished Minister of the Environment, Andrea Orlando,
President of the Campania Region, Stefano Caldoro,
Regional Councilor for the Environment, Giovanni Romano,
Commissioner for Land Reclamation of the Campania Region, Mario De Biase,
Prefectural Commissioner of Giugliano, Giuseppe Guetta,
Honorable deputies Salvatore Micillo and Giovanna Palma.
The recent news relating to the ban on the Giugliano incinerator leaves me astounded by the further indifference with which national and regional policies pay attention to the territory north of Naples.
I write to the SS.LL. as a citizen of Giugliano informed on the facts, as I held the position of Councilor for Land Reclamation for about three years in full waste emergency (years 2006-2008) and I am a researcher in the field of optimization of water resources and remediation of contaminated aquifers working, among other things, specifically also on the solution to the problem of pollution of the Giugliano site which, briefly, I will call Masseria del Pozzo-Schiavi which includes numerous waste landfills.
I therefore write without demagoguery, knowing well the difficulties of governing and administering difficult situations such as those of the waste emergency and complex realities that intertwine many bearers of divergent interests which, in the case of waste, can pit public and private interests against each other. But, at the same time, I also write with the profound conviction that, in the case in question, there are other technical and political solutions to the choice of the location of the "Giugliano" incinerator and the "disposal" criteria of the Taverna del Re bales.
I was the first to ask, together with my Administration, for preliminary investigations for the Masseria del Pozzo-Schiavi site, to alert the Ministry of the Environment and ARPAC and, using all my determination, to ask for a characterization plan that covered a large area of the territory, larger than just the Novambiente and Masseria del Pozzo-Schiavi landfill, which included all the landfill sites (illegal and otherwise) and to consequently start the reclamation process. I keep those numerous emails and documents exchanged with the Ministry of the Environment and ARPAC in which a series of commitments and a binding timetable were defined in 2008 and never respected. It took over 5 years just to get the results of the Characterization Plan! Because the history of the waste emergency in Campania also passes through, but I would say above all, the broken promises, the unfulfilled commitments, the disregarded laws in all these long 20 years which have seen my city first bought, then injured and now struck to death with the choice of the incinerator. There are several reasons, which my fellow citizens like to call, perhaps rightly, principles (like the precautionary one enshrined in European legislation) according to which the territory of Giugliano cannot and must not host a waste incineration plant, which I will try to summarize:
1) Saturation principle
During my administrative experience, to try to initiate an environmental policy, among other things, we created the Environment Office and entrusted the Interdepartmental Center for Research in Environmental Engineering (CIRIAM) of the Second University of Naples with a study of the environmental critical issues of the territory which then led to numerous publications also in prestigious international journals, from which it can be seen that:
- the contaminated site of Masseria del Pozzo-Schiavi occupies an area of approximately 2 square km to which must be added the approximately 1.3 square km of Taverna del Re (overall an area of 3.3 km, corresponding to a small city. To give a territorially close example: Melito di Napoli is 3.72 square km);
- until 2007 alone, in the municipality of Giugliano in Campania, approximately 8 million tons of waste were disposed of, legally and illegally, which - added to the approximately 4 million tons of waste packaged in bales at Taverna del Re and other sites - correspond to over 12 million tons of waste present in the area in various ways. This figure, when compared with an estimated production of approximately 1 million tonnes of waste produced by the citizens of Giugliano, in the same period of time, highlights the serious environmental toll paid by the territory and its population to the waste emergency in the Campania region;
- the environmental damage of this situation, apart from the exaggerations which are also the result of desperation, are evident and have been measured since 2006 by several parties (ARPAC, CIRIAM, Public Prosecutor's Office, etc.), and confirmed by the recent characterization plan of Geoproject srl.
But we must not forget that, in addition to the waste classified as dangerous and non-hazardous, the territory has suffered numerous other wounds, the Cuma purifier which has contaminated the sea, Lake Patria which has been polluted for years also thanks to the canals that spill into it, not to mention the waste burning fires which have gripped us daily for almost twenty years in the complete indifference of the institutions despite the numerous complaints made.
As in other areas of Italy (the closest is Colleferro with the recent construction of the first incinerator in Lazio), the idea of adding sources of contamination in already heavily polluted territories shows all the perverse and violent logic (let me tell you) of some public administrations which, evidently, consider it easier to add pollution to pollution perhaps in the double stubborn belief that the populations are already accustomed to the contamination of their lands and that the territory is already irremediably compromised. It is a cynical and unethical perspective that deliberately and consciously decides to sink what it should instead be trying to save. This double belief, in addition to realizing a lucid plan for the final extermination of the territory, violates a fundamental principle of natural systems, namely not to exceed the saturation point because by doing so the system is no longer able to dissolve, in our case absorb the pollutant and transform it. In other words, pollution after pollution leads to saturation and, therefore, to annul and prevent the natural remediation effects of an environmental system.
This definitively destructive and nihilistic approach, in some cases, then also became concretely violent as happened, using the expression of a dear friend of mine - a researcher in the sociology of cultural and communicative processes - in one of the landfill sites where men, women and children from the largest Roma camp in Campania were left for years, "considering the Roma as human waste"!
2) Principle of dignity
Giugliano suffered first the unauthorized landfills, then the authorized ones for dangerous waste, then the authorized ones for Municipal Solid Waste (MSW), then the plant to produce Fuels Derived from Waste (CDR), then the bales (and not ecobales because never "eco") of Taverna del Re. All in defiance of agreements signed with Land Reclamation Commissioners, Regional Presidents not to even mention State Laws which prevented the opening of new waste storage or disposal sites. We have hosted no "integrated waste cycle" for all these years! But only a continuous emergency, parts of the cycle that were carried out without logic (first one part was built then the other), which did not work according to the regulations and, above all, without any real support action to achieve percentages of separate collection compatible with modern waste CYCLE management. Therefore, hosting the incinerator after more than twenty years would truly be an insult to the dignity of each of us as citizens, with a territory already contaminated and far from reclamation, with waste scattered everywhere, in every corner of the territory (we are assailed by a sense of shame when friends from other regions come to visit us!).
It would be yet another slap in the face, yet another violation of agreements and laws, in short, in addition to the damage there would also be insult! After more than twenty years, when the reclamation should have brought us back to normality, giving us back our fertile lands, our clean air which even the great general Scipio Africanus chose as a place of voluntary exile, we would find ourselves with another critical situation (that of the incinerator) for a further 20-30 years and with at least another ash landfill (equal to approximately 1/3 of the waste burned), not to mention columns of trucks every day that they would cross our streets. The incinerator strikes at the heart of our population, our dignity: rather than an integrated waste cycle, it would be better to define it as a dis-integrated waste cycle!
3) Principle of economic devaluation
The construction of the incinerator, in an area already heavily compromised by social, environmental and crime problems, would represent a further reason for discouraging the demand for housing (already significantly declining in this period of economic stagnation) and for agricultural activities which should represent one of the main development opportunities in the area.
Furthermore, Giugliano and the other neighboring cities have never benefited from any positive economic impact in recent years, as has happened in other polluted areas of Italy, such as the aforementioned Colleferro, in which the industries and plants established have brought considerable employment.
The incinerator, the CDR, the landfills and so on occupied a few dozen personnel for a limited time.
But, the truly incredible thing is that the Taverna del Re area is just under 6 km from the fruit and vegetable market which represents one of the greatest riches of Giugliano, famous in Italy for many fruit specialties, and an excellence in the Campania region. These are evidently industrial, productive and commercial activities that are structurally incompatible with each other!
4) Precautionary principle
One of the main arguments used to convince that choosing a waste-to-energy plant is not dangerous is that there are others in the center of Vienna, Prague, etc. I must say that I find them rather demagogic and childish also because the dimensions spoken of for the Giugliano incinerator would be much larger than those of the cases cited and for the fact that these plants dispose of waste produced by their own inhabitants and not by those of many other cities or provinces as would happen for Giugliano (even if it were only the bales of Taverna del Re!).
The approach to the risk to human health from incinerators is essentially based on the concentrations of emissions into the atmosphere which must be lower than those required by international regulations (although the definition of the minimum thresholds is much debated!). But this is not the only approach: apart from the concentration (expressed in milligrams per cubic meter) what other authors suggest analyzing is the effect of the volume, i.e. the total quantity breathed by a man during the useful life of an incineration plant (but how can we already know the long-term effects?). Imagine that the quantity of fumes produced by a medium-sized incinerator, capable of treating 1000 t/d of MSW, is equal to approximately 20 million cubic meters of fumes per day, corresponding, for example, to the entire surface area of the historic center of the city of Giugliano multiplied by the height of a three-storey building: these would be the fumes that we could potentially absorb mixed with the air we normally breathe.
But there are other equally serious reasons for potential risk: a) in the technical-scientific literature there is no information on periods of malfunctioning of the systems, during which concentrations enormously higher than those permitted could be released into the atmosphere in a few hours; b) the recent events of the Colleferro plant "used" by the Camorra to dispose of dangerous substances, according to various judicial investigations, present terrifying scenarios for Giugliano.
This is why the precautionary principle becomes twofold: on the one hand, not to further contribute to saturating a territory and a population that has already been exposed to pollution of the three environmental matrices (water, air and soil) for over twenty years - which various epidemiological studies have recognized as being at risk of the onset of serious pathologies - but, above all, to avoid building the plant in a territory known to all, unfortunately, due to the presence of criminal organizations that have used the waste for years for their criminal economic interests.
Finally, I would like to point out that, despite the provincialization of the location of waste disposal plants, the Region chooses three sites that roughly form an equilateral triangle with a side of 22 km, in one of the most densely inhabited (and conurbed) areas of Italy (compared to hundreds of kilometers available in the regional territory): Acerra, Capua and Giugliano. Thus the problem also becomes of Aversa (another densely populated city) and of all the neighboring municipalities (Melito, Sant'Antimo, Marcianise, Carinaro, San Marcellino, Teverola, Grumo Nevano, Parete, etc.) which, given the direction of the prevailing winds in the area under examination, would be permanently downwind of at least one of the three plants.
It would therefore truly be institutional madness to choose an incinerator in Giugliano!
Naturally, the problem of Taverna del Re, as well as the reclamation (which some irresponsible people recently defined as "impossible" even in widely circulated newspapers) of the Masseria del Pozzo-Shiavi site must be addressed seriously. There are several alternative hypotheses to the incinerator both from the technical-scientific literature and from citizens' committees. Responsible hypotheses, feasible hypotheses. After more than twenty years of institutional failure, why not leave the citizens of Giugliano six months to prepare their concrete proposal?
We therefore ask the SS. LL. to stop the tender for the incinerator, we ask at least for a real moratorium to start a technical table with the representatives of the committees, with the Mayors, with all those who in recent years have been powerless because they have chosen the path of dialogue and civil protest but have been fooled with promises and laws that have never been applied.
The recent demonstration in Giugliano with around 10,000 participants from many cities in the area showed that this time the situation is different, the tiredness has passed and pride is being rebuilt, the populations do not want to suffer a further slap, they do not want, using a metaphor, to be "incinerated". We ask you to consider our reasons, our "principles" for which we will express our dissent in all possible ways to the choice of the incinerator, to include them in a Socio-Economic-Environmental Impact Assessment which we think is necessary before choosing any waste treatment plant in Campania.
Don't make yet another socio-environmental mistake, you still have time; as has already happened with the Cuma purifier, to give just one example close to us, whose malfunction for about 25 years has polluted the sea, destroying the economy of a coastline of about 80 km (from Pozzuoli to Garigliano), compromising the local economy and moving part of the regional GDP to lower Lazio, now invaded during the summer by tens of thousands of citizens from Campania.
Together with the waste problem, also think about the socio-economic development of a region: in this perspective we also ask the inhabitants, the technicians, the representatives of the institutions of the city of Naples to give us this opportunity and to listen to our reasons. We are certain to find a solution for Taverna del Re that satisfies everyone. If the problem isn't Taverna del Re's lies, if the reasons for the rush are others, then tell us: this is the moment for clarity, for motivated choices and for responsibility. Then each of us will act and choose our own future in full conscience.
(from letter on "Internapoli", Giugliano, 4 October 2013)