POTENTIAL & UNINTENDED CONSEQUENCES OF S21 LISTED ACTIVITIES & ASSOCIATED EMISSION LIMITS FOR PET CR...
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POTENTIAL & UNINTENDED CONSEQUENCES OF S21 LISTED ACTIVITIES & ASSOCIATED EMISSION LIMITS FOR PET CREMATION IN SA. WHO WE ARE. REPRESENTING ENVIROCIN PET CREMATORIUM > EST. 1996 > 35 JOBS REPRESENTING SA ASSOC. OF COMPANION ANIMAL CREMATORIES

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WHO WE ARE

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Who we are

POTENTIAL & UNINTENDED CONSEQUENCES OF S21 LISTED ACTIVITIES & ASSOCIATED EMISSION LIMITS FOR PET CREMATION IN SA


Who we are

WHO WE ARE

  • REPRESENTING ENVIROCIN PET CREMATORIUM > EST. 1996 > 35 JOBS

  • REPRESENTING SA ASSOC. OF COMPANION ANIMAL CREMATORIES

  • CREMATE ONLY ANIMAL BODIES > PREVIOUSLY LANDFILLED > HAZARDOUS!

  • 1 IN 3 PETS CREMATED ARE WELFARE PETS FROM SPCA’s etc.


Historical snapshot

HISTORICAL SNAPSHOT

  • ORIGINALLY INCLUDED IN CATEGORY 8: DISPOSAL OF HAZARDOUS & GENERAL WASTE 31 MARCH 2010

  • COMMENTED 20 AUGUST 2009

  • MEETING WITH MAZWI LUSHABA 2010

  • COMMENTED 30 JULY 2010

  • COMMENTED 30 JANUARY 2012

  • S21 AMENDMENT 27 FEBRUARY 2012

  • S21 AMENDMENT 23 NOVEMBER 2012

  • COMMENTED 23 DECEMBER 2012


Main concerns requests

MAIN CONCERNS & REQUESTS

  • SEPARATION FROM CATEGORY 8: HAZ/GEN

  • CREATION OF CATEGORY FOR COMPANION ANIMAL CREMATORIA

  • CAPACITY THRESHOLD OF 10 TONNES PER DAY HOMOGENOUS ANIMAL MATTER (Directive 2000/76/EC of European Parliament)

  • REVIEW OF BI-ANNUAL TESTING REQ. > CONC VS VOLUME

  • SEEK CLARITY ON “VETERINARY WASTE”

  • THOUGHTFUL REVIEW OF EMISSIONS LIMITS

  • 3% O2 vs 10%?


Research data

RESEARCH & DATA

  • DETRIMENTAL EFFECT ON ENVIRONMENT?

  • WSP ENVIRONMENTAL & WNWN TECHNOLOGIES INDEPENDENT STUDIES

  • COST OF WET & DRY SCRUBBERS PROHIBITIVE

  • INTERNATIONAL > LESS RESTRICTIVE (WNWN)

  • 850°C & 1100°C PRIMARY & SECONDARY (US)

  • EPA INFO > “EMISSIONS FROM PC’S VERY LOW WHEN COMPARED WITH OTHER SOLID WASTE COMBUSTION UNITS”

  • EPA > “ADVERSE IMPACTS ASSOCIATED WITH REGULATION OF PC’s OUTWEIGHS BENEFITS OF REGULATION THEREFORE NOT INCLUDED IN OSWI”

  • WSP > DISPERSION MODELLING > “DO NOT POSE A CONCERN TO HUMAN HEALTH”


Emissions limits

EMISSIONS LIMITS


Unintended consequences

UNINTENDED CONSEQUENCES

  • PETS TO LANDFILL > ZINGISA SMALE

  • WELFARE ANIMALS TO LANDFILL

  • HUMAN RIGHTS/ENVIRONMENTAL ISSUE

  • NON-COMPLIANCE & ASSOCIATED PENALTIES

  • JOB LOSSES & UNEMPLOYMENT

  • PET OWNER UPROAR

  • HORSES

  • INHIBITING GROWTH & EXPANSION


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