Transcript of Mr. Poul Neilsen's response to 22 December letter from the Coalition

January 1999

Livaningo
Mr. Antonio J.L.M. Reina
c/o KULIMA
Av.Karl Marx. 1452
Maputo
Mozambique

To Livaningo:

Thank you for your letter dated 22 December 1998. I am pleased to learn that Mozambican representatives have taken charge of the so-called NGO coalition. This seems highly appropriate as we are dealing with a Mozambican issue. It has often seemed to me that the problems of Mozambique were overshadowed by an international and wider agenda, and sometimes even that the NGO coalition had taken the solution to the problem of the obsolete pesticides in Mozambique hos-tage in the coalition's pursuance of other objectives.

In the same vein, I would like to remind you that in this matter Danida assists the Mozambican authorities to fulfil their objectives. Thus as a starting point, questions concerning the project should be sent to the Mozambican authorities. This applies to most of the questions in your letter as they concern the national authorities directly. I have therefore agreed with the Mozambican authorities, that they answer you directly. Nevertheless, a few issues need to be addressed here.

One is your allegation that Danida has misled the Danish public and Parliament in its eagerness to pursue some hidden agenda. The "hidden agenda" you continuously refer to is beyond me. As far as the establishment of the waste station and a small incineration capacity, Danida has several times - in newspaper articles, in answers to various parliamentary committees as well as in replies to your coalition - emphasised that a medium-term objective would be to provide Mozambique with some means to build a permanent capacity to handle hazardous waste. This objective has never been concealed by Danida.

Also, I can assure you that the project objectives and the budgets have been presented to all interested parties. You will surely recall that the two key bodies for guiding and overseeing activities, funded under the Environmental and Disaster Relief Facility (EDRF), i.e. The Board for International Development Cooperation and the joint Danida-Danced Advisory Committee on the EDRF have both visited and inspected the project in Mozambique, and representatives of these met with Livaningo. They have expressed no reservations as to the immediate and long term objectives nor to the manner in which the project is implemented. Rather to the contrary, a general satisfaction has been expressed that one of the biggest threats to environmental health in Mozambique, is being removed while leaving Mozambique with some means to tackle the medium term problems concerning hazardous waste. I should finally add that we have had a very close contact with the Danish Ministry of Energy and Environment all along, so your claim that one hand does not really know what the other one is doing does not hold.

In short your allegation that I am misleading the Danish public and Parliament is absurd. Especially so because there are several attempts by members of the coalition to misinform the public, including:

-- denials that a public meeting was held in Matola during the preparation of the project, which the coalition has now had to admit has taken place,

-- that a specific report from Danced had not been used in the EIA, while it is clearly listed in the reference list of the report, and

-- presenting pictures to the Press of alleged workers at the cement factory, while I understand, it has now been disclosed that the persons on the pictures were indeed not employed by the factory.

All these are examples of deliberate misinformation of the public. A second issue relates to the reduction of waste in the future. I can only repeat my agreement to the urgent need to promote cleaner production methods. In fact, this is an important part of the project for a national hazardous waste management system, which is presently being planned between Mozambique and Danida. Another key element of that project will be to increase the capacity of the Mozambican authorities to deal with existing hazardous waste, and to future waste. Production of waste in future seems unavoidable, albeit at a reduced level. Danida does try to address this in a coherent manner. We are dealing with a complex set of difficult issues, which may explain why such intentions are easy prey to harsh criticism from those who do not wish to tackle also the difficult issues. We hope to finalise the planning of the above mentioned project this year.

Let me also give you an update on the project budget. In September 1998, the Finance Committee of Parliament approved additional funds, increasing the total budget to 56,9 million DKK. This was necessary as the obsolete pesticides to be collected and disposed of have increased from 540 to approximately 900 tons. Furthermore, this implies that the budget line for the disposal cost has risen from 3,3 million DKK. to 5,9 million DKK. (incl. incineration hardware, supervision and environmental auditing). Regarding the waste station, the total cost of building and running the station amounts to approximately 8,1 million DKK. You might want to reconsider your arguments in the light of this information, even if it was published already 4 months ago.

You ask me to "give the public a true cost estimate for the export option for destruction of the obsolete pesticides (without the unnecessary cost of waste station and incineration construction/retrofitting)". First of all, I have to ask, how you would organise export without the waste station. Secondly, I am not convinced that preparing a detailed cost estimate would make any difference. Your own conclusion seems to be given in advance since your point of departure seems to be that incineration is simply not an option, as "it is not acceptable that destruction technolo-gies will be chosen that will produce more POPs .... while attempting to eliminate others". You will know already that I disagree with this.

Never mind for the sake of the argument, let us consider the two options that your refusal to incinerate leaves us with:

The first is your suggestion to store the pesticides in Denmark, awaiting the development of alternative disposal methods. While this might be a relatively cheap solution, you will realise it would not be line with Danish regulations and practice. In Denmark as well as in most of die EU hazardous waste is simply incinerated in accordance with the commonly agreed rules and standards.

Your second alternative is to export the 900 tons to Denmark and dispose of them by applying ECOlogic's method. The costs of this can be estimated on the basis of the report concerning new methods of disposal sent to me by Greenpeace. The disposal costs alone would appear to amount to somewhere between 13 and 21 million DKK. (This excludes the costs related to building the ECOLogic disposal facility). This is surely a lot more expensive than incinerating the pesticides in Mozambique.

You should note that the above does not deal with the cost of transport which I think you underestimate. Your suggestion of "simply packing the waste and placing it on container ships for export to a country like Denmark" is an oversimplification of the matter and would be environmentally irresponsible. The obsolete pesticides need to be sorted and identified, repacked and secured before being stored on a containership, which by the way for safety reasons can only be done in special containers. This is one reason why the waste station is so important and necessary in any event, be it incineration in Mozambique or export to Europe.

I am somewhat puzzled as to your opposition to building a waste station that shall enable the authorities to analyse and store hazardous waste. Why are you against Mozambique possessing a capacity to analyse its own hazardous waste?

In conclusion on this, I fail to see the logic in arguing that the costs related to a waste station and disposal are unnecessary as they are in fact unavoidable.

The bottom line is that during our debate over the last eight months we have gone through the same arguments again and again. No new, solidly documented (in terms of environmental, technical and financial aspects) and internationally accepted disposal methods have been introduced. The alternatives presented e.g. in the report from Greenpeace are interesting, and I note that FAO call them "promising new developments". However, "promising developments" are not good enough when it comes to dealing with the problems of Mozambique today. What is needed is |a well established and tested way of disposal that allows effective and swift handling of the problem at hand, and that poses no risk to the people in Mozambique. As I have said before, Danida can and will not use a technology which has not been approved by the relevant authorities of this country, and which does not have a proven record of performance. Incineration is the only reasonable solution which has been presented so far.

To refuse Danida to assist Mozambique in getting rid of a major risk in a way which lives up to the standard for incineration in the EU while at the same time trying to avoid such problems in future by co-operating on the introduction of cleaner technologies certainly is a clear example of the best becoming the enemy of the good. This is still a reasonable way of characterising the high pitched opposition you continue to mount against the project.

Yours sincerely,