14 July 2012
Young FoE National Coordinating Group
July 2012
After reading an article about the new Director-General of the EPA, Ms. Laura Burke, Young FoE decided to write her a letter.
Following the 'Polluter Pays' Principle, rather than the People Pay
Dear Ms. Burke,
We are writing in relation to the interview that you gave to The Irish Times which was published on April 17, 2012. We are concerned with your stance on repositioning the “agency to support economic growth and move away from the perception that it was purely an environmental watchdog or policeman”. We find this worrying as the EPA is the only agency in Ireland that stands in the way of environmental degradation and whose focus is to protect, monitor and enforce environmental legislation from the very companies who would disregard it.
We feel that there should be a definitive line between the economy and the protection of the environment. Without this line, EPAs throughout the world have been found to be corruptible. It is our fear that this line could become blurred if the EPA pursues this path as corruption could easily seep into the Irish EPA as it has in other countries. We are sure you will concur that Ireland has had enough corruption.
The role of the EPA is not merely to present the physical environment to businesses as something which affects their profitability and as a source of possible economic savings. It is more than a resource and has many substantial added benefits such as the quality of life of an individual. Most of these benefits, although sometimes quantifiable in economic terms, are not and will never be reducible to economic values. The EPA was established to protect the environment for these reasons and should not prioritise economic issues. Protecting the environment should always take precedence, especially from a body such as the EPA.
Also, as you identified businesses can be motivated to adopt 'resource efficient' practices in order to 'save money' and increase profits. This is usually the dominant motivation for businesses rather than for the protection of the environment. In this instance, we would agree with the review of John McCarthy who contends that prosecutions with substantial fines have the best 'deterrent effect'. For this to be a true deterrent and for business to be compliant, it is vital that the EPA take the strong and determined stance that environmentally destructive practices will receive zero tolerance and the EPA will “pursue the prosecution route to optimum effect”. The EPA is supposed to run with the 'Polluter Pays' Principle.
We understand that you wish to promote the EPA to big business and reduce its monster image, but it is a necessary image and a deterrent. It is the large businesses that are often the greatest polluters. A fine example of its role in enforcement is the EPA's work in pursuing the legal sanctions for Neiphin Trading and other companies involved in the mismanagement of the Kerdiffstown Landfill. The EPA's independence of industrial influences is a key factor in allowing it to act decisively when faced with great environmental injustices.
The EPA is an important agency and it is the environment's first line of defence. We hope that you will consider this a letter of concern and not one of aggression. Young Friends of the Earth are dedicated to the environment and anyone involved in its protection. It is young people who will suffer the most from future environmental impacts of actions taken by businesses and governments today. Part of the problem with environmental protection is that these younger generations have so little influence in political and economic decisions. Perhaps if they did we wouldn't see such disregard of the environment for the sake of increasing economic wealth.
Young Friends of the Earth would very much appreciate the opportunity to meet with you to discuss this further. Our contact details are above. We look forward to hearing from you.
Respectfully, Young Friends of the Earth
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