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Summary
Introduction
The Guilty Parties
My Qualifications as a Witness
Health Surveys - lack of
Health Effects
Conclusions
    1.    Reasons for refusing this application—as a cement kiln alone
    2.    Reasons for refusing this application—as an incinerator and cement kiln

    Finally, I object to the tactics of Castle Cement in this Inquiry.

SUMMARY

I believe that the residents, who will undoubtedly be affected by this application, have not had a fair hearing at this
public Inquiry, in breach of Articles 6 and 8 of the Human Rights Act.

It has been left to residents to put forward the information that the proper authorities have failed in their duty to provide. Should
this application be passed, I believe that residents will be fully justified in taking legal action, not just for a Judicial Review, but
for breaches of the Human Rights Act, and also the Disability Discrimination Act
 
 

Those residents on the ridge facing the works—almost in an identical situation to ourselves above the Ribblesdale Works of
Castle Cement, who already come within the scope of the Disability Discrimination Act in respect of  existing asthma, diabetes, or ME, etc,
will, I believe, have a very strong case for claims against the Welsh Assembly for discrimination, since these are the very people
identified as “sensitive receptors”  --those most at risk from immune system damage, and heart and lung failure from the fine
particulates. There is now a wealth of scientific and medical evidence relating to the death and disease caused by high
temperature combustion, and hazardous waste incineration in cement kilns in particular.

The evidence from leading scientists from Canada, Germany, and the USA on ultra-fine particles, in the Royal Society book,
maybe best shows up the total inadequacy of the environmental impact assessment offered by Castle Cement, even as a
cement kiln and the total inadequacy of the current and proposed regulation of such processes by the Government Agencies.
 
 

Fore-warned, is fore-armed.

After the BSE , Organo-phosphate sheep dip, Gulf War syndrome, and the Depleted uranium exposure scandals, etc, who is
not already aware of the cover-ups and culture of UK Government denials?
 
 

Introduction

In the evidence I presented to this Inquiry, I claimed that the Government are intent on using cement kilns as cheap disposal
facilities for industry’s toxic and hazardous wastes, and that they are willing to sacrifice the well being of local residents in
pursuit of this. Any one who has listened to the evidence presented by the so-called “authorities” at this Inquiry must now
suspect that what I said was true, and that if left to these authorities, the same will happen, without doubt, at Padeswood.
 
 

THE GUILTY PARTIES

Castle Cement have further demonstrated that they are not a fit and proper company to be allowed to run a cement works,
let alone a hazardous waste co-incinerator.
 

Flintshire County Council officers, who recommended that this application be turned down in the first place, on the visual
impact alone, were left trying to justify the perverse decision by Councillors to pass it.
 

Dr Roberts, alleged guardian of Public Health, was willing to freely provide information direct to Castle Cement’s
infamous Kathryn Kelly, whilst denying to the public that such data existed. Almost a week elapsed before this was
inadvertently made public, following which he had then to reluctantly provide it to the taxpaying residents.
 

In lieu of the gift to Miss Kelly, he was willing to accept dubious and misleading information and figures, from Castle Cement
and present it to the Inquiry, apparently as his own.
 

The Environment Agency, who residents naively supposed were there to regulate to protect human health and the
environment, have deliberately obstructed the facts, deliberately withholding all necessary references to EC and UK law
regarding incineration of hazardous wastes, which legally is part and parcel of this application. The Environment Agency
barrister, Mr Tucker, himself, admitted this pre-inquiry agreement with the Planning Inspectorate.
 

The Planning Inspectorate, at the highest level of the Welsh Assembly itself, I understand, is party to this conspiracy of
silence regarding hazardous waste and the health implications of this application. This cover-up was decided upon before the
Inquiry began.  The issue of hazardous waste was not covered in any of the presentations by Castle Cement. Mr Vaughan, the
Planning Inquiry Inspector, refused to allow me to cross-examine Mr Moggeridge on  the visual aspects of the kiln in the
context of residents not only seeing it, but seeing it at the same time as tasting the metal emissions on their lips, smelling what
will become the all too familiar odour, and at the same time suffering the wheeziness or asthma attack, and/or eye and throat
irritation caused by the emissions.
 

The Planning Inspector stopped me from asking these questions, even though these are EXACTLY the symptoms suffered
in our own school playgrounds by scientists, and attributed to Castle Cement in the Environment Agency’s own report in 1995.
The National Physical Laboratory scientists went back to London, after tracking Castle Cements plumes for a month, and
suffering eye and throat irritation, and asthma attack in the process. Even worse, the school-playgrounds in which many of
these health effects occurred are again occupied once more by our 5 to 11 year old children.

What is the effect of seeing the new incinerator/kiln at the same time as seeing your own children wheezing and coughing,
knowing that before it started burning toxic waste, no children carried inhalers to school, but just 5 years later, 8 out of 48
needed inhalers on hand for their asthma every school day. Just what is the visual effect of the kiln when two of the 8 with
asthma are your own children? When the plumes are not coming our way, or blowing on to our school, what is the effect
knowing that it is affecting other children, but nothing you do stops it? These are the questions I wanted to ask Mr
Moggeridge-questions about the effects of seeing the kiln as a constant, daily, symbol of the torture your family suffer daily.
What has happened to us will happen to those on the hillside opposite the Padeswood works, if the new kiln is built.
 
 

MY QUALIFICATIONS AS A WITNESS IN THIS INQUIRY

Vernon Pugh, Castle Cement’s barrister derided me as a witness because he said I had no “professional” qualifications.

The site identified by Ian Walpole, Castle Cement’s “expert” as being subject to levels of pollution over 4 times the UK health
limit, but dismissed as being of no significance, “ because it is on the top of the hill in the middle of nowhere” is where we live.
We are the experts, Mr Pugh. We have the expertise that matters. We are the victims of this hideous crime. We have
watched as our children have both developed asthma, and chemical responses, as I was diagnosed as “asthmatic”, as my
husband became “bronchitic”.
 
 

Health Surveys—lack of

Please, Mr Vaughan, Planning Inspector, ask the Environment Agency for copies of ALL of our written complaints, many
detailing the health effects, from our exposure to Castle Cement’s fumes. Ask yourself how could anyone be thought to be
making them up, given where we live? I am not ashamed of any of them—each and every one is genuine, and described in
detail exactly as it happened. How can the Environment Agency claim NONE of these health complaints have been justified???

Then ask the Public Health doctors how they can claim that there is no evidence of ill health---why have they, nor Ribble
Valley Borough Council been out here with air monitors to prove it one way or the other? Ribble Valley Borough Council
have put in writing that they have never  monitored the air at our farm, despite repeated claims of statutory nuisance. Why have
no real health surveys been done?—the Environment Agency lies when they say real health surveys have been carried out.
 

HEALTH EFFECTS.

These are predictable for residents around Padeswood.

I have spent 7 years seeing my son’s face swell up as his glands under his chin and neck react to the unidentified pollutants
carried on to our isolated hill top farm, on a south wind, from the chimney tops of Castle Cement 200 feet below, three miles
away as the fumes drift, but eight miles away by the nearest road.

Our nearest pollution source is an Aga cooker, half a mile away, in our nearest neighbours house. The nearest traffic is on a
quiet country lane, three quarters of a mile away at the end of our track. None of our family has ever smoked, neither have we
any family history of asthma. We have no open fires in our house, nor any gas.Our daughter’s asthma started on the day I
watched helplessly from our hilltop, as the emissions from the cement works, spread out unceasingly, filtering through the trees and towards her primary school. She has had a hollow cough ever since. I described to the Environment Agency how the
plume was totally uncharacteristic. It normally clags together in a “rope” across the landscape, but this was totally different, it
spread out, all the time near the ground. The Agency, as always, were unwilling to divulge the reasons for the change, nor say
what was being burnt.

I watched as both of them suffered head aches when sent on a crosscountry run when particulates were 3 times above the
health limit, when at the Grammar School. After another run, he was diagnosed with suspected glandular fever. I have spoken
to the parents of my son’s classmate, who went on the same cross country run, following which he developed ME and has not
been fit to return to school since, nor is likely to do so again. I am a parent who has kept our children away from the Grammar
School since the Environment Agency left pupils to breathe in the blue fumes from Castle Cement for 2 full school days without
any prohibition Notice, on March 4th and 5th 1999. The Environment Agency, 16 months later “successfully” prosecuted
Castle Cement for persistent odour, which both sides blamed on SO2, the health limit for which is 15 minutes at a tenth of the
concentration at which it first smells. Both claimed there were no health risks!

Those are my qualifications, and why what I say should mean that residents in N Wales are not subject to the same predictable
health damage. Nor the same predictable insults from those charged with the protection of human health and environment.
 
 

CONCLUSIONS

1.Reasons for refusing this application—as a cement kiln alone
 
 

    No valid environmental Impact Assessment was done

    All of the computer modelling is invalid

                It is based on an efflux velocity of 12.5 m/sec, when the minimum is 15 m/sec. With residents
               along the ridge fully exposed to the fumes, more than the minimum will be required. Castle
               Cement has failed to justify why less than the minimum velocity was used for their entire
               assessments.

         For this one reason, alone, the application must be refused by the Planning Inspector, at this stage. It is
         perverse for the Environment Agency to suggest that they should be the ones to determine this aspect
 
 

    No assessment of impact of malfunctions

                ...............Of mass emission during failed bags

                ……….. Of ring falls

    All deposition levels are invalid, as weather data from a totally unrepresentative source—Speke airport --- was used for the
    calculations. Speke is flat, sits on an estuary. It has coastal meteorology. Padeswood is inland, in a truncated valley with a
    ridge above, and villages below the site level. The land is uneven, with a micro-climate of its own, with areas of stagnant air
    at ground level.

    None of the following have been taken into account, nor the results investigated

                 i.     Particle size, and shape, after the fabric filters

                 ii.     Aerodynamics of the particles
 
 

2   Reasons for refusing this application—as an incinerator and cement kiln

    Oxygen starvation

   Cement kilns cannot make cement at 6% oxygen in the firing zone. 6% oxygen is needed for complete
   combustion. Cement kilns work at a maximum of 2% oxygen.

    The high levels of carbon monoxide confirm poor combustion in kiln 7 at Ribblesdale, when burning hazwaste.

    No account has been taken of the following:-

                …………of leakages

                …………of spillages

    Reduced particle size when burning waste

    Aerodynamics of hazwate particles

    Secondary particle formation

    Increase in mass of waste dust
    It went from 18, 000 tonnes to 28, 000 tonnes at Ribblesdale.

    Increase in heavy metals
    Not only per kg, but also for increased mass of dust, therefore metals

    Increased breakdowns
 
 

Finally, I object to the tactics of Castle Cement in this Inquiry.

 Castle Cement had ample time to write a rebuttal of my evidence, before my cross examination, but failed to
produce one.

A full day was set aside for my cross examination by Castle Cement’s barrister. I travelled all the way down to N Wales to be
at that cross-examination. A wad of paperwork was handed to me, and I went through it with them easily answering their
claims, and rebutting them, even though they had not given me prior sight of it.

 It was their choice that they prematurely stopped the cross-examination, not mine, nor the Inquiry’s.

I object, therefore, to being presented with the same wad of documents, and more, on the 6 th January, it having been sent to
Councillor Armstrong Braun immediately before Christmas, when he was in Ireland for 2 weeks. I have not had time to go
through it all, but see some of it is the same as they presented as questions at the cross examination, and others making false
claims, intended to bring my submissions into disrepute. Since I can, given time, provide all the documentation to substantiate
every statement I have made, I ask you, the Inspector, to disregard this so called rebuttal at this late stage. They are fully aware
that I have the evidence, and that is why they chose to cut short the cross examination, and withhold their so called rebuttal.

Are they willing to pay for my time which is needed to collect the evidence needed to answer these false claims? Please let me
know what you wish me to do about it.

MV Horner.