June 7th, 2021
Dear European MP,
Tomorrow, June 8th the Italian Parliament will begin discussing a Decreto Semplificazione proposed by the ministry of the Environment Mr. Roberto Cingolani. If approved, the Decree will dismantle the fundamental safeguards for the protection of health and the environment in our Country. The main proposed measures are in open conflict with European legislation.
This letter has been signed by 30 committees of citizens from Northern and Southern Italy. Each of them was formed years ago to safeguard some fundamental rights: Public health, quality of life, a satisfying future, a healthy environment, or the preservation of common goods. Each committee was created to protect territories and communities from poorly-conceived development initiatives.
Throughout the years each committee has studied complex policy issues, informed and mobilized thousands of citizens, and established dialogues with institutions locally, in Italy and in Europe. Our primary aim is to defend the places in which we live from predatory approaches by obsolete industries and negligent civil servants.
We are writing today to alert the European Institutions and Citizens about a dangerous attack to public goods, the environment, and the democratic process. Under the pretext of trimming bureaucracy and fostering the post Covid-19 economic recovery, the proposed “Simplification Decree”1
Suppresses the right of local administrations to be consulted and to express an opinion concerning the environmental and public health impact of industrial and infrastructure initiatives. According to the proposed decree, the Environmental Impact Assessment on new investments and infrastructures (Valutazione di Impatto Ambientale, or VIA) would henceforth be the responsibility of a commission formed exclusively by employees of the Ministry for the Environment. The central Italian Government would become the sole and final arbiter on all local issues pertaining to health, the environment, and the landscape. Citizens, health experts, and local administrations will be silenced.
Ignores and overrides two legally binding plebiscites through which a majority of the Italian people has expressed its opposition to nuclear energy and the privatization of water sources, a utility which should be deemed a public good.
Reaffirms (in Article 37) the full standing of the Decreto Clini which, in 2013, transformed waste into renewable fuel, by virtue of a change of terminology: CSS (Combustibile Solido Secondario, or Refuse Derived Fuel). The Clini decree is a mockery of EU norms on two grounds: (a) the emission requirements of furnaces using “reformed” waste are less stringent than those of incinerators, where the waste might evetually be disposed of and (b) For the purposes of carbon credit calculations, the Italian government classifies reformed waste or CSS as renewable energy. This provides a perverse incentive to the creation of waste, as any additional amount of burned waste
1 Decreto Semplificazioni , Ministro Roberto Cingolani, Approved by the coucil of ministers on May 28, 2021
would provide carbon credits and improve the country’s carbon balance, and the cement factory balance sheet.
Since 2018, the EU prescribes the selection and recirculation of waste, as opposed to its incineration; and the Just Transition Mechanism was crafted to support the transition in exactly the opposite direction.
The proposed decree is in open violation of the European norms established and reiterated over the past 40 years. The Environmental Impact Assessment has been a pillar of the EU Environmental Policy since its first EIA directive in 1985 (85/337/EEC).
Since 2003, on a periodic basis, The EU has produced numerous reviews of the implementation of Environmental Impact Assessments by Member Nations. Observations about Italy did not reveal either exceedingly long or complex procedures, nor did they find obstacles and delays to private initiatives. Rather, EU reviewers expressed concerns about the low number of Impact Assessments; the overly stringent requirements needed to grant a request for Assessment; the poor quality of investigations; a preposterous reduction of processes under review, to avoid accounting for their cumulative environmental impact.
Recommendations conveyed by the EU reports pointed to the need for better training and preparedness of the personnel involved; a more accurate evaluation of risks; a broader application of the precautionary principle; replacement of obsolete, inefficient and poorly maintained monitoring equipment; a need to emphasize the relationships between environmental pollution and human health; and an invitation to facilitate public participation.
Italy needs clear, carefully written, and succinct norms, not preposterous deregulation. Under the pretext of simplifying bureaucratic procedures, the proposed decree supersedes well established European norms, and bypasses checkpoints, in the exclusive interest of old, inefficient, and highly polluting industries.
In the case of recycled waste, there is the additional risk of attracting organized crime. In May 2021 the town of Gubbio obtained a rare and welcomed Environmental Impact Assessment concerning the request to use CSS as a fuel by two cement factories adjacent to the town. On April 2, 2021 an employee of the Umbria Regional Environmental Department was arrested for bribery, having received 32,000 EUR to cover up trafficking and disposal of toxic waste. On April 21, 2021 the Chief Prosecutor of Umbria, Mr. Raffaele Cantone declared that the proposed expansion of CSS waste treatment in Umbria “poses a serious danger of infiltration by organized crime” known as “eco- mafia”. On May 27 the Minister of the Environment presented the Simplifying Decree to the Italian Parliament. The decree includes a confirmation of decreto Clini2 on burning CSS in cement factories. CSS occupies only two articles in a very extensive number of cases and norms covered by the 45 articles of the decree.
The Italian Parliament and Government need to hear Your voice. Please convey Your strong reservations towards the Simplification Decree of Ministro Cingolani. Should it be approved, on your next visit Italy you may need to wear a mask … a gas mask.
Thank You for your kind consideration,
2 In March 2021 Mr. Clini, a former Minister for the Environment, was sentenced to a 6 years jail term for bribery.
Coordinamento Civico AMBIENTE E SALUTE
Via G. Mazzini 43 – 73022 Corigliano d’Otranto (LE)
Via Veneto, 4 – 31040 Onigo di Pederobba (TV)
Comitato “ARIA PULITA IN VAL D’ARDA” Via di Mezzo, 5 – 29014 Castell’Arquato (PC)
Comitato “BASTA NOCIVITÀ IN VAL D’ARDA”
Via Wladimiro Bersani, 27 – 29018 Lugagnano Val d’Arda (PC)
ISDE (International Society of Doctors for Environment), Sezione Provinciale di Perugia , Gubbio (PG)
Comitato “LASCIATECI RESPIRARE” 35043 Monselice (PD)
Movimento LEGGE RIFIUTI ZERO PER L’ECONOMIA CIRCOLARE Piazza Vittorio Emanuele II, 2 – 00185 Roma (RM)
Comitato “NO CSS NELLE CEMENTERIE DI GUBBIO” Via di Monte Albigio, 18 – 06024 Gubbio (PG)
Comitato “NO INCENERITORE MATERA – NIM”
Viale Santa Caterina da Siena, 6 – 75100 Matera (MT)
Comitato per la TUTELA AMBIENTALE DELLA CONCA EUGUBINA Frazione Ghigiano, 4 – 06024 Gubbio (PG)
Comitato Cittadini di VIA PROTOMARTIRI FRANCESCANI DI S. MARIA DEGLI ANGELI Assisi PG
Coordinamento Regionale UMBRIA RIFIUTI ZERO APS Via P. Pellini 5 – 06124 Perugia (PG)
Comitato Rifiuti Zero Spoleto No inceneritori PG
ISDE ITALIA Regione Umbira
Comitato Salute e Ambiente Calzolaro, Trestina,Alto Tevere Sud
Cittadinanza Attiva Regione Umbria APS PG
Comitato Popolare Lasciateci Respirare ODUETS (?) Monselice (PD)
Un’ Altra Gubbio Gubbio PG
No Teleriscaldamento #spegnamo il forno inceneritore di Valmadrera
Comitato per Scarpino Genova
Movimento difesa del cittadino di Perugia APS Associazione consumatori-utenti
Via Guardabassi, 14-06123 Perugia
AsociazioneUmbria MC ODV Perugia
Coordinamento Nazionale Rifiuti Zero Nei Cementifici
Coordinamento per l’ Albiente di Gualdo Cattaneo (PG)
CiAS, Associazione Cibo ambiente e salute PERUGIA (PG)
COMITATO PRO ACQUA Gualdo Tadino
Comitato discarica sicura
di Pompiod,(Aymavilles- AO)
Comitato Valli Ferite Verona (VR)
Ass. Monastero del Bene Comune Sezano (VR)