Questions to Andrew Bates
Development control section, City Hall Cardiff. from Max

I wish to examine the claim of ‘negative’ carbon footprint. You said you would ask the applicant for the necessary information.

I believe the ES must contain enough information for the public to assess this claim. The ES is huge – 2000 pages taking 290Mb – so we should not be told to go through it all. As I mentioned, the Supporting Statement section 6 should refer to the parts which are relevant for the claim.

Appendixes have full pdf-security so that it is impossible to use copy/ paste extract parts. This includes the Council’s own Scoping Opinion. Will you ask that this protection is removed, as it hinders public consultation.

Appendix 9 written by SLR explains the carbon footprint as derived
using WRATE software

# there is no explanation of this software, nor any document or manual in the References
# there is nothing about the uncertainty or ‘robustness’ of the software
# there is nothing about the ‘robustness’ of the result due to a range of plausible assumptions.

The Coventry default incinerator in WRATE is assumed. However, that default is known to be wrong – instead of the actual heat supply to the motor works, it took a fictitious figure based on the desire of the Env Agency to promoite CHP. SLR do not explain this.

The Heat Plan Appendix 7 gives no quantities for expected heat supply and no actual examples apart from the special Exeter hospital incinerator. It does not address the issue of large variations in seasonal demand for heat. The plan does not include a proposal for a back-up generator of heat when the incinerator is down, nor for heat storage to cater for the daily cycle in demand if as proposed the incinerator operates continuously. Is supplying heat a serious proposal?

The Appendix 9 says which factors have been assumed from the Coventry case and which have been changed and refers to “supporting spreadsheet files”. I cannot see these in the application documents.

It says the carbon footprint is compared with that from waste-to-landfill (‘baseline scenario’) but doesn’t describe the assumptions of that ‘baseline’ - presumably an out-of-date baseline that is not now allowed under requirements for stabilisation of biowastes, because it mentions “processing waste in the landfill” after Fig 5-3.

Please therefore ask
# for a truthful “carbon footprint” showing the actual CO2 (equ) emitted compared with the claimed ‘offsets’ and including the biogenic carbon emitted
# for an incinerator calculation with real heat use, not the fictitious Coventry figure, justifying the claim the heat credit “is considered appropriate” in real terms.
# for real energy efficiency figures for the actual CNIM technology proposed.

Please come back to me if this is not clear and thanks for your help.