Rodney Berman hot under the collar!

Dear Ms

I thank you for your latest e-mail. However, I have answered many of these points before and you repeatedly ignore the explanations you are given and repeatedly distort what I say. You also repeat allegations over and over again that I have previously refuted.

On that basis, could you please explain why it is that you look forward to my reply?

Yours sincerely,

Rodney Berman

Leader Cardiff council

Yes Rodney

I would have thought that pointing out these NEW serious flaws, described below, would be appreciated and you would address these extremely serious points now that you are aware of them. Your officers have not brought these matters to your attention! You have not addressed these points as yet. Friends of the earth and the green party will continue to ask these very questions and deserve an answer. In addition we will be asking how the Environmental Assessment on the air quality affects of the incinerator was done.

I had hoped you might respond with an open mind.

There are HUGE serious flaws in project ‘green’ and the Viridor planning application in skipping due process. The Viridor site has not been a llocated for waste management purposes in the Development Plan. If allocated in the future LDP, it would be subject to stronger tests, potentially through the public examination process, and to a soundness test

How can you ignore the development plan?

The Cardiff LDP itself is still awaited so has not allocated sites, has not been subject to consultation and would still have to go through public examination. The proper process is for Viridor to argue for this site through the LDP. To grant planning permission would allow them to skip due process and so unfair to both the public and to promoters of alternative residual waste treatments. It should therefore be turned down on grounds of prematurity.

It is clearly an important function of the planning process to determine whether allocations for waste treatment facilities meet the test of ‘Best Practicable Environmental Option’ (BPEO) at a strategic level.

The applicant has not undertaken an SA/BPEO appraisal of the proposal and, because the Authority did not recognise that it was their responsibility to do so. There is, therefore, no support for the allocation being BPEO as required by National Policy. The National Waste Strategy, “Wise about Waste” specifies the minimising of landfill and incineration.

The Viridor proposal amounts to a huge expansion of incineration, both for municipal waste and for industrial waste, instead of the alternatives that exist for both categories. Viridor make a case for 170 000tpa of residual MSW arising in the sub-region. We have shown that even Prosiect Gwyrdd’s assumption brought up to date would give 140 000tpa. Viridor make no case for the 170 000tpa of commercial or industrial waste. Their incinerator would therefore tout for business and encourage incineration rather than waste recovery – preferred in the waste strategy as well as by the basic waste hierarchy (mandated by the Waste Framework Directive…….).

On waste growth, the figures show that municipal waste is stagnant or falling in Wales as well as England. It’s your officers who have to justify projected20increases (as they supported in the Regional Waste Plan), and learn lessons on waste reduction.

They have overlooked the dangerous fact that the process produces vast quantities of Ash which in landfill20produces toxic dust and leachate. A Ministerial answer last week in the Commons specified that incinerator ash has to be tested for being hazardous waste – no mention of that in the project greenwah report or the planning application.

And of course there is a big question to of the propriety of the officers fixing with Viridor a site visit to their incinerator still under construction. No one was informed - that Colnbrook is Viridor's incinerator and not yet operating!!! So what point is there in visiting that? And what opportunities for the public to join that visit?

best wishes

and still hoping for a reply