Friends of the Earth point out
KEY OMISSIONS IN OFFICERS’ REPORT ON VIRIDOR/SPLOTT INCINERATOR
......Bottom Ash is not inert! Most of it is TOXIC Ash!...
......
.......Viridor’s claim to combined heat-and-power is false!.....
Viridor’s Incinerator bottom ash (IBA)
- Viridor’s ES is faulty in saying the IBA is “inert”
- they have failed to address the issue of some or all IBA likely to be classed hazardous
- their claim to recycle the bottom ash in construction projects locally (or
- Their proposals do not meet requirements to minimise the production of hazardous wastes
- Sending large tonnages of ash
for landfilling outside the region conflicts with TAN21 policy (proximity principle).
Viridor’s claim to combined heat-and-power is false
There are no rational uses for the immense 70 MW year-round with no back-up supply in the event of breakdown and maintenance down-time. Nor does Viridor have any real plan to lay pipes to actually supply any of the heat at all.
Officers have failed to apply the Waste Hierarchy
The current Hierarchy (Waste Framework Directive 2008) defines incineration of waste as “disposal” unless it has efficient energy recovery. Viridor’s is very inefficient.
Officers disregard
EfW plant is only acceptable If, inter alia
• it represents the BPEO for residual waste, taking into account transpor
tation;
• it has been designed so as not to inhibit increasing recycling and composting rates at a later date (in the expectation that the Assembly Government increases the targets further);
• it includes combined heat and power wherever practicable
Viridor clearly do not meet the third bullet, they don’t meet the second (cf. the 90% recycling target for commercial and industrial waste, yet Viridor want a huge 175 000tonnes pa) and haven’t met the first bullet, though they claim to.
BPEO decision
The current waste policy (
CONCLUDE
● serious errors and omissions in Viridor’s Environmental Statement mean that it cannot be truthfully approved as under Recommendation 1.
● the Officers’ report does not cover
ANNEX – Viridor’s claim to BPEO is false
Viridor’s ES says
‘BPEOs have been un
… The proposed EfW facility is therefore consistent with the BPEO assessments at all levels.’
Yet it merely compares the climate change impact of its proposed incinerator with that of landfill. (Sections 6.9 and 17 of their Environmental Statement). As can be seen from their Figure 4, it merely compares what would be a very bad climate change impact alternative with the worst one. It has
# no use of the waste heat – the major part of available energy – despite saying it could be used
# huge tonnages of bottom ash, potentially hazardous, to be disposed of off-site
# failure to compare with rational options
The SEWales RWP shortlists incineration as a BPEO. It does so by employing the WRATE software ‘tool’.
The BPEO (Best Practicable Environmental Option) process was established by the Royal Commission (RCEP) and their definition of it adopted by government. It is a
judgementbased process and “must not be allowed to become a technocratic process… the output of which is then used to steamroller a sceptical public into options which they dislike or distrust... it is a "consultative decisionmaking process" … this must be adhered to, including making the use of any model available to the general public wherever practicable (House of Commons 2002 – see Annex below).
The 2002 model was ‘WISARD’, now superseded by ‘WRATE’. The same strictures apply against WRATE as made by the Select Committee and the government response (Annex). Yet WAG officials have used WRATE as a ‘prescriptive device’ to justify their exclusion of MBT for residual waste. This misuse took place in the Regional Waste Plan reviews (2007-8) and in preparing the “Future Directions…” paper for the waste review (see the EA’s support paper[2]).
In respect of climate impacts, WRATE gives a very different result to Eunomia's modelling, which follows the proper international prescription (IPCC[3]):
if incineration of waste is used for energy purposes, both fossil and biogenic CO2 emissions should be estimated
Proper lifecycle calculations (Eunomia 2008[4]) following the IPCC prescription and adopting real efficiency of biostabilisation found that “scenarios using incineration were amongst the poorest performing” while those using MBT ranked among the best.
Government Response to EFRA, March 2002
Selection Techniques for Waste Management Options Recommendation
20. We agree with the Committee that computer models should not be used as prescriptive devices to provide 'the answer'. The Environment Agency's WISARD software is a good example. It produces information on the environmental impacts of different strategies for managing municipal solid waste determined by the user. It provides users with an assessment of the life cycle impacts of these strategies to allow them to be compared and to assist in determining the BPEO. It can therefore aid, but cannot make, decisions on the BPEO.
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Max Wallis, SE Wales FoE Waste Group, May 2009
[1] Eunomia Research & Consulting and TOBIN Consulting Engineers, Meeting
[2] Lifecycle Assessment of Municipal Waste Targets, Environment Agency
[3] Intergovernmental Panel on Climate Change 2006, “Chapter 5: Incineration and Open Burning of Waste,” 2006 IPCC Guidelines for National Greenhouse Gas Inventories, p. 5.5, National Greenhouse Gas Inventories Programme, Pub: IGES, Japan.
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