Prosiect Gwyrdd - the truth rigged for incineration

Prosiect Gwyrdd is a joint project between 5 Councils who chose incineration for dealing with domestic waste. They dressed it up with the name “Gwyrdd – Green” and began asserting “technology neutral”.  WAG made a ‘freudian slip’ when they welcomed the “energy-from-waste” project in January 2009 *.

Background to the choice was the pro-incineration drive in WAG (contrary to declared policy of minimising landfill and incineration) that promised financial support only if Councils would form partnerships – so that their waste totalled enough to fuel an incinerator. Cardiff was pursuing a 300-400 000 t/yr incinerator to meet “requirements of the wider region”.  Viridor then weighed in with 500 000 t/yr

www.cardiff.gov.uk/content.asp?nav=2872,3250&parent_directory_id=2865&id=1509

Battle lines drawn over £150m Cardiff incinerator    LetsRecycle  15-06-2007

www.letsrecycle.com/do/ecco.py/view_item?listid=37&listcatid=217&listitemid=8850

WAG helped fund P Gwyrdd’s office and staff under the “Capital Access Fund” (70% of costs up to £200k for each of 2007 and 2008), but also set recycling targets and talked of limiting incineration to 25% (as Scotland , then WAG increased ours to 30% and now effectively 35% with no justification).

Under this pressure, P Gwyrdd decided their ‘residual’ waste will be 220 000t/yr and used the WRATE computer programme to show that an incinerator was ‘best’. Getting the result they wanted, they didn’t ask if it’s sound and ‘robust’

* others use WRATE and find MBT scores better - it depends on assumptions, eg. all incinerator ash is used for construction and no MBT outputs used for land reclamation (both invalid in English projects)  MBT covers various Mechanical and Bio treatments, including composting.

* a leading consultant using ATROPOS instead of WRATE finds incineration scores poorly compared with gasification and MBT options.

P Gwyrdd dismissed all criticisms, with the promise from WAG for subsidy to make incineration “affordable”.  WAG-sponsored consultants, including the PFI-promoting group “PartnershipsUK” were used to push it through.

KEY POINTS in PG PLAN● the only Reference Project in PG's plan is a single mega-incinerator.  They have designed financing and a 25-year contract for such a incinerator at an incredible £1100 million. 

● Cardiff and other local authorities in P Gwyrdd are aiming for only 65-70% recycling and composting. They are putting this off till 2025, evidently in order to have enough waste to feed their incinerator.

● They say PG is for 'residual' waste after "maximum recycling and composting";  this is false for the Welsh Local Authorities' consultants' report** says they can get 80-90% recycling and composting.

HOW DID THEY FUDGE CHOICE OF INCINERATION

1. used the WRATE assessment tool, which is systematically biased against low-tech mechanical and bio processes (FOE Cymru report,www.assemblywales.org/wm_24_-_friends_of_the_earth_cymru.pdf)

2. set no requirement for use of the heat output – the majority of energy from an incinerator.  Thus Viridor propose to generate 20MW (megawatts) electricity and waste 50MW heat.  As no incinerators in the UK use much heat (except the Sheffield, Nottingham and Lerwick district heating schemes), a requirement for high energy efficiency as under European law would scupper their incinerator.

3. pretend that the grate ash – which is toxic and often hazardous waste – can all be used in building, instead of  having to go to landfill as happens in England;  ignoring the proximity principle requirement for the hazardous flyash to be disposed of in SE Wales, where no disposal ‘facility’ exists.

4. refused to update their assessment for shrinking waste tonnages - PG assumed growth in waste up to 3% /yr, ignoring the last few years when municipal waste has reduced by around 1% /yr. 

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IRRESPONSIBLE REFUSAL TO REVIEW THE MEGA-PROJECT

● Newport ’s chief officer said in discussion they couldn’t reduce the 220 000 tonnes/yr target (35% of the waste stream with 17.5% increase over 2006), as the incinerator would not be viable.  Their prospectus (Nov.2009) instead took 160 000 t/yr and PG talk of increasing population to cancel out decreases in waste.

FOE demanded a reassessment on the reduced figures before going to procurement, but they refused – it was evident from simple scaling of their figures that the financial case for the incinerator would vanish if recalculated, just as chief officer Stephen Davison said.

● PG has no fall-back plan for if the mega-project collapses – all the smaller-scale companies and not-for-profit businesses (eg. Newport Wastesavers) with innovative projects have been scared off and Councils will be left to catch up on their own.

PRETENCE THAT PG WILL SURVIVE THE CREDIT CRUNCH

●  banking costs have jumped up since the Credit Crunch, so PG hope to get Euro Investment Bank or Prudential Borrowing support, both of which are restricted to ‘sustainable’ developments.  As they will probably fail, we’ll be landed with high bank charges typical of PFI.

●  £9 million/yr subsidy. The PartnershipsUK group that promotes PFIs arranged WAG funding of £9.124 million/yr (27 Apr 2009 e-mail to Tara King of PG).  They say it’s not ‘PBFOM’ not PFI, but is likely to fall back to PFI as pointed out above.

* WAG Press Release

**  Eunomia Report

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.

stop Wales being carpeted with incinerators

Last spring 4 of the South East Wales Local authorities (LAs) were grouping together to source a residual waste treatment plant, codename Prosiect Gwyrdd (Project Green Wash). MBT was mentioned but then the focus shifted to EfW

There was a fairly good chance of influencing the LAs until WAG announced their capital spending fund for partnership working on waste projects would only awarded to EfW plants, not MBT. This decision seems to have been taken after seeing the Hyder report they commissioned for the Regional Waste Plan consultations. This, in turn, seems to be based on the WRATE analysis they did of the options.

The WRATE analysis Hyder did was biased in favour of EfW, the WAG should reconsider their position and stop Wales being carpeted with incinerators.