Green Santa says NOT IN SPLOTT

No INCINERATOR for Cardiff
A Green Santa accompanied by members of Cardiff Friends
of the Earth and councillors including Splott Councillor
Gavin Cox deliver a Christmas parcel containing hundreds
of objections against incinerator to Cardiff Planning
Department. 19th Dec

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from waste-to-landfill (‘baseline scenario’) but doesn’t describe the assumptions of that ‘baseline’ - presumably an out-of-date baseline that is not now allowed under requirements for stabilisation of biowastes, because it mentions “processing waste in the landfill” after Fig 5-3.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

Action Outside City Hall, Friday 19th December, 1.30pm

Action Outside City Hall, Friday 19th December, 1.30pm

Press release – Cardiff Friends of the Earth
Title: Green Santa delivers Christmas message from
residents
Contact: Heather Webber, Cardiff Friends of the Earth
Tel: 07504928248
Email: heather.webber@foe.co.uk

Photo Opportunity:
A Green Santa accompanied by members of Cardiff Friends
of the Earth and councillors including Splott Councillor
Gavin Cox deliver a Christmas parcel containing hundreds
of objections against incinerator to Cardiff Planning
Department.

Where: Outside City Hall, Cathays Park, CF10 3ND
When: Friday 19th December, 1.30pm
Opportunity for interviews in both English and Welsh.

Green Santa delivers Christmas message from residents

Hundreds of objections to a massive waste incinerator in
Cardiff are to be delivered to Cardiff council planning
department on Friday,19th December by a green Santa.

Cardiff residents have been voicing their opposition to
a planning application (number: 08/2616) from Viridor
waste management for a 350,000 tonne per year waste
incinerator to be situated in Trident
Park, Cardiff.

Cardiff Friends of the Earth will hand over a petition
with more than 100 signatories from the Splott and Tremorfa
area. Residents here are particularly concerned about
emissions from the incinerator as they
are already subject to the second highest dioxin
emissions in Wales
from the Eastmoors Steel works [1].

More than 100 letters of objection to the planning
application will also be handed in from residents
all over Cardiff who were appalled
at the thought of 256 extra waste lorries every day
rumbling through
Cardiff bringing in waste from all over South Wales.

Heather Webber of Cardiff Friends of the Earth said:

"Judging by the response we have had in such a short
 time, these objections are just the tip of the ice-berg.
People are rightly angered at plans to burn waste from
all over South Wales in an
incinerator in the heart of Cardiff.

This is not just NIMBY-ism, incineration is not a
'green' technology and there is no sense in driving
huge amounts of waste around the country increasing
congestion and pollution. Other, less damaging and
more sustainable, technologies are available that
could be implemented in each local area[2]."

The council planning department have indicated that,
due to the size of the plant, they will accept
 objections into the new year - beyond
the statutory deadline of Christmas Eve.

[1] http://www.facebook.com/l.php?u=http://www.walesonline.co.uk%2Fnews%2Fwales-news%2F2007%2F12%2F08%2Frevealed-
our-biggest-polluters-91466-20222285/2/
[2] There are cleaner, greener technologies – such as Mechanical
Biological Treatment (MBT) – that can work as smaller, flexible
units, close to where waste is produced, and will recover more
recyclable material whilst producing less harmful waste.

Rodney Berman on Scam Green Incinerator

Rodney Berman on Scam Green

Anne to R Berman Leader of Cardiff Council

Green New Deal - not in Cardiff

Nick Clegg will lay out plans to divert the Government's planned economic stimulus to environmentally friendly projects. He will argue that Britain must invest in environmentally friendly projects to ensure the country pulls out of the looming recession on the road towards a low-carbon economy. Independent 15th Dec 2008

REPLY

Thank you for your comments. However, you appear to be conveniently ignoring the fact that Cardiff has become the first city in the UK to provide a free weekly collection of food waste for every street. You also appear to have overlooked the fact that we have also created a significant number of new jobs in recent years in the provision of both the new food waste collections and the previous expansion of green bag recycling collections. These include increased numbers of waste collection staff and new staff at our recycling plant in Lamby Way, one of the largest local authority-run recycling plants in Europe.

For the record, Viridor is a private company and neither Cardiff Council nor the Liberal Democrats are responsible for the fact they have recently submitted a planning application for an Energy from Waste plant.

The intention of Prosiect Gwyrdd, should it progress to a procurement process, is not to rule in or out any technology for residual waste treatment. The five local authorities who have joined together to take Prosiect Gwyrdd forward are committed to ensuring that there is the full opportunity for a range of solutions to come forward during procurement. Any proposal that comes forward would have to be assessed for its viability, but one of the factors that will also be taken into account will be its carbon footprint, expressed as global warming potential in units of tonnes of carbon dioxide equivalents. All of this was explained in the recent report considered by Cardiff's Executive at its meeting on 4 December.

Yours sincerely,

Rodney Berman

Leader of Cardiff Council

Cllr Cox clears up mystery

Councillor Cox clears up the timing - you can put forward representations whilst the application is still under consideration any representations made to the planning authority will be taken into consideration - until it goes to planning committee in Feb?!

The neighbour consultation period expires on 26^th December 2008. The local planning authority has carried out consultations in accordance with the statutory requirements. Neighbouring occupiers adjacent to the site were notified by letter, the application was advertised within the local press on 11^th December 2008 and 6no. site notices have been displayed within the wider area (Glass Avenue, Ocean Way, East Tyndall Street, Bute Street, Splott Road and Muirton Road).

Although the statutory neighbour consultation period expires on 26^th December it should be noted that due to the accompaniment of the application by an Environmental Statement the local planning authority has a statutory period of sixteen weeks within which to determine the application, (ie. until 19^th March 2009). It is therefore, unlikely that the application will be reported to Committee until February at the earliest. Whilst the application is still under consideration any representations made to the planning authority will be taken into consideration.

Anger over plans for massive waste incinerator

Write to Andrew Bates Development Control anbates@cardiff.gov.uk 02920 871704 Strategic Planning & Environment City HallCathays Park Cardiff CF10 3ND

Dec 11 2008 by David James, South Wales Echo WRONG WRONG WRONG

Consideration of Environmental Statements and EIA planning applications
The timeframe for dealing with the application is extended to 16 weeks from the date of receipt of the ES, although this can be extended with the applicant’s agreement.Cardiff planning officer A Bates said that there was plenty of time to write in - while the application is live -still happy to receive letters and views!!!!

RESIDENTS have until Christmas Eve to object to a giant waste incinerator in Splott, Cardiff.

Cardiff Friends of the Earth have accused the developer, Viridor, of timing its planning application for an energy-from-waste plant for the Christmas period to avoid public objection.

Spokeswoman Heather Webber said: “Hauling huge amounts of rubbish around the country to be burnt is not a sensible, or sustainable, waste solution.

“This incinerator is massively over-sized, and would release dangerous emissions and increase congestion and pollution.”

Residents must submit comments to the city council’s planning committee by Christmas Eve.

Developer Viridor is hoping to win the contract to deal with the waste from five South Wales local authorities, including Cardiff.

16 weeks to campaign against cardiff incinerator

http://www.thepetitionsite.com/1/nocardiffbayincinerator
Sign our petition
here's an anti-incinerator victory! This took several months, insisting on answers from the Env Agency on the Environmental Statement. None of that nonsense about 21 days to object when there is in law 16 weeks for deciding on EIA-planning. We must insist on seeing the representations from Stat Consultees like the EA.

http://news.bbc.co.uk/1/hi/england/7773708.stm

The planning decision went our way big time,
with Newark & Sherwood not only objecting,
but saying that if Notts County Council approve the application
they (the District Council) would ask for a public inquiry,
and if the Secretary of State doesn't grant a public inquiry,
Newark & Sherwood District Council would take advice on a legal
challenge (judicial review)
Rainsworths Burning Issue

contact andrew bates with your objections

The planning Officer in charge is: Andrew Bates His number is: 02920 871704
anbates@cardiff.gov.uk

Objections should be sent to:
FAO: Andrew Bates Development Control
Strategic Planning & Environment City Hall Cathays Park
Cardiff CF10 3ND

WAG not happy funding incinerator

from someone who went down to the meeting this afternoon.

Prosiect Gwyrdd item was pretty short - about 5 minutes. The main action was before that and was a very long heated discussion about the proposed school closures and related loss of open space in East Cardiff, and involving a lot of shouting from some members of the public attending.

The Prosiect Gwyrdd OBC recommendations were passed, i.e. for the project to continue along the lines in the report

Margaret Jones presented :
- the OBC is an interim document
- the project is of such a scale that it will need to come back to the Exec and also go to full Council next year
- no decision taken on site or technology
- irritated at misrepresentation of the project inside the Council and elsewhere (i.e. "PG = incinerator"

- the main point of the presentation was to repeat impatience with WAG for not clarifying funding position
- this was supported by all councillors present
- there were no questions about the content of the report

Residents urged to oppose Cardiff Incinerator

Press release – Cardiff Friends of the Earth

Immediate release: 04 December 2008

Contact: Heather Webber, Cardiff Friends of the Earth

Tel: 07504928248

Email: heather.webber@foe.co.uk

Residents urged to oppose Cardiff Incinerator

Cardiff residents should object to plans for a massive waste incinerator built in the heart of Cardiff, burning rubbish from all over South Wales. This is the call from Cardiff Friends of the Earth following Viridor's application for planning permission.

Viridor waste management have submitted plans to Cardiff council's planning department (ref: 08/2616) for a hugely over-sized incinerator. The environmental group is urging people to voice their opposition to this scheme which would hit Cardiff residents with air-polluting emissions, increased traffic and congestion and act as a disincentive to recycling.

The proposed incinerator is designed to process 350,000 tonnes of residual waste per year and to be built in Trident Park, Cardiff Bay[1]. However, with the Welsh Assembly Government’s commitment to achieve 70% recycling by 2020 and Viridor's suggested 25 year contract, the incinerator is more than three times larger than the waste predicted for all five surrounding local authority areas[2].

Viridor have confirmed that transporting this amount of waste across South East Wales would result in 256 large waste lorries arriving in Cardiff every day. This represents a 3% increase in traffic to add to the congestion and pollution on Cardiff's roads.

Incineration is not an efficient way of producing energy from waste and releases large amounts of greenhouse gases such as carbon dioxide. In addition, during some operating conditions, or in case of an accident, emissions are not regulated and harmful dioxins may be released into the air.

One third of the mass burnt remains as ash which still needs to be managed. Around 17,000 tonnes[3] a year of this would be toxic fly-ash which would have to be transported to a special hazardous waste site for disposal. These factors combine to make incineration worse for the environment than landfill[4].

There are cleaner, greener technologies – such as Mechanical Biological Treatment (MBT) – that can work as smaller, flexible units, close to where waste is produced, and will recover more recyclable material whilst producing less harmful waste.

Heather Webber from Cardiff Friends of the Earth said:

“Hauling huge amounts of rubbish around the country to be burnt is not a sensible, or sustainable, waste solution. This incinerator is hugely over-sized, would release harmful emissions and increase congestion and pollution. Cardiff residents urgently need to voice their opposition now by contacting the planning department with their concerns.”

“ There are truly sustainable solutions available if we embrace new technologies that maximise recycling and can adapt to the changing waste streams of the future. But, if this proposal goes ahead, Cardiff could become the waste capital of Wales.”

---

[1] On the site of the former Nippon Electric Glass (NEG) site, between Ocean Way and the docks: http://www.viridor-consultation.co.uk/index.php?contentId=90

[2] The five local authorities (Cardiff, Newport, Vale of Glamorgan, Caerphilly and Monmoutshire) currently produce 370,000 tonnes of municipal waste per year. At 70% recycling this would be reduced to 111,000 tonnes.

[3] 5% by weight of waste incinerated

[4] Rabl, A., J. V. Spadaro, et al. (2008). "Environmental Impacts and Costs of Solid Waste: A Comparison of Landfill and Incineration." Waste Management & Research in press. (Rabl, Spadaro et al. 2008)

Incinerator goes to planning

The planning application has gone in, the
number is 08/2616 and was submitted on the 27th November.

Details of the application are up on Viridor's website:
http://www.viridor-consultation.co.uk/index.php?contentId=128

We have at least 8 weeks in which to raise objections.

The planning Officer in charge is: Andrew Bates His home number is: 02920 871704

Objections should be sent to:
FAO: Andrew Bates Development Control
Strategic Planning & Environment City Hall Cathays Park
Cardiff CF10 3ND

If we get over 50 objections, then it is considered as a petition and
can be heard before committee.

Cardiff Council steamroller dodgy proposal for incinerator through

The Cardiff report smacks of desperation and looks like an attempt to steamroller a dodgy proposal through as quickly as possible before anybody checks their maths. It may be easy for them to blame the assembly but wasn’t their original timeline to complete the Outline Business Plan by December 2007 and to put the advert in the OJEU by March 2008 [1] but they still say it isn’t finished yet and now won’t go into the OJEU until Mar 09. In which case isn’t it really the project team and their (£ 250,000 + to date) consultants who are to blame for the full year slippage to date? And if the project can slip a full year between the July 2007 Cardiff Council Executive meeting and now what are the realistic prospects for it being delivered on time and to budget in the longer term?

Obviously the final draft OBC raises a lot of questions. Why, for example, have they placed so much emphasis on landfill penalties (at £ 200/tonne [2]) in the letter to Jane D, and in the OBC, when all the authorities will meet the Landfill Directive Diversion targets through complying with the National recycling targets?


The growth rates are unrealistically high – and a quick check shows the total MSW has fallen again in each of the authorities. The argument they use (in Appendix 4b and not 2a as they incorrectly reference in para 2.3.2) is a silly one:

“there is concern with basing projections on the high negative growth seen over the last few years, at is not completely understood how this reduction has come about. It would be more prudent to base projections on a higher growth rate in early years”

The ‘prudence’ together with the reduction of the recycling target by 5% means they are pitching for 35% of 575,000 tonnes - which they then add another 10% to, presumably for ‘prudence’ to justify 220,000 tpa.

Prosiect llwyd is not necessary to comply with European targets and adds only 1.2% [3] to recycling – and that is low grade post incineration steel which could be recovered with higher quality at a landfill with a magnet. It is therefore difficult to understand why it is considered so important to concentrate on this residual waste project at this stage as it seems to requires a rather perverse mentality to prioritise this rather than the the main event of meeting the recycling targets,

A more realistic assessment of the residual waste need would, in any case, be 30% of 500,000 tonnes ie 150,000 tonnes. The proposal is therefore probably 50% too big with profound impacts on the costs assessments. This is a shoddy way to play with £ 1 billion of our money.

Even the proposed option with ash recycling would still need landfill for 36,500 tonnes of rejects; 6,300 tonnes of hazardous APCD residues (table 4.4). They should also add the requirement for at least half the bottom ash to be landfilled as this is the level being achieved in Hampshire. If we can demonstrate that the bottom ash is hazardous then even more would be landfilled. Thus the total landfill requirement of the Project would be 42,800 + 16,650 = 59,450 tonnes. The reduction in landfill compared with do nothing thus reduces to c. 90,000 tonnes. These corrections would make a large difference to the cost assessments.

The WRATE assessment is typically awful, but as expected given the fundamental flaws and limitations of the model.

The report has far too much redacted information

[1] Cardiff Council (2007). EXECUTIVE BUSINESS MEETING: 5 JULY 2007 MUNICIPAL RESIDUAL WASTE TREATMENT REPORT OF CORPORATE DIRECTOR AGENDA ITEM: 8 PORTFOLIO: ENVIRONMENT & TRANSPORT Prosiect Gwyrdd procurement.
[2] I think it will be difficult in any case for Wales to maintain the threat of a £ 200 penalty given that the English financial penalty was reduced to £ 150 by Environment Minister Elliot Morley on 9 December 2004 “as part of a package of measures designed to ensure that local authorities have the flexibility to meet challenging targets for the diversion of biodegradable municipal waste from landfill without increasing pressure on council tax”. It follows that landfill will never reach £ 200/tonne when LATS penalties are set at £ 150 in England – authorities would simply pay the penalty or export the waste to English landfills where the LATS can be traded and the market price for landfill would be below £ 150.
[3] The 1.2% is for metal recovery. More worrying is the comment at: 4.4.16 “It has recently (although unofficially) been suggested by the Assembly Government that bottom ash recycling may count towards future recycling targets”. This could add another 5.2% they claim – this is wrong because only half the ash is likely to be recycled and it is, in any case, an approach that has recently been rejected in England.

Report to Cdf Exec on Thursday 4th
Municipal Residual Waste Treatment (Prosiect Gwyrdd) - Report (169k)
Municipal Residual Waste Treatment (Prosiect Gwyrdd) - Appendix 1 (2.87M)
�h Municipal Residual Waste Treatment (Prosiect Gwyrdd) - Appendix 2-5 (350k)

Note they have reduced the 70% recycling target to 65% and say the Eunomia report is still contested.
Will abandon Prosiect Gwyrdd if WAG does not guarantee funding by March.
Regional Waste Plans held up.

Extracts from the Report

． The review of 2002 National Waste Strategy has been delayed;
． The “Eunomia report” (September 2007) outlining the economic and
achievability assumptions was challenged and a further review of this
work has not produced a clear way forward;
． A review of Regional Waste Plans was completed; but a further
review is apparently planned to include relevant Planning Policies
under TAN 21;

Stakeholder Consultation
33. The principal focus of the Partnership thus far has been internal -
although the Project and individual authorities have engaged with
external stakeholders to an extent e.g. Friends of the Earth. The need for
comprehensive stakeholder/community group engagement is recognised
and similar considerations apply to neighbouring local authorities and other public bodies through established consultative mechanisms. A communications strategy will be the main vehicle for doing this and early outputs will include the establishment of a Prosiect Gwyrdd website which members are asked to approve as part of this report.

Procurement & Timetable
36. For the reasons explained above, this report does not seek authority for procurement to commence;

RECOMMENDATIONS
The Executive is recommended to:
(1) Approve the Final Draft Outline Business Case for submission to WAG based upon the affordability gap described in this report for a Residual Waste Treatment Solution predicated upon a technology neutral assumption.

(2) Agree that the Approved Outline Business Case will remain subject to three conditions:

(i) The Procurement being premised upon a) a publicly owned site
being made available to bidders and as such maintaining
discussions with the Welsh Assembly Government is necessary
until a public authority contractually commits to securing an option in the Project’s control and to note that this does not preclude a private owned site being brought forward by a bidder or b) the
Partnership and WAG become satisfied that adequate private sector competition is available;

(ii) The Welsh Assembly Government providing the Authorities
sufficient comfort that they will fund the Project to at least a
minimum level of funding over the life of the Project as per the Outline Base Case; and

(iii) The partner authorities also approving the Outline Business Case with the same conditions applying.

(3) Agree that if the three conditions in recommendation 2 above are not all
met by 31 March 2009, the approval of the OBC automatically lapses
and the Council will reconsider matters including alternative options
outside of the scope of Project Gwyrdd.