Viridor lie on 'heat and power ' and TOXIC ASH

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 SE Wales) is unsound.
• 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. Cardiff’s policy says (SPG paras 4.6-4.7) “All proposals for the development of waste management facilities across the County should conform with the principle of the waste hierarchy. Waste disposal falls at the bottom of the hierarchy…”

Officers disregard Cardiff’s SPG Locating Waste Management Facilities (Sept 2006)

EfW plant is only acceptable If, inter alia

• it represents the BPEO for residual waste, taking into account transportation;

• 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 (Cardiff’s SPG 2006, citing Wise About Waste, WAG 2000) requires open BPEO assessment of waste options, not just running a computer programme. It would properly consider the wider environmental consequences of options, including their greenhouse gas emissions and other climate impacts. The BPEO would include the impacts of toxic residues in incinerator ashes. The Ireland study[1] shows how it can and should be done, comparing with MBT options and finding the latter much better.

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 Cardiff’s Waste policy in the 2006 SPG - send it back!

ANNEX – Viridor’s claim to BPEO is false

Cardiff’s SPG (para. 4.3) says TAN 21 requires that proposals for dealing with waste should be subject to Best Practicable Environmental Option (BPEO). BPEO is a procedure which establishes the waste management option that provides most benefit or least harm to the environment.

Viridor’s ES says

‘BPEOs have been undertaken at national, regional and local levels to demonstrate the suitability of different technologies.’

… 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

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[1] Eunomia Research & Consulting and TOBIN Consulting Engineers, Meeting Ireland's Waste Targets - the Role of MBT Final report for Greenstar http://www.greenstar.ie/docs/Eunomia_MBT.pdf. 2008.

[2] Lifecycle Assessment of Municipal Waste Targets, Environment Agency Wales, 2007

[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.

[4] Greenhouse Gas Balances of Waste Management Scenarios, Eunomia Consulting Report for the Greater London Authority, 2008

serious flaws in project ‘green- ’Viridor planning application skipping due process.

I drew R Bermans attention to Lib Dems to scrap Bristol EfW plans and asked him

Cardiff lib dems to take note ...where is your green agenda/ policy...???

Rodney Berman Lib Dem reply....

1. As you are well aware Prosiect Gwyrdd is also seeking a variety of solutions. You know this as it has been said many times. We want to see what options are available to us when we go out to tender with environmental impact being a factor that we can take into account.

2. Whilst Energy from Waste was used as the reference solution in the Outline Business Case this does not mean this will be the solution chosen. However, my understanding is that it was used as the reference solution because we were required to use it as the reference solution by the Welsh Assembly Government.

3. I understand that the Welsh Assembly Government has recently determined that Energy from Waste is its preferred technology solution for residual waste treatment in its most recent policy document on this issue.

4. In view of the above, you might perhaps wish to redirect your lobbying efforts towards the Welsh Assembly Government.

5. You appear to have forgotten to congratulate the Co uncil on reaching a combined rate for recycling and composting of 40% as reported last week in the Echo.

yours sincerley

Rodney Berman
leader of Cardiff Council

Show some green leadership then..

Sorry but the Cardiff Lib Dems here are still in the age of stupid and are in the business of promoting the most un environmentally friendly policies in Wales and in the name of project green - it is blatent greenwash!

While the libdems make 'green' policy on the hoof in cardiff the green party is very clear where it stands -not just in cardiff but UK wide. Good that recycling is on the increase - however perhaps you would like to tell me how much of the co mingled waste sent for recycling is actually recycled in an environmentally friendly sustainable way? How much of this co mingled waste is actually contaminated badly by the archaic process used? You are proud of the Cardiff recycling so will you do a tour with us and the FOE waste group so we can view the cardiff recycling process together? What happens exac tly to this 40% recycled material and where does it go exactly? Perhaps the press will join us. Even if the 40% figure was entirely genuine it still far behind best practise in Europe. And of course if recycling is getting better - why do we need such a huge incinerator???

How many plastic bottles of water do you and your fellow cllrs and staff consume in council offices and buildings? How much does this cost? What is wrong with drinking the tap water in Cardiff? Perhaps you might reconsider this practice as an indication of your commitment to sustainable and green practices and policy by the lib dems.

Presently we have a bridge and roads for articulated lorries into and through listed Bute Park and new car parks for Sky TV in the park. Trees being chopped down before consultation for the convience of the council as in Bute Park and by St Davids Hall for the erection of an unnecessary TV screen and every time we are told they are conveniently diseased. There is horrendous congestion in cardiff - an expensive bus service not fit for purpose, and you are happy to consider bringing hundreds of huge lorries full of rubbish through cardiff daily fr om all over south wales and build roads into the city centre Bute Park for articulated lorries and encourage and promote increased traffic to the nursery and by promoting events!

Then we have the HUGE serious flaws in project ‘green’ and the Viridor planning application skipping due process.

The Viridor site has not been allocated 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 (* Sound’ within its ordinary meaning of “showing good judgement” and “able to be trusted” and within the context of fulfilling the expectations of legislation.)

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, neither have the Authority. 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 falling20in Wales as well as England. It’s your officers who have to justify projected increases (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 landfill produces 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?

Waste incineration in Cardiff would fans flames of climate change

The Green Party have formally objected to the proposal for a waste incinerator in Cardiff. Without this waste incineration represents an inefficient form of energy generation from fossil fuels which contribute to climate change. Wales has a very poor record of recycling waste. The company proposing to burn the waste has not provided any evidence on how it is to provide heating to the surrounding communities generated from the burning of waste. Whilst recycling of domestic waste in Wales has increased to 32% it is still behind the best practice demonstrated in other parts of Europe - Flanders (Northern Belgium) recycles over 70 per cent of its municipal waste, the Netherlands 64%, and Germany and Austria at or above 60%. Per capita20waste production in the UK is 697kg per person compared to 466 in Germany and 385 in Switzerland.

Burning of waste is a loss of valuable raw materials. Use of virgin materials uses a lot more resources to produce similar amounts of a given raw material, such as paper. For example approximately 28 to 70% of energy is saved by producing paper from recycled paper rather than virgin timber.

The incinerator will produce hazardous fly ash containing persistent organic pollutants such as PCBs.

Waste incineration will contribute to climate change. We have a target of reducing Carbon Emissions by 3% per annum and the incineration of waste will not help us meet this target. We should be looking to reduce the amount of waste we produce rather than burning what is actually a valuable resource.

Incineration will remove the impetus to increase rates of recycling in Wales or to reduce the amount of waste pre capita with Councils being tied into lengthy contracts to deliver waste. Evidence from Denmark clearly shows that in areas where there are high levels of waste incineration there are also low levels of recycling.

There are huge opportunities to reduce the amount of waste produced by requiring a deposit on all beverage containers to ensure that they can be returned where possible for reuse. Estimates suggest that a reduction of 20% could be made in the amount of domestic waste we produce by introducing a return on all beverage containers. No detail has been provided on how neighbouring houses would be provided with heat and it would not be cynical to think that this has only been suggested to help it through the planning process and help the Council avoid paying land fill tax penalties in the future.