Petitions Committee acts over Waste Incineration policy

The National Assembly Petitions Committee held its 3rd oral session on petitions against incineration on Tuesday 29th, taking evidence over video-link from Prof. Vyvyan Howard of Ulster Univ. and Fellow of Royal College of Pathologists.

After questioning Prof. Howard, the committee agreed to:

• Issue a report on the issue of incineration of waste, and request a Plenary debate.
• Write to the Minister for Environment and Sustainable Development to ask him to consider the weight of support for this petition when considering the committee's letter calling for the Cardiff Incinerator plans to be called in.
• Write to those who have given evidence to Committee on this subject to seek their views on the modeling used to inform decisions in relation to Incinerators".

You can find Professor Howard's evidence on the Petitions Committee webpages (Item 2 of 29 May: P-04-341 Waste and Incineration) and see him answering questions from the Committee on the Senedd TV archive – click on 29th May.

His central argument was that official estimates of 'risk' from incinerator pollutants are flawed, giving single numbers when there is a wide envelope of uncertainty. The government relies on epidemiology, which is a "very blunt instrument". The research has not been carried out – both the hazard characterisation and exposures are very uncertain.  Those who present "unparameterised" modelling express an "opinion dressed up in numbers".  He explained exposures may be 100 times higher than estimates by comparing the Viridor claim for Cardiff of 0.24% of PM2.5 expected to come from their incinerator with the 17-32% actually measured in a small Swedish town due to a modern incinerator (meeting Euro-standards). The hazard of average incinerator PM2.5 may be many times worse than a power station's because of the toxic chemicals in waste and produced in burning. The very smallest (nanoparticles) fraction of PM2.5 are a worry as little can be done to filter them out and the volumes of emissions are very large.
[PM2.5 means particles smaller than 2.5micrometres, or 2500 nanometres, which humans breathe into their lungs. 
Nanoparticles means particles in the 10-100 nanometre range]

Llandow Fracking Inquiry 22-23 May

Friends of the Earth were well represented, with a statement from FoE Cymru's Director, Gareth Clubb and written plus verbal statements from Barry & Vale FoE - see Fracking Inquiry page.  Coastal Oil & Gas and the Vale Council discussed it as simply a test drilling operation, with CO&G claiming they were seeking ordinary coal-measure gas with no intentions for high-pressure fracking. They convinced no-one.  FoE argued the test drilling was part of a staged application for fracking and therefore needs full environmental impact assessment.  The Council had failed to 'screen' it for EIA, despite the Minister mentioning this in his letter declining to call-in the proposal.

FoE quoted the First Minister's letter of 29 Sept. to the Vale Council:

•  A “precautionary approach should be taken” and “additional environmental considerations” should be included. It referred to Minerals Planning Policy Wales (MPPW) which specifies “an environmentally acceptable way” of operation and being “consistent with the principles of sustainable development” for unconventional gas development.

The Vale Council officers had ignored this at the Planning Committee and did not argue for any 'additional' environmental precautions at this Inquiry.

There was a lengthy exchange about a Condition to be set on noise levels if the application was permitted. The Inspector first proposed noise guidance levels used for opencast mining and quarrying. FoE said no - to use the policy for industrial areas close to homes, with non-disturbing night-time levels in accord with WHO guidance.  The Vale officers failed to support FoE's approach, even though this was used at the Sunrise wood-burner inquiry.  So the issue is left to the Inspector's decision.  Whose side are the Vale officers on?

Scrap the Vale’s draft LDP (Local Development Plan)

The LDP is wrong not only for devoting huge greenfield areas for housing – a house-builders charter – but also

a) for suppressing all ideas of a Green Belt to the west of Cardiff.

FoE argued strongly for this at the 1999 Public Inquiry and won the argument against the Vale planners and won the Inspector’s support.  He recommended including all the eastern Vale up to Five-Mile-Lane, but the then Vale Council disregarded his arguments.  A Green Belt is the best way to resist developer pressures that would make the eastern Vale into residential suburbs for Cardiff.  Regional planning should meet more of Cardiff’s housing needs in Valley communities that want regeneration and have many brown-field sites waiting.  The LDP fails from the start in refusing to face these issues and going for quite ‘unsustainable’ development in sacrificing huge green-field areas.   

b) for allocating Barry dock for waste incinerators, with no full waste management plan as is required.

The Tory Cabinet and officers want to justify their past approvals of incinerators of waste wood and domestic waste amidst the light-industry businesses and close to housing on Dock View Road. They ignored waste-transporting lorry traffic, the high noise levels of power plant, the vast tonnages of potentially toxic ash that needs on-site processing, the probability of accidental fire and the inevitable emissions of toxic gases and dusts, all considerations for competent planning.

In addition to these obvious reasons, general policy says to site such plant adjacent to industrial heat users, as heat is the majority of the energy output. Barry's chemical complex has empty ex-industrial sites, and Dow Corning did express interest in the heat. Yet the LDP goes for incinerators (masquerading as 'waste management facilities') rather than devoting the half-empty dockland to mixed development with housing in accord with declared 'aspirations'.

The LDP has by law to include principles for an integrated waste plan and Friends of the Earth have put in a strong case that this one doesn't. It needs facilities for reclaiming waste materials including maximising recycling.  It has to justify incinerating household waste rather than previous policy for mechanical and bio-treatment after maximising recycling. It needs to show integration, including facilities for processing the ash from any incinerators. It's not acceptable to plan to send vast quantities of toxic ash for dumping in English landfills.

So Barry & Vale FoE wants Labour's scrapping the LDP to extend to scrapping its awful planning for waste and to addressing the Green Belt idea.

Wales Coast Path far from 'continuous' at Barry and Penarth

Barry and Vale FoE are very disappointed and critical of the lack of effort to implement the continuous coastal path within the Vale of Glamorgan. There's a huge gap east of Barry Island and another gap from Penarth Esplanade to the Cardiff Bay barrage.

This shows failure by officials to implement the declared concept of a "continuous" coast path. We raised this in March, the CCW official gave excuses (Countryside Council for Wales, see letter below) and CCW now talk of a "linked path". The local FoE group have asked the AM, Vaughan Gething to take up the particular gap in Penarth as well as the general failure.

1. Huge gap from Ty Hafan east of Sully to Barry Island, even omitting a km-stretch of the existing coast path to the Bendricks rocks.

As the Vale Council owns the Atlantic Trading Estate, the way from HMS Cambria to the lock at the mouth of Barry Dock has few problems.  Yet the CCW officials made no attempt to re-open the route across the lock to Barry Island, which the public used to use before ABP took over. The section of path from Ty Hafan hospice to the Bendricks rocks at the mouth of the Cadoxton river has been excluded, on the illegitimate excuse that the path and foreshore are owned by the hospice. Thus, we're given a huge diversion around Barry's chemical complex, along the main road through Cadoxton to the Docks Office and on further roads to Barry Island.

2. Failure to consider path around the base of Penarth Head, from the Barrage to Penarth Esplanade

The construction of this path was a commitment in the Cardiff Bay Barrage Act. The Vale of Glamorgan Council conceived a fancy, highly costly scheme (~£20million) that had to be cancelled.  But now, CCW are shielding the Welsh Government from this coast-path obligation. WAG did allocate £7.5 million to it in the Barrage Settlement, well over the Council estimate (£3million) for its cost at the time, to allow for costs in stabilising the cliff as coastal protection. FoE have asked the AM to put down a marker on this issue.

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CCW letter of  2/3/2012  relevant text extracts:

from Sue Rice, Access Programmes Manager                                 Ein cyf/Our ref:ATI 799

In respect of your recent enquiry 22 February 2012 for information (ATI 799) in which you

requested clarification on a number of points relating to the Wales Coast Path (WCP) in the Vale of Glamorgan, the route of which is shown on the attached plan.

Taking your points in order:

 

· Big gap between Bendricks rocks and Hayes Wood and public paths in the western dock

The WCP is routed around Barry Docks for a number of reasons. Firstly we wanted to ensure that the path was available 24/7, something that we could not guarantee if it was routed through the docks. Secondly it was felt that given the state of repair of much of the road surface in this area, and the considerable costs required to create a suitable path, the health and safety implications of using this route were unacceptable. When considering the route to the east of this area, regard was paid to the presence of Ty Hafan and I’m sure you would agree that it would be inappropriate to route the path through the grounds of this children’s hospice. As a result the route is as shown on the attached plan.

· No path around Penarth Headland to the Barrage

Whilst I appreciate that there have been plans in the past to create a route around Penarth headland to the Barrage, this has never formed part of the WCP. The costs of the proposed plan were far beyond the capabilities of our budgets, and it was felt that the health and safety implications related to rock falls and cliff erosion in this area made the creation of a path at the base of the cliffs impracticable. However, as a result the WCP does pass close to the centre of Penarth, ensuring that the town can take advantage of the economic benefits of the path.

Lobby Against the "'Prosiect Gwyrdd' incinerator

Friends of the Earth and Newport campaigners successfully lobbied on 28th February against inclusion of the incinerator in Newport's LDP, which the Cabinet wanted to do b ut feared losing the vote.  The whole presentation of the LDP (Local Development Plan) was withdrawn.

Lobbying the Vale MP on Incinerator ROC-Subsidies

A delegation from DIAG and FoE briefed Alun Cairns MP (3rd February) on  proposed biomass subsidies and discussed the planned incinerators in Barry Dock with him, stressing they could both get "double ROCs" worth about 10p per unit (kWh), far above the wholesale price (2-3p/kWh).  We pointed out that incinerators in England require public acceptability to get Government subsidy (PFI approval) yet public acceptability is not a criterion for ROCs.  Alun Cairns agreed to take this up, pointing out that Dow Corning have a better site for a wood burner where it would supply the company with heat, and would be more acceptable than the 'Sunrise' burner planned close to Dock View Rd housing.

The Commons BiomassDebate 20 Feb. 2012 addressed some of these issues
       Graham Stringer MP pointed out
… 17 deaths per yr from a small biomass (waste wood) plant near his consitituency, but rejected by the Planning Committee 
… would have emitted small amounts of arsenic from CCA in demolition wood
Biomass plants depend on imported wood and whole trees
their carbon-footprint is higher than the average UK power, so it's high not low carbon and above the limit for ROC subsidy
       The Minister Gregory Barker replied - the 17 deaths are an over-estimate and ROCs will have to meet sustainability criteria, including saving 60% carbon compared with fossil fuel.

VoG Council limits Recycling to feed 25-year Incinerator contract

The VoG Council is being asked to confirm its 65% limit on recycling for the 25-year Project Gwyrdd / Incinerator contract.

Project Gwyrdd wants Councils to sign contracts for Guaranteed Minimum Payments for 25 years, based on supplying municipal waste whatever success in reducing volumes and recycling rates.

Calling them Guaranteed Minimum Annual Tonnages last November, P. Gwyrdd recognised this looked like guaranteeing production of waste to feed their incinerator, so changed the name to guaranteed Payments.

Same difference! Each Council is to pay based on guesses at future waste volumes and aiming for only 65% recycling by 2025. Both should be challenged.

P Gwyrdd planned in 2007/8 for increasing waste volumes, yet the statistics show continuing decrease since 2005, from 1.9 to 1.7 million tonnes in 2009/10 (diagram below). WAG set a target for slower decreases by 1.2% pa, then the total dropped faster last year because of the recession. Yet P. Gwyrdd clings to arguments for increasing waste to feed its incinerator.

Second, the Vale Council policy is to maximise recycling and composting, to conform to the Welsh Strategy. The rate has risen from 30% to 50% in a few years. Our leading Councillors talk of boosting recycling and foodwaste collections. They've contracted to Biffa who claim levels of 70% in exemplar Councils. Levels of 80-90% are said to be practicable.

So how can Council leaders contract to only 65% recycling and only by 2025?

FoE asks - will Plaid, the Independents and the Labour groups reject this figure? Will they reject any P. Gwyrdd contract that binds the VoG to residual waste levels based on the 65% and growing waste volumes​?

Wales reaches 50% Recycling: now count out Mega-Incinerators

Councils in Wales reach 50% Recycling making the Welsh target of 70% by 2025 look unambitious.  Various Councils and municipalities already exceed 70% or foresee this level before 2020.

The Vale of Glamorgan Council declares that they will “maximise recycling and composting”. So why set 65% by 2025? And why sign a long-term waste incinerator contract for 35% 'residuals'?

With an eye to the May local elections, the Docks Incinerator Action Group (DIAG) is approaching VoG politicians to reject the 65% limit, and force the Project Gwyrdd (incinerator) to produce revised plans for 70% recycling by 2020 and diminishing volumes of municipal waste (see Figure below).

Mega-Incinerators - No Way!

Figure:

MSW waste arisings in Wales – from Wastedataflow and Municipal Waste Management Report for Wales, 2009-10 (Nov. 2010, Welsh Government 2011).