Key objections to the Voluntary Retrospective travesty of the law for Barry Biomass Incinerator

 This Voluntary Retrospective EIA deserves ridicule and should be dumped.

responses to documents on barrybiomassconsultation.online were due by 17 January, but it's now blocked.  FoE's full response can be downloaded from Facebook

The “scope” was limited in cosy discussions between the WGovt and Barry Biomass outside EIA rules. Welsh policy supports community Health Impact Assessments, but this was ignored. The Welsh Government supports the rights of children to be consulted, but ignored it here.

They limited the site to the original area, yet operating the plant depends on using the northern extension and using Berth 31. They've been caught out by the VoG's enforcement action including the northern extension.

By basing the EIA on 2016, they tried to avoid Welsh 2017 policy on air pollution which adopted the WHO findings of harm at pollution levels below the legal limits and greater harm to vulnerable people.

What are the Critical Objections that should cause the downfall of this Incinerator?

#  Tight air pollution standards issued by the WHO in September over-rule the old limits used in the EIA. This arises as the legal criterion in waste management is no-harm-to-health; the new WHO Guidelines implement this. Barry already comes above the WHO standards.

# Ignoring the law requiring use of the waste heat, refusing to assess opportunities for it

# Ignoring the EIA requirement to assess major accidents and disasters, with their off-site impacts on the local community. There is no assurance the plant can be operated without harm to health and the environment.

# Failure to conduct a community Health Impact Assessment and involve children it it, despite their vulnerability to pollutants, contrary to Welsh policy. Ignoring the health hazard from ultrafine particulates.

# Using the wrong stack diameter: that constructed is 2.75m, but they've calculated the fumes from a 1.6m stack, claiming little difference. In fact it means the smoke plume emerges too slowly, is caught in stack eddies and easily descends onto housing.  Plume calculations are poor in Barry's basin and the 43m height is too short to clear Barry's hills

# Refusal to provide data on the composition of the wood-waste, with its chemicals in coatings etc., likewise no data from comparable working plants abroad.

# Failure to consider noise and pollution at the nearest housing, currently being built at East Quay site. The excuse there was no housing there in 2016 won't wash. Suppressing the issue equals lying.

# Carbon emissions higher than the UK power supply. They falsely claim a huge carbon allowance from replacing other electricity generators (670 instead of the 200 in 2020 and under 100 gCO2/kWh in the 2030s). They claim the few % plastics in the waste is 'biogenic' and fail to exclude the fraction that's recyclable. The emissions from their inefficient wood burning come to 1600 gCO2/kWh, a complete embarrassment to Wales.

# Discharge of the industrial effluent to sewer cannot be allowed, as it frequently discharges (via the Barry Storm CSO, 120 times a year) into the Dock. Nothing is said on the environmental sensitivity and watersport activities that would be impacted by the effluent.

# Tidal surge flooding required the raising of the nearby East Quay site to 8.9m AOD (Q100 level: 8.76m). The David Davies road entrance is 7.6m AOD.

THE FINAL BLOW; The public has a right to expect government to follow the rule of law, not choose bit and make arbitrary changes to help BUK. This ECHR right is called Article 8: the Welsh Government collusion with BUK is in flagrant breach of it.