SUCCESS! Council comes out firmly against Biomass Incinerator

 All but one of the Vale of Glam Councillors voted on Wed. 27^th to

1 Share public concern that no EIA was ever done

2 Review all VoG planning decisions on the incinerator

3 Urge Welsh Govt to issue a Discontinuance Order

4 Consider the expediency of taking enforcement action

This massive industrial plant, close to homes, has no valid planning permission.
Many Conditions on the Outline permission are still unmet, and the buildings differ.
They have to re-start with a proper EIA for a DNS application, or just give up.

The Welsh Minister has to do what she has been avoiding since last April when her Planning officers advised her to issue a Discontinuance Order to comply with her duty to prevent the plant operating without EIA.

The Council Motion's 4th point was amended from the original moved by Cllr Vince Bailey that specified the cessation of all operations on site.  These words were copied from their own Planning Officer who warned the company that 

the only remedy to such a breach of planning control would be to require the removal of the development in its entirety or, at the very least, the cessation of all operations on site.

That is what the public is expecting, now that the Incinerator is in breach of a whole slew of Conditions on the 2015 outline planning consent.  The Vale officers allowed them to breach conditions on noise, emissions and no nightime working when constructing the plant.  At last the Councillors have stepped firmly against this lawless company.

Long-outdated Air Pollution assessment still used in Wales

The official Welsh (WG) classification of Air Pollution levels (link) is inherited from the old Department of Health (DoH), based on COMEAP 'experts' who've changed their minds below). It’s still posted up for use, despite new Welsh policy issued in 2017. This included statutory guidance to Local Authorities on giving special consideration to the long-term risks posed to babies and children via exposure to air pollution. The old DoH/WG classification doesn’t.  This daily air quality index (DAQI) is also based on quite outdated standards for adults.

The World Health Organisation produced guidance in 2012/13, including identifying PM2.5 as a human carcinogen, but the WG took no notice until the Minister’s statement of June 2017. Revised WHO Air quality guidelines are due out in 2020. 

The WHO annual mean concentration guideline for particulate matter stipulates that PM2.5 not exceed 10 μg/m³ annual mean and 25 μg/m³ 24-hour mean; also that PM10 not exceed 20 μg/m³ annual mean, or 50 μg/m³ daily mean ( 24-hour).  PM2.5 is most closely related to ill-health impacts (see below).

The DoH/Welsh classification clings to the pre-WHO numbers, calling PM2.5 values below 35  “low” (40% higher than the WHO limit) and below 53 “moderate” (double the WHO limit).  It’s highly remiss of the Environment Minister that she has failed to withdraw this completely misleading classification and issue a new one for guidance of the people of Wales.

Vale of Glamorgan monitoring of the Barry 'Biomass' Incinerator

The Council has purchased two monitors that measure PM10, PM2.5 and NO2 every 15 minutes.  The averages for each hour are now posted daily.   We presume the numbers are accurate as the monitors have been working for two years.  However, users should ignore the low/moderate/high classification and colouring, which are the old defective WG/DoH ones above. 

View of the World Health Organisation (WHO) on particulate pollution (link)

Outdoor air pollution is a major environmental health problem affecting everyone in low-, middle-, and high-income countries.

   Ambient (outdoor) air pollution in both cities and rural areas was estimated to cause 4.2 million premature deaths worldwide per year in 2016; this mortality is due to exposure to small particulate matter of 2.5 microns or less in diameter (PM2.5), which cause cardiovascular and respiratory disease, and cancers.

  People living in low- and middle-income countries disproportionately experience the burden of outdoor air pollution with 91% (of the 4.2 million premature deaths) occurring in low- and middle-income countries, and the greatest burden in the WHO South-East Asia and Western Pacific regions. The latest burden estimates reflect the very significant role air pollution plays in cardiovascular illness and death. More and more, evidence demonstrating the linkages between ambient air pollution and the cardiovascular disease risk is becoming available, including studies from highly polluted areas.

  WHO estimates that in 2016, some 58% of outdoor air pollution-related premature deaths were due to ischaemic heart disease and strokes, while 18% of deaths were due to chronic obstructive pulmonary disease and acute lower respiratory infections respectively, and 6% of deaths were due to lung cancer.

  Some deaths may be attributed to more than one risk factor at the same time. For example, both smoking and ambient air pollution affect lung cancer. Some lung cancer deaths could have been averted by improving ambient air quality, or by reducing tobacco smoking.

  A 2013 assessment by WHO’s International Agency for Research on Cancer (IARC) concluded that outdoor air pollution is carcinogenic to humans, with the particulate matter component of air pollution most closely associated with increased cancer incidence, especially lung cancer. An association also has been observed between outdoor air pollution and increase in cancer of the urinary tract/bladder.

Origin of the Air Quality index and Banding

COMEAP first introduced the UK’s Air Quality index in 1998 (Committee on Medical Effects of Air Pollutants:  Statement on Banding of Air Quality, 1998. Link).

Their subsequent 2011 Review of the UK Air Quality Index (Daily AQI or DAQI) was introduced by Defra and devolved administrations from 1 Jan.2012.  It was COMEAP’s final publication before being disbanded and the last effort of British medical pollution ‘experts’ to maintain that only sensitive people need worry about air pollution (even said as “exquisitely sensitive” in Prof. Harrison’s evidence for an incinerator company – Portsmouth Incinerator Inquiry, 2000**).  British medical policy leaders in COMEAP, including Prof Harrison, were compromised in favour of incinerators at that time. Evidence on permanent harm to child-lung development was accumulating, measured as lung function, US/Calif authorities were recommending against children exercising outdoors during high ozone episodes, and European experts were developing the WHO guidance.  Prof Stephen Holgate chaired the COMEAP Review, which is thick with material on asthma, Holgate’s speciality.  They devised the irresponsible advice that only children with ‘lung problems’ should ‘consider’ ‘reducing’ ‘strenuous’ exercise at times of moderate or high pollution. The report says they were motivated by inter alia 

•          the need to avoid an exaggerated level of worry and concern
•          our view that children with no known respiratory disease were unlikely to be particularly susceptible to the effects of air pollution.

Most or all of the Review group published a scientific paper (Gowers et al. 2012) which found “outdoor air pollution might play a role in causing asthma in susceptible individuals”, but dismissed it as only a small contribution and a small proportion of the population. COMEAP in effect dismissed the then evidence of the pollution causing onset of new asthma cases, instead of taking a precautionary approach ("exaggerated level of worry and concern"). They had failed to learn from the BSE episode - scientists...part of the problem: Nature, Oct. 2000).   Their advice to asthmatic children was just use their inhaler.

Nowadays, however, Stephen Holgate talks of pollution worsening asthma and COPD and even emphasises the need to reduce NO2 as a cause of new-onset child asthma.  Prof Harrison likewise changed his view, but their COMEAP report lives on the DAQI.  Even though Welsh government policy is reduction of NO2, their Health Boards play it down and their NRW permits increases in NO2 up to the old limits. 

** Unpublished Evidence, via Public Interest Consultants, 2000 

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.

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).

Fracking application REJECTED at Planning Meeting THURS 20th

Resounding victory!
The  Planning Committee unanimously rejected the Llandow application for test-boreholes for #fracking, mainly on the basis of Dwr Cymru arguments on  possible contamination of the groundwater.

BBC Wales broadcasted demonstrations outside the Civic offices live at 18:45 tonight.  The result was later broadcast at 22:30 by Cllr Nic Hodges (Plaid).

Congratulations to theValesaysNo campaign and all who joined in!

This unanimous rejection of the Planning Officer's recommendation should not only stop past practice of facilitating resubmission of a similar application, but also cause Rob Thomas to reflect on his rejection by the ruling Tory group and consider resigning.

No trust for Regulation of Fracking

At the VoG Scrutiny committee on Monday 17th Oct., one contributor declared:

The UK has no regulatory policy as fracking for gas is completely different from coal mining and conventional oil/gas wells.

The regulator (John Harrison, Environment Agency) was asked about the European groundwater directive, which forbids discharges of some chemicals to groundwater and is strongly restrictive on many others.  Since this Directive supports the bans of fracking in France and parts of Germany, why is the EA in England and Wales not applying it similarly?

… one of the things we will take into consideration (John Harrison replied) when we have an applicant’s information on their permit application. 

That sounds like -  try it and see if there are any problems, rather than ban it until we know the groundwater will not be polluted (highly unlikely on US experience). 

Though government tells us to rely on the EA to protect our environment, this exchange shows we and the VoG Council cannot do so.

Scrutiny exposure of Fracking in the Vale

Vale E&E Scrutiny Committee on FRACKING,
  in Council Chamber, Barry 17 Oct. 2011

A range of protesters and independents were permitted to put a 10-minute case to the Committee, with the applicants (a 'family' business, Coastal Oil and Gas) taking twice that long. Cllr Chris Williams in the Chair told everyone not to relate it to the planning application, but then the chief Officer outlined his planning report on the Llandow application. He reported the reply from the First Minister to the Council Leader as arriving too late, giving no guidance and “in essence” saying the application was for local determination. Yet that letter arrived on the day of the evening planning committee (29 Sept.) but was held back, presumably as it said of unconventional gas extraction that

•  “there are additional environmental considerations” and
•  “a precautionary approach should be taken”.

As well as Louis Evans of ValeSaysNo, an ex-industrial chemist Chris Smith and a US investigative journalist Dennis Campbell, were most impressive. Prof. Joe Cartwright of Cardiff Uni tried to argue the fracking process had been used for decades, but was slapped down by others saying it's near horizontal drilling along the strata and injection of chemicals at high pressure with extraction of flow water that is new. Friends of the Earth speaker, Max Wallis, stressed that the leaks of methane in fracking make it as bad as coal – so a switch to fracking-gas fuel can't help meet the UK's carbon targets.

Cllr Rob Curtis, who'd called for the special meeting, proposed a paper motion calling for a suspension of fracking permits until public concerns had been assuaged – and none of the Committee dared vote against. One said forcefully that there's no regulatory regime in place – despite government talk that the public should rely on the Environment Agency as regulator – as fracking for gas is fundamentally different from coal mining and oil extraction. Another said “precaution” requires us to wait a few years pending sufficient evidence.

Friends of the Earth Condemns Vale-of-Glam's change to co-mingled Recycling

Vale Faltering on Recycling Collections   – their rushed decision on short-term Switch to Non-separation threatens Long-term costs

The VoG change is based on conclusions to a shoddy unfinished report. The Council claims support from the Welsh Government, but it’s contrary to the 2011 well-based study** and neither they nor the public can see the VoG consultants' study. The Vale’s Scrutiny Committee failed to examine the issue.

The VoG officers wrote in the report to Cabinet^^ that they “have long believed” in co-mingling (s.8), say there are “drivers requiring a change to co-mingled collections” and rushed to decision before the study results are available (end of financial year) (s.14). It appears they fixed the consultants in order to avoid the earlier conclusions and criticisms of their failures.

Chief waste officer Clifford Parrish in the Council 2-page ad (in the Glamorgan Gem and the B&DN/Penarth Times in July) cited a survey of the top 30 Councils in England and Wales, but not that it was from a big operator of co-mingled systems, and failed to mention the newer Welsh Government-sponsored in-depth and independent study of Welsh authorities. Note that Mr Parrish must take the rap for the Vale’s poor performance relative to all authorities.

The VoG recycling/composting collections are faltering at 38.5% and stagnant, comparing badly with other Welsh authorities. Bridgend's recycling rate exceeds 50% (52% Oct-Dec., 51% July-Sept 2010, up from 33% in 2009), Wales is on 42% (WAG 12 Jan., 29 Mar.,2011). Anglesey and Denbighshire reached 57%. The report said the officers visited Bridgend but suppressed Bridgend’s advice and the possibility of following their example.

Places like Caerphilly (51%) and Cardiff (42%) count all material collected as ‘recycled’ despite rejects being high. Currently the figures are fiddled because all rejects are counted as industrial waste. The Vale Council wants to use this loophole (or scam), but it will soon be closed.

Rather than look at the real reasons, the Vale officers rushed*^ to change to non-separation like Cardiff, despite this being against Welsh government advice and findings on cost-effectiveness. The Welsh report** finds:

• “when optimised systems are compared for all options, kerbside sorting does appear to have the potential to offer a lower overall cost. The advantages of kerbside sorting appear to increase as recycling performance increases. These results suggest that Welsh local authorities will face a challenge in adapting collection systems that may work well now, but may become increasingly sub-optimal as recycling levels increase towards the 70% target.

** Kerbside Collection Options www.eunomia.co.uk/.../Eunomia%20Kerbside%20Collections%20Options%20Final.pdf

• Recently, WAG commissioned consultants to examine the relative merits of different dry recycling systems, making an in depth study of six Welsh 'case study' recycling schemes (two co-mingled, two with material separated into two streams at the point of collection, and two with kerbside sort.
• Their conclusions (Jan.2011) were that “kerbside sort collection... would result in lower financial cost than either co-mingled or two-stream collection (but) the difference in cost is relatively small”. Then with future increased recycling “the cost gap is much greater, with co-mingled and two-stream collection costing £25.6 million (or 22%) and £25.8 (or 22.2%) more respectively” (across Wales).

^^ VoG Cabinet Report of 6^th July 2011  Future Kerbside Recycling Collections

*^  In Sept. 2010, the overall chief Miles Punter was critical of the quality of recycled materials coming through Cardiff's system, told us that he was opposed to co-mingled collection and that any change would be at least a year off and after careful consideration.   Instead they rushed the change through in 9 months - prior to consultants reporting, failing to mention WAG's report of Jan. 2011and  with minimal consultation.

Special VoG council meeting dedicated to fracking

EXTRAORDINARY meeting of a South Wales council will hear arguments on both sides of the debate over the controversial extraction of shale gas in the region.

"Vale Says NO" gives 6pm on Mon. 17th October, which follows a showing of the film Gasland at 3pm and is open to the public.

 Peter Collins reported in the SW Echo 8th Oct.:

Councillors are to hold a special meeting of the Vale of Glamorgan’s economy and environment committee amid growing concerns over plans which could lead to a full-scale fracking operation at the Llandow Industrial Estate.

The Vale Says No campaign group have been invited to address the committee alongside Eden Energy and Coastal Oil and Gas, which has submitted plans to test drill for shale gas at Llandow.

Under planning regulations, the council’s planning committee will have to reach a decision on the plan by October 12 (untrue, and the deferral on 29 Sept. means they won't).

If the test drilling verifies the company’s estimates of the size of the shale gas reserve underneath South Wales, it could open the way for an application for a full-scale hydraulic fracturing operation, known as fracking, to extract the gas.

Pressure is also mounting on the Welsh Government and the UK Government to produce a framework to guide councils faced with planning applications for fracking, which has been accused in America of polluting water supplies.

The scrutiny committee has written to both governments, the Welsh Local Government Association and all Welsh MPs and AMs demanding action on a policy framework.

Environmental campaigner and councillor Rob Curtis said: “The potential discovery of a huge shale gas field below the South Wales coalfield means residents of the Vale need an evidence-based policy which will help protect their local environment.”

Vale council leader Gordon Kemp has called on the Welsh Government to deal with fracking applications given “the significant sensitivities” around applications.

He has called on the Welsh Government to take responsibility in planning matters relating to the exploration and exploitation of shale gas reserves and produce a national Welsh framework policy.

The Welsh Government said it would “welcome working with the UK Government on developing a framework for the whole of UK.”

Louise Evans, of the Vale Says No campaign, said: “I welcome the opportunity to address the committee on this important issue.”

Gerwyn Williams of Coastal Oil and Gas could not be contacted.

The Vale Says No campaign will hold a protest surgery at Cowbridge Town Hall starting at noon on 17th October (tbc).