Welsh Minister Julie James taken in by "carbon-negative" nonsense

Incredibly, the Minister Julie James has been persuaded that the Barry Biomass incinerator would be “carbon negative” so help “build a stronger greener economy... towards decarbonisation”.

These words are in the Minister's letter of 29 July 2021 to DIAG, when she announced that she would assist the company's to overcome the EIA failure. So one would expect this assessment to be firmly based. But it isn't. She repeated numbers from the company, numbers that NRW repeated without scrutiny, apparently lacking any capability among her officials.

Here are Some Numbers, taken from the company 

Burns annually 86 000 tonnes wood wastes - gives direct emissions of 129 000 tonnes CO2. 

Uses over 5000 tonnes for process chemicals and start-up diesel (company figures in 2017), 

Another 20-30 000 tonnes CO2 is due to transport and chipping (the company ignores)

The company say they'd produce 80 000 MWh electricity a year, displacing electrical power otherwise coming from the Grid.

Figures for the average CO2 per MWh from the Grid are published each year - about 0.2 tonnes now with projected decrease to 0.1 tonnes per MWh in 2028 and lower in the 2030s. 

 So their electrical output will save a puny 8000 tonnes CO2 annually coming from Grid electricity - much less than the 25-35 000 tonnes above just for transport, chipping and chemicals+start-up diesel.

Julie James should have smelt a rat when the company claimed the 129 000 tonnes emitted CO2 doesn't count because it's “biomass”. Yet waste wood

# contains composites like MDF (10% level of glue etc.), as well as coatings and preservatives

# much is chipboard, whose coating can be stripped and the chips recycled into new board.

CO2 from glues and coatings is largely fossil; CO2 from burning recyclable woodchip has to be counted even on the bio-CO2 excuse.

Europe has ended subsidy to incineration, as they've realised it impedes the transition towards a carbon-neutral and circular economy. Julie James is responsible in Wales, but incredibly none of her civil servants are able to manage the numbers.

Av. CO2 from UK electricity.  Drops below 100 (kg/MWh or g/kWh) in the 2030s, while Julie James believed Biomass's quote of levels from 2013-14 in claiming CO2 "offset" makes it "carbon negative".

----  References to the Circular Economy ----

The EU in 2021 ended subsidies to Waste-to-Energy incineration, recognizing that WtE opposes the transition towards a carbon-neutral and circular economy

 Waste incineration is a carbon-intensive process [1] undermining the efforts to decrease carbon emissions and, thus, to reach carbon neutrality on time. Additionally, it .harms rather than supports the transition to a circular economy [2] Since both non-recyclable and recyclable waste can be used as a feedstock to a waste incinerator, waste prevention and recycling are discouraged [3],

[1] https://zerowasteeurope.eu/wp-content/uploads/edd/2019/09/ZWE_Policy-briefing_The-impact-of-Waste-to-Energy-incineration-on-Climate.pdf

[2] https://zerowasteeurope.eu/2019/09/waste-to-energy-is-not-sustainable/

[3] https://zerowasteeurope.eu/2017/10/deliver-pay-waste-incineration-causes-recycling-slow/

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 

Cardiff Incinerator challenge by CATI in High Court

NEWS FROM HIGH COURT    17-18th Dec.

The barrister Alex Goodman' case explained why Cardiff Council’s repeated delay to enforce against Viridor’s unlawful building work and failing to require retrospective permission was unique in British law.  Then Cardiff Council’s lawyer took 80 minutes, making brash assertions, some obviously in error. Viridor's barrister came in on Cardiff's side, claiming nothing wrong with starting building 8 months before permission, despite the Council telling them it was unlawful. There followed detailed argument on case law (Whitley Principles) then judge Wyn Wuilliams reserved his decision till later in January.

Cardiff council attacked over city incinerator

www.walesonline.co.uk

Cardiff council must “quash” decisions that allowed work to construct an incinerator to begin because they were taken unlawfully, Cardiff High Court heard today (17 December).

In an action brought by Cardiff Against The Incinerator campaigner Pauline Ellaway, barrister Alex Goodman told Judge Wyn Williams the authority had flouted regulations and allowed waste management firm Viridor to build in Splott when it should not have done so.

Dubbing the council’s actions “procedurally inept” he claimed the authority’s reports and consultation process were flawed and that it failed to stop work when it should have.

Mr Goodman insisted CATI’s “submissions fell on deaf ears because work was allowed to proceed.”

“No robust action was being taken in respect of development that was continuning apace,” Mr Goodman said.

Construction of the £185m plant started in July 2012 before planning conditions had been met.

Developers must “obtain consent and then commence works,” Mr Goodman insisted. “It is a simple sequence,” he said.

CATI’s solicitors repeatedly sent letters requesting enforcement be taken.

“Throughout the claimant has taken considerable action to encourage the council to take action,” Mr Goodman said.

“The council has always acknowledged it was unlawful and that the development was at risk.”

Despite this Mr Goodman said the authority allowed work to go ahead.

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]

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).

PFI rip-off for Incinerators - BBC Panorama + Call from the Treasury

This week is set to mark the end of PFI as we've known it.
## Panorama on Monday and BBC News Channel Thurs 4.30, Sunday 20.30
             "Who's getting rich on your money" via PPP/PFI ?
## Call for evidence from the Treasury comes out on Thurs. for its inquiry into alternatives.
(Both below)

PFI has massively favoured incineration. £3 billion capital spend in the pipeline in England; £2bn commitments in Wales.  The weighting given to 'bankable technology' and giant infrastructure has more-or-less ruled out modular flexible alternatives. On top of which are the PFI credits given as inducements to councils to take on PFI debt. These credits amount to far more than is being given to the Green Investment Bank to support the development of new waste technologies.

Of the total 61 PFI projects still about to go through under the old discredited system, 39% are for waste infrastructure. This is much the largest tranche and represents 3 times that of hospitals and 7x that of schools. Of the 11 PFI waste contracts under procurement 9 are for incinerators. Along with other waste PFIs still in the pipeline this sector accounts for £3 billion of capital spending.

Jesse Norman MP led the campaign to get PFI reviewed and  has called for a moratorium on all those in the pipe-line. The Treasury has ignored this so far.

PFI reform: Call for evidence www.hm-treasury.gov.uk/iuk_pfi_reform_call_for_evidence.htm

The Government will be launching a call for evidence on 1 December that aims to capture the learning and lessons of the past 20 years of PFI. We will look to use those lessons to help inform the development of a new model that addresses the concerns of PFI. We invite those across the private and public sector that have strong ideas on how the future model should work to come forward with proposals and contribute to the development of a new delivery model.

The Government’s approach to reform will be guided by the following principles, for a model that

• is less expensive, and that uses private sector innovation to deliver services more cost effectively;
• can access a wider range of financing sources, including encouraging a stronger role to be played by pension fund investment;
• strikes a better balance between risk and reward to the private sector;
• has greater flexibility to accommodate changing public service needs over time;
• maintains the incentive on the private sector to deliver capital projects to time and to budget and to take performance risk on the delivery of services;
• delivers an accelerated and cheaper procurement process; and
• gives greater financial transparency at all levels of the project so that the public sector is confident that it is getting what it paid for, and that the taxpayer is sure it is getting a fair deal now and over the longer term.

MONDAY @ 20:30 on BBC One   .... also Thurs, Fri and Sunday Who's Getting Rich on your Money?

As Government spending cuts bite, one group of businessmen know they will keep making vast profits from our taxes while getting us ever deeper into debt. Since 1997 almost every new school and hospital in the UK has been built by private companies who lease them back to the government. But what's in it for the taxpayer?
John Ware investigates the inflexible terms and conditions of what has become the government's flexible friend - the Private Finance Initiative - a kind of ministerial credit card which racks up huge public debts without showing on the nation's balance sheet. He uncovers evidence of how government claims that PFI gives taxpayers value for money have been manipulated.
And he asks why the coalition government signed so many PFI deals when in opposition both the prime minister and his deputy branded them as 'dodgy accounting'.

    Credits:  Reporter John Ware;  Producer Leo Telling;  Executive Producer Eammon Matthews

Broadcasts

1. Mon 28 Nov 2011 20:30 BBC One
2. Thu 1 Dec 2011 04:30 BBC News Channel
3. Fri 2 Dec 2011 00:25 BBC One (except Northern Ireland, Wales)
4. Sun 4 Dec 2011 20:30 BBC News Channel