Does WAG supports Merthyr incinertaor application?

Can't change hundreds of tons of rubbish into NOTHING! No incineration produces ZERO Waste . Ms Davidson said: "We need new collection services and new infrastructure  (incinerators?..really?) to use waste in the best possible way (waste to toxins best?) and stop dumping in landfill. "The extra Assembly Government funding opens the way for Prosiect Gwyrdd to move forwards so we can make the most of our resources by producing much-needed energy," she added. (?????) ... But when applied to incinerators, "energy from waste" is a dangerous euphemism. Far from being a sensible, environmentally friendly solution to the enormous amount of  waste created in Wales, incineration is a nasty quick fix to deal with our ever-growing waste mountain. Government "peddling myth" of green energy-from-waste here .. FoE's Senior Waste Campaigner, Dr Michael Warhurst said: "The government and waste industry must stop peddling                                                                                                                                                                                                     the myth that waste incineration is green energy. Incinerators can generate electricity, but they produce more climate emissions than a gas-fired power station." And they are using your money.. The announcement followed the proposal of a grant from WAG of up to £7.8 million to help develop plans for EfW projects across South Wales (RWW 654). Called Prosiect Gwyrdd (Project Green),..(couldn't make it up).. the scheme is a joint initiative between five councils in South Wales (Cardiff, Newport, Monmouth, Vale of Glamorgan and Caerphilly). Covanta Waste-to-Toxins Incinerator Why are the assembly government been encouraging a company that has a string of environmental breaches and union-bashing... why the secrecy? Thursday 29 January 2009 Covanta press release Covanta En ergy to Build $575 Million Energy-from-Waste Plant in Wales, UK Welsh Assembly Government Deputy First Minister, Ieuan Wyn Jones, said, “I welcome Covanta’s inte rest in Wales. The company has a strong reputation for waste to energy activities in the United States in terms of municipal and commercial and industrial waste. Covanta is at the start of a journey which will involve it in applying for planning permission and in tendering for local authority projects alongside oth er interested parties.”

30 Jan 09 Covanta Energy has had detailed discussions about the project with WAG) and IBW, and will begin consulting February 2 with the local population
1st Feb 2009 ...The project, which is being developed following discussions
with International Business Wales (IBW) and the Welsh Assembly Government (WAG),.....

Huw ‘gravy train’ Lewis, labour assembly member for Merthyr Tydfil (even though he lives in Penarth with fellow Labour AM Lynne Neagle) has recently been heard criticising US firm Coventa over plans to build a huge waste INCINERATOR in his constituency. Lewis is right to express his concerns. Covanta was found guilty of violating employment laws in the US and has been fined hundreds of thousands of pounds after exceeding emission levels of carcinogenic chemicals from its American incinerators.

Promoted by IBW "the investment arm of WAG", visited by the deputy First Minister who then organised a "very high leve l meeting" 20 Oct. (brief prepared by IBW's CEO Geraint Jones with input from Covanta). Covanta chiefs met by Rhodri Morgan and Jane Davidson when they came over... And as the e-mails say. they had to be careful not to be seen as promoting Covanta. So at the launch visit on 2 Feb., they decided the DFM was "unable to meet the company" as originally programmed (further e-mails released under FoI).

Layne, Stephen (DE&T - PSCS)
Powell. Mark (DE&T PSCS)
26 January 2009 17:38
Mel Hiscox
From:
Sent:
To:
Cc: Linnard, Sharon (DE&T Ops Invest Wales); Williams, lan (DE&T -lBW); Geraint Jones; Hnyda, Mike (DE&T
-lBW); EKin-Wood. Shan (DE&T MCT); PS Deputy First Minister
Subject: 20090126
Importance: High
'Thanks Mel.
think that we have a potential problem with the Minister being involved in the formal announcement. That concerns the fact that the company has not yet applied for planning permission, that it does not intend to do so for some months, that the
activity could generate local hostility and that the planning application could potentially be called in.
have spoken to Chris Warner who is uneasy but we have agreed to re-group tomorrow.
"'Mark Powell
-Head of Government Business
'Policy, Strategy and Corporate Services and International Business Wales
Department for the Economy and Transport
'Ias Glyndwr
Kingsway
Cardiff F10 3AH
Tel: +44 29 2036 8253
Mobile: +44 7769 883271
From: EKin-Wood, Shan (DE&T MCT)
sent: 26 January 2009 10:02
To: Powell, Mark (DE&T PSCS)
Subject: FW: Covanta
Hi Mark - do you want me to draft some comments or do u have some bullet points with the key messages we want to get across. Having read the documents we obviously need to mention his visit to several of the company 's operations in US, world leading technology etc plus potential for attracting others companies, environmental benefits - although we need to be a bit careful as planning has not been lodged or approved yet.
How do you want to do this??
regards
Shan
Shan Ekin-Wood
Operational PR Manager/Rheolydd Cysylltiadau Cyhoeddus Gweithredol
Welsh Assembly Govemment/llywodraeth Cynulliad Cymru
TeVFfon 02920 898636
Mob.07767486935
E-mail/E-bost shan.ekin-wood@wales.gsLgov.uk
From: Mel Hiscox [mailto:Mel.Hiscox@ibwales.com]
Sent: 25 January 2009 19:55
To: Powell, Mark (DE&T PSCS)
Cc: Geralnt Jonesj EKin-Wood, Shan (DE&T Mer); PS Deputy Rrst Minister
Subject: Covanta
Hi Mark.
Hope you had a good weekend.
20/0212009
~ discussed on Friday, please find attached suggested press release from Covanta.
From our side everything looks fine on content and the company have been very agreeable to us working this up with them.
With regards to the DFM comment requested, Chrls Warner IS aware that I'm channelling this through yourself and will wait to hear from you (Shan also). Could I just ask that any comment include a reference to the DFM's visit to the company and meeting with them during the Ryder Cup in Kentucky.

Further detailed project info. is also attached in a draft letter (awaiting further changes so please treat as confidential at this stage) which will be sent out to all local authority leaders on Saturday 31 61 January (For North Wales consortium, Chris Everet Flintshire) is leading so a personalised version of this will be sent to him for the group). An electronic copy will also be emailed
to all of them on Monday, February 2nd to coincide with the launch date. The only departure from this will be a planned meeting on Monday, 26th January with Jeff Edwards of MTBC but I understand from the client he is already aware of and supportive of the project.

For your background info., plann ed timeline of events over the next week or so are as follows:
• Monday, 26th January - Meeting with MTBC.
• Wednesday, 28th January - Working lunch with DFM to advise and discuss launch.
• Thursday 29th
/ Friday 30th
- Other senior officials from MTBC and CCBC to be advised of forthcoming release (not
detailed info. but heads up )
• Monday, 2nd February - 11 :OOam Press release and official launch date. DFM to visit site for tour and press.
:Chris / Shan.......Thanks again for your help with this. I shall funnel further developments through Mark this week given time
jiff. etc. we have one point of contact with most up to date info.) Geraint is also in Wales on business this week so where
Jossible will attend relevant meetings from our side also.
Mark....hope this is OK, thanks for you r help. Please give me a call to chat through your thoughts when you get a moment.
Hope to speak soon, all the best,
Mel
Mr. Mel Hiscox Senior Vice President International Business Wales
Wales International Center, The Chrysler Building
405 Lexington Avenue, 21st Floor, New York, NY 10174
Direct: +1 (646) 7 92 8922/ Cell (US): +1 (917) 815 7294/ Mobile (UK): +44 (0)7757 681926
www.ibwales.com

International Business Wales is the main investment arm of the Welsh Assembly Government. Our free and confidential service is aimed at giving you everything you need to set up or expand your company's operations in Wales. UK.

Jeff Edwards is the Mert h yr Leader (Independents) who denied he ever met Covanta pre-january, and then had to admit lying because they had agreed to keep the 22 Sept meeting secret.
'Mr Lewis and Labour Group leader Brendan Toomey claim to have seen documents released under a Freedom of Information request that show Coun Edwards signalled support for Covanta in September, despite claims in January that he had no previous dealings with the company.' more here

"COUN CLIVE TO VEY Gurnos Ward

Labour group leader Brendon Toomey added: ‘It appears that clandestine meetings have taken place’.

In my reply I wrote: ‘If Councillor Toomey is worried about ‘clandestine meetings’ he should look no further than then Labour Party in Cardiff and perhaps his ward colleague Huw Lewis AM’.

I have been proved to be correct. I now have a copy of an e-mail sent from Covanta Energy to the Welsh Assembly Government dated September 23, 2008. It was quite clear that the Welsh Assembly Government have been in negotiations with Covanta Energy since September 2008"

Residents A

gainst Ffos-y-Fran (R.A.F.F.)

.INCINERATOR INFORMATION PAGE

Campaigners say USA firm’s safety record should bar it from Wales

Gordon James, director of Friends of the Earth Cymru, said: “This is the latest in a number of worrying incidents where this company has been cited for unacceptable practices. There should be no welcome in Wales for a company with such a blemished track record.”

Wales becoming the land of spin

WAG Spin!!! Greenwash!!!

Re. Wales plans for energy self-sufficiency with renewables in 20 years

Friday 22 May 2009

Wales becoming the land of spin

How do the boasts about 'green' waste and carbon targets (Guardian 22 May) square with the Welsh government support for the largest waste incinerator in Europe – the proposal by US giant Covanta for a 600 000 tonne/year incinerator at Merthyr Tydfil?

Such an incinerator is to produce “renewable” electricity and to be sited far from any significant use of its heat (wastes 75% of its energy). Second, its 200 000 tonne/year of ash are to be used as building aggregate and defined as “recycling”.

The Welsh government will try and get round the toxicity testing that forces much of such ash to be classed as hazardous waste. Any that is hazardous, including the 10 000 tonne/year flyash, will be sent for dumping in England, as there are no hazardous waste dumps in Wales.

The small print of their waste plan says the recycling target will not be 70% but 63% by including the incinerator ash, a re-definition of recycling that's special to Wales**.

The new gas-fired power station at Pembroke (huge, 2000 megwatt) will be defined as supplying electricity to England, so not counted. The CO2 from the new biomass power station at Port Talbot (world's largest, 350 megawatt) will not be counted, though burning imported wood waste from non-sustainable forestry and emitting much carbon in transport.

How do you claim Wales is in advance on renewable energy, when Scotland is forging ahead? They have detailed proposals for heat, hydropower and marine currents, with big plans for Pentland Firth, while in Wales we get 'taffy' talk. Go to the Scottish Renewables Festival in Edinburgh mid-June to smell some action!

It’s 18 months since the Welsh Minister proposed increasing recycling to 70%, which the best European areas already achieve. Consultants Eunomia advised 80% or more – but the Minister laughably reduced the target to 63% and deferred it till 2025. The reason is – the policy is driven by a decision to build waste incinerators, spun as high efficiency, green and clean. Wales is shamed by the resort to sustained spin!

---------------------------------------------
Max Wallis
Friends of the Earth SE Wales waste Network

** http://waleswastestrategy.dialoguebydesign.net/docs/FutureDirectionsForMunicipalWasteManagementInWales.pdf

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.

----------------------------------------------------------------------------

Max Wallis, SE Wales FoE Waste Group, May 2009

---

[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

Can't TRUST Viridor

Viridor Denies Falsified Incinerator Records

Viridor, new to incinerators, are applying to build a large incinerator in Cardiff Bay

The authoritative ENDS (Environmental Data Services) Report for April 2009 reports allegations of malpractice and environmental failures at the Raikes Lane incinerator in Bolton plant by a former employee.

Patrick Sudlow served seven years as a process controller with Greater Manchester Waste, the former council waste company that ran the incinerator and was recently taken over by Viridor.

He told ENDS that he experienced routine falsification of pollution-monitoring records and logbook data, illicit effluent discharges to sewer and engineering problems which have endangered the health of operators. The malpractices, he said, were never spotted by the Environment Agency.

Mr Sudlow had an engineering background running high-pressure steam boilers in the Royal Navy, but said he was appalled by the incinerator’s poor mechanical condition, improper maintenance and the covering up of the plant’s poor performance. He said he “left because of the plant’s continued breaches of the Environment Protection Act, the site licence and other legislation."

One of his most serious allegations is that the plant’s continuous emissions monitoring system was regularly turned off during start-up and shutdown, and when the plant was operating abnormally. This means no accurate record of emissions would be made at these times and the flue gas treatment system was also not in use.

Normally abatement and emissions monitoring would be required at all times when waste was on the incinerator’s grate, but Mr Sudlow said there was an established procedure for turning off the monitoring and abatement system to make it appear the plant was shut down when it was still burning waste.

Mr Sudlow also alleged the management rewrote the incinerator logbooks which he said were bound in a plastic comb binder, allowing pages to be replaced at will. Changes were made to make it appear all waste was burnt off before shutdown, he said, when in fact it had not been. The aim, he said, was to obtain maximum throughput of waste and to ensure the logbook agreed with emissions-monitoring data. An example of rewritten log-book pages is available.

Viridor is aware of the plant’s alleged problems. Mr Sudlow said he contacted them in the past but there was no response. Yet Viridor told ENDS that Mr Sudlow failed to bring these issues to the management’s attention either informally or using established grievance procedures.

Effluent was supposed to be recycled in the process or tankered off-site for disposal, but Mr Sudlow alleged the liquid (likely to be high in dissolved metals) had been discharged to sewer at night.

Viridor deny that processed water has been discharged to sewer and that the grate performs badly. Refractory wall failures have occurred on a very small number of occasions, Viridor said, but the failures were immediately repaired. But Mr Sudlow describes regular breaches of the refractory wall and rock wool padding being used to plug the holes.

The Environment Agency said it was investigating Mr Sudlow’s claims. In a statement to ENDS it said: "All significant emissions to air are continuously monitored and reported… monthly. We also carry out regular inspections including unannounced spot checks."

As Viridor have only recently taken over running of the plant, one might expect them to promise to investigate and, if necessary, tighten up management procedures. Just dismissing the reports as from a “disgruntled former employee" indicates they intent to remain in denial.

Cost of Hazardous waste!

"An Environment Agency spokesman explained zinc oxide has been reclassified as ecotoxic, so if bottom ash contains zinc oxide, it is now hazardous. It has been added to a list of other substances that render bottom ash hazardous.
If bottom ash is not hazardous it can be sold as an aggregate. If it is hazardous it must be disposed of at a specialist site. Fees to dispose of hazardous waste are higher. In addition taxes rise from from £2.50 per tonne for material HM Revenue and Customs considers inert to £40 per tonne for material it considers hazardous."
http://beaconsfield.buckinghamshireadvertiser.co.uk/2009/04/county-council-says-brains-wro.html

Environment Food and Rural Affairs

Incinerators: Hazardous Substances

All Written Answers on 23 Mar 2009 « Previous answer Next answer »

Andrew Smith (Oxford East, Labour) | Hansard source

To ask the Secretary of State for Environment, Food and Rural Affairs whether incinerator operators are required to test incinerator bottom ash for H14 ecotoxicity; and if he will make a statement.

Jane Kennedy (Minister of State (Farming and the Environment), Department for Environment, Food and Rural Affairs; Liverpool, Wavertree, Labour) | Hansard source

holding answer 18 March 2009

Incinerator operators are required to test and assess their bottom ash for all hazards including H14.

Environment Agency - Classification of Incinerator Bottom Ash

Group fears waste made non toxic will cost taxpayer

Buckinghamshire Advertiser - ‎Apr 23, 2009‎

The Environment Agency is considering declaring incinerator ash as a hazardous material. If the ash is ruled as toxic, the cost of running the incinerator ...

Cardiff Planning Officers give incinerator ahelping hand

Do we believe the officers that 'no urban incinerator will accept a visit' -?

THIS is an INCINERATOR even though it avoids this word where possible!!!
NOT a clean 'ENERGY from Waste' ??? Who are they kiddding and there is no customer for this dirty energy!

A HUGE amount of emphasis in the report on energy from Waste
8.6 Sustainability
The proposed facility would provide (at capacity) approximately 30 Mega
Watts of electricity, enough to serve 30,000 homes. This is considered to be in
accordance with the aims of Planning Policy Wales and TAN 21. This is an
important feature of the proposal and..

The Welsh Assembly Government states that energy from waste facilities are
only acceptable if ‘they form part of an integrated approach and that they only
recover energy from residual waste that remains after as much recyclable and
compostable material as practically possible has been removed; they include
heat and power wherever practicable.

The applicant states that the proposed facility is intended to treat residual waste and that materials (such as metals) are to be recovered for recycling..

The carbon footprint of the development
Chapter 5.3 of the submitted Environmental Statement analyses the carbon
footprint of the proposed facility compared with landfill...(WRATE). Compared with Landfill an overall carbon saving of
between -108,000 tonnes and -196,000 tonnes will be achieved in the year 2013. Provided a user for the heat produced can be located the carbon footprint of the proposed facility is estimated to be in the order of -30,000
tonnes CO2eqv in 2013

Hazards of disposing of toxic fly ash sdismissed in this ONE para so this is big issue no 2 to tackle!!
The toxic fly ash is the residue of combustion removed from the flue gases
prior to release into the atmosphere, in order to reduce the pollutants emitted.
The facility would produce approximately 10,500 tonnes per annum. The fly
ash would be removed from the facility using enclosed tankers and would be
transported to a hazardous waste landfill (currently there are none in Wales)..


Looks like this will clash with SEW Waste group meeting - do we have a protest outside..etc7.5 Cardiff Friends of the Earth and South-East Wales Friends of the Earth Waste

From the report..the objections in addition to those by cllrs.
Then 8. ANALYSIS starts
8.1 This is a major application for an energy from waste facility which will comprise
14,400 square metres of internal floorspace and will treat approximately
350,000 tonnes of residual waste per annum.

FROM THE PAPERS to be found here
http://www.cardiff.gov.uk/content.asp?id=2292&$state=calendarmeeting&$committeeID=1423&$meetingdate=06/05/2009&$eventrec=5616

Group object to the proposed development on the following grounds (The full
objection letter is available for public viewing as a background paper):
• The proposed incinerator will, during the long period of its contract,
contravene the requirements laid down in the Waste Hierarchy to;
minimise waste arisings by reduction / prevention, and secure every
possible recovery of materials by re-use, recycling or composting before
burning.
• The proposed incinerator is not demonstrated to be the Best Practicable
Environmental Option, particularly with respect to climate change impact.
• There is public concern that the proposed incinerator will constitute a
health risk because hazardous substances produced, for example ultra
fine particle (
8. ANALYSIS
8.1 This is a major application for an energy from waste facility which will comprise
14,400 square metres of internal floorspace and will treat approximately
350,000 tonnes of residual waste per annum. The facility has a predicted
lifespan of approximately 25 years but may operate beyond this timeframe.
The proposed development includes a waste reception area including tipping
hall and bunkers, offices, a visitors centre, two stacks a weighbridge and
parking for HGVs and cars. The site will employ approximately 50 employees
on a shift basis and will operate 24 hours a day, 365 days per year. Deliveries
to the facility will generally be between the hours of 0700 and 1700 hours.

8.2 The agent has advised that there are approximately 22 energy from waste
facilities which are operating within the United Kingdom, treating residual
municipal, commercial and industrial waste and that there are also
approximately 10 further energy from waste facilities which are in the pipeline.
The applicant Viridor currently operates a clinical energy from waste facility in
Plymouth and is currently developing additional facilities in Exeter, (permission
was granted in May 2008 for a 60,000 tonne per annum facility) and Slough
(planning permission was granted in 2000 for a 400,000 tonne per annum
facility). Viridor has also submitted planning applications for similar facilities in
Oxford and East Lothian, which are being considered currently by the relevant
local planning authorities. It should be noted that the energy from waste
facilities which have been approved by other local planning authorities have
also given rise to a great deal of opposition.

8.3 There is an identified need for another method of disposing of residual waste
for not only Cardiff but for all of the Project Gwerdd Local Authorities of South
East Wales: Caerphilly, Cardiff, Monmouthshire, Newport and the Vale of
Glamorgan. The Lamby Way landfill site had a remaining capacity of only
approximately 200,000 tonnes in September 2008, with historic rates of
300,000 tonnes of waste per annum. The only other operating landfill site
within the Project Gwerdd authorities is at Dock Way Newport which has a
remaining capacity of approximately 300,000 tonnes with a disposal rate of
approximately 90,000 tonnes per annum (ie. approximately 4 years
remaining).

8.4 It is considered that the key planning considerations are as follows:
• European and National Policy
• Sustainability
• Land use policy
• Landscape and Visual Amenity
• Amenity including Air quality and health
• Water resources
• Transportation
• Archaeology and Cultural heritage
• Impact upon the Statutory Designated sites (ie. the Severn Estuary
Special Protection Area (SPA), Site of Conservation Importance (SCI) and
Wetland of International Importance (Ramsar Site) and Cardiff Beech
Woods Special Area of Conservation (SAC).
8.5 European and National Policy
In accordance with the requirements of European Directives, it is necessary to
divert the amount of municipal solid waste disposed of by landfill. Technical
Advice Note (TAN) 21 states that another potential for the waste resource is
as a fuel. ‘Recovery of energy can be done in a number of ways including
direct incineration of parts of the waste arisings that are otherwise of limited
use. Proposals that incorporate combined power and heat plant could
contribute towards district heating schemes. Energy recovery via incineration
is known not to be popular with some sectors of the public, even thought the
industry is now using cleaner and safer technologies than ever, with vastly
reduced and controllable emissions. In a policy area that is aiming to rely less
and less on landfill, the potential for energy from waste facilities is growing’.
The provision of an energy from waste facility accords with the local authority’s
overall commitment to reducing the amount of waste generated within Cardiff,
the reuse of waste materials wherever possible, and the recovery of value
from the residual waste fraction. It is considered that such a facility is required
as part of an integrated and sustainable waste management strategy. The
proposed development is considered to be in accordance with the Deposit
Cardiff Unitary Development Plan (October 2003), which states ‘Proposals for
the development of waste management facilities will be permitted if: g) they
include suitable proposals for energy recovery and the beneficial after-use
products’.
8.6 Sustainability
The proposed facility would provide (at capacity) approximately 30 Mega
Watts of electricity, enough to serve 30,000 homes. This is considered to be in
accordance with the aims of Planning Policy Wales and TAN 21. This is an
important feature of the proposal and, in the interests of sustainability, it is
considered that if planning permission were to be granted, persons having
relevant interest in the application site should enter into a binding planning
obligation in agreement with the Council under Section 106 of the Town and
Country Planning Act 1990 requiring them to use best endeavours to use and
market the energy generated from the incineration process and to produce an
annual report detailing the outcome of these endeavours for presentation to
the local planning authority and also to use reasonable endeavours to market
the bottom ash derived from the incineration process for use as a secondary
aggregate, as indicated in paragraph 1.2 (iv) above.
8.7 Land Use Policy
In terms of land use policy the principle of the development of the site for such
a use is considered acceptable. The site falls within an area of land with
planning permission for business, industry and warehousing. The proposal is
considered in accordance with the aims of Policy 55 of the Local Plan and the
supplementary guidance on ‘Locating Waste Management Facilities’(2006)
which both state that such proposals will generally be encouraged toward
existing areas or allocations for general industry. (see the Strategic Planning
Manager’s advice, paragraph 5.1)
8.8 Landscape and Visual Amenity
The design and external appearance of the development is considered
acceptable. The site is located within an industrial area which is typified by
utilitarian looking industrial buildings. The Strategic Planning Manager
(Design) comments that the quality of the design is high for a facility of this
type (see paragraph 5.2 above). The design has also been endorsed by the
Design Commission for Wales.
8.9 Amenity including Air quality and health
The closest residential areas are a distance of approximately 580 metres away
at Adventurer’s Quay, Galleon Way and Lewis Road (see paragraph 1.2(ii).
The Environmental Statement (ES) contains an assessment of ‘Amenity
Issues’ (Section19) which covers the following matters: Litter, vermin and
pests, waste, discharge to water, air quality, dust and odour, traffic and noise
and concludes that the proposal would not have any detrimental impact on the
surrounding environment.
The submitted Environmental Statement (ES) addresses emissions in two
categories; traffic emissions and emissions from the stack. The ES states that
the majority of traffic will access the site via Rover Way and Ocean Way. A
DMRB assessment was carried out in relation to the Gypsy / Traveller site at
Rover Way. The assessment indicates that ‘long term and short term air
quality objectives / limit values for NO2 and PM10 will be achieved, with or
without the operational traffic for all assessment years’. The ES states that the
maximum predicted short term and long term ground level process
contributions from the facility at the appropriate WID emissions limits have
been classified as extremely small or very small (ie. <5%>2000) between the highest predicted soil concentrations and soil
assessment criteria that are protective of the most sensitive human receptors’.
Furthermore, following consideration of the proposal including the submitted
Environmental Statement neither the Environment Agency (EA) nor the
Operational Manager Environment (Pollution Control) have raised any
objections, subject to the imposition of appropriate conditions (see paragraphs
5.3 and 6.1 above). It is not considered that the proposed development would
prejudice the amenities of residents etc. within the surrounding areas.
It should also be noted that the proposed facility will require an Environmental
Permit from the EA prior to beneficial operation. The potential emissions from
the incinerator will have to be analysed very stringently by the EA to ensure
that the emissions comply with EU legislation. The EA is the competent
authority for assessing the detailed impacts upon the environment from
emissions.
In view of the public concern regarding the proposal (see section 7 above), it is
recommended that the persons having relevant interest in the application site
should enter into a binding planning obligation in agreement with the Council
under Section 106 of the Town and Country Planning Act 1990 requiring them
to establish and support a Liaison Group to involve, (inter alia), the operator,
the local planning authority, local members and representatives of the local
community.
Furthermore, it is considered that the Environment Agency should be
requested to give consideration to the inclusion of a condition to secure a
programme for monitoring and mitigation of emissions to air using a
continuous sampling system on any pollution prevention and Control
Authorisation, and if not, to continually monitor the need for the inclusion of
such a condition in any subsequent review of this authorisation.
8.10 Water Resources
There are no water features present on the site and the site is not within an
area which is prone to flooding. The submitted Environmental Statement
states that the main potential for impact upon hydrogeology is during the
construction phase. Conditions 4-7 regarding contaminated land measures will
ensure that risks to ground water during both construction and operation are
monitored and minimised (see the consultation response received from the
Environment Agency paragraph 6.1 above).
8.11 Transportation
The applicant has carried out a Transport Assessment which was submitted
as part of the Environmental Statement. The Transport Assessment indicates
that the proposed development would generate approximately 82 additional 2-
way trips on the local highway network during the morning peak (ie. 0730 to
0900) and some 62 trips during the evening peak. The additional traffic
generated from the energy from waste facility is predicted to represent an
increase of 3%. Many of the objections received relate to the increase in traffic
from the proposed facility. However, on the proviso that the applicant is willing
to enter into a section 106 Agreement with regard to the provision of a
financial contribution of £180,293 towards public transport movements, traffic
management and telematics, the Operational Manager Transportation has no
objections. The applicant would also be required to enter into a section 106
Agreement with regard to the provision of a revised Travel Plan, in order to
promote travel by sustainable modes of transportation amongst employees
(see paragraph 5.4 above).
8.12 Archaeology and cultural heritage
Glamorgan Gwent Archaeological Trust (GGAT) advise that due to the ground
conditions it would be inappropriate to require a scheme of archaeological
work to be undertaken prior to commencement of development on the site, as
this could result in damage to archaeological resource which may otherwise
remain undisturbed on the site. GGAT have advised (see paragraph 6.3
above) that subject to a condition requiring the applicant to submit a detailed
programme of investigation for the archaeological resource following the
outline given in the environmental statement being attached to any consent
then there would be no objections (see Condition 22).
8.13 Impact upon the Statutory Designated sites
In response to the objections received from CCW (see paragraph 6.2 above),
regarding the need for an Appropriate Assessment to be undertaken by the
Local Authority prior to the determination of the application, the Strategic
Planning Manager (Ecology) (see paragraph 5.5) advises that Cardiff Council
has to reach a view on the possible significant effect of these proposals in the
context of European sites. The possible significant effects would be through
the media of aerial and water pollution, which are regulated by the
Environment Agency. The facility would require an Environmental Permit to
operate even if planning permission was granted. Furthermore, if an
Appropriate Assessment were to be undertaken for this proposal then this
would be inconsistent with the local authority’s stance on previous proposals
(such as Celsa Steelworks and Biomass Plant 08/2653C), and would set a
precedent for future projects. It should be noted that the local planning
authority does not have the technical competencies in assessing complex
issues relating to emissions.
8.14 Many objections have been received to the proposed energy from waste
facility (see section 7 above). In response to objections received and not
already addressed within the above report:
Concerns regarding emissions and the resultant impact upon health
The Operational Manager Environment (Pollution Control) and the
Environment Agency (EA) have been consulted with regard to the emissions
from the proposed facility and both have no objections (see paragraphs 5.3,
6.1 and 8.9 above). It will fall to the EA to consider the emissions very
stringently during the Environmental Permit stage. It should be noted that
without an Environmental Permit the facility will not be permitted to operate.
Incineration is not an efficient method of waste treatment and will discourage
recycling
The Welsh Assembly Government states that energy from waste facilities are
only acceptable if ‘they form part of an integrated approach and that they only
recover energy from residual waste that remains after as much recyclable and
compostable material as practically possible has been removed; they include
heat and power wherever practicable. The applicant states that the proposed
facility is intended to treat residual waste and that materials (such as metals)
are to be recovered for recycling. It should be noted that significant investment
has been made in recycling and composting within the local authority in recent
years and the local authority is committed to increasing rates of recycling and
reducing residual waste.

Hazards of disposing of toxic fly ash
The toxic fly ash is the residue of combustion removed from the flue gases
prior to release into the atmosphere, in order to reduce the pollutants emitted.
The facility would produce approximately 10,500 tonnes per annum. The fly
ash would be removed from the facility using enclosed tankers and would be
transported to a hazardous waste landfill (currently there are none in Wales).

The carbon footprint of the development
Chapter 5.3 of the submitted Environmental Statement analyses the carbon
footprint of the proposed facility compared with landfill. The calculations are
carried out in accordance with Waste and Resources Assessment Tool for the
Environment (WRATE). Compared with Landfill an overall carbon saving of
between -108,000 tonnes and -196,000 tonnes will be achieved in the year
2013. Provided a user for the heat produced can be located the carbon
footprint of the proposed facility is estimated to be in the order of -30,000
tonnes CO2eqv in 2013.

Height of chimney stack
There is currently a chimney stack on the site which measures approximately
80 metres in height. The proposed measures a maximum of 90 metres with an
additional 10 metre lightning rod. The facility is located within an area of
industry and is a typical feature which one would expect to see in such an
area. It should also be noted that the Strategic Planning Manager (design)
has no objections (see paragraph 5.2 above).
8.15 Subject to the completion of a Section 106 Agreement (see paragraphs 5.4,
8.6, 8.9 and 8.11 above), it is recommended that planning permission be
granted, subject to appropriate conditions.