Cardiff, Caerphilly, Newport,
Monmouthshire, Vof G Councils want a big burner which Ties them into a very expensive PFI for 25 YEARS to burn waste rather than improve recycling rates. The Prosiect Gwyrdd councils are striving towards a feeble 65% recycling by 2025 with at least a further 5% being ASH from the incinerator. Many other councils have already exceeded 70% recyling rates.
“Prosiect Gwyrdd” = Scam Green = WAG Welsh Waste Policy = incinerators
Questions for Chair Cllr Mark Stephens Lib Dem and Tara King Project Manager Prosiect Gwyrdd
Has the financial assessment been revised to take into account the falling tonnages of residual waste (rather than increasing tonnages assumed)?
Has a financial assessment been calculated for scenarios in which residual household waste meets the targets given in the draft new Waste Strategy for Wales (maximum 295 kg per inhabitant per year in 2012-13, decreasing to 150 kg per inhabitant per year by 2024-5)?
what is the risk of choosing Viridor-type incineration, if incinerator bottom ash is found to be hazardous waste (cf. the EA says this is to be taken as the default) ?
what is the risk if CO2 from incineration is counted (it isn't at the moment) as adding to the carbon-footprint of 'waste management/disposal', as needed to conform with the EU ETS scheme, whereby the waste sector has to reduce CO2 equiv emissions by 16% (2020 levels compared with 2005)?
Tara King Project Manager Prosiect Gwyrdd wrote in Nov. that they haven't revised the financial assessment - and won't do so till the Final Business Case (after they've excluded better/cheaper options):
"reporting the Final Business Case (FBC). The FBC will not be proposed to Members for a decision for 18-20 months or more from now, the procurement is expected to take that long."
"Whichever way this Project is assessed, there are very significant affordability issues"
OBC Health-Check Addendum 2009
and in para 8.11.8. 9 "Given the magnitude of the ‘Gap’ that arises under both options, it is clear that partnering authorities will face a significant financial challenge to manage their future residual waste arrangements, irrespective of the final option that is chosen."
Tara King Project Gwyrdd manager stated that "all need to‘sell’ the message of PG to wider stakeholders e.g. The Market professional bodies like CIWM." (19th March 2008, County Hall, Cardiff )
Title: Prosiect Gwyrdd Joint Committee
Description: Prosiect Gwyrdd Joint Committee Location: Committee Room 4 County Hall Date: 10/03/2010 Start: 05:00 PM
Cardiff Cllrs on the environmental scrutiny comittee have a chance tonight to stop this plan to mortgage our communities for 25-30 years. They are going for Private Finance over 25-30 yr, despite cross-party opposition in Wales to high cost, inflexible PFI!
The Cardiff publicity is a direct lie.The partnership is not to "recycle and compost" but to dispose of the "residuals" by unwanted incinerators at huge cost.
RIGGED for incineration Not GREEN - They claim they have not chosen technology, yet theprospectus advertised by P Gwyrdd has been rigged to attract large incinerator companies and fix a long-term commitment to incineration, instead of cheaper low-tech mechanical and biological treatment systems. P Gwyrdd claimed to meet Welsh Strategy targets, but there is no mention of the maximum residual waste per person of 150kg, which means 125 000 tonnes maximum compared with their guide figure of 160 000 tonnes (35% of 460 000t).
They’ve told Councils to claim to the public that they aim to “recycle and compost as much waste as possible”. Yet the 65% falls far short of that claim, being less than already achieved in Europe, eg. Flanders, and far below the 80-90% figures said possible by their consultants.
They say nothing about toxic residues from waste combustion and the requirement under the proximity principle to have an outlet in SE Wales (they bother to offer help over waste transfer stations but not over a disposal site).
They set no requirement on energy efficiency, despite Welsh strategy on 60% minimum.
A reminder of some problems with the consultant lead plan!!
.
South East Wales Friends of the Earth Waste Group: Response to Prosiect Gwyrdd Outline Business Case
February 2009
The South East Wales Friends of the Earth (SEW FoE) Waste Group was formed in August 2007
to work on waste and recycling issues and policy affecting South East Wales. The group is made
up of members of Cardiff FoE, Abergavenny & Crickhowell FoE, Chepstow FoE and Barry FoE.
Prosiect Gwyrdd has been of great interest to the group and we welcome the promise on the
Project’s new website (www.prosiectgwyrdd.co.uk) that “The partnership is committed to
delivering a structured programme of consultation to ensure effective, timely and consistent
engagement with both the public and key stakeholders.”1 In response to that invitation, the SEW
FoE Waste Group have framed this feedback to the Prosiect Gwyrdd partnership on their Outline
Business Case.
SUMMARY We have reviewed the Outline Business Case (OBC) available on the official
Prosiect Gwyrdd (PG) website. Sadly this version has had large sections redacted, particularly
the technical assumptions and financial modelling, making it difficult to examine the business
case in detail. However, the following observations are made on the material available.
We note the claim to be technology neutral regarding procurement of residual waste treatment
facilities for South East Wales but have serious concerns about the strong steer toward a single
incinerator. We also see no expectation of meeting the efficiency criterion for energy recovery in
2008 Waste Framework Directive, so that incineration and landfill options will both count as
disposal under the waste hierarchy. We point out that incineration produces substantial tonnages
of toxic ash (30-35% of the original mass), that much of this ash is likely to be hazardous waste
under the new EA protocol. Policy (TAN 21) thus requires any incineration proposal to also
include treatment or disposal of this toxic ash in SE Wales, for which no facilities exist at present.
The assumptions that have been made and the weighting of the tender evaluation criteria need
review in the light of the Directive and the ash classification. We also argue for much increased
weighting of the evaluation criteria covering climate change and flexibility.
· Any incinerator bid should include treatment/disposal facilities for ash (within SE Wales),
including the flyash routinely classed as hazardous waste and the proportion of bottom ash likely
to be classed similarly under recent changes that requires its testing for toxicity. Treatment
facilities for ash that may go to construction uses or for landfill engineering are also needed,
recognising that metals and other toxins tend to leach from all incinerator ashes.
· Any incinerator bid should show it will meet emissions standards on dioxins and similar toxins
at all times, including upset conditions and start-up/close-down operations. To this end it should
include continuous monitoring of dioxins and guarantee to adhere to the 0.1 ng/m3 standard
(though the EA requires only one two spot checks annually).
· Any incinerator bid must include controls and abatement of fine and ultrafine particulates
(though the government and EA do not require this) recognising these particles are considered to
be the most damaging to health. We point out2 technology to measure incinerator emissions of
ultrafines is now well established.
· Any incinerator bid must show firm proposals to meet the efficiency standards for energy
recovery in the Waste Directive; the proposals to include outline agreement with probable user(s)
of the heat, and project outline to show equipment (pipelines etc.) for delivering the heat, plus
financing arrangements.
· Reduce the guideline projection of residual waste tonnage to 140 000tpa in line with accepting
the 70% recycling/composting target and the reducing or stagnant levels of waste arisings.
· Flexible projects limited to 10 years will be preferred; any longer period bids must take on
board the risks of rising levies on CO2 emissions and lower residual waste from the 5 counties
South East Wales Friends of the Earth Waste Group:
Response to Prosiect Gwyrdd Outline Business Case
2
than current projections (due to more successful recycling and waste reduction). Flexibility is to
include the ability to respond to potential changes in waste composition.
· The Carbon footprint and climate impact of projects will be accorded high importance, with
weighting 40-50% in the evaluation criteria. The footprint should be assessed following the IPCC
prescription, rather than or as well as the UK_WRATE system. Projects exceeding 10 years
should include plans for reducing CO2 emissions towards the UK’s 80% reduction target for 2050.
Prediction of future arisings
The partner authorities’ ability to forecast their own performance looks decidedly shaky given the
figures in Section 2.5 and the current recycling rates being reported on the PG website3.
Authority OBC Section2.5
Predicted Recycling
Rates for 2009/10
Website Recycling
Rates for 2008
Caerphilly 27.9% 34.6%
Cardiff 45.2% 33%
Monmouthshire 33.9% 40.73%
Newport 36.2% 38%
Vale of Glamorgan 37.1% 38.57%
Indeed, it would appear Caerphilly, Monmouthshire, Newport and Vale of Glamorgan are all to be
congratulated for being over a year ahead of schedule with their recycling rates.
The data underlying these predictions is presented in Appendix 2a and it would appear not
enough time was spent verifying the base data and analysing current trends before using it to
predict the future. For example, it seems that for Monmouthshire the 2002 data analysis
prepared by AEA4 was used as a starting point and then selectively updated. Resulting in the
bizarre assumption that in 2007 Monmouthshire’s kerbside recycling scheme was already
recycling 98% of the glass arisings5 even though it only covered 75% of the county.
Size of facility The Prosiect Gwyrdd partnership plans to commission a facility 50% larger than
required; this is criticised by the Audit Commission6 as bad practice that increases the overall cost
and cost per tonne. Municipal Solid Waste (MSW) arisings have fallen across Wales - and in the
5 PG authorities - for the past 3 years7. The OBC acknowledges this decline and the new WAG
target of 70% recycling/composting, yet still bases its calculations on a 1% annual increase in
arisings and only a 65% recycling rate. The result is a 220,000 tonnes per annum (tpa) plant
instead of a 143,000tpa facility8.
Options Appraisal Two years ago when this OBC was started, the incineration-biased WRATE
analysis done for the Regional Waste Plan (RWP) review may have been the most recent
modelling of residual waste technologies but much work has been done in this area since then.
The appraisal is already out of date in respect of available technologies (Appendix; several of the
technologies ruled out are now in UK use), of policy (new Waste Directive in force from Dec’08)
and of waste flow predictions. The modelling of the climate change impacts of residual waste
treatment technologies done by Eunomia Consultants for the Greater London Authority9 has now
been accepted by both the UK and the Welsh Assembly Government as more accurate than the
RWP work. The IPCC specifies10 if incineration of waste is used for energy purposes, both fossil
and biogenic CO2 emissions should be estimated. Eunomia’s ATROPOS model follows this so
is to be used as one if not the sole method for assessing the climate change impacts of options.
Carbon impacts have been undervalued. The weighting of the Climate Change evaluation criteria
is set at 10%; we propose a figure like 40%11. At present the UK Treasury uses a shadow carbon
price, approaching £30/t and index-linked (I tonne incinerated gives 1 t CO2, 0.3tC). Carbon
taxes are very likely to come in and increase the cost of operating a CO2-emitting facility. A
maximum CO2-emitting waste option will look very bad for Wales and for Cardiff’s Carbon
footprint (the calculations of ”offset” from electricity production are overstated and increasingly
disparaged – carbon sinks in landfill or biochar are better value). Projects lasting 10 years or
more need to include plans to reduce CO2 emissions in steps over their lifetime proportionate to
the UK’s 80% reduction target.
South East Wales Friends of the Earth Waste Group:
Response to Prosiect Gwyrdd Outline Business Case
3
Long-term commitment to old technology
The 29 year period assumed for the contract12 is unnecessarily inflexible. English Councils have
come to regret13 contracts that require them to supply waste for incineration or pay for the
shortfall. Some have been held to ransom, because the single company they depend on
threatens to pull out/go bankrupt unless the Council concedes better terms.
Newer technologies are quicker and cheaper to build, will face less public opposition, are more
adaptable to varying input streams and will therefore have a shorter pay-back period. The
Sterecycle autoclave process started last year in Doncaster has a 9-year contract. As far as
Councils cannot keep it in-house (as Cardiff’s MRF and food biodigester), a 10-year period is the
maximum to aim for.
Reference Case Using a single centralised incinerator as the reference case for the OBC gives
far to strong a steer to this option – one that would not meet the Waste Framework Directive, but
invites an incinerator defined as disposal. This cannot meet the Proximity Principle or constitute
the Best Practicable Environmental Option (Waste Strategy requirement). The 29 year period
assumed for an incinerator contract14 implies a readiness to tie authorities into an inflexible
technology that is rapidly becoming outmoded. It implies inadequate weight to the flexibility of
newer technologies - quicker and cheaper to build, adaptable to varying input streams – that can
win public support, have shorter pay-back periods and suit shorter contracts, say 10 years. We
therefore propose including MBT and modular facilities distributed through the 5 Counties as a
second reference case.
Positive encouragement to Combined Heat-and-Power (CHP)
In order to meet the requirements of Defra’s Outline Business Case (OBC) guidance document,
councils must provide fundamental evidence to bidders that CHP potential has been examined by
the Authority. The assessments should demonstrate that the pre-procurement preparations give
the market every encouragement to bid a CHP solution if the market sees this to be a viable and
cost-effective approach. ‘Wise about Waste’ and WAG’s policy review both stress the need for
high quality CHP, so Prosiect Gwyrdd needs to follow the Defra guidance or something close to it.
Land Spreading of Organic Output
We are aware of but reject WAG’s proposal to usurp the Environment Agency function of deciding
on land spreading. There is a great need to build up organic matter in soils (as European policy).
There is specific need in SE Wales for soil-forming material for land remediation. The fibre output
from autoclave processes and certain MBT outputs have already been permitted on non-crop
land by the EA in England and there will undoubtedly be progress in this matter within a year or
two, if not months. WAG’s proposed policy to force incineration of autoclave and MBT outputs is
not BPEO, has high carbon footprint, is lower in the waste hierarchy and is costly. We shall
strongly oppose it in the Review of the Waste Strategy and urge Councils to do likewise. In the
meantime, you should allow bids that involve land spreading to the standard used in England, but
encourage applicants to include a variation with disposal of stabilised organic material outputs.
Financing model The choice of DBFOM as the Partnership’s preferred contract and funding
option is ill-advised, especially in the aftermath of the credit crunch. Partnerships UK shares in
the financial practices that have led to the current crisis. The new IFRS rules requiring all assets
to be on balance sheet coming in to force this year cut out the ruse to get round public spending
limits. We are opposed to burdening future rate-payers with the millstone of a PFI contract15, as
are the Welsh Assembly Government’s coalition policy and Cardiff’s similar policy. The PFIpromoting
Partnerships UK have used their much criticised strategem of using a fictitious Public
Sector Comparator (PSC) that implies it would be 32% more expensive for the authorities to
undertake the Project themselves. This is of course an unreal comparator as they would choose
several local sites with existing infrastructure and invest in modular MBT and other facilities that
would be far cheaper.
South East Wales Friends of the Earth Waste Group:
Response to Prosiect Gwyrdd Outline Business Case
4
Appendix I: NEW RESIDUAL WASTE TECHNOLOGIES
This appendix lists several of the alternatives to incineration, including new technologies being
sponsored by DEFRA.
(1) DEFRA New Technologies Demonstrator Programme
The New Technologies Demonstrator Programme was set up to demonstrate innovative waste
treatment technologies. The programme aims to prove the economic, social & environmental
viability (or not) of each selected technology. Half the Demonstrator Projects are now operational.
Most are small in scale and form part of flexible modular treatment facilities, in which modules can
be added , downsized or removed as changes in volumes of recycling and content of waste
changes over the years. Projects receiving grants currently are:
Huyton Business Park, Knowsley (for Merseyside Waste Disposal Authority)
Fairport Engineering.
A £13 million MBT facility containing a Mechanical Heat [autoclave] Treatment plant (opening in
March 08), treating 50,000 tonnes yearly.
Ludlow, Shropshire
Biogen Greenfinch.
A £2.6 million anaerobic digestion plant (opened Spring 07), treating 5,000 tonnes of food waste
annually.
Wharton, Herefordshire
Bioganix Research Limited.
An in-vessel aerobic composting system (opened in 2004), treating 10,000 tonnes of sourcesegregated
mixed garden and kitchen waste.
Isle of Wight
Waste Gas Technology (WGT) UK Limited, Energos.
£8 Gasification Plant (opening June 08), treating 30,000 tonnes of Refuse Derived Fuel yearly
St Ives, Cambridgeshire.
Envar with Gicom Composting Systems.
£1.5 million in-vessel composting system (opened Feb 08), treating 20,000 tonnes of BMW.
Thornley, Durham
Premier Waste.
Aerobic Digestion plant, part of an MBT facility (opened summer 07), treating 25,000 tonnes of
black bag MSW annually.
Seamer Carr
Scarborough Power (Yorwaste ltd, NEL Power ltd & GEM)
£4 million Pyrolysis plant (under construction), treating 18,000 tonnes of MSW
Avonmouth, Bristol
Ethos Recycling and Bristol City Council
Pyrolysis & gasification plant commissioned late 2008. Treating 28,000 tonnes MSW per year
(2) Other Developments
The Greater London Authority plans for 25 Anaerobic Digestion (AD) plants, 11 gasification /
pyrolysis facilities and 57 composting plants. AD and gasification are chosen due to their
“environmental performance in terms of mitigating CO2 emissions” and offering “flexible and
community based solutions and generating energy”.
Plasma gasification
A commercial plasma-arc gasification plant alongside an AD plant processing source-separated
organic waste are planned at Hirwaun/ RCT and converts ash to a glassified (stable) residue.
South East Wales Friends of the Earth Waste Group:
Response to Prosiect Gwyrdd Outline Business Case
5
Autoclave plant
A £10 million autoclave plant, with a processing capacity of 100,000 tonnes-per-annum opened in
Doncaster in June 2008. The facility is operated by Sterecycle. Its main fibre output goes for land
reclamation.
(3) MBT
Various LAs in England and in Scotland are opting for Mechanical and Biological Treatment
(MBT) solutions to their residual waste. MBT includes an evolving, flexible range of technologies,
able to meet changes in waste volumes and composition. Protocols are being worked out
whereby residues from MBT processes are tested for biostabilisation for landfilling – in which
case we submit that the level of landfill tax should be reduced – and for potential use as soil
improvers or in land remediation / reclamation.
Vermicomposting of mixed MSW as pioneered in Portugal has windrow composting, then aerobic
composting with red earthworms followed by mechanical separation and washing of the cleaned
up waste. All metals are recovered, not degraded as post incineration.
With respect to disposal of MBT residues, the following developments are significant:
(1) Dorset-based New Earth Solutions obtained EA certification (Sept. 2007) that its MBT
technology reduces the biodegradability of mixed waste by over 80%.
(2) SITA UK obtained EA permission to use MBT compost from its plant at Newcastle as a soil
conditioner, and also to supply local landowners and land restoration companies in
Northumberland who need large amounts of material to landscape/remediate their sites.
(3) For MBT facilities that include an AD plant, a draft protocol has been released for the
digestate produced by AD plants. It has been prepared by the Waste & Resources Action
Programme (WRAP). If the digestate meets a standard – to be called PAS 110 – it will be
classified not as ‘waste’ but as a product that can be sold as a soil compost / land improver.
______________________________________________________________
References
1 http://www.caerphilly.gov.uk/prosiectgwyrdd/english/about.html, “How are the partners going to
communicate with the public and key stakeholders?” first sentence of the section.
2 Gomez-Moreno et al. Aerosol Science 34 (2003) 1267–1275
3 http://www.caerphilly.gov.uk/prosiectgwyrdd/english/home.html as of 17 January 2009.
4 National Assembly for Wales (2003). The Composition of Municipal Waste in Wales. National Assembly
for Wales/AEAT Technology. NAW, Cardiff.
5 Prosiect Gwyrdd Outline Business Case, Appendix 2a, page 115.
6 ‘Well Disposed. Responding to the Waste Challenge’ Audit Comm. 2008: http://www.auditcommission.
gov.uk/ Products/NATIONAL-REPORT/C0CDCBFE-24E0-494d-824DF053A576661E/
WellDisposed25Sep08REP.pdf
7 Waste Dataflow data reveals a drop of 3.4% across Wales in 2007-08 and a fall of 1.5% across the 5 PG
authorities
8 The OBC says current MSW arisings from the 5 PG authorities are 475,000tpa. Even if the downward
trend should level off and a steady 475,000tpa is assumed, with the 70% recycling rate taken in to account,
only 475,000 x 0.30 = 142,500tpa capacity is required.
9 Greater London Authority (2008)., Greenhouse Gas Balances of Waste Management Scenarios, report
for the Greater London Authority. GLA/Eunomia Research & Consulting. GLA, London.
10 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, pub. IGES, Japan
11 Prosiect Gwyrdd Outline Business Case section 4.3.6, page 43.
12 Prosiect Gwyrdd Outline Business Case, section 4.4.23, page 50.
13 see, for example, http://www.ukwin.org.uk/?p=157
14 Prosiect Gwyrdd Outline Business Case, section 4.4.23, page 50.
15 Prosiect Gwyrdd Outline Business Case, sections 1.7.3 and 8.11.12
File Format: PDF/Adobe Acrobat - Quick View
than current projections (due to more successful recycling and waste ... Municipal Solid Waste (MSW) arisings have fallen across Wales - and in the ...
www.caerdydd.gov.uk/objview.asp?object_id=13604 -
New FOE report
.......and Professor Dr Paul Connett Ph.D on zero waste here
..............................Right now the landfill surcharge is driving the building of massive incinerators
UK is moving from worst solution to the next worse solution i.e. moving from the bottom of the waste hierarchy up.
What we need are financial incentives to encourage communities to move to the top of the waste hierarchy –i.e. towards sustainability. Perhaps........
INCINERATION 20 pounds/ton surcharge
40 pounds/ton surcharge on ash
LANDFILLING 40 pounds/ton surcharge
The Governent is pushing councils in one direction - incineration
Charles Clover in The Sunday Times derided the government for pushing councils towards incineration as a solution for waste disposal. Previously incineration plants had been opposed because of fears of toxic emissions, an issue now largely dealt with by better burners. Clover said incineration should be opposed: "It starves recycling industries of raw materials and prevents a cheaper, greener business model from succeeding."
UK Health research here Effect on health unknown here Welsh councils' incinerator trend Environment minister Carwyn Jones has said the development of incinerators in Wales is ineitable.24-3-07 AN INCINERATOR close to Swansea's prestigious SA1 development is being investigated for allegedly pumping out too many harmful fumes...Residents...have been told that potentially-cancer-causing dioxin emissions were found to have been three times the limit when tested in December last year. Waste Burning Could Be Lethal (from Oxford Mail) Incinerators - are WMD's? Health Impacts of Incinerators here UK without incineration network here
A report from Friends of the Earth reveals the huge extent of the pollution and financial losses caused by our love of landfill and incinerationmore...
Wales Climate Camp
The Minister depicted Prosiect Gwyrdd as "producing much needed energy" that would "use waste in the best possible way", despite the consortium claiming their Business case for procuring a ‘solution’ for residual waste is technology-neutral
WAG Approval of the business case and subsidy for Prosiect Gwyrdd, 27 Jan. 2009:
New funding boost for next generation energy-from-waste plant in south Wales
Why are incinerator residues not counted in the recycling/composting indicator?hereClassification of Incinerator Bottom Ash (updated 29 Nov. 2008)
Facebook Groups
No Incinerator in Cardiff Bay here
- Councils Scam Gwyrdd
Scottish Parliament: National Waste Strategy
Scottish Parliament vote against large-scale incinerators -The vote in the Scottish Parliament, carried because the Tories voted with the Greens and SNP. Just one Lib-Dem supported, 6 Labour absentees.
If burning up to a quarter of Scotland's municipal waste is "a failure of the imagination" how much bigger a failure is the proposed Welsh strategy with burning up to 37% proposed !
It appears that the governing SNP had a change in mind when confronted with 25% in their Minister's plan.
*S3M-4348.1 Scottish Parliament: National Waste Strategy (11 Jun 2009)
11 Jun 2009 ... Greens win Holyrood Vote against "Landfill in the Sky". Parliament today endorsed Green opposition to plans for a new generation of ... there should be no necessity for any large-scale waste-to-energy plants to be built ...
Newport’s cabinet gave the go ahead to allow an Assembly-owned site on Tatton Road to be considered for the project. The site, in the industrial area of Queensway Meadows, is likely to be the only publicly owned site earmarked for the plant.
