Friends of the Earth Cardiff Cyfeillion y Ddaear Caerdydd

Cardiff Friends of the Earth have submitted an objection to Viridor's planning application to Cardiff County Council Planning Department.

The objection, compiled for Cardiff Friends of the Earth by the South East Wales Friends of the Earth Waste Group, objects to the planning application on the following grounds:

Non-compliance with the waste hierarchy
Viridor's incinerator would not comply with the waste hierarchy because it will be burning a lot of materials that should have been recycled or composted. The most efficient way to recover energy from waste is by recycling or composting it.

Incinerator contracts act as a disincentive to recycling because their long waste contracts for large amounts of waste bind councils in to producing waste when recycling could be used.

For example “Project Integra” in Hampshire has three new incinerators (built since 2003). The majority of local authorities in Hampshire are now failing to meet their recycling targets, with incinerators absorbing virtually all residual waste and, more alarmingly, waste that was sent to be recycled is being diverted to the incinerator.

We believe that Viridor have over-estimated the waste needing to be burnt. Their calculations require a 13 percent increase in waste between 2006 and 2013. However, waste data shows a decline in total household waste for September 2007 to Septmber 2008 of 1.5 percent in Cardiff and 3.41 percent for Wales.

The Viridor incinerator will produce around 75,000 tonnes of bottom ash per year which Viridor, assume in their planning application will find a use in the road building and construction and so classify this waste as 'recycling'. However, at present, only half of the bottom ash produced by incinerators finds a market with the rest being landfilled.

Not the Best Environmental Option
Cardiff Friends of the Earth do not believe that Viridor's incinerator is the best environmental option for the treatment of South Wales' waste.

Waste incineration typically emits between 0.7 and 1.3 tonnes of CO2 for each tonne of waste burnt. This means that Viridor's incinerator would release over 400,000 tonnes of CO2 a year.

There is no commitment, or adequate provision, in the planning application for the use of the heat generated in the incineration process for combined heat and power (CHP). Unless Viridor can confirm their incinerator will achieve at least 65 percent energy efficiency (impossible without CHP) it should not be allowed.

Studies have shown incinerators to be “amongst the poorest performing on greenhouse gas emissions, with all but one of the scenarios being a net contributor to climate change”.

There are several residual waste treatment alternatives to incineration – including mechanical, biological treatments (MBT) – which could carry out more recycling and composting, generate 'energy from waste' more efficiently and create less climate change.

Concern over Possible Health Impacts

Modern incinerators are a good deal cleaner than older ones; nevertheless, burning waste produces toxic substances harmful to human health. Cardiff Friends of the Earth believe that there is enough doubt over the ability of incinerator pollution control systems to reliably prevent the release of these toxic substances that precautions should be taken.

Incinerator emissions are only spot checked, infrequently and during normal operating conditions.

In March 2005, a spot measurement on a Nottingham incinerator found the dioxin levels to be 9 times higher than the emissions limit.

A study has shown that continuous monitoring of emissions over a period showed that actual measurements could be 30 to 50 times higher than spot measurements. Another study found that emissions during start up and shut down were higher than during normal working conditions.

A DEFRA report found that incineration resulted in the highest emissions of nearly all substances, including nitrous oxides, particulate matter, arsenic and furans as compared with other waste management options.

In addition to the emissions from the incinerator, there is also the 10,500 tonnes of toxic, hazardous fly ash which will need careful handling and bottom ash has been found, in several studies, to be hazardous.

Concern over potential to damage a nature conservation site
Cardiff Friends of the Earth object to the application on the grounds that the air pollution produced would potentially damage the Severn Estuary Special Protection Area as toxic particulate matter from an incinerator can be carried 17 or more miles.

Non-compliance with the proximity principle
The proximity principle states that waste should be treated and or disposed of as near to the source of origin as possible because transporting waste itself has an environmental impact.

Cardiff Friends of the Earth believes that there is no reason why five local authorities should be served by a single waste facility – with parts of Monmouthshire being 50km away from the proposed incinerator. Given the waste reduction that is likely to come about from increasing recycling rates, waste may been to be brought in from further afield to keep the incinerator operating at capacity.

The toxic fly ash will have to be transported to a special, hazardous, waste disposal site (probably in Cheltenham).

All of this transport will result in 260 lorries per day on the roads transporting waste all around south Wales. Clearly this is against the proximity principle.

Inadequate Public Consultation
Viridor's pre-application public consultation was neither well-publicised nor well attended despite the planning requirements for engaging the public at an early stage.

Two public exhibitions held by Viridor attracted only 17 members of the public. Cardiff Friends of the Earth believe that this was due to late and inadequate publicity and as a result not enough has been done to ensure effective public involvement at an early stage, especially because of the likely impact the incinerator would have on the local communities.