January 29, 2018

NRW Consultation – Barry compared with Roath

28th January 2018

Gareth O’Shea, Executive Director John Hogg, Head of Operations Natural Resources Wales

Cambria House 29 Newport Road Cardiff

CF24 0TP

Sent by email to:




Dear Mr Hogg and Mr O’Shea


I am writing behalf of DIAG for an explanation as to the way in which NRW has reacted to concerns over the Roath Brook Gardens scheme as compared to the way in which NRW has treated the residents of Barry.

In Roath where NRW were concerned about a few trees, NRW decided that it was appropriate to hold public workshops at which both of you attended on one of the workshops with about 6 other NRW staff; it is therefore clear that you understand the utility of this method for consultation and scrutiny.

NRW has also in the Roath matter established a webpage that sets out in accessible non-technical language the issues that needed to be addressed. It also carries links to the technical documents.

NRW did nothing similar in Barry. Our entries on NRW’s webpage have carried misleading statements (‘gasification’ technology, ‘similar to natural gas’), no e-links to documents and no explanation that would permit access the Public Register. This Public Register is a series of hundreds of documents, many with uninformative titles, not searchable and without an index.

We see that one of the issues that NRW wished to address at Roath was the possibility of tidal surge. The web page that was set up by NRW to advise on the issues goes on to advise that the likelihood of flooding will only increase over time, as a rise in sea levels and more frequent and intense heavy rainfall are predicted as a result of climate change.

In Barry by way of contrast we believe that it is fair to point out:-

1 it is agreed that we are discussing a development that has potential for danger/pollution affecting the environment and local residents;

2 DIAG offered to arrange and pay for facilities for a public meeting to allow the public to raise questions with NRW representatives to help the public understand the “minded to” documentation and how they may better take part in this consultation. NRW refused to take part in any public meeting notwithstanding that the Barry issue is one of high public interest;

3 NRW did little if anything to explain the very complicated documentation produced by the applicant for this incinerator so that the public had a chance of understanding at least a small amount of the paperwork. No dedicated webpage exists setting out the issues in terms that are designed to help our residents who live in this deprived area;

4 although NRW is concerned about tidal surge for Roath notwithstanding that Roath Park is approximately 3 miles from the coast, at Barry the tidal surge issue is far more compelling; the incinerator site has been predicted to suffer tidal surge flooding to a one-metre depth. Yet, in Barry, the NRW have brushed aside the whole possibility of flooding and the consequences for operation of a hazardous industrial plant. The Welsh Government says that incinerators are “highly vulnerable” to flooding, yet NRW is ignoring the issue in Barry. The incinerator site is a matter of metres from the dock water and NRW is well aware of the tidal surge calculations that were made for the dockside housing development and the water sports centre.


A comparison of the ways in which NRW have approached these two issues may very well convince the disinterested/objective viewer that Barry residents have been dealt with much less favourably than the trees at Roath Park. We do not mean to suggest that the issues at Roath Park are not important but any comparison as between the two ought to highlight the increased risk to human health for the Barry residents with the incinerator in Barry sited in an area of severe deprivation and close to housing and small businesses. Any comparison will highlight how the health interests of Barry residents are dealt with very lightly (if at all) by NRW whilst at the same time NRW is committing so many resources to an argument over some trees.

You will appreciate that Barry residents are people who would want to give you every opportunity to explain the very significant difference of approach when dealing with these two matters. It is important for the people to understand how NRW decides who/what is important and who/what is not.

We would very much welcome your explanations in order that we may forward these to other interested people in Barry to ensure that everybody does not jump to the wrong conclusions but understands more fully the position of your department.



Alexis Liosatos

Chair Docks Incinerator Action Group