Presentation to the



25th April 2006





GAIN welcomes this opportunity to contribute to the vital work the committee is doing.


For too long we have preferred to dump anything and everything into holes in the ground and to ignore the problems this causes. Now, dealing with waste properly is an important part of the sustainability agenda.


The County’s decisions will have long term consequences for residents and it is not easy to balance the environmental, quality of life, financial and other factors involved.


Since the SITA contract was signed there have been many technical developments in the waste management field and these can be expected to continue, or to accelerate.


We are concerned that the contract continues to drive waste management strategy and ask the committee to press for a properly worked through incinerator free package.


A flexible and evolving programme, introducing various technologies supporting and complementing the responsibilities of the Waste Collection Authorities can provide solutions which will serve us well in the long term. Opting now for an inflexible technology to treat residuals may well act as a braking mechanism on higher level activities in the waste hierarchy and a financial burden in the future.


We very much want to build on the good work done by the Boroughs and Districts over the past few years and our many contacts with residents give us confidence that the vast majority share our aspirations.


First Steps – Matching technology with waste  


We have a fairly good understanding of residuals at present, but content proportions will change as collection authorities make it easier for people to recycle more.


There is now considerable pressure to introduce variable charging, as is the case in much of Europe. Evidence shows that this typically cuts residual waste by 10-25%.


Some materials may be phased out of the future waste stream.


What work has been done to assess how the content of residuals will change in the future?


The sorting and separation of waste increases treatment options.


A ‘one size fits all’ treatment solution is unlikely to be the best option and flies in the face of dealing with residual content as far up the waste hierarchy as possible.





Energy from Gas


Incineration is not the only process that offers the potential to generate energy. 


Gas can be harnessed from in-vessel composting, from anaerobic digestion or even from undesirable mixed landfill. 


Biogas plants receive Renewable Obligation Certificates for each MWh of electricity generated.


The potential to produce energy from the biological fraction of residual waste could be valuable in generating energy for cleaning the non-biodegradable fraction in an adjoining plant.        


INCINERATION – with Energy Generation


The Defra report of 2004 has been much cited by both proponents and opponents of incineration. I believe we have addressed this document very fairly and thoroughly in our submission to you. Two things generally agreed are that there are uncertainties about the health effects of waste management practices and that landfill is a very damaging way of dealing with mixed residual waste containing high levels of biodegradables. Given the fact that our intent is no longer to rely on landfill then we should be comparing the effects of incineration not with landfill, as Surrey have continually done, but with other technologies.


It is to be welcomed that the Waste Incineration Directive is now applicable to all incinerators in the UK. Reading the list of emitted substances that are now required to be continuously monitored, or to be regularly measured, shows what a cocktail of pollutants are created by burning.


No industrial process works at 100% efficiency, equipment can fail, human error is always a factor and weather conditions affect dispersal. It is acknowledged that emissions occur even under normal optimum operating conditions. Accidental exceedances are reported. Permitted exceedances, which form a large part of excess emissions are not, and are not recorded as incidents. These are most likely during commissioning, start-up and shutdown.


If something does go wrong the consequences are likely to more serious than they would be in a simpler treatment system due to the toxins and pollutants produced by burning. Past emission breaches have led to concerns about the industry and it’s policing by the Environment Agency. 


As part of a risk assessment it is reasonable to ask why we are proposing to use a technology which by design produces a large amount of highly contaminated toxic Fly Ash


APCE residue needs a hazardous waste site. Where will any ash from Surrey end up?


The industry has said that it is possible to acidify fly ash to make it suitable for landfill in non-hazardous sites. This does little to alter the toxicity in the ash from heavy metals, dioxins and furans and disperses these within normal landfill – which we are supposed to be cleaning up! We understand that the Environment Agency has concerns about compliance with the applicable regulations as regards this.


The most recent data available reported to Parliament this year showed that over 60% of bottom ash ends up in landfill.


Background pollution levels for Nitrous Oxides are already high in Surrey. The Sustainability Appraisal states that incineration, ’is a poor performer in terms of the likely impact on air quality and potentially also on biodiversity’.


Health concerns will not go away when respected bodies like the Health Protection Agency, (HPA) comment that there are limited data on which to base conclusions and the British Society for Ecological Medicine is not satisfied with monitoring at facilities or with the compounds being monitored.


Large plants have a substantial footprint and visual impact and the environmental costs of transporting waste are high – pollution, CO2 emissions, traffic congestion


Burning destroys materials that can be treated as a resource – that resource has to be replaced at a cost to the environment.


If a shortage of feedstock arises some years down the line of an inflexible long term contract then waste could be transported from further afield in order to achieve financial payback, with consequent environmental impacts.


Economic Factors


Because of their high capital cost incinerators have a long payback time and therefore companies seek very long contracts with fixed quantities of waste being guaranteed over the period.


Waste companies need large plants for financial viability because the expenditure on air pollution control equipment forms such a large part of the capital cost, it has been estimated to vary from between 40-60%.


Obtaining permission to incinerate has generated opposition throughout the UK, this option results in significant costs to the applicant and to any local authority promoting incineration.


Burning of MSW results in a ‘resource’ being wasted, the item destroyed has to be re-produced. For instance, timber and oil may be imported, raw or processed, to achieve this. Recycling materials prevents these financial and environmentally negative actions and provides resource and employment.


It is extremely unlikely that any incinerator can be sited where production of CHP can be  utilised.


Electricity produced from EfW does not fall with the Renewables Obligation scheme and therefore does not receive a preferential sale price.


The Waste Hierarchy


We believe that incineration works against the aims of the Waste hierarchy.


It is argued that EU countries that incinerate are better at recycling and composting than the UK and that this proves that incineration does not conflict with the waste hierarchy. However, incinerator bottom as is counted in some recycling figures. In Germany, some incinerators are importing mixed waste from Eastern Europe to keep up throughput where high recycling levels are reducing local inputs. Interestingly, one of the best performing countries, (and one that has already met it 2016/20 Landfill Directive target), Austria, only incinerates 10% of its waste, a similar amount to that presently burnt in the UK.


It was reported last week that Hampshire’s three incinerators have not been able to get enough black bag waste, due to increases in recycling, the shortfall being topped up by residuals from recycling centres. Hampshire’s recycling rate is quoted at 31% - what incentive is there to do better!


Will we get to 50%-60% if we have incineration? Especially bearing in mind that any incinerator would be operated by the same company that controls CA sites where big recycling gains can be made?




The GAIN ‘Waste Management Template’






Why do it?


Can be applied to either source separated waste or to mixed waste after mechanical pre-treatment.


Technologies are well proven and form an important part of waste management activity in Europe.


Treatment facilities are often modular and can be sized to meet local needs.


Can generate energy and heat.




We welcome Surrey’s proposal to introduce In-vessel composting and we note the support that this technology is receiving from government.


It is important that quality standards are established for composts, these are of longstanding in Europe and give confidence to the market.


In anticipation of a very significant increase in composting in the next 5 to 10 years, WRAP has commissioned Enviros to produce draft guidelines on the use of compost, from source-segregated organic municipal wastes, in agriculture and field horticulture


Composting is a flexible waste management treatment which can greatly reduce landfill reliance. In Europe there are many applications of different sizes and technological complexity.  


In-vessel composting – with energy generation

Provided that the sites are carefully chosen and the plants sized appropriately we believe that introducing these facilities is likely to be much less contentious than any incinerator application and can make an early contribution to a reduction in landfill.


The modular nature of systems gives flexibility, the encapsulation of material allows precise temperature control and green and kitchen waste can be treated separately or together. Biogas is produced and good quality compost.


Anaerobic digestion – with energy generation


We believe that anaerobic digestion, widely used in Europe, generally as part of an MBT system can play a role in dealing with Surrey’s waste. It has fared well in sustainability appraisals and provides renewable energy. Systems can be modular and so can be sized according to local needs or can be ‘grown’ over time. A number of AD plants are now in operation in the UK.


If appropriately sited a digestion plant can produce both heat and power – such a facility is opening in Ludlow this spring with heat being exported to a neighbouring industrial estate.


Clean Anaerobic digestion


Source separated, well screened input will produce good quality output that can be used as a compost or soil conditioner, markets for these products exist already and could be tapped.


Mixed Waste Anaerobic Digestion


Outputs from more mixed streams could be stabilised if necessary and then used in landfill management. We agree that more clarity on outputs would be helpful. However we note that the EA has said that ‘suitably stabilised waste from MBT processes’ may be used for landfill cover or in landfill restoration given certain provisos.


Whilst market uncertainties are continually quoted in relation to MBT/AD outputs, we hear little of the difficulties of finding hazardous waste capacity for APCE residue or the likelihood that most bottom ash will continue to be sent to landfill because it cannot find outlets for recycling.




The Committee’s inquiry has helpfully and clearly exposed



We hope that as a result of this invaluable inquiry, the Committee will call for an incinerator-free MBT option (with Anaerobic Digestion) to be worked up to establish


The best mix of MBT treatments taking account of