The Surrey Waste Plan

Response by GAIN

December 2005


GAIN is a voluntary organisation that works to promote more environmentally acceptable approaches to waste management than thermal treatment or unsorted, untreated landfill.  Working closely with the community, we have enabled residents to make over 86,000 objections to incineration in Surrey.  The main thrust of GAIN’s work is promoting positive solutions to Surrey’s waste management problems.  GAIN would welcome opportunities to work in partnership with Surrey County Councillors and is very disappointed that opportunities for community partnership with members have not been made available to date in spite of the recognition in policy documents that engaging the community has a crucial role to play in achieving waste objectives.



Unaddressed concerns raised in our response to the Issues and Options pre-consultation on the Waste Development Framework for Surrey remain valid, including our comments on the BPEO Assessment (which has informed the Sustainability Appraisals and Strategic Environmental Assessment) and we ask for these to be taken fully into account in this consultation exercise.  A voluntary group should not be expected to have to rehearse all the arguments afresh when such a multiplicity of consultations is issued.





We welcome the fact this Plan is much clearer in its use of the Waste Hierarchy than previous Plans.  For example, it now comes across much more clearly that recovery of materials is to be encouraged above the recovery of energy.


The greater emphasis given to reduction, reuse, recycling and composting and other materials recovery is also welcome.


However, we are not at all clear that the Plan will act as a driver for achieving this outcome in practice.  If the Plan is to give more than lip service to the top of the hierarchy and to influence the actions of others, policies for shifting action up the hierarchy will need strengthening.  The Sustainability Appraisal advises that you need targets to help to turn these aspirations into reality.  To quote ERM: “The framework has no targets for minimization, recycling etc and there is no commitment to achieve any kind of performance in terms of the hierarchy.” … “The policy framework should include a commitment to targets for minimization, reuse, recycling, composting, recovery and disposal.”   We also believe the Plan should indicate the capacity required for various segregated material streams eg various types of biodegradable waste.


Without clear targets for materials recovery, the Plan gives the impression that Surrey is saying “Here are possible sites for various types of waste activity.  Let’s see what applications we get.” 


It appears that the current draft Plan has responded to the built in obsolescence of previous targets by removing them.  We recognize this problem and submit that a better solution is to include longer-term targets that establish a “direction of travel”.  This will be particularly important when it comes to sizing capacity for any material and energy recovery facilities and to maintaining flexibility.  Unless longer-term targets are used, there will be a risk of over capacity in provision lower down the hierarchy over time. 


For example, if the current recycling target of 36% were used to size capacity, a case could be presented for up to 64% of Surrey’s municipal waste to be incinerated under the Plan, even though considerably more than 39% of this would be biodegradable and 69% potentially recyclable or compostable.  If Surrey used a recycling target of 50%, a case could be presented for up to 50% of Surrey’s municipal waste to be incinerated under the Plan, although much more than 20% of this would be biodegradable and 60% potentially recyclable or compostable.  If the Regional 60% recycling target figure is used and there is a clear requirement to match facilities to the nature of the materials in various waste streams, this starts to offer a framework for moving waste processing up the waste hierarchy as the Plan advocates.





Right from the outset the Plan should be much clearer that, in line with Regional Guidance, Surrey will adopt an approach that materials that are currently perceived as waste should be treated as a resource with value.  The initial definition in the Plan of discarded material needs setting in the context of a “resource management approach”.





The Plan should include a policy promoting the separation of waste streams so that materials can be directed to the most appropriate management method for maximizing recovery.  This is strongly encouraged by the Regional Guidance, which identifies the need to establish “resource recovery systems based on material streams, serving all sectors.”  “This requires a focus on key material streams (for example food waste, paper, plastics, metals, chemicals, aggregates) rather than waste origins (for example household, commercial), segregation of these as far as possible, and assessment of the most appropriate management methods to maximize recovery.”


At present Surrey’s Plan only looks at the source of the waste (eg municipal) and suggests that “most waste streams can be managed through similar facilities.”   In spite of all the excellent work that Surrey has done on waste composition, the Plan makes no attempt to identify the most appropriate facility for different types of material.  If we are to capture as much material as possible higher up the hierarchy and progress towards our various recovery and diversion targets as required, achieving a match between different materials and the most appropriate facilities will be essential.


It is particularly important to note that 60% of Surrey’s Municipal Waste is biodegradable.  Government anticipates that systems for separation of biodegradable waste will develop early in the period for the Strategy.  So this Plan needs to encourage facilities that support a widely established system of separate collection of organic materials and their extraction from mixed waste streams.  The BPEO  analysis (3-29) worked on the basis that “a minimum of 11 composting facilities and 11 MRFs will be required to manage municipal waste for all options”.  It is not at all clear how this plan would implement this or what the consequences of not doing so would be.





The Regional Planning Guidance urges speedy introduction of better facilities to separate waste at Civic Amenity Sites.  The Plan needs to give much more impetus to improving Civic Amenity Sites.  Surrey’s were assessed by DEFRA because their performance was well below average in England.  Significantly, the range of materials separated was seen as inadequate.


With improvements, it was suggested that sites could achieve a 54.6% recycling rate and an overall diversion rate of 61.3%.  The report estimated that in the first year after improvements, over 50,000 tonnes of material, of which half would be biodegradable, would be diverted from disposal.  Helpfully, the DEFRA report also estimated savings from the improvements of £6.3 million until 2020        





New Regional Planning Guidance is giving us a clear direction from the Government to work towards 60% recycling and composting of Municipal Waste in the region by 2025.  This plan will be shaping decisions on the facilities we have in place in Surrey to achieve this.  David Munro’s announcement that Surrey proposes a 50% recycling rate as a stepping stone to this is welcome.  However, when it comes to sizing capacity in the Waste Plan it will be essential to keep our sights on the 60% figure if we are to avoid over capacity below materials recovery in the hierarchy.   


80% of Municipal Waste in the region is technically recyclable or compostable.  So this plan needs to get us on track for capturing three quarters of this.  If we get the mix of facilities wrong in this Plan, because we don’t think ahead, we will be hindering achievement of this target and faced with the need for additional facilities in future.


High recycling and composting consistently feature well as a means of meeting targets in sustainability appraisals at regional and county levels.  The Sustainability Appraisal recommends that the Plan “makes an explicit commitment to achieve a high recycling rate and to deliver more dispersed facilities”.  We support this.       


It is important that this Plan does not just work to immediate targets.  Surrey’s current recycling target may be 36%, but this plan will make judgments on facilities that we will have to rely on to get us to 60% recycling and composting, may be more.  It is important to remember how quickly the targets in the waste contract became out of date.  The contract is not that old really and when it was drawn up the true recycling figure was 12.5%.  It has since been updated to just 25%.  Yet the Best Value target is already 36%.  What hope have facilities in the current contract got of setting Surrey on the path to 60% recycling?   The modest Civic Amenity Site upgrades being delivered under the contract now were originally only intended to achieve 12.5% recycling.  





The plan seems to rely heavily on moving development up the hierarchy by requiring incinerator proposals to show that their waste stream has undergone recycling and composting first.  Our concern is that this could result in Surrey attracting incinerator applications and then trying to nudge applications up the hierarchy from that starting point.


We would like to see the Plan do much more to encourage applications for biological treatment, such as closed vessel composting, anaerobic digestion or MBT, all of which are higher up the waste hierarchy and have fared well in Sustainability Appraisals.  Regional Guidance advises that biological processes, such as anaerobic digestion, should be considered favourably.  The Plan could place much more emphasis on the high proportion of Surrey’s waste that is biodegradable and promote applications dealing with this fraction.  This Plan needs to achieve the outcome that applications for biological treatment of the biodegradable waste stream will be determined ahead of proposals for non-biodegradable residual waste.


The opportunities for recovering energy from waste without burning it need to come across more clearly in the Plan.  Composting and other biological treatments produce biogas, which can be used for energy.  As the Regional Planning Guidance describes, anaerobic digestion of biodegradable waste converts up to 60% of the organic matter into methane and carbon dioxide, which, following treatment, can be burned to produce energy and/ or heat.  Given that so much of Surrey’s waste is biodegradable, this is a particularly interesting option in Surrey and can contribute to both material and energy recovery.     


We note that the landtake requirement for MBT is greater than that for anaerobic digestion alone and that closed vessel compost plants with gas captured can be very readily accommodated within developed areas.  We believe that this should be reflected in the locational policies of the plan.  MBT would need sites of a scale unlikely to be found or acceptable in built up areas.  Anaerobic digestion could potentially be accommodated in appropriate industrial areas.  Closed vessel compost plants should be distributed across the county, accessible to all major centres of population.  Eleven such facilities would be consistent with the assumptions in the BPEO analysis.





During the consultation period of the Plan, Surrey’s lead member for the Environment zealously promoted incineration as Surrey’s preferred option for residual waste to such as extent that this has to be taken into account in understanding the intentions of this Plan.  We are very troubled that the messages that are being put across, are not clearly drawn from the analysis undertaken for this Plan but are likely to have a very strong influence on the outcomes.  We believe it is inappropriate for the Plan to encourage incineration for residual waste.  Even if it were just included as an option, incinerator applications are likely to ensue.  We ask Surrey to look again at the signals being sent on the mix of facilities required and at what impact these might have on applications, especially if thinking has moved on from mass burn incineration.  On the one hand, the Plan claims to reflect the waste hierarchy without being technology specific.  Yet on the other hand, the Plan is peppered with comments that can be interpreted as favouring incineration of residual waste.  Is it incineration and “Energy from Waste” that the Plan needs to be singling out for encouragement in the Core Strategy or other types of facilities, especially given the large quantities of biodegradable waste needing treatment?


From our perspective, the Plan and appraisals have been distorted by giving such high status to Surrey’s “Statements of Principle and Intent”, on which there was no consultation.  Much of this Statement is a recant of national and regional policy and adds little, so the elements that stand out are the references to the contract and the statement that Surrey considers incineration to be the most practicable, viable and sustainable approach currently available for residual waste.  As ERM have observed, “the statements on the preferred technology and on recycling levels appear to pre-empt the outcome of the Sustainability Appraisal and it is recommended therefore that these are re-examined in the light of the Sustainability Appraisal findings.”  It seems curious to do an appraisal of options when you have already set out your preferred option in advance.  And when you look at the planning framework, various appraisals done by consultants for this Plan and at the outcome of previous consultations, it is very far from certain that Surrey’s preferred option is the best way forward for Surrey.  Anaerobic digestion and MBT both offer certain advantages for Surrey’s waste.  The Sustainability Appraisal states, “It is noted that the Statements of Principles and Intent indicates that incineration is regarded by Surrey County Council as the most sustainable approach presently available.  It is recommended that the outcome of this appraisal is used to help inform that position.”


We ask you to remove the “Statements of Principle and Intent” from the Core Strategy.  Surrey is producing this Waste Plan wearing its Waste Planning hat and not as a Waste Disposal Authority.  The Statement seems to blur the distinction and many sections of it are written from the perspective of Surrey’s disposal role and PFI-based contract.  By supporting incineration for Surrey’s own contract-governed waste activities, this statement also encourages incineration by third parties in Surrey for other parts of the waste stream.  The pro incinerator Statement is not based on planning guidance or environmental appraisals that have been through democratic consultation and should not be given such prominent status setting the overall framework for the formal Waste Plan.  It sits uncomfortably in a Plan that claims elsewhere to be taking a neutral stance on the choice of technology beyond supporting the hierarchy.  It also undermines and prejudges the work of the Joint Municipal Waste Strategy.  It cuts across the message emerging from Regional Guidance that biological processes such as anaerobic digestion should be considered favorably. 


The Strategic Objectives for the Waste Plan include “to enable the provision of a range of waste technologies including Energy from Waste”.   There is no comparable reference to the importance of developing a range of biological treatment facilities given that over 60% of Surrey’s waste is biodegradable.  Is your intention to secure a role for incineration in the Plan or is this policy also intended to include generating energy from biogas?


The Plan is very dismissive of the potential for alternative options.  However, it is not at all clear what is being dismissed because there are no targets.  Is it saying there is no alternative to an approach of identifying sites for thermal and non-thermal facilities and leaving the industry to decide what proposals come forward?  Or does it mean that there is no alternative to the preferred option of incineration for residual waste?  An incinerator free approach to waste management, as proposed in the Integrated Waste Strategy, could meet targets and, especially given the amount of public support this approach received, it is surprising not to see a clearly reasoned assessment of the extent to which non thermal treatment might be deployed.


Incineration did not come out that well in the assessments undertaken as background to this Plan.  In the BPEO, the weightings had to be fixed to give incineration a higher score (doubled from 22% to 44% to change the outcome of the BPEO assessment to incineration) and even then there were flaws in the figures so the true score for incineration was weak.  The score for incineration was largely elevated by the fact that the industry is familiar with this technology.  The Regional Planning Guidance refers to incinerators being seen as capital intensive and inflexible.  


We would welcome an addition to the Plan along the following lines:



“As a Waste Disposal Authority, Surrey County Council has a PFI-based contract to deliver two incinerators in Surrey and has previously advocated mass burn incineration.  More recently, the Authority has expressed a preference for incineration for residual waste.


“In consultations on Issues and Options undertaken as part of the review of the Surrey Waste Plan and in the consultation on the Integrated Waste Strategy a large majority of respondents have expressed a preference for a waste strategy in Surrey that avoids the need for incineration and other thermal treatment.


“Sustainable Development, Waste Strategy 2000, PPS10 and the strategic objectives of this Plan encourage partnership with the community.  Deploying waste technologies that encounter less public resistance could help harness public support for wider waste management targets, especially those higher up the waste hierarchy.


“The Sustainability Appraisal has identified NO2 and NOX emissions as critical factors in Surrey in terms of air quality and impacts on biodiversity.  It has assessed that incineration would have greater impacts than other options on these.


“Also, Surrey is a very densely populated county and there are therefore advantages in deploying waste technologies that are more acceptable in close proximity to residents wherever possible.”



“Where consistent with the waste hierarchy and waste targets, the Authority will be particularly interested in proposals that meet high environmental standards and employ non thermal methods of waste treatment.”


Such a statement would not rule out any technology, but give a steer to potential applicants that the community may be more likely to be supportive of feasible non-thermal proposals.  It might also give a more constructive signal to waste companies than the current situation where companies are reluctant to invest in proposals for waste facilities in the county.   


With the current Plan, which appears to safeguard a place for incineration, we ask whether residents will be motivated to work with Surrey as partners in this Plan to achieve targets 


We do not accept that the Plan should provide any sites for incineration or any other thermal process because of the impacts of this technology, which creates pollutants as a result of the burning process itself and because there are better options.  Given the risks, and track record of this technology, we are particularly concerned that such technology should not be located close to any centres of population.  We include below a summary of unanswered concerns with incineration.




Even modern incinerators have a poor record on emissions

Studies only look at ideal operating conditions at odds with reality  

NO2 and NOX emissions tip Surrey above limits

Hazardous landfill site needed in Surrey for toxic ash produced as result of burning process itself

Waste drawn in from London

Human body vulnerable to inhaled toxins

85,000 objections to incineration in Surrey

Not well suited to Surrey’s waste





Use of expressions such as “the drive to divert waste from landfill” in the Plan make it easy to lose sight of the fact that it is biodegradable waste that needs to be removed from landfill as a priority under the Landfill Directive and LATS.  Being precise about which waste streams need to be removed from landfill clarifies the task and makes it easier to identify appropriate and timely processes for diverting this material.


The Plan makes it clear that wherever possible any waste going to landfill should be the residual from a treatment process to recover resources.  The Plan should also incorporate an expectation that any such material going to landfill has been treated to make it as inert, stable, and non reactive as possible to reduce the adverse impacts at the landfill site. 


The Plan should also establish a much more explicit link between recovery processes and landfill of residues.  It should be clearer about the need to make provision for ash, including fly ash, if any thermal processes are given consent.  In the case of incineration about 30% of the material burnt comes out as ash that is taken to landfill.  A further 6% is fly ash that has to go in sealed containers to landfill sites for hazardous waste.  It would not be acceptable to export this, as currently envisaged, if other technologies avoided the creation of such toxic outputs.


The Plan also needs to address the potential for using the residues of varying qualities from biological processes, including any landfill requirement. 





For the avoidance of doubt, GAIN does not support incineration at Capel as part of this Plan or at any of the other possible sites.  The priority for waste planning in Surrey in this plan period should be to invest in:

-            Civic Amenity Sites as part of a major drive to achieve separation of material streams, and

-            biological treatment plants (closed vessel compost plants, anaerobic digestion plant and MBT based on anaerobic digestion to produce inert residue), all with capture and use of biogas.

The development of a biological materials and gas recovery facility in Surrey in the early stages of this Plan would do far more to further the objectives of the waste hierarchy in the county than the early development of an incinerator at Capel.


It is very hard to comment on the identification of Slyfield as a preferred site in the Plan when no information is available about the proposed Slyfield Action Plan.  It is a very serious issue that it is not possible to make informed comments about one of only two preferred sites in the county during the statutory consultation period for the Plan.  We look to Surrey for advice on how this issue will be addressed in a manner that achieves fair and acceptable standards of consultation, bearing in mind that comments on the Slyfield element may have consequences for other parts of the Plan.


We are particularly concerned that as a consequence of only identifying two “preferred” sites, given the prevalence of Green Belt in the county, pressure could be placed on these two sites to accept inappropriately large facilities.  The Plan should place very clear size limits on facilities at any site, given traffic, pollution, landscape and other sustainability impacts.  For example Slyfield may be appropriate for some kind of biological treatment facility but it not large enough for a full scale MBT plant.  For example the landscape and traffic impacts would be too great and it is too close to residential areas.


The Plan states that the planning, environmental and traffic impacts of a greater number of smaller sites would be cumulatively greater than a smaller number of larger sites.  The Sustainability Appraisal concludes that, “This statement is not borne out by the outcome of the appraisal.”  A network of closed vessel compost plants with gas capture across the county emerges as a very sensible early priority from the appraisals associated with this Plan.  The Plan should play a much clearer role in enabling this.    





We do not support the sequential test for the location of waste facilities being proposed because it does not pay sufficient attention to the varying impacts of different facilities and different waste streams.  It would be completely unacceptable to locate thermal treatment close to people.  We would advocate an approach that separated out different waste streams more clearly and identified the different impacts and locational needs of each.  We suggest that this will be the key to freeing up sites, especially nearer to centres of population.  A specific process for a particular specified clean waste stream is more likely to find an acceptable location than a large, general, mixed-waste facility.


In important first step should be to find sites for closed vessel compost plants with gas capture across the county and in so doing remove a significant proportion of Household and Commercial and Industrial waste from the waste stream.





We find the extent to which this plan is being driven by Surrey County Council’s waste contract with Surrey Waste Management unacceptable.  We consider the contract to have been poorly managed and inflexibly drafted, and to be outdated.  We fear that Surrey appears to be finding it more expedient to try to make the Plan fit the contract rather than to adapt the contract to deliver the community’s waste needs.  DEFRA has made it very clear that it would expect a contract that is incompatible with the Local Development Framework to be reviewed and changed.


The Council’s contract-led policy statement is described in the “Selection of Preferred Options” section of the plan as one of the “drivers of the plan” and elevated to a status comparable with planning policy.  We find this unacceptable .





We find it unacceptable that the short version of the Waste Plan questionnaire does not offer clear options.  Most respondents would be unaware of what they were agreeing to.  We endorse the letter submitted by many residents expressing concern at the way the questionnaire has been worded.  We would have expected the Statement of Community Involvement to set standards in this regard and ask for this concern to be conveyed to DEFRA as an objection to the current Draft Statement of Community Involvement.


We also consider that the Statement of Community Involvement should include a clear undertaking to give well reasoned responses to well reasoned community concerns shared by significant numbers of the community.  We find the current draft waste plan to be dismissive of a lot of work and effort that the community has put into developing more acceptable waste options.  The response to well made community concerns has been inadequate.


We would welcome an undertaking in the Statement of Community Involvement for opportunities to be created for County Councillors to meet with and discuss issues with community interest groups.  For example, this would be particularly valuable at the plan making phase of the waste development framework process.




There were significant errors in the figures in the Need Assessment report, which raises the concerns that report may be being accepted without working through its assessments.


We suggest that the growth assumptions in the report need to be reviewed given the enormous significance of this variable for waste planning.  We are concerned an assumption is made that all landfill capacity will cease creating an unlikely scenario with an overly dramatic reduction in void space.  The key issue is how void space is used. The possibility that some landfill continues to be used for waste that has been separated and pretreated to make it stable is not considered even though this maybe an environmentally acceptable option.


We are disappointed that the report does not distinguish between different types of waste material but only at which sector produced that material.  We submit that a vital part of any need assessment should be to know what the materials are for which provision is to be made.  This makes forecasting for reduction policies and for processing capacity more realistic.  You can’t treat waste as a homogenous mass.  For example the amount of garden waste collected rather then composted by households could have a significant bearing on the weight of household waste collected.





POLICY CS7 should include a requirement to comply with the Strategic Environmental Assessment and further the objectives of the Strategic Environmental Assessment.


The Section on the Local Policy Context refers to aspects of the BPEO being superseded.  The text should also clarify that the BPEO assessment has informed many of the documents informing this Waste Plan (that are valid under the new rules) and therefore has a particular relevance for this Plan.  This Plan is being produced during a period of transition.


Inadequate account is taken in the Plan of the fact that Anaerobic Digestion and MBT fare well in assessments and that incineration does not emerge as a particularly convincing solution.


The Plan needs to take much greater account of the fact that a larger number of smaller sites emerged as a better option in the Sustainability Appraisal.  This chimes with public opinion as measured by the Surrey Integrated Waste Strategy consultation.  Several smaller facilities could be better suited to a densely populated but small county.



GAIN December 2005