a)
We broadly
favour a greater number of smaller
facilities (as long as these are not, and never will be, thermal treatment
facilities); of the options available we have a strong preference for option (h); but we strongly disagree with the proposed key policies as they advocate
"recovery" which includes incineration. We support the Strategy’s vision and welcome the inclusion of an
incinerator-free option. We strongly
oppose mass-burn incineration and other forms of thermal treatment such as
pyrolysis and gasification.
b)
Contrary to
Government guidelines, the scope of the Strategy has been widened to include
commercial and industrial waste. No other local authorities have taken this
view in their Joint Municipal Waste Strategies. This is of concern because the Best Practicable Environmental
Option (BPEO) will be shaped by the nature of each waste stream.
c)
The Strategy
appears to accept continued growth in waste as a fait accompli; this is
disappointing and illustrates a lack of commitment to waste minimisation.
d)
Reducing the
percentage of organics in the primary and residual waste streams should be a
top priority. Separate collection of food waste should be considered. In-vessel
composting facilities are needed for processing the food waste.
e)
According to
the Regional Assembly (SEERA) and the European Court of Justice, some forms of
mass-burn incineration should no longer be considered as "energy
recovery". This has in effect given incineration a lower position in the
waste hierarchy.
f)
We advocate an incinerator-free approach, which maximises waste
minimisation, reuse, recycling and composting.
In order to meet Government targets and the EU Landfill Directive,
pre-treatment facilities
may be needed, as an interim measure only, to minimise the biodegradable
content of residual waste so that it is fully stabilised prior to landfill. However, with sufficient investment in waste
minimisation, re-use, recycling and composting, along with improved methods of
source-segregated collection, the need to rely on pre-treatment facilities will
diminish. The need to provide
two-stream facilities, which are able to handle both kitchen waste and general
organic waste, is compatible with the desire for small local facilities and
with the possibility of inter-district cooperation. The pre-treatment of waste has received backing from both Government
and Non-Government Organisations.
Guidelines are being produced by DEFRA to define standards that
pre-treatment facilities must meet in order to comply with the EU Landfill
Directive.
g)
We are
strongly opposed to Mechanical Biological Treatment (MBT) that is used to
produce fuel pellets, which are burnt to generate electricity (i.e. Refuse
Derived Fuel).
h)
To achieve
the target of 60% recycling it is essential to win people’s hearts and minds.
In this respect the proposed education and awareness campaigns are
insufficient.
i)
We seriously
doubt the effectiveness of the implementation mechanisms in the Strategy and
support the formation of a Surrey Waste Forum with representatives from the
Local Authorities and community groups.
The Forum should be given responsibility for driving change,
co-ordinating work across the Boroughs and achieving Surrey's waste
targets. It should be supported and
jointly funded by the Surrey Local Authorities.
j)
Plans for
working more closely with businesses and community groups need to be improved
to demonstrate genuine commitment to partnerships that the Government expects.
k)
Plans for
partnerships with the waste management industry (including Surrey Waste
Management Ltd) and reprocessors need to be improved.
l)
The
consultation process for the Strategy has been a major disappointment with
misleading terminology such as "recovery" being used, poor publicity
and insufficient leaflets. Despite
these shortcomings, GAIN's request for an extension of the consultation
deadline was refused.
m)
The
implications of the Waste and Emissions Trading (WET) Bill need to be included.
This Bill is now called the Waste and Emissions Trading Act 2003 since it
received Royal Assent on 13 Nov 2003.
n)
The £100m of
Private Finance Initiative funding held by Surrey County Council should be
invested in recycling and composting facilities now.
Rather than go
through each policy in turn, this document focuses on a number of key topics
expanding on the points above. References are made to the relevant paragraphs
and policies within the Strategy using the following notation: “[para. X]”.
We support the
Strategy’s vision and welcome the inclusion of an incinerator-free option. With
the right leadership and political will we believe that 60% recycling can be
achieved in Surrey, therefore we favour option
(h). We broadly favour a greater
number of smaller facilities, but only if these facilities do not involve
thermal treatment and they are built to high standards. We understand that the
Environment Agency lowers the standards for smaller facilities. We strongly disagree with the package of
key policies because they advocate "energy recovery", which in this
Strategy includes incineration and other thermal treatment technologies.
Despite concerns we raised with SLGA in Feb 2003, the Strategy still states
that the objective is "maximising recovery" [para 3.11]. We cannot
support the overall objectives of the policies as they are currently stated in
policy 1 and policy 5 because they still support incineration. However, we
welcome and broadly support the other policies, particularly those relating to
increased recycling, composting, re-use and waste reduction. If the policies
and the body of the strategy were reworded to clearly state that incineration
and thermal treatment will not be considered, then we would support the overall
package of policies.
The consultation
process for the Strategy has been a major disappointment. The ‘media launch’
was too low key to raise awareness and despite a commendable effort in
providing a website with information and ‘downloadable’ documents, the site is
not widely known. (GAIN has endeavoured to rectify this by providing ‘links’
from the GAIN website.) It is frustrating that printed copies of the Strategy
were only sent to Council Offices, Libraries and Day Centres in limited
quantities. It is not possible for most people to spend their time at these
locations reading the Strategy. The one-page leaflet gives a useful summary but
insufficient quantities have been distributed and the method of distribution
sadly inadequate. The confusion between the way the options are set out in the
main document and the way they are described in the leaflet is also highly
unfortunate (ie. options (a) to (h) vs. options 1 to 7). GAIN's request for an
extension of the consultation deadline was refused. It is disappointing that
the SLGA do not recognise there is a problem and are therefore not prepared to
rectify the situation. An opportunity to carry out a full and enlightening
consultation has been missed. In all, the consultation process is perhaps one
of the best-kept secrets in the County.
The following
points in the Strategy and the one page leaflet are particularly commendable:
§
On the
subject of improving participation rates the leaflet states that “each of us
can play a part in the solution”; “this is your world, your community, and only
by a joint effort can we reduce the problems and the pollution caused by waste”
§
“society has
become increasingly aware of the world’s finite limit on resources” [page 2]
§
“There are
increasing concerns about the environment’s capacity to deal with current
levels of pollution” [page 2]
§
"The
main underlying driver for change is the concept of ‘sustainability’".
[para. 3.2 & 3.3]
The Strategy takes
account of commercial and industrial waste in addition to its remit of
municipal waste [para 1.13, 4.7]. We strongly object to the scope being widened
in this way so that waste streams are being muddled and confused. We fear that
doing this could force crude, quick fix solutions and cut off future options
for waste treatment. The Strategy should be clear about the different
obligations and responsibilities that Surrey’s local authorities have for each
of these waste streams.
We note the
reasons given for doing this [para. 1.13] however, we wish to stress:
§
DEFRA
guidelines state that the scope of the Strategy should be limited to Surrey’s
municipal waste (see DETR “Guidance on Municipal Waste Management Strategies”
March 2001).
§
The current
version of the Waste and Emissions Trading Bill makes it clear that Joint
Municipal Waste Management Strategies must encompass “waste from households,
and other waste that, because of its nature or composition, is similar to waste
from households” (clause 18).
§
We have
looked at Joint Municipal Waste Strategies produced by 11 local authorities and
none of them have included commercial and industrial waste. Are we to believe
that they are all wrong?
§
Residents may
view this approach as a fudge to artificially inflate future waste arisings.
§
The
composition of commercial and industrial waste is different from that of
household waste. BPEOs need to consider the composition and source of each
waste stream.
§
We were
surprised by the assumption that recycling by business in Surrey will not
improve for the next 20 years [para 4.5].
§
Commercial
waste disposal does not respect county boundaries or use long-term
contracts.
§
Surrey County
Council (SCC) would have very little influence over which companies used its
facilities.
§
The EU
Landfill Directive focuses on biodegradable household waste.
The Strategy
stresses the importance of waste minimisation [para 5.45]. However, the
Strategy appears to accept that waste growth is unavoidable [para 3.1, 3.31]
and describes a number of factors that are supposedly driving waste growth
[para 3.29]. We are disappointed with this assumption as it illustrates a lack
of commitment to waste minimisation. This comes at a time when Somerset Waste
Partnership has seen a reduction in its total waste growth from 3.4% to zero
over the past year since holding awareness campaigns. We are very concerned
that the graph showing waste management capacity for Surrey [Fig 7, page 31]
assumes that an incinerator plant with a capacity of 110,000 tonnes per annum
has been granted permission and is operational from 2008. No similar graphs
were produced for any other form of waste treatment.
The technique used
in the Strategy to work out future waste arisings is now outdated. As Gordon
Halliday, the chairman of the North East Region Technical Advisory Board, put
it “predict and provide is dead”. The dilemma we face with waste has much in
common with the problem of congestion on our roads. Planners could predict
future traffic volumes and provide 10 lane motorways all across the country.
The alternative approach, which has now been implemented in London, is to
change the public’s attitude to transport in order to stem the growth in
traffic. In just the same way the Strategy needs to identify ways of changing
the public’s attitude to waste. Variable charging (or “pay as you throw”) could
be introduced in order to give residents a financial incentive to participate
in recycling.
The Strategy
states that Surrey County Council’s contract with Surrey Waste Management Ltd
requires them to slow the rate of growth in household waste to 1% per annum by
2005 [para 2.25]. Failure to meet this contractual condition will result in
financial penalties. Yet the Strategy itself assumes growth of household waste
at 3% p/a until 2005, then 2% p/a from 2006 to 2010, and then 1% p/a from 2011
to 2020 [para 3.31]. Furthermore, Surrey Waste Management’s newsletter produced
in Aug 2002 stated that waste growth had been reduced to 0.5% p/a (see SWM web
site http://www.surreywaste.co.uk). At the very least the Strategy should be
changed to use a 1% p/a growth figure.
Even given that
Commercial and Industrial waste should not feature in the Strategy, we are
disappointed with the claim that "industrial and commercial waste
production is rising" and that "a buoyant economy will usually
indicate increased levels of waste production" [para 3.30]. The Strategy
assumes that commercial and industrial waste will grow at 1.1% every year until
2020 [para 3.31]. This theory appears to be have been proved wrong based on
statements made in the House of Commons during a recent debate on the Waste and
Emissions Trading Bill. The Environment Minister Elliot Morley informed MPs
that, "Provisional Environment Agency data, based on returns from licensed
landfill sites, suggest that the amount of industrial and commercial waste
going to landfill may have decreased by about 8% between 1998-99 and
2000-01" (ie. an annual reduction
of 2.6%).
REF: House of Commons Hansard 28 Oct 2003, column 254
http://www.publications.parliament.uk/pa/cm200203/cmhansrd/cm031028/debtext/31028-32.htm
The Environment
Select Committee at the House of Commons have considered this matter at a
national level. Many witnesses suggested that the apparent growth in municipal
waste was a result of the diversion of waste (partly as a result of the
Landfill Tax) from the commercial waste stream into the municipal waste stream
through the use of civic amenity sites The following text is an extract from
the Report and Proceedings for the House of Commons Select Committee on
Environment, Transport and Regional Affairs, Fifth Report (1999-2000 session).
REF: HC 36-I ISBN
0102169012
http://www.parliament.the-stationery-office.co.uk/pa/cm200001/cmselect/cmenvtra/36/3602.htm
Extract from Hansard
|
The National
Association of Waste Disposal Officers were uncomfortable with the projection
of continued growth in municipal waste and noted that: "there is
absolutely no statistical basis for making forward projections beyond a very,
very short-term period ... So the questions of: how much do we deal with now?
How much do we deal with now and how much do we deal with in the future? Are
fundamentally not known." [The Select
Committee concluded that] the statistical support for projecting the growth of
municipal waste is thin, based as it is on a short time-period, during which
the waste management systems were being restructured and the Landfill Tax was
introduced. We are sceptical about the Government's projections of future
growth of municipal waste. The combination of predicted increases of between
1% and 3% and the 'gap' between targets for recycling and recovery may be
providing a green light for excessive incineration capacity. The Government
must work to determine the reasons which underpin the growth of municipal
waste arisings and use this analysis to drive its minimisation efforts,
rather than accept the growth as a fait accompli which must be accommodated. |
The need to
improve recycling performance in general in the UK has been underlined by the
EU targets now to be achieved. (See
recent Environment Agency article attached.)
We are convinced
that a crucial part of facing up to our environmental responsibilities involves
separating out the various waste streams at source. Once you have mixed waste
in a bin bag or wheelie bin, you’ve lost it’s potential. It becomes nasty, smelly stuff, which is unpleasant
for residents and refuse collection crews to handle. When it’s separated it
becomes glaringly obvious that it’s a resource. Sorting gives us an opportunity to change the attitudes of
residents and businesses.
One of the guiding
principles of the Strategy should be to clean up the residual waste stream; the
top priority should be to reduce the percentage of organic waste. District
councils should provide separate food waste collection for households. This
should be supplemented by home composting schemes, as stated in the Strategy
[policy 1 action 7], and periodic garden waste collection.
Given the high
percentage of organic material in Surrey’s waste (39%) this approach offers a
great opportunity for improving our recycling rate and minimising pollution
resulting from unsorted landfill. This approach will help Surrey to comply with
EU Landfill Directive's requirement for reducing the amount of biodegradable
being sent to landfill. A study carried out in 2002 for the European Commission
recommended that source separation of compostable household wastes should be
made mandatory across the EU. The
study concluded that shifting biowaste from landfill or incineration, to
composting or anaerobic digestion is "favourable... on environmental
grounds".
The study was
ordered to inform drafting of the BioWaste directive that the Commission has
pledged to propose before the end of 2004.
Ref:
"Economic analysis of options for managing biodegradable municipal
waste".
http://europa.eu.int/comm/environment/waste/compost/index.htm
The points in this
section relate to policy 1 and policy 5.
The word
‘recovery’ should not be used instead of mass-burn incineration (see points
below regarding SEERA changes and implications of the European Court
judgement). One paragraph in particular has cause for concern: "[local
authorities] need to put in place effective arrangements to reduce waste, and
maximise recycling and recovery." [para 3.11] Does this mean maximise
incineration? This needs to be reworded to clear up any confusion, particularly
since the implications of the European Court judgment would give incineration a
lower place in the waste hierarchy.
The sentence on
environmental and health issues relating to incineration states the following
“public concerns: dioxins and local air quality deterioration (driven by poor
perception)” [page 42]. This sentence should be changed to remove the words
“driven by poor perception” based on the reasons given below. The Strategy
should be changed to reflect the genuine public concerns given below.
In brief, we
object to mass-burn incineration [paras 5.30 – 5.34, and table 8] for the
following reasons:
§
It is
inflexible; incinerators demand a fixed amount of waste to be fed in throughout
their operational lifetime. So even if waste minimisation is successful in
Surrey, waste would be imported from a wider geographical area in order to
satisfy the incinerator’s appetite.
§
It destroys
mixed waste that contains materials, which could be re-used or recycled.
§
The safe
operation of incineration plants relies upon the Integrated Pollution
Prevention Control (IPPC) regime and its effective monitoring and enforcement
by the Environment Agency, which has shown itself to be incapable of this task
to date.
§
Emissions
such as dioxins build up in the tissues of living organisms. Three municipal
waste incinerators in the Lille area of France were ordered to close in January
1998 after elevated levels of dioxins were discovered in milk from cows grazing
near one of the plants.
§
All types of
incinerators emit very fine particulates (eg. PM10’s), which penetrate deep
into the lungs causing decreased lung function, increased respiratory diseases
and premature mortality. The World Health Organisation supports these concerns
and has stated that there are no safe levels of particulates. Unfortunately
there are no regulations on very fine particulate emissions.
§
Approximately
18% of the ash is highly toxic fly ash, which must be sent to landfill sites
that are licensed to accept hazardous waste. Both the Chairman and Chief
Executive of the Environment Agency have highlighted that from July 2004 there
will be no landfill space for hazardous waste in the region due to changes in
landfill restrictions.
§
In February
2003 the European Court of Justice gave a judgement which supports the argument
that municipal waste incineration is inherently a “disposal” operation rather
than “energy recovery” (case no.
C-458/00, Luxembourg). DEFRA are currently looking into the impact of
this judgement. Changes have recently
been made to the wording of SEERA’s Regional Waste Strategy in the light of
this outcome. Similar changes should be made to the IWM Strategy.
We object to
pyrolysis and gasification [paras 5.35 – 5.38, and table 8]. The first three
points highlighted above for incineration also apply to advanced thermal
treatment. We agree with the following points on pyrolysis taken from the
Strategy:
§
“Relatively
unproven worldwide on non-uniform waste”
§
“currently
expensive without wider (economic) incentives”.
Prefer in-vessel composting for food waste
Until recently
there had been some uncertainty with regulations relating to composting of
organic waste such as kitchen waste. A new EU directive (EU Animal By-Products
Regulations took effect on 1 May 2003) on the disposal of waste containing
animal by-products (eg. kitchen waste) favours bio-secure in-vessel, high
temperature composting technology. The Vertical Composting Units (VCU) provided
by OrrTec Ltd are a good example (REF http://www.vcutechnology.com). These
facilities are a specific type of in-vessel composting facility: they are
odourless, have a small footprint, and are relatively low cost (around £70,0000
for one unit). The Strategy should emphasise the facilities urgently needed for
handling food waste [policy 1].
Although Anaerobic Digestion is preferable to composting environmentally
(because it is a net producer of energy), difficulties with some aspect of this
process leave in-vessel composting as the preferred process.
After maximising
recycling, composting, re-use and waste minimisation, any residual waste should
be processed at Pre-treatment facilities
to minimise the biodegradable content of residual waste so that it is fully
stabilised prior to landfill. In the Strategy these facilities come under the
generic name of Mechanical Biological Treatment (MBT). However, we have avoided
use of the term MBT as the Strategy describes other forms of MBT (ie. ‘MBT with
Refuse Derived Fuel’) which we are strongly opposed to. The Strategy should be
changed to make a clear distinction between these two options.
We support the
following statement in the Strategy regarding Pre-treatment facilities: “proven
in mainland Europe. UK test-bed in progress” [para 5.39 – 5.41, table 8].
However, the Strategy fails to mention that Pre-treatment facilities can be
designed in a modular way to provide ultimate flexibility, both in terms of
quantity and composition. As people get better at source separation and the
residual waste stream is reduced, the plant can be converted to in-vessel
composting units for source-separated organics. In this way Pre-treatment
facilities should simply be seen as an interim solution to help SCC comply with
the Landfill Directive in the short-term, and to help us on our way towards
“zero waste production” in the long-term. The aim of “zero waste production” is
to ensure that all products are made from materials, which can be repaired,
re-used or recycled.
A short video has
been produced by the Grass Roots Recycling Network, which illustrates our
aspirations in terms of facilities and the overall approach. In the video (“On
the road to zero waste, part 1”) Professor Paul Connett describes the approach
taken in Nova Scotia, Canada. Copies of this video have been distributed to
local politicians, including members dealing with this Strategy. Additional
copies are available from GAIN in return for a donation of £5 (minimum).
The Strategy must
be changed to remove statements about uncertainty regarding Pre-treatment
facilities [para 5.44]. During a recent debate on the Waste Emissions Trading
Bill, the Environment Minister Elliot Morley gave the Government’s backing to
these facilities. Mr Morley said that these facilities should help waste
disposal authorities to achieve Landfill Directive targets for reducing the
amount of biodegradable municipal waste being sent to landfill. He said that,
"Mechanical and biological treatment is a perfectly legitimate operation
in respect of meeting the requirements of the directive, when it reduces the
biodegradable activity in the waste". He also announced that DEFRA are
carrying out research to define standards that the residues must meet in order
to comply with the Landfill Directive. REF: Commons Hansard 28 Oct 2003, column
255
http://www.publications.parliament.uk/pa/cm200203/cmhansrd/cm031028/debtext/31028-32.htm.
See also letter
from Elliot Morley attached. [1]
Pre-treatment
facilities have gained widespread support from the following organisations:
§
Greenpeace:
See “Cool Waste Management” (March 2003) and “How to comply with the Landfill
Directive without incineration” (Oct 2001)
§
Research
carried out for Friends of the Earth by Dominic Hogg (Eunomia) reached the
following conclusion: "In our analysis of residual waste treatments, waste
which is pre-treated through MBT prior to landfilling tends to fare much better
than untreated landfill, and in several impact categories it is one of the best
options for dealing with residual waste."
(See
http://www.foe.co.uk/resource/reports/maximising_recycling_rates_report.pdf)
§
Ecologika:
see Robin Murray’s book “Zero waste” (ISBN 1 903907 01 2) published March 2002
SITA Environmental
Trust recently announced that they have made £2million available to suitably
qualified organisations to carry out research into MBT on their behalf. This
research would include Pre-treatment facilities as well as other forms of MBT.
(http://www.sitaenvtrust.org.uk/mbtspecification)
We are broadly in
favour of “generic option 6” [page 51] which is one potential form of option
(h) with pre-treatment facilities.
However, we wish
to raise the following concerns:
§
At the bottom
of the page it states that: "Rejects from all four plants are taken
directly for disposal to the landfill site. The collected untreated residual
waste will continue to be taken directly to landfill." We believe that all
residual waste should go through some form of pre-treatment before it is sent
to landfill.
§
There is no
explanation of why the organic waste stream is split into two. With annotation
or additional notes it would be easy to explain that one is for food waste and
one is for garden waste.
§
Instead of
using Anaerobic Digestion to treat food waste within the organic waste stream,
our preference is for a number of small in-vessel composting facilities.
With this type of
facility the residue is used to produce fuel pellets, which are burnt in order
to generate electricity (see “generic option 7” [page 52]). We are strongly
opposed to this approach because it destroys material that could otherwise be
recycled. Secondly, it relies on thermal treatment and generates harmful
emissions.
Once you remove
organics, plastic and paper from the residual waste stream by source
separation, there will be a significant reduction in the calorific value of
waste going into a facility of this type [para 5.41].
The current draft
of the EU Bio Waste Directive suggests that Pre-treatment facilities are
preferable to burning bio-waste to generate energy.
We support the use
of clean MRFs to "separate clean co-mingled recyclates" (ie. dry
recylables) [para 5.21, table 8]. We agree that MRFs provide "an important
material processing/bulking role" [table 8].
The Strategy
briefly mentions some improvements to CA sites [policy 1, action 3], but it
does not go far enough. As suggested in policy W12 of SEERA’s Regional Waste
Strategy, CA sites should be rebranded “Resource Recovery Parks” or “Recycling
Enterprise Park”. These facilities need to provide better facilities for
hazardous household waste (eg. anti-freeze, paint). Again, this helps to clean
the residual waste stream by removing potential pollutants at source. We would
like to see facilities where ‘rubbish’ is no longer seen as ‘rubbish’, but is
instead seen as a valuable resource. Materials considered for reuse could
include wood, furniture, items for charity shops, electrical and electronic
goods, and other metals.
The points in this
section relate to policy 2 and policy 4.
We strongly
support the following statements in the Strategy:
§
“Waste
reduction is the ultimate solution to the waste management problem since it
removes the wasteful use of resources and requires no ‘end of pipe’ facilities
to manage the waste created.” [para 5.5].
§
Waste re-use:
“Local authorities could have a role to play in the set up and development of
re-use schemes for furniture, bicycles, etc.” [para 5.13]
§
Waste re-use:
“local authorities have a role to play in encouraging the development of
markets for recycled goods and in purchasing recycled goods and encouraging
others to do so.” [para 5.13]
We are
disappointed with the following statement: “The Strategy will aim to achieve at
least the 36% recycling target across Surrey” [policy 5].
We are also
disappointed that the Strategy assumes “The maximum amount of household waste
that
can be recycled
for source segregated material is 60%” [para 5.4]. The 650,000 people of
Edmonton in Alberta (Canada) raised their diversion rate (ie. waste not sent to
landfill) from 15% to 70% in two years. The 350,000 people of Halifax in Nova
Scotia (Canada) achieved a diversion rate of 61% in less than five years.
The Strategy
states that "Industrial and commercial waste has no broad legislative
targets applied to it though it does have the impacts of producer responsibility
to contend with." [para 4.5].
This is not
consistent with SEERA’s Regional Waste Strategy which states that Waste
Strategy 2000 stipulates the following target: "by 2005 to reduce the
amount of industrial and commercial waste sent to landfill to 85% of that
landfilled in 1998." (See section 2.15, page 23 of the Regional Strategy)
The strategy
claims that no mechanisms exist to encourage communities and businesses to
pursue the goal of zero waste [para 5.8]. The Strategy appears to overlook the
Waste Minimisation Act 1998, which gives local authorities the power to
introduce pilot schemes on incentives for householders to reduce and recycle
waste.
Examples include:
§
Performance
rewards scheme: the householder receives some sort of financial payback or
voucher proportional to the reduction in waste (eg variable charging scheme
introduced in 2001 by Blaby District Council in Leicestershire) [source:
Strategy Unit report "Waste not want not" Nov 2002]. Recent
statements by the Environment Minister Elliot Morley indicate that the
Government supports variable charging (see Hansard 28 Oct 2003, WET Bill
debate).
§
Subsidised
nappy laundry service (eg. West Sussex County Council undertook a 12 month
trial)
§
Introduce a
ban on green waste in the household waste stream; this is has been implemented
in Exeter. Provide householders with an alternative by funding Community
Compost Schemes and promoting home composters. This would be in addition to
facilities provided at CA sites.
The Strategy
should encourage local authorities to provide recycling bins in public places
(eg High Streets, parks, train stations, etc). Although it may not generate
high volumes of recyclables, it would be symbolic. It would give a clear signal
to the general public that Surrey means business when it comes to providing
services and facilities for recycling. Guildford Borough Council have recently
provided bins for plastic and cans at a number of locations.
Although Surrey
Waste Management has a small waste minimisation team, many residents and indeed
some district councillors are unwilling to deal with SWM because of their
apparent determination to build incinerators in Surrey.
We are disturbed
by the following quote in the Strategy: “Unfortunately, [waste reduction] is
the most difficult to achieve and is ultimately out the hands of local
authorities.” [para 5.5]. If this statement accurately reflects the collective
view of local authorities in Surrey, this is a cause for concern. There is a
strong case for setting up an independent body to drive waste minimisation
forward (see below).
The points in this
section relate to policy 2 and policy 3.
We seriously doubt
the effectiveness of the implementation mechanisms in the Strategy. District
councils need to give a commitment that they will take responsibility for
specific actions within their respective area. Similarly SCC needs to give a
commitment that they will provide the required infrastructure in terms of
facilities within a specific time period. However, there is no indication of
who will co-ordinate all these activities and take on other countywide actions
that do not relate to infrastructure.
It’s difficult to see how the 11 District councils in Surrey could carry
out the tasks listed below without introducing unacceptable levels of
duplication and inefficiency.
We strongly
support the formation of a Surrey Waste Forum made up of representatives from
the Local Authorities and community groups. It should be supported and jointly
funded by the Surrey Local Authorities. The Forum should be given
responsibility for driving change and coordinating work across the Districts
and meeting the waste target for the County’s authorities. It should achieve these objectives by
carrying out such tasks as:
·
Win the
hearts and minds of residents and businesses by carrying out education and
awareness initiatives. Persuade them to participate in recycling, composting
and waste minimisation. Inspire and motivate people to make the right choice
when buying goods (ie. “change attitudes and behaviour to waste” [para 5.46])
·
Co-ordinate
and monitor the activities of District councils and SCC in order to achieve
Surrey's waste targets. Also share best practice [policy 8 action 4].
·
Act as a
central point of contact for district councils, SCC, residents, businesses,
retailers, waste & reprocessing companies, Non-Government Organisations
(eg. WRAP, Business Link Surrey)
·
Carry out
effective media and public relations campaigns using all media channels (eg.
radio, TV, newspapers, posters, door-stepping)
·
Organise
public events such as a Surrey Waste Summit. Also have a presence at public
events organised by other groups.
·
Produce and
distribute information to the public in an effective way (eg. newsletters,
videos, internet, email)
·
Portray an
image of openness and encourage dialogue. Set up a telephone hotline to answer
specific questions from residents and businesses. Host web-based discussion
forums similar to those set up by SEERA.
·
Raise funds
·
Carry out
road show events
·
Build
partnerships with residents, businesses, special interest groups (eg. GAIN, Capel
Action Group) and local authorities by encouraging active involvement.
The SLGA exists
primarily to work with councillors and officers representing the local
authorities in Surrey. The majority of people in Surrey have never even heard
of the SLGA. As demonstrated by their inadequate consultation on this Strategy,
they are simply not cut out for delivering public services and actively working
with the public. At the Chilworth waste workshop organised by GAIN in July 2001
Councillor Vivienne Johnson (from Guildford Borough Council) expressed concerns
with SLGA's involvement in producing this Strategy. SCC Councillor David Davis
and many other delegates welcomed the proposal to establish a countywide forum
on waste involving the community. Similar forums have been set up in the past
with SCC's backing, such as the Transport Consultative Forum.
Plans for working
more closely with businesses and community groups need to be improved to
demonstrate genuine commitment to partnerships that the Government expects.
Plans for
partnerships with the waste management industry (including Surrey Waste
Management Ltd) and reprocessors need to be improved.
We would like to
see creative partnerships developing at every level of local government: District council to District council, and
District council to County Council. This is already happening with District
Councils in East Surrey.
In terms of
partnerships with the County Council, the Strategy needs to take account of the
Waste and Emissions Trading Act 2003, which received its Royal Assent on 13 Nov
2003. The Strategy only briefly mentions “tradeable landfill permits” [para
5.72]. The new Act will introduce a Landfill Allowance Trading Scheme (LATS) to
help reduce the amount of biodegradable municipal waste going to landfill.
Under this scheme Surrey County Council will be allocated a landfill allowance
for the amount of biodegradable waste that can be sent to landfill. The County
council could face fines of up to £200 per tonne for failing to comply. Surrey
County council will be able to give instructions to District Councils regarding
the separation of waste delivered to the County's Waste Transfer Stations.
Although it's not specified in the Act, this could ultimately mean that
District councils introduce compulsory separated food waste collections for
households, as specified in the draft EU Bio Waste Directive.
To achieve the 60%
target, SCC needs to give a clear endorsement of an incinerator-free approach
together with a significant investment in facilities. We urge SCC to invest its
£100 million Private Finance Initiative (PFI) funding in recycling and
composting facilities now, rather than holding it back for last resort
incinerators.
This document was produced and distributed by
Guildford Anti-Incinerator Network (GAIN)
c/o The Vicarage, 5 Orchard Road, Guildford GU4 7JH
web site: http://www.no-incinerator.org.uk
Email: elandal@ukgateway.net
Tel: 01483-300858
[1]
|
17
Smith Square London
SW1 P 3JR Telephone
08459 335577 Website
wwwdefra.govuk |
defra Department
for Environment Food and
Rural Affairs |
|
Sue
Doughty MP House
of Commons London SWI
OAA |
Your ref: SDITJN Our
ref: 18751 1 IDW 12 November 2003 |
From the Minister for Environment
& Agri-Environment
Elliot Morley MP
Dear Sue
Thank you for your letter of 13
October on the Waste and Emissions Trading Bill and the definition of
biodegradable waste.
As you will know, I did not table an
amendment introducing the changes you suggest during Report and Third Reading
of the Bill on 28 October. This is
mainly because the definition of biodegradable waste is included in the
Landfill Directive and we cannot change it. Having said that however, I hope I
shall be able to convince you that an amendment is not necessary to achieve
your aims.
As has been made clear in the
nationwide "road shows', to brief local authority officials and others,
conducted by my officials and Environment Agency staff, mechanical and
biological treatment is a perfectly legitimate operation in respect of meeting
the Directive when it reduces the biodegradable activity in the waste. What is
not legitimate are operations that merely reduce the water content of the
waste, but the biodegradable activity remain unaltered and therefore will still
result in methane emissions in landfall conditions.
It has also been made clear at the
road shows that when legitimate mechanical and biological treatments have been
carried out, the waste disposal authority should reap the benefit of any
reduction in biodegradable content of the waste it landfills. Whilst it is true that-such treatments are
unlikely to result in zero biodegradable activity they can make a considerable
reduction. The mass balance monitoring
system will be designed to pick up this reduction. It will do this as a result of a research project. This project will set out the reduction in
biodegradable content achieved by each treatment type. If a waste disposal authority can then
demonstrate that its residual waste was subject to a particular treatment, then
it will be credited with the biodegradable content reduction assigned to the
treatment.
As you will appreciate,
the systems we put in place to monitor the amount of biodegradable municipal
waste going to landfall must be robust enough to satisfy the European
Commission that the figures we report to them are accurate. We believe that our mass balance monitoring
system will achieve this while being fair to waste disposal authorities. If you wish to find out more the Landfill
Allowances Trading Scheme consultation document will help
(www.defraweb/corporate/consult/current.htm).
Yours
Elliot
ELLIOT MORLEY