GAIN’s comments on the consultation draft of

“An Integrated Waste Management Strategy (IWMS) for Surrey (Sept 2003)”


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]”.


Our Preferences

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.


Disappointment with the consultation process

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.


General comments

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]


Inclusion of commercial and industrial waste is contrary to Government guidelines

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.


Predicted growth in waste volumes

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 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


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


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.)


Source separation

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.


Separate collection of food waste

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".


The points in this section relate to policy 1 and policy 5.


Rejection of incineration

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.


Rejection of pyrolysis / gasification – advanced thermal treatment

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 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.


Prefer pre-treatment facilities for residual waste prior to landfill

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).


Both the Government and Non-Government Organisations are backing Pre-treatment facilities

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

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."

§         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. (


Broadly in favour of “generic option 6”

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.


Strongly opposed to MBT with the output going to Refuse Derived Fuel (“generic option 7”)

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.


Support clean Materials Reclamation Facilities (MRF)

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].


Rebranding of Civic Amenity (CA) sites

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.


Good points on waste reduction and re-use

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]


Reject limits on household recycling

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.


Targets omitted for commercial waste

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)


Give householders incentives for waste minimisation

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.


Provide recycling bins in public places

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.


Who can drive waste minimisation forward?

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.


Delivery of the strategy

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.


Working with the commercial sector [policy 6]

Plans for working more closely with businesses and community groups need to be improved to demonstrate genuine commitment to partnerships that the Government expects.


Working with the waste management industry [policy 1, policy 8]

Plans for partnerships with the waste management industry (including Surrey Waste Management Ltd) and reprocessors need to be improved.


Local authorities working together [policy 3]

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:


Tel: 01483-300858





17 Smith Square

London SW1 P 3JR


Telephone 08459 335577

Website wwwdefra.govuk


Department for Environment

Food and Rural Affairs



Sue Doughty MP

House of Commons





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).