Guildford Anti-Incinerator Network (GAIN) is pleased to see significant changes to the consultation draft, but latest changes to policies are not adequate. We strongly object to the Strategy and its package of policies for the reasons outlined in this document.
Our main areas
of concern are summarised below:
a) The omission of an incinerator-free
option is our main concern. The Strategy proposes that 11 incinerators will be
needed by 2010, increasing to 23 by 2020. Annex 6 of the Strategy makes it very
clear that targets can be met or exceeded using recycling and composting alone,
so there should be a presumption against any new mass-burn incinerators [policy
W7, W12, para 3.7].
b) the accuracy of data in terms of
volume, composition and annual growth (ie. “forecasts of waste management
need”) [policy W5, W6, W13]
c) the provision of waste handling
capacity for London’s waste means that the South East region will have to
stock-pile London’s incinerator ash in perpetuity [policy W3]
d) set a target of 50% recycling and
composting by 2010 for municipal waste [policy W6]
e) the omission of a policy on reuse and
corresponding targets
f)
the omission
of zero waste in the Strategy’s vision [para 1.7, 1.8, 1.15]
g) the definition of “recovery”;
incineration should not be classified as “energy recovery”
h) there is too much emphasis on
developing waste facilities on green belt, Areas of Outstanding Natural Beauty
or National Parks [policy W18]
i)
concerns with
the proposed implementation plan [policy W20].
GAIN wishes to
raise a number of general concerns with the consultation process and the
approach adopted by SEERA:
j)
disappointment
with consultation process and subsequent use of MORI survey results to support
SEERA’s assertion that there is “broad support” for their pro-incineration
approach even though the vast majority of respondents were against it [page 6
forward]
k) failure to communicate effectively and
engage with communities/businesses
l)
lack of an
opportunity to discuss our aspirations with the Assembly.
We have
concerns with the accuracy of data and assumptions made with respect to
predicting future waste handling capacity requirements. This could have a
significant impact on the Strategy and its policies. The Strategy stresses the
importance of waste minimisation, however it states that “there are significant
barriers and constraints to achieving minimisation” [Annex 4 para 4.2]”. We are
disappointed with this assumption, which appears to illustrate a lack of
commitment to waste minimisation.
We believe that
the Assembly 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 Strategy assumes
that municipal waste will continue to grow approximately 3% per annum [Annex 4
paragraph 4.9]. However, DEFRA published data at the end of April 2004 which
shows a 1.8% rise in municipal waste, and 1.1% in household waste, nationally
[Ref. 1]. 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. In Surrey, Guildford Borough Council have recently
revealed that in 2003/2004 there has been a 2.8% reduction in the amount of
waste collected per head as a result of improved kerbside collection and a
joint education/awareness programme with Waverley Borough Council (note that
this figure has not been audited yet).
The Strategy assumes
that commercial and industrial waste will grow at 3% in 2001, but will be
reduced by 1% in 2011/12, with a further reduction of 3% by 2021/22 [Annex 4
para 4.6]. However, during a 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 2]
The Strategy
proposes that 16 additional “recovery” facilities, which will predominantly be
incinerators, will need to be built in the region by 2010 [policy W7, W12, para
3.7]. Residents in various parts of the South East region have repeatedly
demonstrated that this technology is not acceptable to them. Given that SEERA’s
own documents [Annex 6] indicate that an incinerator-free approach is feasible,
it is very worrying that the democratic process appears to be disregarding this
public aspiration. It seems an arbitrary decision has been taken to ignore and
exclude incinerator-free options on the basis that they do not include
incineration. The Best Practicable
Environmental Option in SEERA’s sustainability appraisal comprised of
‘recycling and composting only’, this was not pursued simply because it
“excludes additional thermal treatment”.
This reflects a wider concern about the way in which the concept of BPEO
is weakened in this Strategy.
SEERA has
failed to ensure there is wide public consultation for this Strategy. There have been no public meetings to debate
the Strategy, no road shows, and no advertising to raise awareness of the
Strategy. Most people are not aware
that the Strategy exists and are unaware of the significant impact it will have
on sub-regional waste planning. SEERA’s failures to communicate effectively and
engage with communities are deeply worrying, especially given that the driving
principles of this strategy are supposed to be to “improve understanding and
openness” [para 1.16].
We object to
the use SEERA has made of the MORI survey findings. It is rather worrying that
the sample seems to have been taken from areas not affected by incinerator
applications. Two thirds of the people sampled considered themselves to be not
very well informed on waste-related matters. We firmly believe that SEERA’s
interpretation of the results is unsound based on the available data.
Despite our
best efforts we have not had an opportunity to discuss our aspirations with the
Assembly. See appendix to this document for details of GAIN’s aspirations.
The Strategy’s
vision should support the multi-national concept of “zero waste
production” (ie. the long-term aim to
ensure that all products are made from materials which can either be repaired,
re-used or recycled).
GAIN supports
this policy, but the target growth figures need to be more ambitious. Targets
should be set to reduce growth of all waste to 0% by 2010 and reduce total
waste volumes by 3% by 2020 (like Yorkshire and Humberside region). In terms of household waste, rather than
set targets for reduction in the rate of growth (ie. a relative percentage) it
would be better to set targets for reduction in the amount of waste produced
per person (ie. an absolute figure). This would be better for comparison and
more meaningful.
GAIN supports
the policy to advocate Government, in particular for a national awareness
programme.
Where is the
policy on reuse (apart from the welcome reference to construction material in
W2)? A new policy is needed to set
reuse targets as with recovery and recycling. This policy could include targets
for reuse of wood and furniture for example.
GAIN supports
the more positive wording of this policy.
The proposal
to make provision for a declining amount of waste from London does not go far
enough. It is not acceptable to take
net waste from London. The Assembly
appears to advocate that the region should take London’s incinerator ash in
perpetuity [para 2.25] given that there will be no capacity for hazardous waste
after July 2004 (due to changes in landfill regulations).
GAIN strongly
objects to proposed “provision of capacity for rapidly increasing …
recovery.” In this context recovery
clearly means recovery that is not recycling or composting. It could mean incineration and this is not
acceptable. The word
"recovery" should be removed from this sentence. A separate sentence on such recovery should
be added which is much more cautious and reflects the desire of the public to
pursue strategies that avoid incineration wherever possible.
GAIN supports
the policy’s collaborative approach. However, it is not acceptable to take net
waste from London.
Annex 6 of the
Strategy makes it very clear that targets can be met or exceeded using
recycling and composting alone. This should be reflected in the wording of
policies.
GAIN supports
the use of Mechanical Biological Treatment (MBT) facilities to reduce residual
waste, remove gases and stabilise it, then sending it to landfill for
pre-treated waste (untreated landfill should be phased out). We are strongly
opposed to MBT when it is combined with incineration for processing Refuse
Derived Fuel (RDF).
GAIN strongly
objects to the forward projections of need because of concerns over the
accuracy of data used (see section 1 of this document).
GAIN supports
the separate collection of organic material, but we suggest that this should be
stated in a policy [para 2.31]. In light of the forthcoming EU BioWaste
Directive this would seem to be a prudent approach given the lead-time required
to set up the required facilities.
Composting
should be included in the penultimate paragraph of this policy (as in the
previous version of the Strategy).
GAIN supports
the increase in targets for recycling and composting, but target dates could be
improved (50% by 2010).
Local
Authorities should be required to ensure that their strategies and plans for
meeting recovery targets are based on a compositional analysis of the waste
stream for all sectors. Basing policies
on overall figures for municipal, commercial, industrial, construction and
demolition waste is not acceptable and will not achieve the objective of giving
priority to reuse, recycling and composting.
For example, Surrey’s recent waste analysis has revealed a very high
proportion of biodegradable waste with significant implications for the most
appropriate treatment facilities.
GAIN supports
resource recovery parks [para 2.44]. We are pleased to see the statement that
“80% of municipal waste stream is technically recyclable/compostable, and that
recycling generally is the most effective means of recovering embodied energy
from materials” [para 2.49].
The policy
should be revised to emphasise the need for separate collection of organic
material.
The policy
should be reworded to be more direct: in the opening sentence change it to “must be achieved” (rather than
“should”).
GAIN supports the
use of enclosed composting facilities. We also support the use of MBT as a
pre-treatment facility prior to landfill. However, we are strongly opposed to
MBT when it is combined with incineration for processing Refuse Derived Fuel.
GAIN supports
improvements to civic amenity sites and their proposed rebranding as resource
recovery parks. However, the last paragraph of this policy needs strengthening.
Resource parks should be seen as playing a crucial role in educating to assist
with waste reduction targets and in providing facilities for meeting reuse, as
well as recycling and composting targets. Every district should have such a
facility. Community ownership of the
problem and involvement in the solutions is vital. Resource parks should be
seen as a vital part of every district or borough community.
GAIN objects
to the use of overall forecasts for all
waste streams with respect to predicting future waste handling capacity
requirements. The appropriate type of waste management facility will vary
according to the properties of the specific waste stream it is intended to
process.
GAIN strongly
objects to the pro-incineration nature of this policy. There should be a
presumption against incineration (see our comments below against policy W12 and
in section 1 of this document). SEERA needs to provide strong guidance to local
authorities by ruling out incineration.
GAIN supports
this policy but we would prefer the wording to be more direct by use of the word
“must” rather than “should”.
GAIN supports
separate collection of recyclable/compostable material from households and
business. However, all businesses regardless of size should fall within the
requirement to sort waste, therefore delete the words “small and medium sized”.
The need to
collect kitchen waste separately should be built into operational practice now
rather than bolted on as EU Directives come into force. The wording of the
policy should reflect the urgency of this matter.
GAIN supports
the statement on civic amenity sites (see our comments above against policy
W7).
GAIN supports
this policy.
(a) Plastic
GAIN supports
the development of new reprocessing facilities for plastic [para 2.68].
However, the policy needs to emphasise that joined up thinking is required to
link collection with reprocessing. Waste collection authorities need to handle
kerbside collection of plastic, otherwise new reprocessing facilities will be
forced to import plastic from outside the region or even overseas (this
situation has already arisen at a plastics facility in the West Midlands).
GAIN objects
to the inclusion of pyrolysis in the Strategy text. It is relatively unproven
worldwide on a non-uniform waste stream. It suffers from many of the same
issues as incineration: inflexible; destroys mixed waste containing materials
which could be re-used or recycled; its safe operation relies upon the Integrated
Pollution Prevention Control (IPPC) regime. These points are covered further
under policy W12.
(b) Glass
Recycling
glass is good, but why not re-use the bottles and save energy? SEERA should lobby
Government to introduce a standard sized beverage bottle (this has been done in
Canada).
(c) Tyres
GAIN objects
to the proposed facilities for handling tyres, namely incineration, pyrolysis,
fuel for cement kilns. Used tyres should be shredded and used as a resurfacing
material.
(d) Electrical
We are pleased
to see references to facilities for handling household batteries in the
Strategy text [para 2.68].
The Strategy
text and the wording of this policy place too much emphasis on using garden
waste as a source of fuel (ie. biomass fuel) under the banner “energy recovery”
[para 2.70]. GAIN strongly objects to this policy, since it could be used to
justify incineration of material that would otherwise be composted. This policy
should be much more cautious and should clearly state it will not be permitted
for materials that would otherwise be in the waste stream. GAIN objects to the way in which discussion
of the development of energy from biomass has been introduced into a strategy
concerned with waste. It is further
unacceptable that this policy appears to be drafted in such as way that it
assumes the biomass will be burnt rather than undergo a biological process to
release its energy. Many of our
concerns about the environmental impacts of incineration would apply to the
incineration of biomass grown expressly for burning.
GAIN strongly
objects to this policy and the supporting Strategy text. The proposal that
energy from waste should only be included in development plans “as part of an
integrated approach to management” should be replaced with a stronger
presumption against incineration. As already stated in policy W5, priority
should go to reuse, recycling and mechanical and/or biological treatment
(MBT). It follows that other recovery
should only be required where targets have not been met by pursuing maximum
reuse, recycling and MBT. Any recovery
used in addition to these should also be the best practicable environmental
option.
This policy
and the Strategy text [para 2.76] should be changed to reflect genuine public
concerns with mass-burn incineration. Theoretical limits on regulating
emissions from an incinerator bear little resemblance to reality. In response
to a Parliamentary question in February 2001, the Environment Agency admitted
there had been 899 emission breaches over a 5 year period. In March 2001, a
Government Select Committee said, "the regulation of incinerators to date
has been rather poor".
In brief, we
object to mass-burn incineration for the following reasons:
a) It is inflexible; incinerators demand a
fixed amount of waste to be fed in throughout their operational lifetime. So
even if waste minimisation were successful in the region, waste would be
imported from a wider geographical area in order to satisfy the incinerator’s
appetite.
b) It destroys mixed waste that contains
materials, which could be re-used or recycled.
c) 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. For example, in October
2000 there was a serious fire and explosion at an incinerator in Sandhurst near
Gloucester. Despite the fact that the public were at risk of exposure to
hazardous waste, the operator Cleaning Services Group Ltd was fined a mere
£250,000.
d) 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.
e) 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.
f)
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. Incinerator operators and Waste Disposal Authorities are
facing a crisis. This casts serious doubt on the operational viability of
incineration in the region.
The Strategy
should emphasise that facilities are urgently needed for handling food waste
and introduce an appropriate policy. Although Anaerobic Digestion is preferable
to composting environmentally (because it is a net producer of energy),
difficulties with some aspects of this process leave in-vessel composting as
our preferred process. The Vertical Composting Units (VCU) provided by OrrTec
Ltd is a good example (http://www.vcutechnology.com). Other examples of VCU’s
can be found at
http://www.londonremade.com/recycling_reprocessing_organics.asp#organics These facilities are a specific type of
in-vessel composting facility: they are odourless, have a small footprint, and
are relatively low cost.
GAIN supports
MBT with the output going to inert landfill [para 2.75]. However, we are not in
favour of pyrolysis, gasification or MBT with RDF [para 2.74] for the reasons
previously mentioned in this document.
GAIN objects
to this policy. It needs to specify that all non-inert waste intended for
landfill should undergo pre-treatment (ie. MBT) in order to stabilise it and reduce
any potential environmental impact. This policy should set targets for the
pre-treatment and stability of landfill material as well as for cutting
volumes.
Instead of
encouraging collection and energy recovery from landfill gas, the strategy
should be encouraging gas capture and energy recovery during composting and
during pre-treatment prior to
landfill of a stabilised product. At
present polices seem to be focused on the amount of landfill at the expense of
considering its nature.
This policy
should be reworded to be more direct: change it to “must” (rather than “should”).
GAIN objects
to this policy. As stated against policy W12, there will be no capacity for hazardous
waste in the region after July 2004. The policy fails to explain how this
urgent matter will be dealt with and yet still comply with the regional
self-sufficiency policy.
GAIN supports
this policy.
GAIN objects
to this policy. We are concerned with inclusion of "existing waste
management land use". We suggest this is redrafted to reduce the
likelihood that once a site is used for waste it will always be a waste site.
The best location should be decided on a case-by-case basis. Otherwise, for
example, local communities will resist a local compost plant on the basis that
the site will become a waste site in perpetuity and may in future attract an
incinerator application. Just because a site was used for landfill in the past,
that fact does not necessarily make it a good location for an incinerator or a
Materials Reclamation Facility (MRF). It is already hard to find waste sites
without attracting avoidable long-term concerns.
See our
comment below against policy W18 below for our suggestion on an addition to
this policy.
GAIN objects
to this policy. When identifying locations in Development Plans there should be
no presumption in favour of existing waste management locations. The
appropriate location for a waste management facility and its proximity to the
waste source will vary according to the properties of the specific waste stream
it is intended to process. There must be a match between the type of facility
and the location.
This is one of
the places in which the Strategy seems to be diluting the principle of BPEO in
finding solutions.
In relation to
development on green belt, Areas of Outstanding Natural Beauty, National Parks
the current wording of this policy implies that the proximity principle is the
overriding factor. This is unacceptable since it prejudges the Best Practicable
Environmental Option (BPEO). GAIN objects to the way in which in the policy
appears to deliberately target specific areas of the region, namely green belt,
etc. This contravenes both the spirit and the letter of existing planning
guidance.
We therefore
recommend that this policy be dropped. Policy W17 should be modified to include
the following point: “There must be a match between the type of facility and
the location taking into account the properties (and potential risks) of the
specific waste stream it is intended to process”.
GAIN objects to
this policy. The first bullet point should specify recycling and composting as
the priority means of achieving recovery targets. Otherwise such a policy will simply fuel incineration proposals
for commercial, industrial, construction and demolition waste.
This policy
should advocate the introduction of an incineration tax to encourage waste
treatment higher up the waste hierarchy.
This policy
should advocate the introduction of new legislation to allow Waste Collection
Authorities to introduce variable charging (or “pay as you throw”). This would
make it possible to give residents a financial incentive to participate in
recycling/composting/re-use. The Environment Minister Elliot Morley has
indicated that the Government supports variable charging (see Hansard 28 Oct
2003, WET Bill debate).
GAIN objects
to this policy. By supporting incineration, it essentially means that the
Strategy is based on conflict with local people. Planning applications for
three proposed incinerators in Surrey were amongst the top ten most objected to
planning applications in Britain’s history. We agree that the Strategy’s
implementation plan will only succeed with “buy-in from the region’s citizens”
[para 2.118]. Most of the 1700 people who took the effort to respond to the
SEERA’s consultation in 2003 have been largely ignored since incineration is
still included. This approach will not help SEERA to achieve the widespread
support that is needed to change public attitudes.
The
implementation plan does not adequately tackle the key issues of education and
awareness.
1) Municipal
Waste Management Statistics 2002/3, DEFRA, London, 2004.
http://www.defra.gov.uk/environment/statistics/wastats/bulletin/index.htm
2) House of
Commons Hansard 28 Oct 2003, column 254
http://www.publications.parliament.uk/pa/cm200203/cmhansrd/cm031028/debtext/31028-32.htm
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
Members of the
Guildford Anti-Incinerator Network (GAIN) are keen to point out that we are neither
eco-warriors nor experts in waste management.
We are just ordinary residents who have become concerned and informed
and would like to help in finding solutions to our waste problems. We have never been just an “anti” group. Ever
since our group was formed in September 2000 we have gone to great lengths to
put across our aspirations for an incinerator-free approach. However, we have
found it impossible to discuss these ideas with the Regional Assembly.
In terms of
location, GAIN does not just think about Guildford. We have always opposed
incineration in principle, wherever it is proposed and developed partnerships
to explore countywide solutions. We have supported other communities threatened
by incineration such as Capel, Redhill, Basingstoke and Slough.
We are proud
of GAIN's major achievements to date, which include:-
·
Jan 2001:
Invited to address members of Guildford Borough Council Planning Committee at a
special meeting held at the Guildford Civic Hall (in front of a capacity
audience of 1,600)
·
July 2001:
Organised a Community Waste Workshop at Chilworth Manor (we successfully
brought together councillors and senior officers from across Surrey for the
very first time; guest speaker Robin Murray)
·
Aug 2001: Invited
to address the crowd from the main stage at Guildford Live music festival (in
front of an audience of 40,000)
·
Dec 2001:
Defeated proposed Guildford incinerator at a special meeting of Surrey County
Council Planning Committee (Surrey incinerators were amongst the top ten most
objected to planning applications in Britain's history)
·
Delivered over
53,000 of the 81,000 objections to incineration in Surrey to date:-
|
Responses to
previous Surrey Local Waste Plan Review (2000) |
2,500 |
|
Letters to political
parties / elected councillors |
14,500 |
|
Planning
objections |
32,000 |
|
Petitions
opposing 3 incinerators |
12,670 |
|
Objections
to Environment Agency |
12,000 |
|
Letters to
Thames Water |
1,000 |
|
Various
petitions to Surrey County Council |
3,900 |
|
Objections
to waste aspects of Draft Structure Plan |
725 |
|
Written
responses to SEERA consultation |
1,066 |
|
Written
responses to SLGA consultation |
1,079 |
|
|
81,440 |
·
Feb 2003: Invited
by Surrey Local Government Association (SLGA) to address councillors and senior
officers from across the county on Surrey’s Joint Municipal Waste Strategy
·
June 2003:
Received the Guildford Mayor's "Living in Harmony" award
·
Dec 2003: Invited
to take part in the Examination In Public for the Surrey Structure Plan.
GAIN is a
growing coalition of residents' associations and concerned individuals, funded
by public donation. GAIN has maintained a close working relationship with
Guildford Borough Council. We have given countless media interviews to local
newspapers, regional TV, regional radio, and national press including The
Times.
Refer to
GAIN’s web site (http://www.no-incinerator.org.uk) for further details of our
work.
The diagram
overleaf illustrates our aspirations for facilities associated with municipal
waste. The diagram was produced by GAIN as part of our involvement with
Surrey’s Joint Municipal Waste Strategy. Option (h) was an incinerator-free
option put forward by SLGA.
GAIN’s
aspirations for waste management in the South East region are summarised below:
1. SEERA needs to provide strong guidance
to local authorities by ruling out incineration.
2. SEERA needs to provide the leadership
and plan for infrastructure to enable the people in the South East to recycle
at levels beyond 50%.
3. SEERA needs to adopt a waste
minimisation target for the region. This should ultimately lead to establishing
a long-term goal of working towards zero waste production. The South West
Regional Assembly have already made a commitment to becoming “a minimum waste
producer by 2030”.
4. SEERA needs to promote investment in
green, clean technologies for dealing with the waste that is left after an
intensive waste minimisation, reuse and recycling scheme. The overall approach
needs to be flexible and must rely upon sorting and cleaning the waste stream.
Every household must have kerbside collection of dry recyclables, kitchen waste
and un-recyclable residual waste. This approach has been tried and tested in
many countries and is based on the following strategic facilities:
·
Composting
facilities incorporating gas capture, with separate handling of organic garden
waste (producing compost that can be sold) and of food waste (for prescribed
use). These biodegradable materials
account for much of the South East’s waste stream.
·
Sending
residual waste to Mechanical Biological Treatment (MBT) facilities to reduce
it, remove gases and stabilise it, then sending it to landfill for pre-treated
waste (untreated landfill should be phased out). MBT combined with incineration for processing Refuse Derived Fuel
is not supported.
·
Promoting and
improving facilities at Civic Amenity sites, not only to maximise reuse and
recycling, but also for hazardous household waste (eg. anti-freeze, paint). As
suggested in policy W6 Civic Amenity sites must be rebranded “resource recovery
parks”.
5. SEERA needs to make a commitment to
waste minimisation for the commercial waste stream. As suggested in policy W8,
we need separate collection of recyclable and compostable material from small
and medium-sized businesses (for a fee). SEERA needs to co-ordinate local
authorities in the region and make policy W8 happen.