Comments on SEERA’s proposed alterations to Regional Planning Guidance for the South East – Regional Waste Management Strategy (May 2004)


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.



Key concern: Accuracy of data

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]


Key concern: Omission of an incinerator-free option

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.


Key concern: Inadequate consultation

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).


POLICY W1: waste reduction (formerly W1 – W4)

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.


NEW POLICY W1a: reuse

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.


POLICY W2: Development plans (formerly W5)

GAIN supports the more positive wording of this policy.


POLICY W3: Regional self-sufficiency (formerly W9 + W26)

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. 


POLICY W4: Sub-regional self-sufficiency (formerly W10)

GAIN supports the policy’s collaborative approach. However, it is not acceptable to take net waste from London.


POLICY W5: Targets for recovery and diversion from landfill (formerly W6)

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).



POLICY W6: Targets for recycling and composting (formerly W7 + W12)

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”).


POLICY W7: Provision of waste management capacity (formerly W11)

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.



POLICY W8: Improving recycling rates (formerly W13)

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).



POLICY W9: Markets for recycled materials (formerly W14)

GAIN supports this policy.


POLICY W10: Specific material streams (formerly W2)

(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].


POLICY W11: Other recovery and diversion from landfill (formerly W15)

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.


POLICY W12: Anaerobic Digestion, advanced thermal treatment & incineration (formerly W16)

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 ( Other examples of VCU’s can be found at     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.


POLICY W13: Landfill (formerly W17 + W19)

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.


POLICY W14: Restoration (formerly W25)

This policy should be reworded to be more direct: change it to “must” (rather than “should”).


POLICY W15: Hazardous Waste (formerly W20)

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.


POLICY W16: Waste and Transfer (formerly W22)

GAIN supports this policy.


POLICY W17: Location of Facilities (formerly W24)

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”.


POLICY W19: Advocacy (formerly W18 + W8)

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).


POLICY W20: Implementation

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.


2) House of Commons Hansard 28 Oct 2003, column 254



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





A.1.1 About GAIN

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.


A.1.2 Our achievements and accolades

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)


Letters to political parties / elected councillors


Planning objections


Petitions opposing 3 incinerators


Objections to Environment Agency


Letters to Thames Water


Various petitions to Surrey County Council


Objections to waste aspects of Draft Structure Plan


Written responses to SEERA consultation


Written responses to SLGA consultation





·         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.


A.1.3 Support and Communications

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 ( 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.