Waste Strategy Consultation
South East England Regional Assembly
Fax: 01483 - 555250
Consultation Draft of the Regional Waste Management Strategy from the South East England Regional Assembly (SEERA)
As a resident of the South East, I object to the Consultation Draft of the Regional Waste Management Strategy and support the concerns expressed by the Guildford Anti-Incinerator Network (GAIN). The Strategy does not reflect my aspirations for waste management in the region.
I object to the following points in the Strategy:
1. The Strategy proposes that between 11 and 27 additional incineration plants will need to be built in the region by 2010. Residents in various parts of the South East region have repeatedly demonstrated that this technology is not acceptable to them, and I wish the democratic processes to respect this view, especially given that an incinerator-free approach is feasible. [para. 6.33]
2. Whilst the Strategy recognises that we need to address the root causes of the growing amount of waste [para 1.21], the policies put forward are not very convincing when it comes to delivering this vision. SEERA illustrates their lack of commitment to this vision by dismissing the 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). SEERA should aspire to the vision of the South West Regional Assembly who are now working towards zero waste production in their region. [policy W1-W5, para. 1.10, 5.1 - 5.18, 7.3 - 7.17]
3. The Strategy gives a very pessimistic view of the maximum achievable levels for recycling and composting of household waste. It states that no matter what approach is used the maximum level is 50%. Even though these levels have already been achieved elsewhere in the UK and Europe the Strategy suggests that people in the South East are unique and are incapable of matching this. [policy W7 + W13, para 5.22 5.31, 7.18 - 7.25, 7.56]
4. Whilst the Strategys vision recognises the importance of waste minimisation and more efficient management of natural resources, it is totally lacking in suggestions of how these policies will be implemented. It focuses too heavily on changes to land use planning and fails to tackle the key issues of education and awareness. [policy W1-W5]
5. The Strategy fails to highlight the current crisis facing the incineration industry relating to the disposal of ash. Incineration reduces the weight of the waste input by up to 70% and generates ash as a by-product. According to the recent Cabinet Office report Waste not want not, 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 recently highlighted that from July 2004 there will be no landfill space for hazardous waste in the region due to changes in landfill restrictions. Unless SEERA agree that dumping toxic waste in the River Thames is acceptable, this casts serious doubt on the operational viability of incineration in the region. [policy W20, para. 5.47, 7.91-7.93]
6. Incineration should not be classed as energy recovery. 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. [policy W6]
7. SEERA have admitted that there are no accurate figures available for current waste arisings of commercial, industrial, construction and demolition waste. SEERA have relied on DEFRAs Waste Strategy 2000 and assumed a 3% growth figure for household waste, even though this figure has been challenged by independent experts [ref. House of Commons Environmental Audit Committee 5th Report, Session 2000/01]. Furthermore, there are no accurate figures to indicate the current amount of landfill void space. Therefore I have serious doubts about the predicted capacity figures given in the Strategy. As the chairman of the North East Region Technical Advisory Board said, predict and provide is dead. [para 4.9, 4.11, 4.13, 4.24]
8. The Strategy identifies a number of possible waste management options. SEERAs preferred option and alternative option are both based on mass-burn incineration in conjunction with recycling and composting. All other technologies are excluded on the grounds that there is insufficient data available to illustrate their effectiveness based on the typical UK waste stream. The real problem is that SEERA does not have sufficient information on the composition of the regions waste stream, and has failed to commission a study to gather this information in order to establish how best to treat it. The Governments recent response (6 May) to the Cabinet Office Waste not, want not report states that the Government will promote the development of new and viable waste management technologies. Therefore SEERAs selection criteria must be changed. [para 6.21 6.33, 6.56, 6.57, 7.45 -7.47]
9. SEERA have failed to ensure there is wide public consultation for this Strategy. There have been no public meetings to debate the Strategy, there have been no road shows, and there has been no advertising to announce the report. Most people are not aware that the Strategy exists.
My 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%. As proposed in Joan Ruddocks Municipal Waste Recycling Bill, the regional target for recycling and composting of household waste should be 50% by 2010.
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 bio-degradable materials account for much of the South Easts 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). I am opposed to MBT when it is combined with incineration for processing Refuse Derived Fuel.
· 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 W12 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 W13, 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 W13 happen. [para 7.59 - 7.60]
Please place this individual letter on deposit, acknowledge its receipt and send me a reference number to use in future correspondence.
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