Mr R. Hargreaves

Head of Planning and Development

Surrey County Council (Ref EH room 415)

FREEPOST KT2451

Surrey KT1 2BR

Dear Mr Hargreaves,

As a resident in the county, I object to the Policy on Waste Management (DN19) in the Surrey Structure Plan deposit draft and support the concerns expressed by GAIN. The policy does not reflect my aspirations for waste management in the county. I am deeply concerned that it will be exploited to permit the development of incinerators for household, commercial and even “regional” waste in Surrey.

1. I object to the statement in Policy DN19 that waste management will be “in accordance with the waste hierarchy”. This is because:

• I object to the description of the waste hierarchy given in the commentary on DN19. I believe that six categories would reflect recent changes in waste policy: minimisation, re-use, recycling and composting, energy recovery (from which thermal treatment for normal waste should be excluded), sorted and stabilised landfill, unsorted and untreated landfill (which should be phased out). The draft puts recycling and recovery into the same category and also describes generating energy from waste as “recycling” which it is not. In recent government publications, recycling is placed above “energy from waste recovery”. I would like to see a clear distinction made between recycling and recovery, with energy recovery placed below recycling and composting. I also wish a distinction to be drawn between sorted, stabilised landfill and unsorted, untreated landfill, the latter being lower down the waste hierarchy.
• I object to the test “failing that value should be recovered” as a test of accordance with the waste hierarchy. I wish to see recycling and composting encouraged (when waste avoidance or reuse is not possible) but I do not want any thermal treatment of Surrey’s general waste. The plan should reflect the concerns about incineration so widely held within the county and explicitly state that Surrey will not use incineration or other thermal treatment as a means of energy recovery. Thermal treatments should be kept for dealing only with the most specialist needs and not used for general waste disposal.
• I object to the test that “only if none of the above offers an appropriate solution should waste be disposed of in landfill. How is “appropriate” decided? I wish the words “sorted and pre-treated” to be added before landfill at the end of 4.65.

2. I object to the statements in Policy DN19 that provision will be made “for sufficient waste facilities to deal with the quantity of waste arising in Surrey” and that provision of new capacity will be “in line with local and regional needs”.

• This wording does not adequately reflect the policy objective of managing demand (as opposed to an outdated “predict and provide” approach). Reference is made to “monitoring and controlling” the supply of facilities but not to managing need. The draft makes insufficient provision for waste minimisation policies to have an impact over time and suggests the absence of any intention to pursue minimisation in spite of its status at the top of the waste hierarchy.
• The commentary states that the Joint Municipal Waste Strategy will take account of commercial and industrial waste in addition to its remit of municipal waste. I object to the way that the scope of DN19 is being widened in this way so that waste streams are being muddled and confused. The policy should make clear the different obligations and responses that the county has for each of these streams. They should not be treated as a single entity within this policy. A county plan should be very clear about the lack of influence a county has over which businesses use waste facilities within a county’s boundaries and also about the enormous potential for waste minimisation initiatives within this sector.
• The commentary states that Surrey will make an appropriate contribution to regional waste needs. The beginning of the policy itself refers to provision for “waste arising in Surrey” whereas the end of the policy makes a provision for “regional needs” to influence the supply of new facilities. I would like it made clear that an appeal to regional needs will not be used as a reason for imposing unwanted facilities on Surrey residents.

3. I object to the statement in Policy DN19 that “Land in existing waste management use will be safeguarded for future waste use needs.”

• There is no provision for deciding that further waste use of a site might be inappropriate. For example, a landfill site might be in the floodplain and future development of that site might be deemed inappropriate in line with the heightened awareness of flood risk reflected in PPG25. A landfill site might have been restored to a conservation and amenity use. A site used for composting would always stay a waste site and could be a target for other waste proposals such as an incinerator.

4. I object to the statements in Policy DN19 that “waste facilities will be located as close as possible to the origin of the waste, subject to acceptable impact on amenity.”

• This lacks sufficient clarity to be workable. On what scale will this operate? Does this mean that all facilities will be small such that each community can have a facility on its doorstep? Does this mean that major, county-wide facilities will be located at a point closer to where most people live and work than any other? How would this be applied to commercial and industrial waste given that the county would have no influence over the location of companies using a facility, which could be from London or elsewhere in the region? Should commercial waste facilities be as close as possible to London within the county? How will account be taken of the portfolios of different waste operators? Where they own sites and where they have contracts to receive waste may not be proximal.
• How does this take account of the site safeguarding policy referred to in 3 above? If existing waste managements sites are to continue in waste management use, in reality will the proximity principle mean: “of the existing waste sites in the county, the ones nearest most people will be chosen for county wide facilities such as large scale incineration”?

5. The performance indicators in the section ‘How this policy will be implemented’ reinforce my objections to Policy DN19.

• The first indicator is far too vague. If waste minimisation is priority number one then “capacity for treating” is not an appropriate measure because with minimisation the need for treatment capacity is avoided. A better measure would be: “avoidance of thermal waste treatment combined with reduction in unsorted, untreated landfill”.
• Waste mileage by road is too simplistic and would be impossible to measure for commercial and industrial waste. Mileage is but one consideration when undertaking environmental assessments of options and determining the best practicable environmental option. Singling out this impact would distort decision-making. A better indicator would be continuing improvement in environmental performance as judged by periodic strategic environmental assessment of the impacts of waste management in the county.

6. Under “How the policy will be implemented” I should like to see:

• A clear commitment that the county will work constructively with all interested parties in implementing its waste policies in the way that government guidelines require. It is regrettable that there is no reference to partnership or consultation with the wider community who have such a vital role to play if waste management objectives are to be achieved.
• A distinction made between stabilised and untreated landfill.

Please place this letter on deposit, acknowledge its receipt and send me a reference number to use in future correspondence.

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Yours sincerely,