Mr R. Hargreaves
Head of Planning and Development
Surrey County Council (Ref EH room 415)
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
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
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
- 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
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
- A distinction made between stabilised and
Please place this letter on
deposit, acknowledge its receipt and send me a reference number to use in