i) Are the Proposed Alterations consistent with national policy and European legislation?
The proposed alterations help but do not yet make the strategy consistent with national policy and European legislation. The Regional Strategy also needs to take account of Directives coming into force during the period of the Strategy.
Taking account of: the EC's Framework Directive on Waste, the Landfill Directive, the Bio Waste Directive in preparation, the Strategic Environmental Assessment Directive, the introduction of Environmental Sustainability Appraisals nationally, and Waste Strategy 2000, we are concerned that the Regional Waste Strategy should give more prominence to the following:-
· Planning provision for activities higher up the waste hierarchy.
· Distinguishing between planning provision for recovery of materials and for lower priority recovery of energy.
· Encouragement of and planning provision for re-use.
· The importance of separating materials into different streams which lend themselves to different treatment processes.
· Basing decisions on BPEO appraisals.
· Removal of biodegradable material from landfill.
· Pre-treatment to stabilise landfill.
· Public concern about incineration and aspirations for a more environmentally sustainable approach.
· SEERA's environmental sustainability appraisal which found that targets could be exceeded by recycling and composting alone and that this would be the best environmentally sustainable option.
· The need for an extremely rapid and major expansion of food waste collection and processing facilities.
· The need to base decisions on waste processes on the nature of each waste stream (eg glass, paper) as much as on which sector produced the waste (eg. C&I, MSW).
· Energy from waste incineration should be the last processing option not just "integrated".
In view of this, we recommend the following changes:-
· Second sentence after "increasing" insert "re-use" which is an important priority as reflected in the Waste Hierarchy in WS2000.
· Second sentence delete "recovery" which is used in Policy W5 to include recycling and composting. Insert instead "other recovery of materials". (Refer to hierarchy in Waste Framework Directive article 3 and WS2000 Section 4.5)
· After second sentence insert "Incineration with energy recovery" is only to be considered after the above options have been explored." (Refer to WS2000 Section 4.5)
· Second paragraph, first sentence, at end insert "and which has been stabilised". (Refer WS2000 Section 4.5 iii and Waste Framework Directive Article 4 and Landfill Directive.)
· First sentence delete "including", replace with "taking account of" and at end of sentence add "and of the overriding priority to be given to waste reduction and re-use". Waste minimisation and re-use will only be achieved (WS2000 priority) if integrated into relevant aspects of the Strategy.
· First sentence insert "re-use", before "recovery" to reflect the priorities of Waste Framework Directive and WS2000.
· Also add "untreated or biodegradable" before "landfill" to reflect the objectives of the Landfill Directive while allowing for landfill of stable material that could be the BPEO.
· Recovery targets should also be set for each waste stream e.g. if considering plastic , knowing the source of the stream and what facilities are in place to deal with it is just as important as knowing who produced it. WS2000 Section 4.4 is clear that the BPEO will vary for different waste streams. Setting separate targets for each of these streams will optimise the contribution of each waste function to overall targets and encourage the use of processes higher up the waste hierarchy.
· A distinction should be made between the first three processes (see bullet points) which are a higher priority and the last which is a lower priority according to WS2000 section 4.5.
· Insert after the 4 bullet points, "Priority will be given to processes higher up the waste hierarchy and Environmental Sustainability Appraisals will inform process selection".
· In the last sentence insert "stabilised" before "residue " and after "that" insert "has been stabilised but that" to make clear that the landfilling of unstable waste goes against the objectives of the Waste Framework Directive Article 4 and the Landfill Directive.
· Policy W5 should push forward a short-term solution for complying with the EU Landfill Directive based on using pre-treatment facilities (MBT, Mechanical Biological Treatment) to stabilise the biodegradable content before sending it to sorted landfill.
· Again targets should be set per waste stream to complement those per sector e.g. food waste provision needs to be phased in to deliver Bio Waste Directive objectives. Separating out this faction and setting targets would focus efforts on delivering processes for treating a very significant part of the region's waste.
· Third sentence, before materials recovery facilities insert, "resource recovery parks,".
· This policy should be reworded to relate the development plan requirements to the priorities of WS2000 and relevant Directives.
· Delete "An" at the beginning and replace with "Best Practicable Environmental Option assessment, Environmental Sustainability Appraisals and the waste hierarchy will determine the" and after following activities insert "which".
· Insert as first bullet point "activities requiring easy public access for collection of separated materials and encouragement of re-use.
· Move up the last bullet point to reflect its priority.
· Move third bullet point to the end. Before "Activities", insert "where segregation of materials is not the Best Practicable Environmental Option," and at the end add "may be required."
· At end add "Each borough or district should make provision for its own or shared use of a closed vessel compost plant for processing food waste."
· After first sentence insert "Provision for separate food waste collection should be provided to facilitate compliance with the Bio-Waste Directive and contribute to the targets in W6." This will avoid a repeat of the problems with failure to phase in the requirements of the Directive on electrical goods.
· This policy has a distorting effect on the priorities of the waste hierarchy the strategy purports to further. In this respect it is at odds with national policy and the thrust of European Directives.
· Delete words after "development" and instead insert "of a closed vessel compost plant with gas capture for food waste and other appropriate biodegradable waste in every borough and district because of the significant contribution separating out this waste stream can make to waste policy objectives during the period of the strategy. Priority will be given to treating separated waste streams for reuse of secondary materials. The Regional Assembly will encourage the development of anaerobic digestion and advanced recovery technologies where these are the BPEO for a particular separated waste stream or to stabilise post separation residual waste."
· Second paragraph, delete "as part of an integrated approach to management" which is at odds with WS2000. According to the national strategy the test should be "if opportunities for recycling and composting have been explored." Given the immaturity of recycling and composting and the potential of these and other material and gas recovery to meet targets during the plan period, we submit that there should be no provision for energy from waste during the period of this strategy.
· Last sentence insert "and material should be pre-treated to increase its stability".
· Policy W13 should be changed to set targets for the pre-treatment of non-inert waste going to landfill.
W17 and W18
· These need to refer more closely to the BPEO guidance in WS2000 Section 4.4. The policy should make clear that different locations will be appropriate for different waste streams and processes e.g. whether a built up area or remote location is appropriate.
ii) Are the Proposed Alterations well integrated with RPG9 and its partial reviews, particularly on transport and renewable energy?
· SEERA’s Strategy for Energy Efficiency and Renewable Energy (Oct 2002) states that “We consider that renewable energy targets should not drive decisions on the management of waste”. In spite of this, policy W11 and paragraph 2.70 emphasise the use of garden waste as a source of biomass fuel.
iii) Are the Proposed Alterations well integrated with other South East regional strategies (including Vision, strategy principles and objectives)?
· To disregard the conclusions of the Environmental Sustainability Appraisal, which showed that targets can be met or exceeded using recycling and composting alone, would be at odds with the Region's strategy on Sustainable Development.
· Community groups from across the region, including GAIN, have repeatedly demonstrated that waste targets can be met via reduction, re-use, recycling and composting without the need for any thermal treatment. Please see Appendix A attached to this statement. To disregard this would be at odds with the Region's aspiration to work with the community for a better environment.
i) Is the assumed reduction in rates of growth of waste an appropriate starting point for the waste management strategy (Policies W1 and W19, Annex 5)?
The target for reducing the waste growth rate (to 0.5% p/a by 2020) needs to be more ambitious. Based on the strategies produced in other regions, such as the South West, and Yorkshire & Humberside, a target should be set to reduce growth of all waste to 0% by 2010 increasing to 3% by 2020.
We have concerns with the accuracy of data and assumptions made with respect to predicting future waste handling capacity requirements. Firstly, SEERA’s Regional Waste Strategy assumes that municipal waste will continue to grow approximately 3% per annum [Annex 4 paragraph 4.9]. However, figures published by DEFRA show a 1.8% rise in municipal waste, and 1.1% in household waste, nationally [See “Municipal Waste Management Statistics 2002/3”, DEFRA, Apr 2004.].
Secondly, SEERA’s Regional Waste 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 Commons debate, the Environment Minister Elliot Morley informed MPs that the amount of commercial and industrial waste going to landfill saw an annual reduction of 2.6% between 1998 and 2001 [See House of Commons Hansard 28 Oct 2003, column 254].
ii) Do the Proposed Alterations adequately reflect the measures necessary to encourage this reduction to happen (Policies W1 and W19, Annex 5)?
Advocating Government to develop awareness campaigns and fiscal measures [policy W1 + W19] are a step in the right direction. However, policy W20 and the Implementation Plan [section 3] are not adequate to bring about the required reduction in growth rate.
Details given in SEERA’s documents in relation to the “public consultation” suggest that SEERA had difficulty in engaging with the public and businesses. SEERA’s assertion that there is “broad support” for their pro-incineration approach is primarily based on the results of a MORI survey of 800 people. This interpretation is unsound for the following reasons:
· Two thirds of the people sampled in the MORI survey considered themselves to be not very well informed on waste-related matters.
· 71% of the 1,746 people who responded to SEERA’s consultation were opposed to incineration.
· Numerous other consultations (eg. Surrey Waste Local Plan, Surrey Structure Plan, planning applications for three incinerators in Surrey) confirm that thermal treatment is not an acceptable technology to the general public.
If SEERA adopts a strategy which meets targets and also avoids the most unpopular technologies it will find it easier to work in partnership with the public in delivering waste reduction objectives.
The Implementation Plan does not adequately tackle the key issues of education and awareness.
The key organisations listed in section 3 of SEERA’s Regional Waste Strategy need to give a commitment that they will take responsibility for specific actions within their respective area. It is unclear how these activities will be co-ordinated. SEERA has very limited capability for delivering public services and actively working with the public. We therefore suggest that SEERA supports the creation of a waste forum in each county with representatives from local authorities, community groups and businesses to facilitate a co-ordinated approach and effective community involvement.
i) Are the Proposed Alterations explicit enough about the means of creating new markets and business opportunities for recycled and recovered materials (Policies W8 and W9)?
· In general terms we support the Proposed Alterations with respect to policy W8 and policy W9.
· We suggest that policy W8 is changed to make it more forceful by replacing the word “should” with “must”.
· We suggest that policy W9 is changed to replace the words “will look to” and make it clear who will be co-ordinating the work of SEEDA and WRAP.
· Effective communication by SEERA is essential to keeping the relevant people informed of progress and sharing knowledge with other regional assemblies.
· The policy W9 should be changed to include the following additional point: “All local authorities and public sector organisations in the region should lead by example by changing their procurement practices to favour products made from recycled materials”.
Guildford Anti-Incinerator Network (GAIN)
c/o The Vicarage, 5 Orchard Road, Guildford GU4 7JH
web site: http://www.no-incinerator.org.uk