Issues and Options –

A Waste Development Framework for Surrey

 

Comments by GAIN - February 2005

 

GAIN would very much welcome an opportunity to discuss its submission with relevant members and officers just as Surrey meets with other partners involved in waste issues in the county.  We believe that this consultation provides a very important opportunity to align waste policy in Surrey with rapidly changing modern standards and with well-reasoned community aspirations that meet those standards.

 

COMMENTS ON INFORMATION AVAILABLE UNDER INSTRUCTIONS SECTION:

 

i) Failure to include Council’s Waste Policy in Consultation Exercise:

The County Council has issued a position statement on waste. This clarifies that the Council’s currently preferred waste ”disposal” option is incineration This policy will be an important driver and is crucial to understanding the context of waste decisions in the county.  This policy statement is not made readily available to those responding to the consultation.  The Council was requested to make this position statement available as part of the consultation package at a seminar for local authority, industry and community partners prior to the consultation launch.  The implications of many of the proposed plan policies are very different if one is aware of the declared preference for incineration.  The Council’s decision not to assist participants by making the waste policy statement readily available undermines the credibility of the consultation and leaves many respondents ignorant of the weight likely to be given to different options in practice.  Policies, which appear neutral across a range of options, would in practice be used to enable incineration.  The council is not being open and clear with participants.

 

ii) Information on Background Reports is Inadequate:

We are concerned that the Statement of Community Involvement is not given as one of the background documents and summarised.  This is an ongoing consultative document.  We consider that many respondents would have been interested to learn that they have statutory rights as consultees, that Surrey has not been able to comply with its statutory community involvement requirements and that Surrey is not only required to consult but also to demonstrate how it has taken account of what the public has said.  This is particularly relevant given that there have now been well over 80,000 objections to incineration in Surrey, many of them supported by clear commitments to feasible alternative strategies, of which the county council has taken little account to date.

 

We welcome the decision to include the three background reports as part of the consultation following requests made at the pre-consultation seminar.  We are disappointed, however, that the summaries give insufficient information on the specific assumptions being made and focus too much on the general process.  Such is the importance of the background reports that we believe their main recommendation should have been included in the main consultation package.  This is a particular problem with the BPEO report.  Without looking at the summary of this background report, anyone responding will be unaware that specific recommendations are being made for the mix of technologies in Surrey.  If they were made aware that the BPEO report was proposing incineration as the best and most practical option many more people would be likely to look at the BPEO report.  Many people will look at the policies in the Issues Papers and assume they offer even-handed, open waste options.  They will be completely unaware that they have to look at the background reports to see that incineration is being advocated as the best practical option.  Many policies in the Issues Papers take on a different complexion once this is known.  The approach lacks transparency.  It should have been made clear to all consultees accessing the consultation that incineration and other burning options are being advocated so that the public can respond to this approach.  The Issues section of Paper 2 provided a ready opportunity to insert this information.  If the Council only reveals its preference for incineration in the main documents at the next stage of the consultation, the debate at that stage will be about sites rather than the principle of which technologies best meet Surrey’s needs.  Alternative incinerator-free scenarios would be easier to develop at this stage than later in the consultation exercise.

 

Comments on the Best Practicable Environmental Option Report:

 

GAIN is strongly committed to the principle of a well-founded, accountable BPEO process.  However, we see the current BPEO report as fundamentally flawed.  We also question the wisdom of using the same consultants as Surrey Waste Management to produce it.

 

Waste Composition:

Surrey has excellent data on the composition of its waste.  However there has been no matching between waste treatments proposed and the composition of the waste.

 

The fact that 62% of Surrey’s municipal waste is biodegradable is drawn upon to propose that composting and biological treatment alone will not deal with the county’s waste.  This misses the point that there are tremendous opportunities to deal with much of the County’s waste through these technologies.  The fact that 38% of Surrey’s municipal waste is not biodegradable means that this can be dealt with without affecting the landfill targets and much of it can be recycled.  It just needs to be separated.  As for the 62% that is biodegradable, it makes little sense to burn it when much of it can be recycled, composted or made sufficiently non-reactive to be put on land.

 

The wisdom of burning biodegradable waste, from which material could have been recovered and biogas captured, is not considered an issue in the report when incineration is proposed.

 

Selection of Technology Options:

Option H, involving recycling, composting, anaerobic digestion, mechanical and biological treatment and landfill, which was favoured in a joint consultation by the Districts and County, is ignored and not related to the options developed.

 

Closed Vessel Compost plants are not considered and insufficient account is taken of the potential for gas capture under biological processes to generate energy.

 

Impacts of Options:

a) Emissions to air are considered under three headings:

-         air acidification

-         greenhouse gas emissions

-         health effects

If the scores of these three impacts are combined, emissions to air can be seen as the biggest concern.  If these three impacts are considered together, rather than separately, then a different ranking of the technologies emerges.  We note that anaerobic digestion fares well, and incineration badly, on health effects.

 

Babtie’s review of the BPEO report observes that far less weight is given to emissions to air in Surrey than was the case in a similar exercise in East Sussex and Brighton ad Hove.  This should have raised questions and triggered a sensitivity analysis.  It is unlikely that the two planning regions are so very different.  This raises the question as to whether, in each case, the stakeholder groups being used were reflective of opinions across the community.

 

b) Air acidification:

SO2 emissions are used as a proxy for all acidifying gases.  Yet NO2 emissions have been by far and away the biggest concern when considering the impacts of waste plant in Surrey because the county already has high levels for this pollutant in many areas.  Previously proposed incinerators would have had significant impacts on NO2 levels.  NO2 emissions would be a much more appropriate proxy.  Incinerators do not fare particularly well with respect to NO2 and it will be important to assess how this compares with other waste technologies.

 

c) Real data:

The impact assessments are based on ideal/ normal operating conditions.  It is crucial when considering the impacts of waste technologies, and in particular thermal treatment processes, that realistically achievable emission data are used.  Waste can be a very variable fuel and process efficiencies fluctuate greatly.  Impact assessments based on theoretically achievable outputs are not relevant.  It is emissions and other impacts achieved in practice when operating waste plant that are relevant.

 

d) Ash impacts:

It is assumed that incinerator bottom ash will be recycled.  This has not been achieved to date.   Indeed, as cited in Surrey’s background paper on Waste Management Technologies in the section on incinerators: “Ash residues still tend to be disposed of to landfill.”  Yet in the BPEO report it has been assumed that none on the bottom ash goes to landfill.

 

e) Compost impacts:

When considering the impacts of composting the reduced impacts of closed vessel systems and the possibility of gas capture are not considered.

 

f) Landfill impacts:

The greatly reduced impacts of non- biodegradable, non- reactive landfill are not considered.

 

Valued performance data:

It is of interest that the incineration option fares badly in relation to health impacts, landtake, extent of public involvement, reliability of delivery and waste hierarchy ranking.

 

Weightings Consultation:

We do not consider that the members who were involved in weighting the assessment criteria represented an appropriate cross section of stakeholders.

The weightings should be redone in a more accountable way taking account of concerns across the community.

 

Weightings:

We share the concerns of Babtie that the significance attached to practicality sways the findings significantly.  We note that had the East Sussex and Brighton and Hove weighting set been applied, then option 8 (high recycling and composting, two anaerobic digestion plants and landfill) would have come out as the best option.

 

Practicality vs Environmental Criteria:

This is a curious section in which even the weightings agreed at the workshop are overridden and the weighting given to practicality (cost plus reliability of delivery) is arbitrarily doubled to 44%.  At this level it is claimed that incineration (rather then MBT to produce pellets) becomes the best option.  The process by which these figures have been derived is totally dubious.

 

Landtake;

To conduct a sensitivity analysis on the criterion considered to be the least significant seems curious.  It is noted that excluding the land requirements of landfill associated with incineration elevates this option to rank second.

 

The BPEO report represents a missed opportunity to rigorously assess a range of waste options for Surrey.  We note with considerable interest that Anaerobic Digestion fares well across a range of weighting sets when rerunning this BPEO analysis.  It would also meet targets and fit in well with Surrey’s waste composition analysis, the Regional Strategy and community aspirations.  We also record that the type of MBT many in the community, including GAIN, would be particularly interested in investigating is MBT based around anaerobic digestion to produce compost, soil conditioner and residue with reduced reactivity and biodegradability.  It appears that this would be a very productive avenue to investigate further.  It is regrettable that ERM only considered MBT to produce refuse derived fuel.

 

Comments on the Strategic Environmental Assessment:

 

GAIN notes with concern that only two of the invited organisations responded to the consultation on the scope of this report.

 

We note that Surrey is carrying out a Strategic Environmental Assessment during the preparation of its Waste Framework and that a Report has been produced to inform this ongoing process.  We welcome the opportunity to comment on this report and request that we may send in our comments by the end of March as it is not possible for us to do justice to this important document alongside all the other consultative papers.  We would find it helpful to know whether Surrey has started its Strategic Environmental Assessment based on this report and to receive any papers on this ongoing process as the Framework develops.

 

We ask if it is appropriate for ERM to undertake an assessment of the BPEO report?

 

Comments on the Sustainability Appraisal:

 

GAIN would welcome an opportunity to discuss this further with Surrey and was grateful to be invited to join the meeting that launched this process.  At present we are concerned that although general sustainability issues have been identified, more time needs to be taken to identify sustainability indicators that are particularly relevant to waste.  We do not see this is a criticism.  It is more that Surrey was one of the first to embark on a new planning process and we suggest that further collective work is needed to develop sustainability measures in a way that assists waste planning.  We would welcome an opportunity to discuss this.

 

PAPER 1

 

Paper 1, Question 1: COMMENTS ON BACKGROUND SECTION:

 

Outline of Topic:

GAIN suggests that what is missing is an objective for Surrey that residents can rally around and feel motivated by.

 

The EU Waste Framework Directive’s purpose is our well being and that of the environment.  The appropriate extract from the directive should be quoted in the background section of paper1 just as appropriate extracts are usefully being quoted in other parts.  The desire to protect human health and the environment as required by the Directive should be made overarching objectives and made relevant to Surrey residents.

 

Line six should refer to the desire to reduce the disposal of unsorted, putrescent waste to landfill.  Not all landfill is bad.  Surrey is a county with significant mineral extraction for which safe landfill material is required to make good such sites, often as a condition of the planning consents given.

 

We note with interest that, in the third sentence, the development of incineration is not being advocated as a way of making waste policy more sustainable in Surrey.

 

The references to waste growth in the county should be redrafted.  We suggest it is important to encourage and motivate the community, encourage any good changes in behaviour to date and make people aware just how much of a difference curbing rates of growth can make.  To assist in this it will be important to distinguish between waste per capita or household and overall rates.  Some communities in Surrey will grow significantly during the life of this plan.  This needs to be taken into account if residents in expanding settlements are not to be discouraged from changing their waste practices by being told waste is increasing in spite of their efforts.

 

Waste Generation in Surrey:

Missing Section on Waste Composition:

We are very disappointed that the very useful work on the composition of Surrey’s waste is not set out alongside how much is produced.  The nature of the material is crucial for establishing the options as to what might be done with it.  It is particularly important to set out for both Municipal and for Commercial and Industrial waste how much is biodegradable, how much is recyclable and how much is best composted (rather than recycled).  Plastics should be identified separately by volume because this is a more significant measure than weight for this lighter material.

 

We are shocked by the figure that the amount of waste from London that is disposed of in Surrey amounts to over 40% of the waste generated in Surrey.   The London waste disposed of here is well over two times greater than the Municipal Waste generated in Surrey (2.24 times).   We take little comfort from the fact that in future this waste may be pre processed if this means much of it will be incinerator bottom ash.  This is a very reactive material.

 

Background Information:

We very much welcome the reference to the Waste Framework Directive and in particular the clarification that energy recovery comes after material recovery.  Some representations of the waste hierarchy blur this distinction and lump recovery of materials and energy recovery together.  We ask that this distinction is made clear throughout the documents.  We also suggest the word “material” is added before recovery in line three of paragraph 1.3.1 for clarity.

 

Landfill Directive:

We welcome the reference to the overall aims of the Landfill Directive.  This reminds us that it is crucial to avoid switching to another process with comparable pollution and environmental problems.

 

The Landfill Allowance Trading Scheme is being cited by Surrey to the Districts as such a major influence that the Surrey is turning its back on the work undertaken with the SLGA on an incinerator-free approach.  It is therefore surprising that we are not being given an opportunity to analyse the Council’s case for needing incineration to comply with LATS.

 

It is important to remember that it is biodegradable material that is to be removed from landfill.  It is not an overall landfill allowance.  Biodegradable landfill targets can be met either by landfilling ash from a thermal process or by landfilling material that has been subjected to mechanical and biological treatments (including anaerobic digestion).  In the case of ash, the material is not biodegradable but reactive.  In the case of MBT digestate, the material has reduced biodegradability and reduced reactivity.   The LATS allowances could be met by either route.  The important factor with the biological and mechanical processing route is to ensure that waste streams are segregated so that as much of the output as possible is clean enough to use as compost and soil conditioner and does not need to go to landfill.  As mechanical and biological processes work on a range of scales and larger

plant is often modular (using several parallel streams), separation of streams for different end uses is readily achievable with these technologies.  For example, compost from food waste could be identified and might be used in parks and gardens but not on farmland.  Garden waste could produce premium compost.  If, as GAIN advocates, every District in the borough had a closed vessel compost plant with two streams, one for food waste and one for garden waste, surprisingly significant volumes of waste would be diverted from landfill.  Energy could also be generated from captured gas.

 

An important factor in considering the need to reduce biodegradable landfill is the fact that such as large proportion of Surrey’s waste is potentially biodegradable.  This presents enormous opportunities for treating waste using biological processes.  Curiously, the BPEO report argues: “Only around 62% of Surrey’s MSW waste is biodegradable, and therefore, for example, it would not be appropriate to design an option that solely relied upon composting and biological treatment for example.”  We would argue that because such a high percentage of Surrey’s waste is biodegradable, if the county made the development of composting and biological processes a real priority, and maximised recycling, landfill and other targets could be met without needing to commit to any thermal process.  Another advantage of this approach is that compost facilities can be brought on stream relatively rapidly.  Also, once putrescent, biodegradable waste is segregated, householders will find it easier to separate other discarded materials and higher recycling rates for other materials should be more readily achievable.

 

 

Waste Management Hierarchy:

We are disappointed that the version of the Waste Hierarchy used in 1.3.4 does not make a clear distinction between preferred recovery of materials and recovery of energy.  “Recovery” is being used throughout this document in too many different ways to be useful.  Sometimes it is a euphemism for incineration and takes no account of the potential for energy generation from gases generated by composting or digestion.  Sometimes it includes materials and energy recovery.  Sometimes it just means energy recovery.  Materials recovery in the second sentence of 1.3.4 includes reuse and recycling but does not refer to composting or reclamation.  In the accompanying diagram in box 1, composting is included under recovery, which is welcome, but energy recovery is given the same status as recycling.  Materials recovery should be given higher status.

In the last sentence of 1.3.4, materials and energy recovery are again inaccurately given equal status.

 

The importance of the potential contribution of composting should be flagged up in this section.  It has a high status within the hierarchy and a vital role to play in meeting targets on diverting biodegradable waste from landfill.  Its role is made all the more important by the fact that such a high proportion of Surrey’s waste is biodegradable.

 

The last sentence of 1.3.4 should also make it clear that final disposal should be consistent with the objectives of the Waste Framework Directive and minimise the risk to the environment and human health.  This means it is important to ensure any “residual” landfill material is as safe and non reactive as possible.   Unsorted, reactive landfill would not comply with the Directive’s objectives.

 

Self Sufficiency and Regional Sustainability:

Surrey is being asked to do much more than to provide facilities for waste volumes anticipated in 10 years.  It is being asked to provide very significant volumes of capacity over and above this for London’s waste.

 

We consider that it is unfair on Surrey residents to deviate as proposed from an approach of regional self-sufficiency in waste capacity.  We submit that there should be no capacity for net imports.  It may be the best option for Surrey to take some imports and to make some exports.  The proximity principal allows for this.  If we are required to take some landfill from London, London should reciprocate and process some of our waste.

 

Regional Strategy:

The draft Surrey Framework does not give adequate attention to the region’s support for Anaerobic Digestion (under bullet point three).  This is very important because anaerobic digestion also fared well in Surrey’s BPEO assessment of health impacts and in the BPEO rerun by Babtie using a different weighting set.  It is also of great interest to many residents concerned about thermal processes.  Anaerobic Digestion could form part of a Mechanical and Biological Treatment plant intended to produce stabilised compostable material and energy from biogas.

 

The last sentence of 1.3.7 has important implications for Surrey’s Framework.  We strongly encourage Surrey to adopt the approach in its Framework of working in partnership with the Community to find waste solutions that have general public acceptability.  It will be less difficult to find sites in Surrey if the Council encourages facilities that make the best possible neighbours and that can be integrated into communities across the county.  We submit that if the Council made a commitment to move away from thermal processes it could harness a real enthusiasm and commitment within communities to find workable waste solutions.

 

Paper 1, Question 2:  COMMENTS ON ISSUES SECTION

 

Developing a Culture of Waste Minimisation:

GAIN strongly welcomes the emphasis being placed on waste minimisation.  We would like to the see the council making greater use of its powers to reward good practice in waste avoidance and charge for excessive waste generation.

 

The potential significance of home composting should be referred to here.  Food and garden waste suitable for home composting (in cones, wormeries and composters as appropriate) make up a significant proportion of the Municipal waste stream in Surrey.  Subsidised domestic compost facilities have the potential to make a very significant impact to the volumes of waste passing into the waste stream to be dealt with by the County.  The logic is similar to the use of water tanks in houses to store water.  Each tank is relatively small but added together they store a lot of water.  Without them very many enormous, expensive water storage reservoirs would need to be built at great environmental cost.  In the case of compost the objective is treating not storing, but in both cases small facilities in many homes avoid the need for large infrastructure.

 

We note and welcome the fact that a Best Value Target for minimisation could be introduced during the life of this framework.

 

Promoting and Facilitating the Reuse, Recycling and Recovery of Resources from Waste:

We note the confusing reference to “recovery of resources” from waste in this subheading.  The first sentence then refers to focusing effort on “recovery” and partnership with community groups to encourage this.  (Refer to previous comments on the waste hierarchy in our response.)  Because recovery is so often used a euphemism for incineration, and will probably mean incineration in practice in this plan, trust and partnership with many residents is lost.  We cannot support a policy that is code for encouraging incineration.  Indeed, Government policy is that incineration should be minimised as one of the last resort processes.

 

The Best Value Target referred to is for recycling not for recovery.  Many in the community are very keen to support the Council in its Best Value Target and to go beyond this.  The Council’s enthusiasm for incineration is hampering partnership.  Many residents have very well informed, deep concerns about incineration and feel that they cannot work in true partnership with the Council until and unless technologies with more acceptable impacts are pursued.  A switch from incineration is the key to unlocking community support.  If the policies specified the types of material and energy recovery to be encouraged and avoided thermal processes, enormous support and commitment from residents and community groups would be unlocked.

As this paragraph stands we strongly oppose it because the reference to recovery means incineration.

 

Missing Section on Separation:

A key issue for this section is separation of waste materials.  We consider it is important to change attitudes to the “bin” or the skip.   The nature and role of the bin at home, in the work place and in the classroom, need to change.  The Framework should facilitate such change.  Once different types of materials are co-mingled in a bin, opportunities for reuse and recycling are diminished.  The bin becomes unpleasant for the householder or employee to handle, it becomes a hassle to separate material and cross contamination occurs.  Changing the nature of the receptacles that discarded materials are placed into will have a crucial role to play in delivering the Framework’s objectives for reuse and recycling.  Separating waste takes up more space and this will need to be taken into account in the design of homes and workplaces.  “Bins” will have to be replaced with more modular or compartmentalised material “sorters”.  In this way materials would be kept separately making reuse and recycling easier.   The council should take a lead in encouraging the design and distribution of “sorters” to replace “bins” in schools, homes and workplaces.  This is not trivial semantic and design issue.  It is a crucial starting point for achieving the reduction, reuse and composting objectives of the plan.  No sorting system is as efficient as the householder’s separation of his or her own waste.

 

The Council should, in partnership with the Districts, offer incentives to residents who home compost and who separate their waste.  It should also charge residents who do not sort their waste for recycling.

 

Market Development for both Reuse and Recycling:

We welcome this section and suggest that much more should be made of the need to treat “waste” as a potential resource.  It would be helpful to set out how the proportion of potentially useful material in waste is often much greater than in a primary raw material.

 

We suggest that using a proportion of recycled material in products should also be encouraged.  For example, at present many leading brands of toilet paper use a proportion of recycled material.  Use of recycled material in these products far outweighs the amount of recyclate used in toilet roll marketed as being made from recycled materials.  We should not just be aiming to develop a niche for 100% recycled bin liners but also encouraging the vast majority of bin liners to contain some recyclate.  There could be many cases where the aim should be to make use of recycled materials so commonplace that it is not a major issue in the image and promotion of the product.  Surrey should be aiming for widespread use of a proportion of recycled materials not just a few niche markets.

 

We urge the Council to encourage the Government to use its powers of taxation to reward manufacturers who use recycled materials and avoid excessive waste.

 

Sufficient Waste Management Capacity:

This section is far too thin.  The Issues Papers produced for consultation on the aborted review of the Waste Plan, gave a much more detailed analysis of the need for capacity.  A much more rigorous case on the need for capacity is required for the Framework.  This should not just look at overall volumes but composition.

 

This section again refers to recovery.  Reuse and recycling are forms of materials recovery and it is unclear what recovery refers to.  The objective is not just to reduce reliance on landfill but also to minimise the use of incineration.

 

Refer to our comments on net self-sufficiency and concerns about imports from London in section 1.2.  The last sentence hoping that waste from London will diminish ignores crucial facts.  The destination of most waste is determined by commercial considerations such as which company has facilities where.  Also London’s Municipal waste is only part of the waste being generated by London.  Commercial and regulatory influences on Commercial and Industrial and on Construction and Demolition waste will be far more important in determining flows of waste across regional boundaries.  No grounds are proposed for assuming the volumes of these waste streams crossing into Surrey will diminish.

 

Missing Section on the Need for Flexibility:

GAIN is very conscious that waste policy is evolving very rapidly.  Almost as soon as it was signed, Surrey’s waste contract was out of date.  There are bound to be further changes during the life of the Framework.  Surrey should ensure that it does not commit to a small number of very large facilities in long -term commitments.  It will be important to build in flexibility to adapt and improve facilities over time.  A larger number of smaller facilities will assist in this.

 

Paper 1, Question 3 POLICY 1:

GAIN notes with considerable concern that the consultation has not asked for views on the merits of the proposed policies in this section.  It has purely asked what role Surrey should play in promotion and implementation.  This could distract many consultees from feeding in their comments on the content, balance and mix of the draft policies.

 

GAIN strongly supports the following words, which should be captured in the policies in the plan and not just used as preamble in the consultation:

Residents and businesses in Surrey need to ”reduce the quantity of waste produced and to manage arisings in accordance with treatment methods and technologies placed high in the waste hierarchy.”  This means that different types of discarded materials need to be separated to maximize opportunities for materials recovery and that technologies that mechanically and biologically recover materials should be promoted above thermal process whose principal output is energy.

 

Paper 1, Policy 1:

GAIN does not see why the Council will work in partnership with business, local authorities and public bodies and not with the public in (ii).  We will have our “awareness raised” but not be “partners”.  This is not a trivial point but represents a fundamental flaw in thinking.  If waste policy objectives are to be met and the fundamental changes necessary in public behaviour achieved, communities need to be engaged in a real partnership with Surrey.  This is achievable if Surrey adopts approaches with widespread community support.  Telling residents you are going to raise their awareness while forcing upon us unwanted thermal technologies that are low down the waste hierarchy is not likely to be a fruitful way forward.

 

This policy should include a strategy for encouraging home composting for appropriate garden and food waste (including wormeries and cones) working in partnership with Collection Authorities.

 

This policy should include a commitment to introduce variable charging for waste collection in partnership with Collection Authorities.  The emphasis should be on rewarding good practice and discouraging excessive waste generation.  It should be carefully structured to avoid giving any incentive for residents to burn rubbish in their homes and gardens.  The reward would be for using a compost bin, wormery or food cone and where this is not possible separating this material for sending to a community facility.  Obviously where this material is collected this becomes materials recovery not minimisation for the authorities.  However, this is still a good thing and should not distract attention from how much waste can avoid needing to be collected by such an integrated measure.  Another really important aspect of such a policy is that it would assist in taking food waste out of the domestic bin.  Once this is removed, residents will find much of the rest of their rubbish far less disagreeable to handle and a barrier to sorting and recycling will have been removed.

 

Paper 1, Policy 2:

GAIN is strongly opposed to the intention to promote and facilitate “recovery” in this policy.  This is because the BPEO report, Surrey’s policy statement and the contract indicate that “recovery” is intended to deliver energy recovery through incineration and possibly also through the burning of refuse derived fuel pellets.  If this policy were focussed on materials recovery and energy from biogas we would support it.  The same applies to the use of recovery in (iii).

 

Again, in (ii) we are concerned that the public and community groups are not being treated as partners and refer to our comments under Policy 1 above.

 

This policy should include a strategy for working in partnership with Collection Authorities to encourage separation of discarded materials to maximize the opportunities for reuse, recycling and other materials recovery.

 

This policy should include a commitment to introduce variable charging for waste collection in partnership with Collection Authorities.  The aim should be to reward good practice in separating discarded materials to maximise opportunities for reuse, recycling and other materials recovery.  Householders who declined to separate their waste would not benefit from rewards or a reduced tariff.

 

Paper 1, Policy 3:

GAIN would like to see this policy include a commitment to urging Government to introduce incentives for the use of recycled materials and disincentives for products that are unsustainable and generate excessive waste.

 

Paper 1, Policy 4:

GAIN is deeply concerned by this draft policy.

There is no link with a genuine attempt to reduce the amount of waste generated.  The approach is simply the outdated one of “predict and provide”.

Nor is there any link with the desire to give greater encouragement to waste facilities higher up the waste hierarchy.  It does not work to group policies for encouraging recycling with policies that could be used to encourage incineration.  Incineration is far lower down the waste hierarchy.  Waste Strategy 2000 and the Waste Framework Directive are quite clear that materials recovery should be given greater encouragement.

 

It is not sufficient to say Surrey will grant enough capacity to contribute to regional targets.

 

Reference to a range of facilities is far too vague.  There should be a clear sequential test for proposals linked to the waste hierarchy, with materials recovery well above energy recovery.

 

Committing to grant sufficient capacity for recovery will in reality mean allowing incineration to meet regional needs in Surrey.  This will open the way for incinerator applications.

 

In practice this policy will mean that facilities will be granted consent on a speculative agenda with the choice of technology driven by the waste industry.

 

This policy gives no scope for favouring and encouraging technologies that are higher up the waste hierarchy.

 

We are also deeply concerned about the ready acceptance of waste from London in this policy.  It commits Surrey to receiving landfill from London without any reciprocity.  Surrey should have no net imports.  It also commits Surrey to taking incinerator ash in the long term rather than encouraging London to look at waste options that do not produce vast quantities of ash.  Similarly, London should be under much more pressure to recycle and reuse its Construction and Demolition waste rather than sending it to landfill in Surrey.

 

Another shortcoming of this policy is that it does not relate waste handling capacity to the various fractions of the waste stream.  Having done all its useful work on the composition of the waste stream, it is of great importance that Surrey now drafts a policy that links the provision of capacity to the process that best suits each waste stream.  General tonnage figures are wholly inadequate for modern waste handling provision.  This policy should set aspirations for various waste fractions and establish the kind of handling facilities that will be appropriate.  In each case it should be clearly established that facilities should be as close to the top of the waste hierarchy as possible.  For example Paper :

Describe as a % of waste stream

Agree target % of this paper fraction to be recycled

Agree target % of this paper fraction to be composted

 

The policy should also recognise the need for some flexibility over the 10-year plan period and envisage that some new capacity will need to be held back to fill gaps in provision during the life of the Surrey Framework as policy evolves.  As reuse, recycling and composting rates rise, more facilities will be needed.

 

PAPER 2

 

Paper 2, Question 1: COMMENTS ON BACKGROUND SECTION

 

The Proximity Principle:

GAIN finds the reference to the Waste Framework Directive here particularly useful.  The desire for disposal facilities to be near is qualified in numerous and very important ways.  They are to be “integrated”.  They must be “appropriate”.  They must also offer “the most appropriate methods and technologies in order to ensure a high level of protection for the environment and human health”.

(The latter part of the extract would also be especially relevant at the beginning of the Issues Paper 1.)

The second paragraph of 1.2.1 appears to disregard the important qualifications placed on the proximity principle.  The reference to increased thermal efficiencies from a smaller number of larger plants is worrying.  It again reveals a fixation with thermal processes even though a case has not been made for these being the best ways of meeting the Directive’s requirements.  There is a really important debate to be had over the size and number of facilities but the subject is inadequately addressed here.  The appropriate scale and number of facilities depends on the part of the waste stream one is considering.  Heavy materials such as food waste, which can be readily dealt with in local facilities such as Closed Vessel Compost Plants, should probably be treated in a larger number of small facilities.  The Biological and Mechanical Treatment of screened waste to produce a stable residual might be better dealt with in a more modest number of facilities.

 

Sustainable Development:

There is a need for a section on sustainable development.  This is an international and national obligation that is passed on to local authorities and public bodies as a statutory duty.  It is very relevant to waste policy and should be seen as an important driver.  It involves wise use of resources to ensure that we hand on an environment to future generations that is not diminished.  This means we should not squander primary non-renewable resources.  We should use renewable and secondary materials as much as possible to reduce our impact on the planet and slow the rate at which we are consuming non-renewable resources.  A sustainable development approach to waste management requires us to ensure we treat discarded materials as resources to be reused or recycled whenever possible.  Burning discarded materials when they have been used only once is not sustainable.

 

National Planning Policy Guidance:

Reference should be made to PPG/S 25 which deals with flooding.  Flood risk is a seemingly ever more relevant issue and significant parts of Surrey are in the flood plain.  It is very important that strategic sites such as some types of waste facilities are not placed in the flood plain.  It is advised that strategic facilities should avoid the 1 in 25 year floodplain.   This is because we should not impede the storage capacity of functioning floodplains, because potential disruption and damage to vital facilities should be avoided and because of potential pollution risks.

 

Surrey’s Assets:

The list of Surrey’s assets should include its valued historic towns and villages of character.   It should also include its important rivers and waterways such as the Wey Navigation.

 

Surrey’s heaths also need a special mention by name not just as SACs.  They are very rare, threatened as a result of fragmentation and very susceptible to acidification through air pollution.

 

Paper 2, Question 2: COMENTS ON THE ISSUES SECTION

 

Need for Facilities and Balance with Land Use Restrictions:

GAIN is again concerned by the use of the word recovery in this issues section.  There is an unquestioning acceptance that lots of new facilities and a range of facilities will be required without any commitment to manage the capacity needed and the type of facilities.  The key point in this section, however, is that it will be hard to find sites that do not harm valued assets in Surrey.  This places a responsibility on Surrey to come up with ways of managing waste that will fit into the landscape of Surrey in a way that does minimal harm.  If valued countryside and character townscapes are to be protected and also human health, it will be important to create a network of waste facilities that make acceptable neighbours.

 

 

 

Wastewater and Sewage Treatment:

These types of waste should follow the logic of no net imports.  New plant should not be built in Surrey, to deal with waste from a catchment outside Surrey, unless part of Surrey’s waste is being dealt with elsewhere in the catchment.

 

Gain is opposed to the burning of sewage sludge preferring aerobic digestion.

 

Planning Applications:

Individual proposals should be expected to submit BPEO assessments as well as to show how they fit in with a strategic BPEO report for the county.  The current BPEO report has many flaws and needs significant amendment before it can be relied upon with confidence to guide waste decisions on the county.  It also sets a bad precedent.  It appears that the weighting given to factors where incineration scores well have been increased until incineration apparently does best.  The practicality weighting is doubled, downgrading all the environmental scores, to increase the score for incineration.  Surrey has set a dangerous precedent where applicants could deploy similar tactics to make their proposal appear to be a good option.  GAIN is strongly supportive of a BPEO approach buts calls for it to be conducted taking true account of environmental concerns.

 

The second paragraph of this section misses a very important point.  Yes, unsorted, untreated landfill is a bad neighbour but so too is incineration, which is the recovery process being advocated by Surrey.  Also, incineration will lead to the landfilling of hazardous fly ash. The problem again arises that the broad categories being used to describe waste processes are not useful.  A small closed vessel compost plant, a remote landfill taking only sorted, pre-treated waste or a community recycling centre will be less difficult to live alongside than an incinerator.  Traffic, pollution and risk of pollution incidents are key concerns to residents.  High design quality will be desirable for an appropriate facility but getting the type of facility right will be a far greater concern to many, as demonstrated by the 17,000 letters of objection to the Guildford incinerator.

 

Paper 2, Policy 1:

GAIN welcomes the reference to the “types and sources of waste”.  This should be redrafted to make it clear that the key issue is the composition of the waste not which sector produced it.

The policy should also reflect the Directive’s requirement that, when considering proximity, one should also look at the appropriateness of the proposed technology and methods, in terms of delivering a high level of protection for the environment and human health.

Sections (ii) and (iii) helpfully refer to the scale and type of facility.  However, both policies go on to assess these factors in relation to “contribution to meeting the needs of Surrey.”  This is an inadequate and unclear measure.  The “needs of Surrey” could be taken to mean a range of facilities, as long as they are above unsorted landfill in the waste hierarchy.  It could mean making a significant contribution to regional need including a very significant tonnage of waste from London.  It needs to be made much clearer that facilities would be expected to maximise the potential for treating waste higher up the waste hierarchy, wherever possible recovering materials.

 

Paper 2, Policy 2:

GAIN warmly welcomes this policy.

This logic should be extended to imposing conditions on the type of waste to be managed at a facility.  This will be valuable in ensuring facilities are used for delivering an anticipated role in the waste hierarchy and do not process waste that would be better treated at a facility that is higher up the hierarchy.  It might also be valuable in preventing inappropriate categories of waste, such as clinical waste, from being processed at an unsuitable facility.

The Council should confirm that it may impose conditions in relation to impacts and emissions.

 

Paper 2, Policy 3:

GAIN would add “The character of historic towns and villages and of valued townscapes.”

 

Paper 2, Policy 4:

GAIN is opposed by the introduction into this policy of the option of treating waste water and sewage that cannot practicably and reasonably be treated elsewhere.  The proximity principle should apply to such waste.  There should be no net imports into the county of such waste.

 

The policy of recovering biogas as an energy source should be further qualified by requiring acceptable landscape and amenity impact.  This is because many such facilities are located on exposed sites in open landscapes and extraction of biogas could be associated with infrastructure of greater landscape impact.

 

Thermal treatment of biodegradable sewage sludge should be resisted.

 

Paper 2, Policy 5:

We welcome the qualification of what type of waste facility might be appropriate in Green Belt.

In the case of development at preferred sites, be they Green Belt, countryside or based in an urban area, Surrey should make a commitment to only developing facilities that have acceptable landscape impacts and achieve a high level of protection for the environment and human health.  A move away from incineration and thermal processes would remove many obstacles to finding sites, be they in town or country.

 

Paper 2, Policy 6:

GAIN calls for fundamental redrafting of this policy.  Although it has a list of helpful considerations at the end of the policy, part (a) is essentially code for saying applications should be for incinerators and, if it is not too impractical, possibly for MBT plants to produce refuse derived fuel for burning in incinerators.

The current BPEO report is too flawed to be relied upon to deliver the mix of facilities required in Surrey.  Policy 6 should therefore include a sequential test.  This would favour facilities higher up the waste hierarchy.  A facility at any position in the hierarchy would only be permitted if the facilities were already in place to optimise the amount of waste being processed higher up the hierarchy.  For example, a process primarily concerned with energy recovery would only be approved if sufficient appropriate materials recovery facilities were in place.  Reuse facilities would take priority over recycling.  Applications taking an integrated approach would need to demonstrate an appropriate contribution to various stages of the hierarchy.

Section (b) should use the words of the Directive and require a high level of protection for human health and the environment as well as not significantly adversely affecting land, infrastructure and resources.

 

Section (i) needs to be drafted to take account of two types of potential pollution.  One is concerned with emission levels when a facility is running normally.  The second is the emission levels when perturbations occur and can be calculated from the experience of comparable plant.  The latter measure is very important in the case of waste processes because waste is a very variable material and many waste processes experience significant fluctuations in emissions.  It is essential to get a true picture of likely emissions if appropriate assessment is to be made and abatement or mitigation opportunities identified.

 

A risk assessment should be added to the list of requirements.  This should include the probability of a potentially damaging event occurring and an assessment of the likely consequences.  This is important in assessing the appropriateness of locating a facility near to residents.

 

PAPER 3

 

Paper 3, Question 1: COMMENTS ON BACKGROUND SECTION

 

Waste Arisings and Current Landfilling:

GAIN considers that it is vital to describe the nature of the material that is being landfilled by each sector, not just the total tonnage sent to landfill per sector.  The background information on Waste Arising is useful and would be a very helpful tool for directing policy if the waste composition analysis findings were added into it.

 

It would be useful to refer to the Landfill Allowance Trading Scheme again briefly in this paper. This would also be helpful to reinforce the point that it is biodegradable material that is to be removed from landfill, not an overall landfill allowance, contrary to the impression given in paragraph three.  Biodegradable landfill targets can be met either by landfilling ash from a thermal process or by landfilling material that has been subjected to mechanical and biological treatment (including anaerobic digestion) and that has significantly reduced biodegradability.  The third paragraph should describe how LATS allowances could be met by either route.

 

 

 

Landfill Void Assessment:

This section is hampered by the same limitations as the Babtie report.  It fails to use the invaluable waste composition analysis done by Surrey.  This greatly limits its usefulness in identifying how much waste can readily be diverted from landfill and which types of facility might best handle particular materials. It does not distinguish between biodegradable landfill, which needs to be cut, and other potentially less reactive materials.  It makes assumptions on how much capacity, and what mix of facilities, will be needed without any link to the nature of the materials concerned, to environmental impacts or to public acceptability.  It does not look at a scenario (Option H) that was widely supported by the SLGA consultation.  When an incinerator free option was given most support in a joint initiative by all the Districts and the County working together, it is frustrating that this option has not been worked up as an option in the Babtie report.  It appears that Babtie have simply used the same options as they have used for other counties.  The Babtie scenarios did not look at all types of waste capacity on an equal basis.  They assumed future consents for incinerators but that no more landfill would be consented once current capacity was used.   It is unrealistic to assume landfill provision will drop off so suddenly and to do so risks distorting decisions on the capacity required from other types of facilities.

We note that, as in the case of other reports commissioned by Surrey, there were undetected errors in the figures in one of the tables.  This undermines confidence in whether the figures being used by consultants to make recommendations shaping waste policy in Surrey are being adequately checked.

 

This section does not flag up the implications of husbanding landfill resources discussed in the background section.

 

Self Sufficiency:

The notion of sub regional self-sufficiency is totally distorted by any requirement to take waste from London.  We would support the concept of no net imports at a sub regional level.  However, we are deeply troubled over how London’s waste might be allocated and very aware that this will often have less to do with planning and more to do with the asset structure of companies competing for market share of this waste.  We are very concerned that an increasing proportion of this waste could be incinerator ash.

 

Groundwater Protection:

We very strongly support the Environment Agency’s concern that groundwater pollution should be avoided and managed as a long-term issue.  We note that the nature of the material being place in landfill is a significant consideration here and hope that the County and the Agency will work to identify circumstances where landfilling of separated materials that are non reactive might be appropriate to landscape voids.

 

Environmental Implications:

We support the intention to control other impacts such as leachate from landfill.  We again see this is a reason for only allowing landfill of sorted material that has been pre-treated with a view to making it as safe and non- reactive as possible for landfill.

 

While welcoming this section, we find it curious that there are no comparable sections on the emissions and wastes from incinerators, other thermal process and other technologies (apart from a reference to the siting of open windrow composting).  As incinerators are being advocated by Surrey as a technology, it is crucial to establish the impacts of potential concern.

 

Paper 3, Question 2: COMMENTS ON ISSUES

GAIN notes with concern that the first sentence of this section places energy recovery before “resource recovery”.

 

We welcome the reference to pre-treatment of material going to landfill at the end of the first paragraph.  However, we ask that a very clear distinction should be made between pre-treatment to reduce the impact of the material in a landfill and cases where pre-treatment just means “incinerated first”.  Policies should encourage instances in which the material is pre-treated to maximize recovery of materials and then to make it as safe as possible for landfill.  In cases where pre-treatment refers to a thermal process to generate energy, the resultant ash will not have been made as non-reactive as possible for landfill.

 

The second paragraph should make it clear that is it is untreated, unsorted landfill that is the option of last resort.  Landfilling of treated, sorted residual material has an important place in the waste hierarchy and is much to be preferred to traditional landfill and the landfilling of incinerator ash.  We welcome the decision to identify appropriate sites working in partnership with the Environment Agency and the commitment to give preferred landfill sites in this Framework.  To do otherwise would be to distort future estimates of capacity by ignoring void spaces that will be created by extraction and that will need filling.

 

We understand the concerns in the third paragraph that ready availability of landfill could discourage companies from using other types of facilities higher up the waste hierarchy.  However, we support the suggestion that the way to avoid this is through very strong conditions governing how void space is used.  This will also achieve the objective of husbanding landfill capacity, which we would support.

 

We note the requirement for a risk assessment for landfill and cite this in support of our case that a risk assessment should be required for other types of waste facility too (policy 6 of paper 2).

 

Paper 3, Policy 1:

GAIN welcomes the general approach in this policy.

 

We ask for the wording of test one to be looked at further.  It should ensure that opportunities for reuse and materials recycling have been maximised and that, where part of the best option, energy has also been recovered (which could involve burning gas).  It should also ensure that the material has been treated in a way that makes it safe to landfill and acceptably non reactive.

 

We look for assurances that this section could not be used as a justification for incineration and other thermal processes.  This section should allow for the possibility that it could in some circumstances, especially during a transitional phase in the waste strategy, be the best option to landfill some sorted material that has been treated with a view to making it more acceptable for landfill.

 

We appreciate that it is a difficult balancing act to get this policy right because we agree with the desire to avoid the future use of landfill for unsorted material that should be being treated in more environmentally acceptable ways.

 

This policy should also allow for the possibility that landfill could be used as a store for a material for which the facilities are not yet in place to recycle.  Such an option may be particularly useful during a period of transition as waste policy faces significant change.  For example, separate collection facilities may be in place, but not the processing plant, for reuse, recycling or materials recovery of the product.  Rather than lose the material resource by mixing it with general landfill waste, it could be a good environmental option to set up a landfill store from which the material could be retrieved at a later date.  Later retrieval could involve far fewer resources than deriving the product from virgin raw materials.

 

Paper 3, Policy 2:

GAIN welcomes the first part of this policy but is concerned that the second part of the policy does not place any pressure on London to diminish its landfill demands on Surrey or to enter into reciprocal arrangements of “no net waste imports”.   We are also concerned that the availability of landfill should not be viewed in isolation but alongside the availability of other types of waste facility, in particular materials recovery.  A link should be made in this policy to a sequential test encouraging waste capacity up the waste hierarchy.

 

Paper 3, Policy 3:

GAIN welcomes the wording in this policy and encourages this most helpful breakdown of materials recovery to be adopted throughout the framework documents.  Energy recovery should of course be separated out as an activity lower in the waste hierarchy and not just tagged on the end of materials recovery.  Hence the plan could adopt the following approach:

 

Reduction

Materials Recovery: Reuse

Recycling

Processing to produce compost

soil conditioner

inert residues

Energy Recovery

Landfill (unsorted and untreated)

 

We strongly support the suggestion of introducing conditions to control the type of waste going to landfill.  However, our comments on Policy 2 above are relevant to this policy as well.

 

Paper 3, Policy 4:

GAIN submits that this policy should allow for the possibility of future retrieval for processing of separated, landfilled materials.

 

PAPER 4

 

Paper 4, Question 1: COMMENTS ON BACKGROUND

 

GAIN believes the second paragraph misses the point.  There is a crucial link between the land-use implications of waste management activities and technologies.  The Regional Waste Strategy recognised this by looking at different type of land use requirements for different types of technologies.  Residents recognise this in that certain types of facility risk greater impacts and therefore cause more anxiety.  We are concerned that paper 4 describes a need to secure sites for “recovery” without being more specific.  The outline section is written with no reference to the BPEO or to Surrey’s approach of promoting incineration and other burning options.

 

Background Introduction:

GAIN is concerned that we are not being given a real opportunity to discuss how the objectives in paragraph one will best be met in Surrey.

 

In the second sentence of paragraph one, it would be better to use the breakdown of materials recovery in Policy 3 of paper 3.

 

How can we accept the principle of a site being developed when we do not know what is proposed for it?  By the time we know what is proposed we will have little scope to influence whether that facility is the best option for Surrey or whether the site is appropriate.

 

The third paragraph refers to identifying sites to give certainty over where development should be located. Our concern is that the plan is not specific enough about what types of facilities might be appropriate.  The approach is far too general.  There are enormous differences in the impacts of different types of waste facilities.  The public is being asked to agree to the principle of preferred sites without having had an effective opportunity to discuss the type and mix of technologies that would be best.  The public is entitled to be invited to make informed decisions on which technology would meet targets and also deliver high environmental standards that enjoy community support.  The community voted overwhelmingly for an incinerator-free “option h” in the Surrey Local Government Association consultation.  However, this option has never been taken forward by Surrey and worked up as a plan option.

 

The Framework consultation makes no reference to the contract with Surrey Waste management, which is to deliver two incinerators and recycling rates of only 25% (below the target required of Surrey).  The contract is like a hidden hand driving waste policy towards incineration and yet the public was not consulted on this.  When the BPEO report found MBT to be the best option for Municipal waste and then curiously doubled the rating for practicality to make incineration the best option after all, was this the unspoken influence of the contract?  Was it more practical to incinerate because Surrey has a 25 year contract for two incinerators?  Babtie, who peer reviewed the BPEO report, were concerned at the lack of transparency in the way practicality was boosted as a factor in the selection of options.  Indeed, GAIN would argue that in the light of flaws in the BPEO, confirmed by Babtie, the current draft cannot be relied on to inform policy decisions.

 

GAIN shares a very real concern of many residents that we are being asked to select sites when we have not yet had a genuine dialogue with Surrey over what processes should be allocated to such sites.  There are real options over the mix of technologies but we have not been offered them.  When we have made suggestions we feel our views have been ignored.  Over 81,000 letters of objection to incineration represents a very significant body of opinion.  The vast majority of those objections have also included constructive alternative approaches.

 

In this consultation, where is the invitation to make informed choices between waste facility options?  The first issues paper claims to be promoting minimisation, reuse and recycling and sometimes strays onto promotion of “recovery” and energy recovery as well.  There is no explicit discussion of the relative merits of various recovery technologies or of an appropriate mix.  Paper four moves rapidly to finding sites and what will normally be allowed where.  It does not offer options for the mix of technologies.  The BPEO report should be of prime importance in enabling a public debate but it has been treated very much as a background document and fait accompli.  The BPEO report options do not tie in with option H, which the public supported in the SLGA consultation.  The public has not had an effective opportunity to say what weighting it would give to various impacts of waste processes in the BPEO assessment.  The Districts also feel alienated from this process.  The BPEO report and the way it is being presented do not offer residents any sense of choice in the approach to meeting waste targets in Surrey.

 

We would welcome the pragmatism of a combination of preferred sites and criteria based approach, once we have had a genuine dialogue over the mix of technologies we would like to work towards in Surrey.

 

Identifying sites will trigger blight rather than give certainty if Surrey persists in favouring thermal waste treatments and continues to ignore residents’ concerns.  Also, because of the policy that sites that have a waste use will be favoured for other waste uses, there is a fear that allowing a relatively modest community waste facility could pave the way for a waste use of greater impact in the future.  This could lead to avoidable resistance to modest community waste uses.

 

Reference is made to the comments of the Inspector who only approved the 1997 Waste Plan as an interim measure because of its failure to identify sites.  It is important to note that at this stage of this consultation we are still little further forward because specific sites have yet to be identified.  We have a long list of sites but no list of the facilities proposed for those sites that we can comment on.  Surrey has a very specific list of facilities it has already contracted out on our behalf in 1999 but even these have not been set out for comment.  Why these have been kept secret so long is bewildering.

 

Self Sufficiency:

As in Paper 3, our objective would be to achieve no net imports.  We also note the important qualifications placed on proximity by the European Directive including appropriateness, integration, and achievement of a high standard of protection for human health and the environment.

 

Need to Identify Sites Suitable for Waste Management Facilities:

We again note the qualifications placed on proximity by the Framework Directive.

 

We ask for the last paragraph of this section to use a more specific version of the waste hierarchy making it clear that materials recovery comes above energy recovery.  We also suggest that this is an important place to clarify that unsorted, untreated landfill is more of an issue than sorted, treated landfill.

 

Paper 4, Question 2: COMMENTS ON THE PROCESS FOR IDENTIFYING SITES

 

Identification of Urban Sites/Industrial Sites:

The first sentence fails to include the qualifications in the proximity principle concerning human health.  It also suffers from being too general.  GAIN would readily agree that certain types of waste facility are best located in an urban or industrial area.  However, there are some types of waste facility where this logic does not apply such as open composting.

 

If the Council persisted with incineration against the wishes of so many in so many submissions, the preference for an urban location would not apply.  Such a facility would be an exception in both urban and rural locations in Surrey.  Given the primacy of protecting human health, a key consideration in finding a location would be to find a site where the consequences of any pollution incidents and perturbations were minimized.

 

GAIN would see this as a reason for not pursuing incineration but instead adopting technologies that can more readily be accommodated in urban and industrial sites.  However, while thermal treatment remains a possibility in Surrey, GAIN cannot support a preference for urban sites for such technology.

 

Selection of Criteria:

The selection process is far too general and needs to be specific for the type and scale of facility.  A Community Recycling Centre or district closed vessel compost plant would be very different from an MBT plant.

 

We are concerned that the criteria used should include “potential risks, and consequences for human health, of pollution incidents”.  Waste is not a homogenous material and some processes for dealing with it experience significant fluctuations in their emissions and other impacts.  It is vital to take account of the range of impacts possible from various facilities when looking for suitable sites.  This is also a reason for being process and waste stream specific when looking for potential sites.

 

We call on Surrey to work with each District to identify a site for a Closed Vessel Compost Plant and for a Community Recycling Centre.  If Districts knew that these, and only these, were the proposed uses, there should be fewer barriers to finding sites.  If every District had to find such sites there would be no fear that if a District found a site, it could get other District’s waste too.  Community Recycling Centres should be in the heart of communities and a real focal point for the revolution needed in waste separation, collection and reuse.

 

For other types of waste facility, GAIN believes it would be far preferable to identify (through a consultative process offering real choices) how many of a particular type and size of facility will be needed.  Then, for each facility where more than one is required, the county could be subdivided into areas of search for sites that meet the requirements for that type and scale of facility.  There should be a presumption in favour of several smaller facilities spread throughout the county, wherever this is a good environmental option, to reduce the impact on any one site.  This approach would have the advantage of a sense of fair play, make communities and sub regions feel more responsible for their waste, follow the proximity principle and avoid dumping on any one community a major thermal facility.  The unacceptable spanner in the works in this process would be the very real concern about London’s waste and incinerator ash.  This is why a policy of no net imports from London is so important.

 

We note that the Inspector of the 1997 Waste Local Plan advised that, “the selection process should arise from an audit of the environmental capacity of the County to accommodate waste-related development.”  It is not at all clear that an audit process has been undertaken, more a trawl of possible available sites.  The observations made on the sites suggested are not linked to any environmental capacity assessment.

 

Paper 4, Question 3: COMMENTS ON PREFERRED SITES IDENTIFIED

 

GAIN would not support the construction of a thermal processing plant on any of the proposed sites.  GAIN sustains its objection to the use of Slyfield Industrial Estate for an incinerator and it would not wish a facility of this nature on any part of Guildford or any other community in Surrey.

 

When it comes to assessing the potential for other types of waste activity on any of the sites, the scale and the nature of the activity would be such key factors that GAIN would not wish to comment without specific proposals.  We would also expect proposals to be rigorously linked to environmental capacity.

 

Paper 4, Question 4: COMMENTS ON ISSUES SECTION

 

GAIN is concerned that the comparison between waste plant and other industrial activity in Surrey is being taken too far.  There is very little industry in Surrey that compares with thermal treatment of waste in which a varying cocktail of materials is brought together and burnt in a process that is very difficult to control and produces many of the worst known pollutants as a result of combustion of the mix.  The solid inputs are unpleasant and the solid outputs are a mixture of reactive and hazardous.  The track record of such plant on emissions to air is cause for real concern.  Such are the impacts of thermal waste treatment that GAIN and very many residents argue it should not be undertaken at all in Surrey.  We would, therefore, not see it as an appropriate activity for industrial sites in Surrey.

 

We find it curious that concern about bio-aerosols from windrow composting leads to the advice that they should be at least 250 metres from housing yet there are no similar concerns about housing next to an incinerator that can be expected to breach emission standards relatively frequently.  In the case of composting, GAIN would in fact support closed vessel composting or anaerobic digestion above open windrow.

 

GAIN is very deeply opposed to and troubled by the paragraph on thermal treatment.  There is no analysis of options for meeting targets or justification for rejecting other approaches.  We are just told it is a “viable option” and “required”.  We are not told how sites would be selected or how many.  There is no acknowledgement of the depth and extent of public concern about this technology.  Many residents relate to the following comment by Dr Connett (1998):  “When you build an incinerator in your community, you are advertising to the world that you are not clever enough, either politically or technically, to recover your discarded resources in a manner which is responsible to your community or future generations.”

 

We read the sentence on the advantages of large facilities with dismay and alarm.  We find it hard to imagine that a community in Surrey would see road improvement and extra landscaping as a benefit from having a very large waste facility!  Indeed the Surrey Local Government Association consultation found overwhelming support for a larger number of smaller waste facilities.  Yet again the findings of this work seem to be being ignored.

 

Whether an urban or rural location is best will depend on the nature of the activity.

 

Draft Policies:

GAIN argues that the case for thermal treatment is not made.

GAIN calls for the following breakdown of the waste hierarchy to be deployed as used in paper 3:

 

 

 

Reduction

Materials Recovery: Reuse

Recycling

Processing to produce compost

soil conditioner

inert residues

Energy Recovery

Landfill (unsorted and untreated)

 

It is recommended that a sequential test should be used for assessing proposals linked to the waste hierarchy above.

GAIN is strongly opposed to the proposal that all types of waste facility (except thermal treatment) could potentially be developed at any appropriate site.

 

Paper 4, Policy 1:

GAIN calls for this policy to identify the intention to develop a “Recycling Centre” (or Resource Recovery Park) in every District.

The possibility of using Action Plans to develop sites is resisted.

 

Paper 4, Policy 2:

GAIN considers that this policy should also be signalling the intention to develop a “Recycling Centre” (or Resource Recovery Park) in every district.

The possibility of using Action Plans to develop sites is resisted.

 

Paper 4, Policy 3:

GAIN considers it is very difficult to comment when the sites and criteria are missing.

GAIN proposes that this policy should also identify the intention to develop a Closed Vessel Compost Plant in every District.  Composting should be specifically mentioned, as should processing to produce soil conditioner and inert residues.

 

This policy needs to be very tightly drafted to deliver activity high up the waste hierarchy.  At present it is far too vague to guide policy and will just allow speculative proposals for any non-thermal recovery.  The policy needs to be drafted to distinguish between materials recovery and, lower priority, energy recovery (non thermal).

 

The preferred scale and number of various types of activity should be given.

 

The need to secure a good match between different technologies and different waste streams should also be set out.

 

The policy does not appear adequate to consider proposals for MBT using anaerobic digestion.  One can only imagine that this is because it is envisaged that incineration and thermal processes will be deployed.

 

The possibility of using Action Plans to develop sites is resisted.

 

Paper 4, Policy 4:

This should not be the only policy on composting.  Although open windrow composting is the only type of composting planned in the contract, to limit composting to such facilities would fail to deliver the high composting rates that are potentially achievable and highly desirable.

 

Paper 4, Policy 5:

GAIN is particularly troubled by this policy and strongly opposes it.  We call for the policy to be changed to “not be granted”.  The justification should be given as a combination of the impacts of incineration and its waste products, the lack of public support, the fact that it consumes material resources and the fact that to build incinerators in Surrey in the life of this Framework would detract from encouraging facilities for materials recovery that are higher up the waste hierarchy.

 

The absence of site criteria for this policy is regrettable and makes it very difficult to comment on aspects of this policy.