Memorandum submitted by Alpheco Composting
Ltd
BIOCOLL AND SATCOMP PROPOSAL
EXECUTIVE SUMMARY
1. A novel biowaste collection and innovative
network of in-vessel composting facilities is proposed that, when
integrated with recycling, is forecast to divert over 60% municipal
waste from landfill and for small or no increase in costs overall.
(a) BioColl would use 25-litre household
biowaste buckets for weekly kerbside collection by compact, efficient
vehicles carrying 120-litre bins in to which the households' catering
wastes, possibly in biodegradable bags, are placed. Through-running
those 120-l bins to the proximate composting facility offers two
to threefold reduction in biowaste haulage so offsetting the cost
of BioColl. Commercial and institutional catering wastes go directly
into 120-l bins for co-collection. Soft (non-wood) "green"
wastes would be co-collected, while wood wastes should be chipped
at the kerbside periodically. Computerised weighing and billing
can be included for easy allocation of differential charges or
rebates.
(b) SatComp. The composting systems proposed
would:
(i) comply fully with the new EU Animal
By-Products (ABP) regulations, the proposed UK ABP Order requirements
and the rules anticipated for the 2004 EU Biowaste Directive.
Since all types of raw and cooked food including meat can and
may be processed, the simple rule "Compostables = anything
that lived" applies. This will minimise hassle in the home
and so win high capture rates for putrescibles with a knock-on
increase in the recovery of recyclables;
(ii) be modular with vessels out-doors
so the mandatory building is minimal making sites of only 10,000
tonnes/year competitive and amenable;
(iii) be electronically linked to a site
management PC that would in turn network to head office and integrate
with the BioColl software.
These characteristics permit a network of proximate,
satellite sites with economies of scale normally associated with
large, centralised plants.
2. Recycling and Residuals. By removing
the putrescibles conveniently and weekly, the dry-recyclables
and residuals can be virtually free of obnoxious matter and so
may be collected fortnightly. Dry-recyclables may be set out for
sorting at the kerbside in to a compartmented vehicle or mingled
in a bin (120 to 240 litres) for collection by a conventional
refuse vehicle (RCV) and sorting in a clean MRF. Residuals may
be collected in the alternate week to the dry-recyclables to make
efficient use of crews and RCVs, and by scheduling on the same
day as BioColl, householders should remember to put out the appropriate
receptacles. Thus there would be about 104 waste collection vehicle
passes per property per year which, although more expensive than
the 52 passes required for mixed waste collections, will be offset
by using the more efficient BioColl vehicles, the reduced distances
and the major savings on landfilling.
3. Biowaste types, permissible sanitization
regimes and alternative collection methods lead to about 14 options.
This particular proposal as, illustrated by the flow chart below,
is for catering wastes that include household meat and fish wastes
but not the other EU Category three animal by-products. Therefore
the plant must reduce particles to 60 mm, provide the two barriers
proposed for the UK ABP Order and have unclean/clean separation.
The flowchart also illustrates the BioColl through-running method.
4. Operating costs including equipment leasing,
infrastructure amortization, labour and maintenance are forecast
in the range £27-£34 per tonne of biowaste intake at
SatComp facilities of 10,000 to 25,000 tones per year. The costs
of the separate collections of compostables, recyclables and residuals
will depend on location and circumstances, but are not expected
to total much more than current practices due to SatComp efficiency
and BioColl distance savings that will offset provision of the
extra rounds.
5. The scheme also offers benefits by way
of scope for co-composting sewage sludge, for automated differential
charging of households, for remediating contaminated land and
for heat recovery from the biowastes. The impediments that have
so far prevented such a scheme being piloted in the UK are identified
as the moratorium on composting due to the ABPO, risk aversion,
lack of funding such as exclusion from the DEFRA £140 million
"Challenge fund" and the low priority to date given
to biowastes and composting by WRAP.

Integrated collection, composting and
recycling scheme
6. Outline. An innovative scheme is proposed
that would integrate the kerbside collections of biowastes, dry-recyclables
and residuals with their composting, recovery for recycling and
disposal respectively. Holistic integration of these activities
is forecast to offer diversion rates of over 60% at very little
or no extra cost per council taxpayer compared to current arrangements.
The addition of bio-stabilization or bio-drying of the residuals
could increase that diversion to about 80%.
7. End markets for compost. Although sustainable
waste management is the subject, the paramount objective is to
recycle resources, which demands product quality-cum-value. WRAP
is developing markets for dry-recyclables and the new PAS 100
standard should stimulate demand for proper quality compost. Some
people fear that compost derived from municipal biowastes could
swamp potential markets but that is wrong[8].
Bulk compost to improve agricultural or horticultural land will
probably earn a market value of £2-£6 per tonne delivered
on or close to the designated field.
8. The obtainable price of compost will
depend on nutrient and organic matter levels as well the freedom
from contamination required by the PAS100 standard. That will
almost definitely require catering, "green" and other
biowastes to be kept separate from source. Enterprises must focus
as much on compost production as on waste disposal. A sustainable
composting scheme therefore needs to balance the demands of farmers,
growers, and gardeners with, on the other hand, householders and
waste collection authorities.
Biowaste collection methods
9. High diversion rates coupled with good
quality recyclates (including compost) clearly need high levels
of participation and of compliance with the separation rules.
Those are essentially voluntary activities so minimal "hassle"
in the home is essential. The simple rule that "compostables
= anything that lived," with weekly kerbside collection from
a small bin that is easily accommodated and washed by the householder
(a biodegradable liner may be used) should be almost as easy as
current habits. Woody wastes should however, be set out for periodic
kerbside chipping because they are bulky and very slow to decompose,
[9]but
as they only arise in gardens there is obviously holding space.
A self-funded kerbside chipping service would not discourage home
composting in the way that big (120-litres) bio-bins do and many
gardeners will keep the wood-chips as mulch thus reducing "waste"
haulage.
10. The convenient and regular weekly removal
of all putrescibles should leave the recyclables and residuals
virtually free of obnoxious matter[10]
and hence lead to higher recovery rates than if some (EG cooked
food wastes) were still to go in the "black" bag or
bin. Consequently the recyclables and residuals may be collected
fortnightly; uncooperative householders will find their carefully
sized recycling and residuals receptacles beginning to smell and
perhaps overfilling. Since the average household only generates
about 10 litres of catering wastes per week it is uneconomic to
provide a big bio-bin that attracts more "green" waste
and also necessitates an inefficient refuse collection/compactor
vehicle[11].
BioColl proposes that households have 25-litre bins with anti-pet/vermin
lids and handles for easy emptying in to 120-litre bins; both
bins are specifically chosen to comply with lifting and handling
regulations. Dense housing areas can be served by bio-collectors
with six to eight 120-litre bins on a pedestrian controlled vehicle
(PCV)[12];
full bins are transferred on to an inexpensive, flatbed truck
for through-running to the composting facility. That truck[13]
can also collect directly from more dispersed housing and swap
full for empty 120-litre bins at commercial and institutional
premises. It can also deploy and recover the PCV(s) from base.
Composting facilities
11. Composting of catering wastes that include
meat and fish residues and cooked food is permitted by the extant
European and proposed UK regulations[14]
provided they:
(a) have a reception, preparation and loading
building. BioColl's through running allows a smaller building
than would conventional big bio-bin schemes where the RCV must
discharge on to the ground inside the building.
(b) separate the "unclean" and
"clean" areas to prevent cross-contamination. Clothing
and equipment changes or disinfection are required and the collection
containers or vehicles must be cleaned while inside the unclean
area. BioColl would simplify this by the automatic washing of
the 120-litre bins that are "through-run."
(c) use a closed reactor inside which to
compost for a minimum of seven days[15]
during which one of the three mandatory sanitization regimes must
be fulfilled.
(d) take additional measures[16]
in UK; they may become mandatory throughout Europe or the they
might be relaxed in due course.
(e) monitor and record temperatures to prove
compliance and keeping with other records to provide an audit
trail of the biowastes, their treatment and distribution of the
compost.
Based on R&D testing over the past six years,
Alpheco Ltd is entirely confident that its systems will comply
with all those requirements. Some but not all other in-vessel
systems can probably do likewise. Therefore we refute a footnote
in the recent SU report[17]
that anyway seemed a variance to the preferment expressed therein
for composting. That preferment is also clear in certain EC documents[18].
Furthermore the risk assessment that informed the DEFRA proposals
noted that composting is potentially less risky than continuing
to landfill untreated animal by-products. [19]
12. SatComp is proposed as a concept for
a network of in-vessel composting facilities linked electronically
to give economies of scale while complying well with the proximity
principle.
(a) They would complement BioColl in minimising
the road haulage of biowastes and of the compost produced[20].
Also being in the order of 7,500-25,000 tonnes per annum throughput
each and of modular constriction, planning considerations of road
traffic and access, noise and visual impact are relatively amenable.
(b) Management, marketing, compost sales
financial control, invoicing, technical advice and maintenance
support can all be centralised and make full use of the computerised
records required for every batch. IntMan software will link the
system control computers and site management PCs with head office.
Furthermore automatic weighing on the BioColl vehicles can also
feed in data to simplify the invoicing of commercial customers
and to permit waste authorities to reward householders, whether
by differential charging or rebates.
13. Recycling
(a) Some waste authorities and their contractors
have already built an MRF[21]
while others have opted for a truck with several compartments
that is, in effect, a mobile MRF. The latter must deliver to a
transfer station for bulking up the different recyclates. This
proposal can integrate with either method since the compostables
and recyclables must go to different delivery points, assuming
quality compost is required rather than the stabilized biowastes
from a mechanical and biological treatment plant (MBT). As there
is no need to co-locate composting, MRF/transfer station and landfill
with MBT, the location of each facility can take more account
of local circumstances than with "strategic" sites.
(b) Since all household putrescibles will
be collected weekly, the dry-recyclables may be collected fortnightly
provided the households have reasonable storage space both inside
the receptaclecardboard boxes can be collapsedand
for the receptacle itself. Many terraced houses are short on space
for one 240-litre bin, but the 25-litre bio-bin can easily be
hung inside or outside of the bigger bin.
14. Residuals
(a) An energy from waste (EFW) plant may
already be available within economic distance given the reduced
tonnage to be hauled and the higher calorific value by excluding
the moist putrescibles and soft "green" matter. Alternatively
the residuals might be "biostablized"[22]
in an MBT plant or merely landfilled until 2020 with its requirement
to reduce to less than 35% on the 1995 level.
(b) Similarly to the recyclables, the residuals
may be collected fortnightly. Householders might be required to
continue with black bags or use a 35 to 50-litre residuals' bin,
which could also hang from the recyclables bin.
15. Costs:
(a) Collection As mentioned at footnote 12,
the populations of each parish or ward in the whole of Cambridgeshire
with Peterborough unitary authority and, separately, in Colchester
Borough and Tendring District were tabulated so that probable
tonnages of their catering and "green" wastes could
be calculated from national average figures. Distances from those
parishes or wards to potential SatComp and to existing landfill
sites were measured. By assuming five tonnes of biowastes per
BioColl type truck, the total annual biowaste-kilometres were
calculated. For Cambridgeshire the reduction was two-fold while
for Colchester and Tendring taken together the reduction was three-fold.
Further study would be needed to fully estimate the cost differences
but given that:
(i) the BioColl trucks cost only about
£40K compared to a typical RCV at £125K,
(ii) the former does not need an HGV1
qualified driver and the singular efficiency of using PCVs in
dense housing areas, significant savings per household are expected
compared to merely doubling or tripling RCV rounds to cope with
the different streams.
(b) Composting. As mentioned in paragraph
three and the lower side-bar to the flowchart, there are 14 feasible
combinations of biowaste type, treatment regime and collection
method. For convenient comparison of costs, just five have been
selected and designated according to the following legend key:
MECW for meat excluded catering wastes,
ACW for catering wastes that may include
meat and fish residues
Cat-3 for ACW plus the other category three
animal by-products.
UK1 for the particles 400 mm, 600C for two
days regime proposed by DEFRA
UK2 for the particles 60 mm, 700C for one
hour regime proposed by DEFRA
EC for the particles 12 mm, 700C for one
hour regime established by the EU.
RCV for conventional collection by RCVs from
big bio-bins,
TRB for the through running of BioColl bins.
The charts below show forecast CAPEX and OPEX
in £ per tonne vs. facility throughput in tonnes per annum.
The OPEX figures included capital costs by inclusion of a typical
rate for leasing the demountable composting and the mobile ancillary
equipment over a five-year term. The buildings and site infrastructure
were amortized over a 15-year term and the site rent was included
at a rate of £3.6 per square metre per year, which is considered
typical for bare, industrial land.

MECW/UK1/RCV is cheapest as it does not require
the "barrier two" additional treatment whereas seven
days in each of the Barrier one and two closed reactors is allowed
for in the other forecasts. EC treatment is more expensive than
UK1 regimes because of the equipment needed for size reduction;
sadly DEFRA's two year moratorium on composting has precluded
testing which of the treatment regimes is most cost-effective.
The conventional RCV collection makes the composting plant more
expensive than with TRB (BioColl) because of the stronger shredder/macerator
needed and the screening machine that it also necessitates.

The operating costs includedbesides leasing,
amortization and rent-labour, fuel, electricity and equipment
maintenance. Figures were based on Alpheco's six years' practical
experience of in-vessel composting food wastes we collected from
Sainsbury's, McDonalds, Plantsman, the Ipswich Hospital and Suffolk
Coastal District Council[23].
The steep reduction from 5,000 to 10,000 tonnes
per year is mainly due to defraying the cost of the reception
building proposed by DEFRA. The slight increase for some regimes
going from 15,000 to 20,000 tonnes per year is due to adding a
second macerator/loader and might well be smoothed out in practice.
Besides noting that the modularity of the Alpheco
composting system allows relatively cost-efficient and thereby
proximate facilities, probable diversion rates may also be borne
in mind.
In a separate study (available on request),
we estimated the maximum probable diversion rates of an integrated
recycling and composting scheme using four scenarios shown in
the columns below. Cells in the table below show participation
per cent multiplied by compliance per cent to calculate the recovery
rates. We assumed that an effective publicity and education campaign
would build on the promising public interest reported by some
recent studies. Convenience (ie hassle of separating meat and
cooked foods from other bio-wastes) and "smells-cum-flies
& maggots" if putrescibles are only collected fortnightly
were also estimated effects.
Collections
Streams & composition
| Meat excluded Catering Wastes Conventional RCV; Weekly
| All types of Catering Wastes Conventional RCV; Fortnightly
| All types of Catering Wastes Conventional RCV; Weekly
| All types of Catering Wastes BioColl-Weekly
|
Recyclables 43% | 95% x 90% = 86%
| 95% x 90% = 86% | 95% x 90% = 86%
| 95% x 90% = 86% |
Compostables 48% | 75% x 67% = 50% due to hassle
| 75% x 67% = 50% due to smells | 95% x 85% = 81%
| 95% x 85% = 81% |
Residuals 9% + unrecovered recyclables and compostables
| 0% + Meat + 14% of 43% + 50% of 48% =53% |
0% + 14% of 43% + 50% of 48% = 49% | 0% + 14% of 43% + 19% of 48%screenings = 35%
| 0% + 14% of 43% + 19% of 48% = 33% |
Overall diversion without MBT | 47%
| 51% No "meat" to landfill | 65% Weekly bio- collect encourage
| 67% as no wood screenings |
Overall diversion with MBT | 65% *
| 69% | 77% | 79%
|
| | |
| |
If the residuals with the un-recovered recyclables and compostables
(Row four) were put through an MBT plant with energy recovery
or bio-stabilization so that only the residues from that MBT plant
had to be landfilled, the overall diversion rates would be increased
from Row five to Row six levels. Please note * however, that bio-stabilized
residuals, while possibly contributing to diversion rates, may
not be counted in recycling and composting rates as they are of
little or no value.
16. Potential extra benefits of the proposed scheme are
several as follows:
(a) Biosolids (sewage sludge cake) could be co-composted
near the communities that produce them. The EU Urban Waste Water
Directive has led to more biosolids, all of which must be disposed
of on shore. DEFRA's has recently proposed new regulations[24]
that inter alia require enhanced treated biosolids to be sanitized
to similar levels as for catering wastes. Mixing the biosolids
in with the catering wastes and "green" botanical wastes
also produced by any particular community would usually make a
fine mixture for properly controlled composting. The resulting
soil improver should be safe for use on agricultural land and
more nutritious for plants than composts made without the biosolids.
The potential synergy of co-composting may remain unexplored while
the water and sewage companies eschew municipal waste with its
management and licensing laws and the waste management authorities
and contractors avoid sewage legislation.
(b) "Pay as you throw" integration. The BioColl
and recyclables/residuals vehicles could have auto-weighing and
bin-ID reading devices with on-board computers to record data.
That data would be downloaded in to Intman or separate software
where it could collate the running totals of weights in each of
the three waste streams with household-IDs and then be used by
the waste authorities to calculate charges or rebates[25].
(c) Land remediation. Modular composting facilities that
are largely demountable can be set up on brown-field sites for
a limited period during which the compost they produce may be
used to bio-remediate the contaminated soil on that site. Reports,
primarily from North America, show how successfully and cost-effectively
old hydrocarbon and explosives contaminated sites have been cleaned
up this way.
(d) Heat recovery. The Alpheco and perhaps a few other
in-vessel composting systems enable the excess heat from composting
to be used for greenhouse or similar heating. This heat is too
low-grade for electricity production but even in biogas production
(ie anaerobic digestion) plants only about 1/3 of the energy recovered
can be electrical; 2/3 are inevitably in the form of heat. In
composting plants the heat is a by-product while in biogas plants
the digestate is a by-product that most probably needs composting
before it can be sold.
(e) Research. As mentioned in footnote 16, DEFRA's proposals
for the ABPO amendments are based on a risk assessment that was
almost entirely theoretical. They are probably justified under
the precautionary principle but may be more stringent than necessary
and also than the laws of other EU member states. That could be
to the UK's economic disadvantage, so validation of the risk assessment
in commercially sized plants seems sensible. The stability at
which composted biowastes stop being a significant pollution risk
should also be investigated in time to inform the EU Biowaste
Directive that is scheduled for 2004. Unnecessary prolongation
of controlled waste status would inevitably add to the cost of
composting biowastes.
17. Impediments. It may be asked why such a scheme has
not yet been tried.
(a) Several municipalities in Northern Italy[26]
have introduced similar schemes in which the "comfortable",
convenient and frequent collection of catering wastes is key.
They report diversion rates of over 60%. Although the SU's "Waste
not, want not" asserts that England can learn from the best
performers, it only states that some other EU countries recycle
over 40% of household waste. One wonders why the reports Lombardy
and Ghent of municipalities diverting over 60% are not acknowledged.
(b) Within the UK several factors seem have prevented
such schemes:
(i) Legislation. The moratorium on spreading compost
derived from catering wastes that was imposed in early 2001 and
may only be lifted when the ABPO is amended in April 2003. While
research projects are said to be permissible, funding for them
has proved utterly elusive.
(ii) Risk aversion and lack of funding. The split
between waste collection and disposal authorities and their aversion
to the risk of trying innovative schemes. "Too good to be
true' therefore it cannot be" was one response that should
be overcome by one or more reference-cum-pilot schemes, for which
funding has not been forthcoming so far:
1. Our four, landfill tax-credits applications
were rejected apparently for financing policy rather than technical
reasons.
2. DEFRA advised[27]
that applications for its £140 million Waste Minimisation
and Recycling fund that involved the composting of catering wastes
would be ruled out by the current ABPO. If that fund is renewed
as recommended by SU, the lead-time[28]
will prevent pilot schemes coming on stream until well in to 2004.
Alpheco has had a closed reactor prototype sitting idle since
July 2001 and meanwhile funding has been allocated to many collection
and composting schemes that may never be able to comply with the
EU and forthcoming UK regulations for catering wastes.
3. DTI SMART, BioWise and the Training Company
schemes all require matched funding so private money is essential.
We have been unable to raise any significant investor interest
since 1998-99 however because of the uncertainty over ABPO and
WRAP's decision not to focus on biowaste[29].
(iii) Prospects. The SU "Waste not, want not"
recommended:
1. setting up an operational task force
to help bridge the gap between central policy-making and action
at a local level.
2. a WRAP-led programme of advice to local
authorities on the expansion of kerbside collection
3. that there should be particular emphasis
on supporting the roll-out of organic waste collections where
current provision is low.
4. the waste industry should provide an
appropriate range of waste-handling facilities and pursue opportunities
for developing new technologies.
It remains to be seen if WRAP any more than the Environmental
Audit Committee or the Audit Commission when promoting Best Value,
be willing and able to accommodate such innovative schemes as
that proposed here. Meanwhile my contacts in the waste management
companies opine that they will not fund R&D ahead of profitable
contracts.
(c) Hopes that home composting may suffice. While laudable
for minimising biowaste collection and making the public more
aware of composting, there will be those without space, physical
ability or motivation to compost at home. In any case all are
advised not to home compost animal by-products (including faces
and litter) and indeed small holders and others with pet ruminants
and pigs may be prohibited from home composting their catering
wastes under the ABPO proposals. It seems that over-emphasis on
"green" waste firstly from CA sites and latterly by
kerbside collection has diverted attention from the key role of
animal by-products and led to misleading hopes for home composting.
Alpheco Composting Ltd.
3 January 2003
8
If 15.5 million tonnes per annum (mpta) of biowaste, being 55%
the annual total for England of 28.2 mtpa municipal waste, were
co-composted with the 4.8 mtpa of sewage sludge cake, the resulting
15 mpta approx. of compost spread at the permitted rate in Nitrate
Vulnerable Zones (NVZ) would take up only 9% of England's agricultural
land or 30% of the land on which cereals are grown. Considering
that compost would probably applied at 2 to 3 times that rate
in the half of the country not designated NVZ and that horticulture
and gardening have taken most of the compost available in the
more advanced European countries, the chances of saturation are
insignificant. Back
9
The lignin of the wood cell walls takes many months of fungal
activity compared to the few weeks needed to decompose the putrescibles
and soft matter. If woody and soft matters are mixed ab initio,
the collection truck must be much bigger, the whole mixture must
be shredded, the compost must be screened and the screenings recycled
all of which are wasteful and cost extra compared to kerbside
chipping. Back
10
Lombardy schemes using this approach report just 10% biodegradables
in the residual stream compared to 40% in many Dutch and German
schemes where big bio-bins attract more garden wastes and are
often collected in alternate weeks. Many householders will put
putrescibles in whichever bin is next to go. Back
11
Such RCVs typically of 26 tonne gross vehicle weight cost about
£125K CAPEX and £125K per annum OPEX. Their fuel consumption
for halt-to-halt is bound to be high and leaves the driver only
part employed. The rest of the crew is unproductive during "commuter"
journeys from "round" to landfill, incinerator or composting
facility. Back
12
Belfast, Haringey and Islington all use pedestrian controlled
vehicles (c £10K) for recycling collections. One operator
can typically collect from 1,000 properties in one day compared
to 850 by an RCV, which also holds up more traffic and requires
a part-redundant driver/crew. Back
13
Typically a 7.5 tonner costing £40K when complete with tail
lift and flatbed with means to hold the 44-50 x 120-litre bins
in place. 7.5 tonne trucks are seldom excluded by Borough Bye-laws
whereas conventional RCVs often require special exemption to enter
towns by day. Back
14
EC 1774/2002 of 3 Oct 2002 and due to be transposed into UK law
by end April 2003 by further amendment to the Animal By-Products
Order 1999 (as amended May 2001). Back
15
EC 1774/2002 and the UK proposals are still ambiguous on retention
time. Most composting experts foresee the EU Biowaste Directive
scheduled for 2004 specifying a respiration rate at which the
compost will be sufficiently stable to cease being classified
as a controlled waste. Attainment of that threshold will probably
require 14-21 days closed reactor composting or at least seven
days in-vessel followed by 21-28 days actively managed windrowing. Back
16
These in effect require a repetition of one of the mandatory sanitization
regimes to ensure that 99.8% of the biowastes have been satisfactorily
treated to reduce pathogens to an acceptable level. EC1774/2002
Article 6(2)(g) permits national laws for composting catering
wastes pending rules from the EC Standing Committee on the Food
Chain and Animal Health. Annex VI, Chapter II, paragraph 14 however
requires that national regulations must "... guarantee an
equivalent effect regarding the reduction of pathogens."
Equivalent in that context refers to the immediately preceding
paragraph which stipulates (a) maximum particle size of 12 mm
before entering the composting reactor; (b) minimum temperature
70C of in all material in the reactor; and (c) minimum time
of 60 minutes in the reactor at 70C (all material). Since
the 100% implied by "all material" is unobtainable in
any real system, other European member states may have to adopt
similar additional measures to the UK's proposals. Research could
however show that the UK proposals, which are based on a mainly
theoretical risk assessment, are more stringent than they need
be. Back
17
Footnote 91 to SU "Waste not, want not" states, "In
the absence of domestic legislation on this issue, the terms of
the EU Animal By-Products Regulation will become UK law. These
requirements are much more stringent and probably rule out composting
operations using catering waste as the feed material." Back
18
DG ENV.A.2/LM/biowaste/2nd draft on the "Biological Treatment
of Biowaste" and COM(2002) 179 final of 16/4/2002 "Towards
a Thematic Strategy for Soil Protection" have been called
the prospective parents of the EU Biowaste Directive that is scheduled
for 2004. Back
19
DEFRA Risk Assessment, Conclusion 6: "The composting approach
outlined here provides more control points than landfilling. Composting
could potentially present lower risks to animal health than the
current practice of disposal of catering waste to landfill."
The scientists were not tasked to study or assess the obvious
risk from continuing to landfill untreated meat, hence the cautious
expression. Back
20
Parish-by-parish and ward-by-ward studies by the author of Cambridgeshire,
Colchester Borough and Tendring District indicate that BioColl
feeding in to SatComp sites offers a two to threefold saving in
biowaste haulage distances compared to feeding in to big centralised
facilities, whether landfill, incinerator of composting. Back
21
Materials Recycling Facility: Viridor's 1998 "dirty"
MRF at Great Blakenham, Suffolk, only recovered about 11% of the
Babergh MSW stream. Pink bags for dry recyclables only raised
that rate to about 15% probably because householders saw those
bags going in the same RCV as the residuals; separate collection
of the pink bags has just been introduced, but that leaves yet
more room in householders' 240-litre bins, which must still be
collected weekly because of the putrescibles. Since the putrescibles
are unlikely to increase significantly, extra "green"
waste is likely to fill the space available and so discourage
home composting. Back
22
"Biostabilized wastes will not qualify as compost. Besides
if the putrescibles are efficiently collected as per BioColl,
the nitrogen available in the residuals may be too little for
the bacteria to self-heat the wastes sufficiently in an economic
period to stabilize them to the required level. Back
23
Detailed spread-sheets of costs from the charts are derived will
be forwarded on request. Back
24
DEFRA Consultation Paper of October 2002 on proposals to amend
the Sludge (Use in Agriculture) Regulations 1989 (SI 1293 as amended
by SI 880 in 1990). These would incorporate the voluntary "Safe
Sludge Matrix of 1998 and anticipate the EC's intended revision
of the existing 1986 Sludge Directive. Back
25
Following The Times leading article "The green agenda
needs fresh thought not punitive taxes" of 24 May 1999, The
Times published this author's suggestion that cash rebates
by annual cheque would be a more positive stimulus than a reduction
in the waste element buried in council tax bills. That also allows
waste authorities to collect for a budgeted service provision
that could cope even if householders failed to cooperate as well
as had been hoped. Back
26
"Optimization of schemes for source separation of compostable
waste considering the locally most suitable technique;" Favoino,
E., June 2001. Back
27
Babergh District Council, Head of Environmental Services in September
2002. Back
28
From announcement of a new scheme through applications, allocations,
disbursement of monies, manufacturing, installation and commissioning
will take about 18 months minimum. Back
29
This is not to denigrate WRAP's work on standards but they are
rather arcane and complex when explaining prospects for composting
to potential business angels. Even the new WRAP Business Development
initiative excludes composting and there is obvious risk that
if WRAP's next initiative in this sector is for opening up the
markets for composts, the development of schemes like the one
proposed here will go unfounded for a further few years. Back
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