Memorandum submitted by Capel Action Group
(Waste 13)
1. ABOUT CAPEL
ACTION GROUP
The Capel Action Group (CAG) is a committee
formed some years ago under the auspices of Capel Parish Council
to make known the views of local residents on key issues likely
to have an impact on the community. In addition to making submissions
on local and regional plans, CAG has submitted written evidence,
and has been called to give oral evidence to a House of Commons
Select Committee on waste issues (31 October 2000—Report
dated 14 March 2001 HC 36-1).
In 2002, CAG successfully applied to the High Court
to obtain an order to quash the seriously flawed decision of the
Planning and Regulatory Committee of Surrey County Council in
relation to the then proposed Capel mass burn incinerator.
In 2003 CAG participated in the Examination in Public
for the Surrey Structure Plan and in October 2004 participated
in the Examination in Public for the South East Regional Waste
Management Strategy.
In April and May 2006 CAG submitted written
evidence to a review undertaken by Surrey County Council's Environment
and Economy Select Committee on waste technologies and the County
Council's waste strategy and appeared in front of the Committee.
CAG submitted written evidence to the Examination
in Public for the Surrey Waste Plan, which concluded in September
2007, and participated on many of the days on which hearings took
place to consider the plan's core strategies. Additionally the
Inspector allocated three days for a formal site specific session
on the Clockhouse Brickworks site, which has been allocated in
the plan as the preferred site for an incinerator. The process
involved leading counsel and the cross examination of witnesses.
2. EXECUTIVE
SUMMARY
We welcome Waste Strategy for England 2007 and
believe it builds significantly on Waste Strategy 2000. We believe
the emphasis placed on driving up levels of recycling and composting
to be correct and we are particularly pleased to see such strong
support for Anaerobic Digestion.
In our comments we highlight:
— The need for Government to require
single waste management structures to be established in two-tier
authorities
— The need for proportionate regulation,
which must be enforced.
— That strong emphasis be placed on
source separation, with an urgent need to separately collect food
and garden waste.
— The need to research the optimisation
of product design and the benefits/excesses of product packaging,
as DEFRA envisages through its Waste and Resources Evidence Strategy.
— The pressing need to address methane
emission levels from landfill sites, as the US is doing.
— That contribution to climate change
should be a factor that is taken into account in decision making
processes for all future waste management facilities.
— Our support for Anaerobic Digestion
as a preferred disposal option, but that we consider mass burn
incineration to be unacceptable due to the health risks it poses.
— The emphasis that planning authorities
must place on identifying suitable sites for the significant increase
in facilities that will be required to enable the recycling and
composting targets in WSE2007 to be met.
3. THE ISSUES
(a) How policies will be implemented,
roles of waste creators and disposers, localisation v centralisation
1. Waste is the antithesis of most forms
of enterprise. The product already exists at the bottom of the
supply chain. As there is too much waste the first challenge is
to seek to reduce the quantity. The next challenge is to find
uses and markets for what remains.
2. Minimisation is rightly at the top of the
waste hierarchy and should engage the minds of creators and leaders
in manufacturing industry, who are at the top of the supply chain.
Those that feel the real impact of waste are consumers and those
responsible for managing waste—at the bottom of the supply
chain.
3. Sound effective solutions inevitably must
be found in large part at the local level. The burden at local
level can be expected to lessen through effective minimisation
action at the top. The top level also needs to establish frameworks
and policies to enable local action to proceed in an optimal fashion
eg WRAP was a much needed initiative to enable markets for recyclates
to emerge, although there is much still to be achieved here.
4. A prerequisite for progress at the local
level is effective structures for the management of waste at local
government level. We refer in section 12 to our concerns over
the effectiveness of waste management processes in two-tier authorities.
5. We also believe that flexibility to embrace
new approaches to waste handling and new technologies and are
concerned that long term contracts, of 25 years or more, with
waste disposal companies can act as a barrier to change, in an
area where the need for change is paramount.
(b) The role for and implementation
of regulations, and their enforcement
1. Regulation is essential in waste related
matters. We in the UK probably would not even be where we are
today (which remains a long way behind others) were it not for
the collective will established through EU member states agreeing
a vision and way forward. To that we would add that since 2000
the Government has provided strong leadership with the Waste Strategy
for England 2007 (WSE2007) moving matters on further.
2. Regulations should be proportionate setting
clear targets, where needed. There is no point in regulation if
it is not enforced.
(c) The Classification of Household
Waste
1. Much research and analysis has been undertaken
into the composition of household waste. Such an analysis was
reported on in Surrey in 2004. It showed that nearly 80% of the
waste was potentially recyclable, reusable or compostable and
that 67% was biodegradable waste. The most significant parts of
the total waste stream were garden waste (23%), paper/card (22%)
and food waste (16%).
2. The analysis also covered the composition
of waste collected from kerbsides and road sweepings. The major
components of this waste stream were paper/card (28%), food waste
(22%) and green waste (13%).
3. WSE2007 identifies seven key waste materials
categories where diversion from landfill could realise significant
further environmental benefits. These benefits are clearly set
out in chapter 4.
4. A pre-requisite for managing the streams
of the seven key waste materials is the separation of household
waste either at source or early on in the supply chain at materials
recycling/separation facilities. Many collection authorities have
much ground to make up eg many are not yet collecting food waste,
a major source of biodegradable waste.
(d) Proposals for financial incentives
to increase household waste prevention and recycling
CAG responded to the consultation. Our response
is at the appendix.
(e) Composting
Composting has a clear role to play in recovering
value from garden and food waste, as does anaerobic digestion.
In many counties both approaches may be feasible depending on
population densities and the availability of suitable road access.
(f) The Government's approach to waste
minimisation
1. Waste minimisation is a topic at the top of
peoples' minds when asked about how the waste problem should be
tackled. Excessive product packaging is often quoted. It is always
possible to point to excesses and to take action on those. But
the majority of packaging exists for very good reason, primarily
to protect the product. Manufacturers and retailers will not readily
dispense with packaging if the result would be to suffer higher
product damage or loss, which could prove to be expensive, and
more environmentally damaging.
2. A question posed on packaging by DEFRA's Waste
and Resources Evidence Strategy 2007-2011 (page 17) is very relevant
here:
What evidence is required to amend existing
regulations to achieve packaging minimisation?
The strategy identifies a research project to
tackle this and other packaging and resource efficiency issues,
including the critically important issue of optimising product
design (page 28). We consider this to be essential research/evidence
based work.
(g) Contribution to climate change
1. Methane from landfill contributes significantly
to total methane emissions in the UK. The cause of this is biodegradable
waste that is placed in landfill. A major part of the solution
will be found once all biodegradable wastes are separated and
recycled and composted. Green and food wastes are major contributors
and a key priority should be the establishment of collection schemes
throughout England.
2. But landfill will be with us for very many
years to come. As existing and closed landfill sites will continue
to emit methane a strategy is needed to deal with this. In the
US the Environmental Protection Agency (EPA) operates a Landfill
Methane Outreach Programme. Almost 20% of US MSW landfills in
the US operate such a scheme and the EPA estimates that a further
25% could turn their gas into energy, producing enough electricity
to power 870,000 homes. (www.epa.gov/lmop/benefits.htm)
3. Contribution to climate change should
be a factor that is taken into account in decision making process
for all future waste management facilities. Disposal facilities
can be effective in reducing impacts on climate change but some
clearly do not egincineration without combined heat and power
recovery.
(h) The promotion of anaerobic digestion
for agricultural and food waste
1. We find encouragement overall from WSE2007
and the elevation of anaerobic digestion (AD) to be one of its
most encouraging aspects.
2. The ultimate disposal of waste, after manual
and mechanical separation and sorting, brooks great controversy.
The UK waste industry has very largely aligned itself to mass
burn incineration (or EfW) despite the fact that it represents
an old technology and is rapidly being challenged by new, emerging
technologies. Most other European countries have made much more
progress in managing household waste than has been the case in
the UK. Countries, such as France, embraced incineration on a
wide scale early on but new investment on the continent increasingly
is finding its way into MBT, AD and other forms of thermal treatment.
We believe mass burn incineration to be an unacceptable option
for many reasons including impact on the environment but also
due to the health risks posed, which we address in the next section.
3. One of the principal reasons put forward
by the UK waste industry for its promotion of incineration is
the relative ease of raising finance for a financially proven
technology derived from a long track record. It claims that it
is less easy to raise finance for newer technologies that do not
have established track records. The industry also cites unreliable
sources for the product outputs as a result of market uncertainty.
4. WSE2007 support for AD is therefore very
welcome indeed. Firstly because AD is a cleaner and better technology
than incineration; secondly because this endorsement, together
with the support that will be available under the renewables obligation,
will provide greater certainty for the UK waste industry and potential
investment sources.
(I)
HEALTH CONCERNS
WITH INCINERATORS
1. In May 2004 Defra published its review
of the health and environmental effects of waste management. The
review was in itself peer reviewed by the Royal Society, which
said:
"that it is important that anyone using
these data takes adequate consideration of its inherent uncertainty."
2. Certainly, there is good evidence that
the emissions standards have driven down the actual emissions
from incinerators and this will continue with the implementation
of the Waste Incineration Directive. But it is also generally
accepted that emissions standards are still based on what can
be measured and what is technologically achievable, rather than
what is safe." (House of Commons Select Committee Report—point
put forward by Capel Action Group (Q149) and accepted by Environment
Agency (Q896), para 93, Select Committee)
3. Continuing para 93 of the Select Committee
report:
"Inevitably, this simple fact undermines the
safety case which can be made from an incinerator meeting modern
emission standards. In particular, the scientific evidence and
consensus about the health risk posed by dioxins is not fully
developed and the US Environmental Protection Agency have recently
published for consultation a review which concludes that dioxins
could be some 1000 times more toxic than previously thought. The
Environment Agency told us, more generally, that our understanding
of the heath risk of air pollution is "at an early stage".
4. Waste operators have often asserted that
incinerators are safe, but there is extensive evidence to the
contrary. The following comments highlight that evidence, drawn
from a report on "The Health Effect of Waste Incinerators"
published by the British Society for Ecological Medicine in 2006.
5. Large studies have shown higher rates
of adult and childhood cancer and also birth defects around municipal
waste incinerators: the results are consistent with the associations
being causal. A number of smaller epidemiological studies support
this interpretation and suggest that the range of illnesses produced
by incinerators may be much wider.
6. Incinerator emissions are a major source
of fine particulates, of toxic metals and of more than 200 organic
chemicals, including known carcinogens, mutagens, chemicals that
damage the immune system and hormone disrupters. There is no safe
threshold for many of these substances. Emissions also contain
other unidentified compounds whose potential for harm is as yet
unknown (as was once the case with dioxins). Since the nature
of waste is continually changing, so is the chemical nature of
the incinerator emissions and therefore the potential for adverse
health effects.
7. Monitoring of incinerators has been unsatisfactory
in the lack of rigour, the infrequency of monitoring, the small
number of compounds measured, the levels deemed acceptable, and
the absence of biological monitoring. In particular, the three
most problematical pollutants are either not monitored at all,
or are monitored so infrequently as to be of no practical use.
PM2.5 particulates are not measured at all (only the far less
relevant PM10s), dioxins and heavy metals are measured 3 to 6
monthly and then annually. In other words these highly dangerous
substances are not measured over 99% of the time.
8. So far, there has not been a single scientific
study of the safety of modern incinerators. Rigorous independent
health monitoring might give rise to suspicions of adverse effects
on the foetus and infant within a few years, but this type of
monitoring has not been put in place and probably would not reach
statistical significance for individual installations. Effects
on adult cancers would not become apparent for at least ten to
twenty years. It would therefore be appropriate to apply the precautionary
principle here.
(j) Adequacy of existing infrastructure
for disposal, capacity for recycling and consideration of new
technologies
1. There is a shortage of facilities to
treat residual waste. This has arisen largely due to the dogged
persistence on the part of waste operators in promoting incineration
in the face of continued opposition by local communities. This
has resulted in delays in the development of much needed facilities.
The Government has acknowledged this in WSE2007.
2. This change has arisen mainly because of higher
targets being set for recycling and composting, properly reflecting
the primacy of the waste hierarchy and reflecting the new focus
on managing key waste material streams. But there is no doubting
that the "casualty" has been energy recovery, which
has seen its targets reduced, most significantly in 2015 where
it is a massive 12% lower than in Waste Strategy 2000. The new
target for 2020 (of 25%) is 9% lower than the WS2000 target for
2015. The new target for 2010 is also lower.
3. Arguably this need not have been the
case as the Government could have chosen to signal a desire further
to reduce diversion to landfill by 2015. Instead diversion to
landfill remains at 33%, the same level as in WS2000. In our view
this apparent reluctance to further reduce diversion to landfill
by 2015 signals two things: firstly that mass burn incineration
is no longer seen as the first choice technology for energy recovery,
even when heat recovery is part of the scheme, which is not always
the case: secondly that AD has replaced mass burn incineration
as the preferred approach, although options are being kept open
should AD not deliver.
4. Further processing capacity for recycling
and composting will undoubtedly be required now that recycling
and composting targets have been increased in WSE2007. As a matter
of urgency planning authorities will need to identify suitable
sites that have a high potential to be realised in practice.
5. In our response to the consultation on
incentives for recycling we drew attention to the particular problems
facing two-tier authorities.
"Our view is that the two-tier authority structure
has an inbuilt handicap in managing waste issues, compared with
unitary structures. This is recognised in this consultation document
but no solution is offered other than an exhortation for the WDA
and WCAs to work together. Waste management is a function best
performed by a unitary structure, which waste authorities are
free to establish but are not required so to do. We believe that
progress in waste management would be much better in two-tier
authorities were they to be required to set up a separate structure,
on which the WDA and WCAs would be fully represented. Such a structure
would also enable members of the public to be represented. We
urge Government, as a matter of urgency, to strengthen the requirement
for such structures to be established in two-tier authorities."
Appendix 1
Incentives for Recycling by Households[20]
Capel Action Group
October 2007
20 Not printed. Back
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