Waste decision deferred

I have just spoken with the author of the letter below - Mary Newton from Gloucestershire Friends of the Earth - I've only recently been in contact with her over waste matters and she has kindly given me permission to copy the letter here - it was sent to Stroud District Councillors ahead of the Cabinet meeting last night that was looking at waste.

In fact the decision to approve or not the County waste plans was rightly deferred - the issues raised below are serious - you will note that I have also raised some of these points earlier in this blog and also raised it with key Cabinet members - however I have also spoken with the County Council's Cabinet member re waste this evening and he assures me no decision has been taken re waste and they are seeking to maximise recycling and composting - there are also a few points I would like to raise re the letter below - hopefully in next few days.

It is vital we get this right or we could be landing tax payers with serious problems in the future - to say nothing of the impact on the environment......

Dear Councillor,

In approving the Joint Municipal Waste Management Strategy (JMWMS) the Stroud District Council is also approving five other volumes they may not have viewed which are part of the JMWMS . As set out in the Headline Strategy Vol. 1, 3.3 the strategy consists of 6 volumes.

In Volume 2 “High Level Action Plan”

4.5 Residual Waste states that the Gloucestershire County Council is developing a residual waste management project for a preferred technology on a preferred location.

4.6 Risks states “The affordability of the selected waste treatment technology is a huge risk. These are large scale, specialist and capital intensive facilities” and “If waste growth is less than forecast we might have new facilities that are not operating to capacity”

Why should Stroud District Council be concerned?

1) There is a risk that in committing to the development of a large scale facility that is capital intensive and accompanied with a long term contract the Waste Disposal Authority is also committing itself to ensuring that the facility has priority in supplies of residual waste.

It could mean:-

• the transportation of waste over distances within the County to the one large facility conflicting with the proximity principle
• may lead to the importation of waste to the County to keep it supplied.

It could also deflect efforts from;-

• the reduction of waste at source
• increase in waste separation for recycling at kerbside
• and thereby the development of new businesses from dry and wet recyclables

because why invest in reduction and separation when investment at great risk is being undertaken by the development of this large long term project to take residual waste? These are all matters that the Stroud District Council has the right to consider as a Waste Collection Authority and a partner with the Waste Disposal Authority.

2) In St. Arvans, Monmouthshire a “0” Waste project which promotes waste separation kerbside collections of paper, glass, cans, foil, textiles, plastics, tetrapak cartons, green waste and food waste, has diverted from landfill 73% of household waste and achieved 95% participation rate of residents in just over one year. The Consultation on the JMWMS revealed an overwhelming support from residents and Parish Councils for greater separation of waste streams for kerbside collection. The Consultants recommended in their Report on the JMWMS Consultation that Objective 3 should be reworded “to reflect the intention of maximising the range and quantity of materials separately collected.” Objective 3 has not been reworded.

3) In Gloucestershire recent planning applications and planning permissions for in vessel composting (IVC) facilities will remove from the wet biodegradable residual waste stream about 100,000 tons per annum (tpa) :-

• 30,000tpa at Sharpness, Stroud District,
• 32000 tpa at Wingmore Farm, Tewkesbury District (S106 to be agreed)
• 20,000 tpa at Dymock, Forest of Dean
• 22,000 tpa at Sunhill Farm, Cotswolds (if granted planning permission).

these new businesses also need a guaranteed residual waste supply.

4) Before the Stroud District Council has even had the opportunity to consider all the volumes of the JMWMS the Gloucestershire Waste Programme Board registered an Expression of Interest on the 30th September 2007 to DEFRA for PFI funding for a facility at Javelin Park to process 130,000 – 200,000 tonnes per annum (tpa) of residual waste requiring a long term contract likely to be for 25 years. The County Council is actively seeking to purchase 12 acres of Javelin Park.

Normally, an Expression of Interest should be based on a unanimous decision from all the District Councils on the JMWMS. As far as we can ascertain to date Gloucester City Council, Cotswold District Council, and Stroud District Council have not made a decision on the JMWMS.

5) The Minerals and Waste Development Framework is under review and the Waste Core Strategy for the Plan is likely to go out for public consultation in January 2008 leading to a Pubic Inquiry. It is premature to make the important decision of registering an Expression of Interest for a large, long term facility before the process of the Review of the Waste Core Strategy is completed at least to the stage of the Inspectors Report.

This Expression of Interest has been registered without the impartial testing through Public Inquiry all the material on which the expression of interest is based, particularly:-

· the methodology in examining alternative options
· the soundness of their choice of technologies
· the soundness of data used and projections of tonnages
· the choice of site, 12 acres at Javelin Park

The Expression of Interest is likely in practice to have a very significant effect on the policies to be brought forward by the Gloucestershire County Council in the Inquiry and plan-making consultations in 2008. These policies should be open to development through the testing of methodologies, technologies, data and choice of site in the Waste Core Strategy Public Inquiry.

For example, the Expression of Interest is formulated on the basis of several key waste policies:-

• it states that a strategic facility is required which implies a long term contract likely to be for at least 25 years for the handling of residual waste of 130,000tpa – 200,000 tpa
• it has selected a shortlist of technologies
• it has selected a site
• it is thereby proscribing the possibility of developing flexible, small scale facilities serving local communities whilst dealing with the residual waste arising from within those communities and thereby limiting the transport of waste
• it is thereby proscribing the development of possible new approaches such more reduction of waste at source, more separation of waste at the kerbside and the development of new recycling businesses

Climate change has become a central principle issue for the Government in the maintenance of sustainable communities underlined with the imminent publishing of Planning and Climate Change which will supplement Planning Policy Statement 1. In January 2008 the South West Regional Spatial Strategy Panel of Inspectors Report is likely to be released. These are two of many important documents which should provide the backdrop by which the future of waste in Gloucestershire is decided until 2020 in the Core Waste Public Inquiry.

6) For the reasons stated above the Gloucestershire Friends of the Earth Network request the Cabinet of Stroud District Council not to approve the JMWMS at their meeting of 13th December 2007 to enable:-

1. the Stroud District Council to discuss amendments to the JMWMS by adding a clause for greater separation of waste streams at kerbside collection to Objective 3
2. not to approve any procurement plan or outline business case for one large facility for residual waste accompanied by a long term contract
3. the Stroud District Council to request that the premature Expression of Interest be put on hold until at least the Inspectors Report on the Waste Core Strategy is publicly released, to enable the impartial testing through Public Inquiry all the material on which the Expression of Interest is based

Yours sincerely,

Mary Newton, Planning Officer, Gloucestershire Friends of the Earth Network