Sep 012008
The following may be of use to other groups submitting comments on waste development control policies, etc.
21st August 2008
Waste Development Control Policies : Public Consultation
Attn. The Inspector,
Wate Development Control Policies,
Wiltshire County Council,
E.S.D.
County Hall,
Trowbridge,
Wiltshire
BA 14 8JD
Dear Sir,
This submission is made on behalf of The Air That We Breathe Group which supports the Development Plan Document (DPD). I am Chair of this community group.
The DPD should demonstrate the alternative strategies and should then evaluate them against existing strategies on a sustainability appraisal. This then involves social, environmental, economic and resource objectives ( ref 3.1 of SFGN )
We believe that the soundness of the DPD is basically flawed by current strategies. They have failed to minimise air pollution by opting for incineration of Salisbury’s MSW residuals in the Colnbrook Grundon Viridor Incinerator in Berkshire ( postponed contract for 1 year ). Also the choice to deal with West Wiltshire, Kennet and North Wiltshire Districts MSW residuals via MBT/SRF to be incinerated in the cement kilns of the Lafarge Plant Westbury is not justified
We have found no proper justifications for these incineration decisions in terms of air pollution.
The different types of volatile gaseous chemical compounds which are emitted by incinerators are not monitored under the Waste Incineration Directive. These have been at the centre of numerous correspondence with WCC and as public servants we view their choices should reflect a precautionary position, especially when considering the different strategies. There should not be a guinea pig like trial via incineration with our collective health in the balance.
In terms of conserving energy we are concerned that current strategies restricting growth of recycling and composting to a ceiling of 50% by 2020 when there is a clear opportunity to exceed this % figure is not justified. We believe there is a greater opportunity to engage with community groups to discuss the viability of conserving energy via established recycling and reprocessing options. If this ceiling was lifted then the choices to incinerate would be under threat as contracts to provide tonnages of feed stock for the duration of the contract, would leave WCC with few options to meet their contractual obligations. ( for example – importing waste from Italy to meet their contractual arrangements/ as has happened in Germany )
Conserving raw materials such as cardboard,textiles and plastics via household collection and also household kitchen waste for anaerobic digestion for conversion into compost and methane /energy production provides a very real alternative to incineration options and therefore current strategies is not justified.
Our Group are not convinced that proper evaluation of the waste management options for the conservation of raw materials have been considered by WCC, there is no published justification for their decisions on the sustainability criteria.
Our Group consider the production of energy to be a crucial element to any waste management decision and we see the destruction of food waste as being unjustified when it can produce energy via anaerobic digestion. Why destroy by incinerating when you can reuse and create energy? This should be central to their core strategy under a sustainability appraisal and there is no evidence that the Council has engaged with the local communities to develop the DPD.
Financial implications of the choices that have been made by WCC have not demonstrated best value in an open and accountable way and this concerns our Group. The existing strategy provides no evidence that we as rate payers are getting the best financial option and this should concern us all. The way in which decisions flew against all community advice which was provided by the Wiltshire Waste Forum caused much anger amongst those of us who gave our time and energies to provide WCC with real alternatives which met the Sustainability Appraisal and fitted into the Core Strategy.
We believe that WCC decisions and the process behind decision making is unjustifiable. It is not based on fact finding and certainly has failed to properly engage with the communities that will have to deliver those strategies. It is our assertion that we are being delivered poor quality waste management options that do not represent best value and this must be reviewed as the existing strategy is open to abuse whether that is fact or not.
In conclusion we require a full evaluation of waste management options available to WCC in order to demonstrate which options offer best practice for pollution control , energy conservation, raw material conservation and the promotion of renewable energy done under the best value criteria justifications. All of these evaluations should demonstrate an assessment under the sustainability criteria where the impact on environmental, social,and economic factors apply to human and natural world. When these evaluations have been done then the community at large should be engaged to discuss the outcomes on the Waste DPD.
Our oral participation would be better served in a joint presentation with Wiltshire Friends of the Earth who we work closely with, but we would remind any inquiry that our Group has only limited resources although we have a determined view regarding the practices involved in waste management decision making
This is our submission.
I am, Yours Faithfully,
David Levy-Chair
on behalf of
The Air That We Breathe Group
