Bristol Against Mass Burn Incineration (BAMBI) is an alliance of groups who are opposing the West of England Partnership plans to use incineration as a method of dealing with residual waste.
The West of England (WoE) Partnership is currently consulting on their Core Waste Strategy. The WoE Partnerships’ preferred Option C has one 400,000 tonne capacity waste site, plus 4 smaller approx. 100,000 tonne sites.
Bristol Friends of the Earth suggest that BAMBI supporters oppose Option C, and support Option B instead – which has 8 x 100,000 tonne sites.
Reasons for supporting option B include:
– consultees to the previous Issues and Options consultation expressed a clear preference for small waste treatment sites
– adopting 8 sites of 100,000 tonnes pa would allow waste to be treated as close to where it is generated as possible
– having smaller EfW sites would give the best chance of delivering CHP to community use – for example, if sited close to the proposed urban extensions
Reasons to oppose options A & C:
– consultees to the previous Issues and Options consultation said that they wanted waste to be treated in small sites, sited as close to where the waste is being generated as possible
– adopting 1 or 2 large sites of 400,000 tonnes pa would not adhere to the proximity principle – one of the alleged underlying principles of the WoE Waste Planning Strategy
– having 1 or 2 large EfW sites would not allow for genuine ‘community’ use of CHP
– A large 400,000 tonne pa facility in, for example, Avonmouth is very unlikely to attract a customer for all its waste heat. Using smaller, more dispersed facilities will maximize the potential number of customers for year-round supply of heat.
Below is a suggested response to the consultation from Bristol FoE:
West of England Waste Core Strategy consultation
Please help try and stop incineration from making a comeback in our region by taking part in the WoE Waste Core Strategy consultation:
Online at: www.westofengland.org/waste
send comments by email to: wepo@dialoguebydesign.com
request a form: 0117 922 2785
or write to: West of England Partnership, Freepost SEA 12430, Thornton Heath CR7 7XT
deadline for responses: 12 March 2009
If you only have a few minutes, our suggested short response to the consultation is:
Skip straight to the Recovery section of the questionnaire and:
• register your support in Q.10 for Option B (8 x 100,000 tonne waste facilities)
• your opposition in Q.9 to Option A (2 x 400,000 tonne facilities) and
• your opposition in Q.11 to Option C (1 x 400,000 + 4 x 100,000 tonne facilities)
If you have a bit longer, then you can read our suggested longer response. Please put these points into your own words wherever possible, and add any other comments of your own.
General comments
1. Do you have any general comments you would like to make?
• Although outside the scope of this consultation, we want to make it clear that we are opposed to the use of EfW by incineration at any of the identified potential sites.
• Concerns about climate change impacts should inform all aspects of the Waste Core Strategy – it makes no sense to carry out a Sustainability Appraisal of the potential waste sites, without
consideration of the climate change impacts of the facilities that might be built on those sites.
Studies by Eunomia, and the WoE’s first 2 climate change assessments, have shown that adopting EfW by incineration will make our climate change impacts worse than they are now.
• We are concerned about the number of identified potential waste sites that are in flood risk areas – especially if the climate change impacts of any facility built on those sites is likely to make
flooding more of a possibility.
• Electricity produced through EfW by incineration is NOT renewable energy. Waste is not a renewable ‘fuel’ – it is destroyed by burning. More energy can be retrieved from waste by maximizing recycling. Without CHP, the efficiency of an EfW by incineration plant will fall to
around 27% – below the minimum efficiency required for the electricity generated to qualify for ROCs (Renewable Obligation Certificates). It is essential that any waste sites identified through the
Core Strategy can genuinely deliver CHP to the community. It is not sufficient that sites be ‘capable’ of delivering CHP – they must deliver it.
• Although outside the remit of this consultation we are disappointed by the unambitious household waste recycling targets being set in Bristol, and by the lack of development of any Recycling Strategy. A target of 51% recycling only just scrapes above the legal requirement, and is nowhere near European best practice that can achieve levels of 70% recycling or higher.
Waste minimisation
There are two proposed policies for Waste Minimisation
• To promote the use of Waste Audits
2. Do you have any comments on this policy?
‘Promotion’ of Waste Audits is an unsatisfactory and vague aspiration, when it does not come with any targets for reducing commercial waste.
• To identify the types of developments for which waste audits would be applicable.
3. Do you have any comments on this policy?
Why should any developments be exempt from considerations of waste minimization?
Recycling and composting
Views expressed on the Issues and Options consultation were strongly in favour of recycling. This planning document has to plan where to locate facilities for recycling or composting material produced by commercial and industrial concerns. These would include recycled aggregate processing facilities, material recycling/waste transfer stations, and open windrow and in vessel composting facilities
The proposed policies for Recycling and Composting are:
• Inert (construction and demolition) waste recycling facilities – to provide facilities at existing mineral sites, brown-field or industrial sites in urban or rural locations and existing and former waste sites.
4. Do you have any comments on this policy?
No comment.
• Non-Inert material (commercial and industrial) recycling/waste transfer facilities – to keep existing facilities on industrial/brown-field land with an acceptable access on to the primary route network.
5. Do you have any comments on this policy?
No comment.
• Household waste recycling centres – to provide facilities to serve Bath, Bristol, South Gloucestershire and North Somerset
6.Do you have any comments on this policy?
• The Preferred Options document is very vague about how many sites might be provided. The current provision of only 2 sites for Bristol, means unnecessarily high ‘waste miles’ in travel to the
sites.
• People living a long way from the sites are unlikely to use them, and will dump items instead.
• The current system is impractical for access by public transport, and BCC collection costs for large items are prohibitive.
• The situation in rural areas of the WoE may even be worse than in Bristol, and there may be a need for more provision of mini recycling centres (especially to take items not dealt with through
doorstep collections).
• Greater sorting of recyclate categories should be allowed. Best practice elsewhere in the world, allows sorting of up to 30–40 types of recyclate.
• Open windrow composting – to support proposals for small-scale ‘on-farm’ facilities
7 Do you have any comments on this policy?
We would support this in principle, along with similar ‘community composting’ schemes, so long as waste miles are minimized.
In-vessel composting facilities – to locate these facilities on brown-field or industrial sites in urban or rural locations along with existing and former waste sites
8. Do you have any comments on this policy?
We support this policy in principle, but want to see any in-vessel composting plants being used to generate genuinely renewable energy.
Recovery
Recovery is the process of extracting a product of value from waste materials through recycling, composting and other forms of material recovery. In addition, modern technology enables us to generate valuable ‘renewable’ energy from waste and contribute towards the regional targets set out in the draft Regional Spatial Strategy for renewable heat generation. There is an annual target for almost 800,000 tonnes of waste to be managed through recovery facilities by 2020, and there are no such facilities currently operational in the West of England. There are a number of different options for locating recovery facilities across the West of England. These are known as spatial options. Three spatial options have been identified:
Option A: Two recovery facilities which would each handle 400,000 tonnes annually.
9.Do you have any comments on option A?
We do not support this option because:
– consultees to the previous Issues and Options consultation said that they wanted waste to be treated in small sites, sited as close to where the waste is being generated as possible
– adopting only 2 sites of 400,000 tonnes pa would not adhere to the proximity principle – one of the alleged underlying principles of the WoE Waste Planning Strategy
– having 2 large EfW sites would not allow for genuine ‘community’ use of CHP
• A large 400,000 tonne pa facility in, for example, Avonmouth is very unlikely to attract a customer for all its waste heat. Using smaller, more dispersed facilities will maximize the potential number of
customers for year-round supply of heat. Also, if facilities should be located near to where such energy can be used, then customers for waste heat should be lined-up before sites are finalized.
Option B: Eight recovery facilities each handling 100,000 tonnes annually.
10. Do you have any comments on option B?
We support this option because, as stated above:
– consultees to the previous Issues and Options consultation expressed a clear preference for small waste treatment sites
– adopting 8 sites of 100,000 tonnes pa would allow waste to be treated as close to where it is generated as possible
– having smaller EfW sites would give the best chance of delivering CHP to community use – for example, if sited close to the proposed urban extensions
Option C: A combination of different scale facilities suiting the density of the surrounding area – this is the preferred option of the West of England Partnership. This means providing facilities at:
11. To what extent do you agree with our preferred option C?
• We do not support this option, for the same reasons that we object to Option A.
• Although this option fares better for the proximity principle, in practice what is likely to be delivered is 1 x large EfW incinerator + 4 small non EfW facilities. This will minimize the potential for delivering genuinely useful ‘community’ CHP.
• The 3 key points to emerge from the Issues and Options consultation, as summarized in the Preferred Options consultation document are (quoting directly) to:
• support the need to reduce the distance waste is transported
• …in favour of a large network of smaller localized facilities dispersed across the area
• facilities that generate energy should be located near to where such energy can be used
• And, as already pointed out in response to Q.9: a large 400,000 tonne pa facility in, for example, Avonmouth is very unlikely to attract a customer for all its waste heat. Using smaller, more dispersed facilities will maximize the potential number of customers for year-round supply of heat. Also, if facilities should be located near to where such energy can be used, then customers for waste heat should be lined-up before sites are finalized.
Landfill per year capacity
NorthWest Bristol 390,000 tonnes
Elsewhere in Bristol 60,000 tonnes
Weston-super-Mare 100,000 tonnes
Keynsham 150,000 tonnes
Yate 100,000 tonnes
Non-Inert Waste
• Requirement for new non-inert landfill capacity to replace existing facilities as they close, up to a maximum capacity of 265,000 tonnes per annum;
• Identify Areas of Search and adopt a criteria-based policy approach.
Hazardous Waste
• No policy required. Waste to be exported to specialist disposal facilities.
Inert Waste (construction and demolition)
• No policy required. Each council to make provision for their own area.
12. Do you have any comments on the policy on landfill?
• Why is the WoE proposing such a large capacity for non-inert landfill? The whole aim of the WoE Joint Municipal Residual Waste Management Strategy should have been to move towards
removing non-inert or biodegradable waste from landfill.
• The WoE policy is very vague on the potential liability of dealing with the hazardous waste that would be produced by an EfW incinerator. All of the fly ash is hazardous waste, and there are
moves to reclassify the bottom ash as hazardous. There is no provision for disposal of this waste within the WoE region, which is counter to one of the WoE core principles – that of regional self
sufficiency.
There are a series of WoE drop-in events around the region, close to potential waste development sites:
15.00-19.00 11 February 2009
BAWA, Filton – 589 Southmead Road, Filton, Bristol, BS34 7RG15.00-19.00 13 February 2009
The Campus, Weston-super-Mare – Highlands Lane, Locking Castle, Weston-super-Mare, BS24 7DX15.00-19.00 17 February 2009
Hollies Council Chamber, Midsomer Norton – The Hollies Building, High Street, Midsomer Norton, BA3 2DP15.00-19.00 19 February 2009
Easter Compton Village Hall – Main Road, Easter Compton, BS35 5SJ15.00-19.00 20 February 2009
The Vassell Centre, Fishponds – Gill Avenue, Fishponds, Bristol, BS16 2QQ12.00-16.00 23 February 2009
Guildhall, Bath – High Street, Bath, BA1 1LZ15.00-19.00 26 February 2009
Avonmouth Community Centre – 257 Avonmouth Road, Bristol, BS11 9EN15.00-19.00 4 March 2009
Knowle Methodist Church Hall – Redcatch Road, Bristol, BS4 2EP
