From Aberdeen Friends of the Earth, Ref ACIIh
To Peter Olsen, North East Scotland Waste Strategy, SEPA, IV15 9BR
NEWasteResponces@sepa.org.uk
March 2002


Peter
We would make the following responce to your Waste Issues Paper.

Q1.  Do you think the BPEO process is clear and useful

Step1 is clear.

Step 2 gives the impression that the BPEO might be heavily influenced by current plans.  The Plan should not take into account existing contracts and plans which have pre-empted the AWP, as these have no bearing on which option is the BPEO.  

Also, the Plan should not be based entirely on existing recycling facilities.  The expansion of recycling required by the Government will necessitate the opening of new facilities, some of which will be closer, reducing transport costs.  Where new facilities or legislative support are required, the Plan should spell this out rather than assuming that they will not materialise.

In Step 3, it is not clear whether assessment will merely be a comparison of the indicative options or whether it will be more wide ranging.  It is not clear where the costs are derived from and, while recycling costs include collection, it is not clear whether some of the other options do.

The criteria are clear and comprehensive.  However, it is not clear how these will be weighted in the final assessment.  There is an odd comment in the section on Flexibility, where population growth is mentioned: the document mentions earlier that a 3% decrease is forecast over the next 10-15 years.

Q2. Are there other criteria that should be considered?

Health should be a separate category.  Currently, only accidental risks are mentioned, but there are also risks from the ordinary operation of waste treatment facilities.
Likely future legislation should be considered.
The benefits for local people of waste spending should be considered.  Systems with a high ‘multiplier effect’, where money spent stays in the local economy for longer should be preferred.  (E.g. All else being equal, labour-intensive systems are preferable to capital-intensive).

Q3. What waste minimisation activities should the Area Waste Plan include?

Assuming that ‘waste minimisation’ covers the options of Refuse, Reduce and Re-use from the Waste Hierarchy,
The Plan should include support and encouragement of businesses and institutions which re-use and repair goods or materials, such as Thrift Shops, Instant Neighbour and Wood Recyclability.  In Aberdeen a particular constraint on such institutions is finding space.
As large resource users, the Councils should have strong waste reduction policies in all departments.
Education is important but it should be emphasised that education must go hand in hand with the provision of sustainable waste facilities.  In the absence of this, education produces cynicism rather than enthusiasm.  The Plan should recognise the success of the Buchan Villages Project and attempt to replicate this in all areas (The Aberdeen Environmental Forum is currently considering such a mentoring-based environmental project.).
The use of re-usable rather than disposable products should be supported where appropriate: e.g. nappy washing services.
There is evidence that separated collection of waste encourages minimisation, presumably by making people more aware of what they are throwing away.
The plan should note the need for Central Government support on waste reduction, with measures such as the poly bag tax recently introduced in Ireland.

Q4. What is your opinion of these indicative options for household waste?

These options are incomplete.  None of them seems to us to be the BPEO.

We find that the options make it very difficult to make meaningful comparisons.  For instance, since all of them involve 25% recycling, a comparison of the options will say nothing about what level of recycling is achievable or desirable.  Similarly, there is no detail in the options on waste collection methods.

Some figures seem entirely arbitrary.  For instance, Option 1 (Maximise Recycling and Composting) involves less composting than Option 2 (Incineration with Energy Recovery, Recycling and Composting).  Why should an incinerator make it possible to compost more?  This makes comparisons of these 2 options misleading.  Composting is never greater than 20% of the waste stream.  There is no reason why this figure should not be significantly higher.

There is also a lack of detail in other areas.  ‘Recycling’ could refer to a number of materials, some of which are more of a priority than others.  There is also a difference between recycling materials which have been through an incinerator or otherwise contaminated and recycling materials from a separated collection.

Q5. Do you have a preferred option for future waste management in the area?

It is impossible to simply rate the options without being misleading.  However:

Option 1 - D - As given, Option 1 is poor, appearing to be the minimal compliance option.  However, genuinely maximising recycling and composting would be a good strategy.  The Plan should spell out the Central Government actions which would be required to support this.

Option 2 - E - This option is very poor.  The recycling and composting rates given in it make it appear attractive but these appear to be arbitrary and not related to the incinerator.  The problems lie in both the size and the technology of the incinerator.  The size would mean that incineration would be liable to displace recycling and composting.  Alternatively, if recycling and composting were maximised, waste would have to be brought in from a distance to the incinerator.  We have strong concerns about the health implications of a  mass-burn incinerator and the social implications of the current proposals for where to site one.  An incinerator of this size would also make the strategy inflexible and vulnerable to change.

Option 3 - C - We are not qualified to comment in detail on pyrolysis and gasification, but if recycling and composting are maximised, these could be preferable to mass burn for the remainder.  As smaller plants, they would give the Plan more flexibility.

Option 4 - D - Anaerobic digestion should not really be necessary in a BPEO strategy because digestible waste should already have been sorted out in a separated collection.

Option 5 - D - Waste export violates the Proximity Principle and, on the scale proposed, would make for an inflexible Plan.  This is not to say that export could not play a smaller part in an integrated strategy, so long as transport was by rail, not road.

Our own BPEO strategy would include strong support for waste minimisation; a separated collection of waste, supplemented by bring sites where appropriate; removal from the waste stream and separate treatment of wastes such as batteries and chlorinated plastics (until these are phased out by Central Government); maximum recycling, particularly of metals; and close to 100% composting of biodegradable materials.

The BPEO should recognise that legislation and technology are both changing, so methods for treating the residual waste (landfill, incineration, heat treatments) should take into account both environmental impact and flexibility.  We believe that incineration scores particularly badly on these combined counts.  Any option which includes energy generation should be situated where it can supply Combined Heat and Power.  Any other energy-generating option cannot be the BPEO.

Q6. Is the proposed approach for developing management options for commercial and industrial waste adequate?

The assumption that the BPEO for commercial waste will be the same as the BPEO for domestic waste seems accurate.
The approach of breaking Industrial Waste into priority waste streams seems sensible.  It is important to consult waste producers but, as with the MSW plan, the BPEO should not be influenced too much by what is current practice.

Q7. What activities should be considered to improve the management of commercial and industrial waste?  

There are many examples of companies saving money by reducing waste, but companies often do not do this as they lack the time or skill and see it as a distraction from their main business.  The Area Waste Plan should include ways of providing these skills.

Q8. Would you be willing to separate  you  waste  into different containers before putting it out for collection?  If so, how many - one, two or three?

Yes. Three.

Q9. How can we reduce the amount of disposable products we use?

Legislation, education and support for re-usable items (e.g. nappy-washing service).

Q10. How can we increase the proportion of waste recycled in the North East?

By introducing a separated waste collection.
By legislating and working with producers to make the waste stream more recyclable (producer responsibility).
By getting ‘added value’ out of keen recyclers by providing facilities for greater levels of separation (e.g. white office paper).
By providing ‘recycling credits’ to community groups and others.

Q11. All options will cost more.  Should we choose
(a) the lowest cost?
(b) another option which will cost more but have other benefits?

Option b.  We should bear in mind that the cheapest option may have hidden costs due to changes in legislation in the future.  We should also take into account whether the money is spent in ways which will keep it in the local economy or send it straight out.

Q12. Did you find this document easy to read, clear and informative?

Yes.

Q13. Can you suggest improvements to assist in the production of the Draft Area Waste Plan?

The Draft Area Waste Plan should go beyond the Indicative Options in the Issues Paper.
Waste streams should be analysed individually.  For instance, the benefits of recycling metals are very different to those of recycling plastic and the composition of the waste stream going into treatment plants can have a major effect on their effectiveness.
Collection options should be a far clearer part of the Plan.
The question ‘Is the option likely to work in practice given current arrangements, contracts, etc.?’ should be removed from the local decision criteria.  This criterion does not appear in any other Issues Paper written for any other waste management area in Scotland.

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