Draft Waste Strategy Responce

Thank you for the opportunity to comment on Aberdeen City Council's Draft Waste Strategy. To summarise the response below, our main points are:

Aberdeen City Council - Draft Waste Strategy Consultation

Response from Aberdeen Friends of the Earth

The document entitled Aberdeen's Draft Waste Strategy is already being referred to in public by officials as the adopted Waste Strategy: Peter Cockhead refers to it as the adopted waste strategy on page 3 of his report on the construction and development of a civic amenity site on the old incinerator site at East Tullos (Application Ref. A1/0338) and Ian Gerrie told a packed hall at Loirston Primary School that this was the finalised waste strategy. If this is the case, there would seem to be little value in a consultation.

Aberdeen City Council has signed a binding 25 year contract with a waste disposal company. This has effectively removed waste disposal options from democratic control, and will incur high costs for the citizens of Aberdeen socially, financially and environmentally for the next generation. We are also concerned at the way that the decision to sign this contract was made with the press and public excluded and that, despite enquiries through various channels, none of our members have been able to see the contract in order to find out what we, as citizens of Aberdeen, have committed ourselves to.

The final strategy should contain a firm commitment to make the contract and the decision-making process open to public scrutiny.

While it is difficult to be certain due to the Council's refusal to make the waste contract with SITA public, we understand that the price per tonne paid to SITA will increase if the amount of waste delivered to them decreases. This would seem to create a disincentive to waste minimisation.

We welcome the creation of Aberdeen Forward and the recent work of the City Council's 'Clean and Green' officers. We think that the funding available to these should be increased. At present we understand that only the landfill tax recoverable by the City Council goes to Aberdeen Forward. This is money that is already reserved for environmental spending by the landfill tax system.

We welcome the intention to reduce total waste arisings. We hope that the City Council will be interested in the result of Aberdeenshire Council's Villages Project which has reduced residual waste arisings almost tenfold.

We welcome the Council's support of Instant Neighbour and believe that this support should be extended to other re-use projects.

Waste could be further reduced if the Council's waste collection worked more closely with Instant Neighbour or a similar body such as VSA. Re-usable furniture, for instance, is often thrown out in Aberdeen and is currently collected and landfilled by the Council. Council collectors could be given mobile phones and enabled to call Instant Neighbour or a similar organisation when they found items in good condition.

Aberdeen currently recycles 5.4% of its waste. We believe that effective recycling requires separation of waste at source. The final strategy should contain a commitment to investigate and implement, rather than only to investigate, kerbside collection methods for recyclables. We urge the City Council to learn from towns in Britain and overseas which have found ways of achieving this which are clean and easy for householders to use. Areas which have introduced such measures have found that a new 'waste culture' soon emerges, with people keen to separate and generally more aware of their waste. Despite comments from some parts of the Council, we believe that the people of Aberdeen are entirely capable of developing this culture if given the chance.

Along with recyclables, we believe that it is important that hazardous waste, such as household batteries, is separated out at source. The fact that the City Council has already brought in wheelie bins which are not designed for recycling is a problem, but one which can be worked around.

We also note that research has shown that recycling generates considerably more employment than energy-from-waste/incineration. Based on figures from the policy research group, Demos, in a town the size of Aberdeen about 122 permanent jobs would be created simply by collecting, sorting and bulking municipal waste. For Britain as a whole its reckoned that 15,000 jobs would be created in collection and sorting, and at least 25,000 to 40,000 jobs in manufacturing and reprocessing. Encouraging local recycling enterprises would create jobs in Aberdeen and reduce the energy used in transporting materials.

The waste strategy mentions a Materials Reclamation Facility, but no details of how this would operate are given in the document. We believe that this facility should be a 'clean MRF' dealing with separated waste rather than a 'dirty MRF', where recyclables are picked out of mixed waste. The jobs created by dirty MRFs are low quality jobs which are monotonous and hazardous. Rotting vegetable material and sharp cans make for unhealthy working conditions. Recyclate produced by such methods is generally of a lower value than clean recyclate.

We would like to see more ambitious targets for the accessibility of recycling facilities. The current 1km target is too far for those without cars. We would like to see the new Civic Amenity site in a more accessible location and are concerned at the proposal to build it on a site which is likely to have been contaminated by the previous incinerator.

Undertaking recycling projects is one way for community groups to raise funds for local projects. However, many such groups have had bad experiences of recycling projects due to being dependent on the fluctuating market value of the materials collected.

If well supported, community recycling projects offer the opportunity to fulfil the objectives of increasing recycling and of supporting communities and decreasing social exclusion at the same time. We would like to see a commitment to channelling landfill tax money to such groups, especially in deprived areas of the city.

The production of high quality compost requires the separate collection of compostable waste. The final strategy should contain a commitment to collect all putrescible waste for composting.

The decision-making process as to the technology and collection regimes used for composting must be open to public scrutiny.

We are extremely concerned at the proposal for a large waste incinerator: SITA representatives have told various public meetings that the capacity will be around 150,000 tonnes, with two burners.

A strategy based on the size of incinerator being proposed would be extremely inflexible and would leave the city unable to respond to new developments in technology and policy. The House of Commons Select Committee on waste has proposed an incinerator tax similar to the landfill tax. The EU is discussing binding targets for recycling, as opposed to diversion from landfill. By going for a system that represents the minimum progress up the waste hierarchy demanded by law and by spending a large amount of money on an incinerator sized to take all of the City's current waste arisings, we will leave ourselves in a very poor position to respond to future legislation. Sinking such a large amount of capital into one structure will also make it harder for the City to take advantage of future innovations in waste systems.

A large incinerator would require the import of waste from outside Aberdeen to run at capacity. This would lead to an increase in traffic in the area and violate the proximity principle. We are concerned that there will be little public control over the kinds of waste that the private operators of the facility will choose to burn.

We accept that in the short and medium term there will be a fraction of waste that is impossible to re-use, recycle or compost and that energy-from-waste is better than landfill. Any energy-from-waste element of the strategy should be no larger than is required for this fraction. It should also only be implemented in the form of Combined Heat and Power. This recovers 70-80% of the recoverable energy, as opposed to 30% for energy recovery alone. A smaller-scale approach would also make it easier to take advantage of technologies such as pyrolysis which may prove themselves in the future.

Putting mixed waste into a burner makes it very difficult to control the properties of the burn. It is also essential that hazardous waste is removed from the waste stream. At present there is nowhere in Aberdeen to take household batteries, which therefore end up in the waste stream. The City Council should also lobby central government for chlorinated plastics to be banned as these are a major source of dioxins in incinerators.

Some of the statements in the section on the Waste Hierarchy under 'The Future for Aberdeen City's Waste' are debatable and should not be included in the final strategy. The statement that EfW "reduces the impact on fossil fuel combustion processes" is open to question. If incinerators burn plastics, they are burning fossil fuels, and the incineration of recyclable waste results in fossil fuel energy being consumed in replacing those materials. Also, EfW/incineration should not be classed along with recycling and composting in the waste hierarchy. It comes below.

This section also claims that the residue may have recycling opportunities in the construction industry - we note that the Teeside plant was still sending the bottom ash from Cleveland to landfill in 1999. Also, the DETR says that glass and metal recovered post-incineration, as well as ash 'recycling', cannot be counted towards recycling totals.

Building a mass burn incinerator for mixed domestic waste also violates the precautionary principle. Bromo-substituted dioxins have been doubling in breast milk every five years since 1972. The EU considers these to be just as dangerous as chlorinated dioxins. These are currently not even measured for. There are serious doubts over the health impact of ultrafine particulate matter. Most particulate matter emitted from incinerators is ultrafine. The effects on human reproductive success and foetal development of PAHs are just beginning to be assessed.

The final strategy should contain a firm commitment that any energy-from-waste facility will take only sorted waste, will be sized to take only the fraction of Aberdeen's waste which remains after every effort to re-use, recycle and compost it has been made and will be in the form of combined heat and power.

As mentioned above, the final strategy should contain a firm commitment to the source separation of waste as this is crucial to the success of a sustainable waste strategy.

Education is of course essential, but will only work if people perceive a commitment to managing waste environmentally from central and local government. Otherwise, as in other areas, exhortations from government will generate cynicism rather than responsibility.

We welcome the Council's intention to carry out an internal waste audit and to develop an internal waste reduction plan.

The Council is a major buyer of some materials such as paper. The Council should use its buying policy to help to create markets for recycled goods. This is crucial since, for many materials, market support is even more important than collection in terms of supporting recycling. The final strategy should therefore contain a firm commitment to buying recycled goods.