the Wiltshire and Swindon Waste Local Plan – 2011 Consultation on Issues and Options and

addresses the problems associated with the siting of an Integrated Waste Management Facility

proposed within the "Area of Search" along the A36 corridor.

Specialist reports have been prepared by a Planning Consultant and by an expert on the

problems associated with incineration. These are enclosed. A separate report on incineration

prepared by Swindon Friends of the Earth is also enclosed.

This Group was established in January 2000 by residents of Whiteparish as a result of the

concern expressed by a large number of villagers to the siting of a proposed Waste

Management Facility on the outskirts of the village.

The Group has a constitution, chairman, committee and at present, some three hundred

members. Membership is growing on a weekly basis.

The Group meets on a regular basis and keeps the local community advised on developments

associated with the Issues and Options document and acts as a "Voice" and focal point for

objecting to the proposed Waste Facility.

The Group circulated notices regarding the two public meetings held in Whiteparish Village Hall

January 2000 which necessitated a follow up Public Meeting one week later, due to the large

number of people not being able to gain admittance into the hall at the first meeting.

The conclusions of this report can be summarised as follows:

3.1 There needs to be a national policy to minimise generation of household waste.

The conclusions of this report can be summarised as follows:

3.2 The division of the County into three areas is misguided, as with the possible exception of

Swindon, the areas generate insufficient waste to support the optimum means of disposal on a

commercial basis.

3.3 The "Proximity Principle" as currently applied is seriously flawed. There is no requirement set

by the Government or E.U. to a ten mile radius around Salisbury.

3.4 The ten mile radius as proposed involves a large area of Hampshire and therefore the area for a

possible Area of Search is halved.

3.5 The Salisbury districts secondary major settlements – Amesbury, Wilton and Mere exert a

combined demographic "pull" to the North and West, which is not accounted for in the way the

"Proximity Principle" has been applied.

3.6 Future housing development as indicated in the Salisbury District Local Plan will take place

almost exclusively to the North and West of Salisbury. To accord with the "Proximity Principle"

a waste facility needs to be near to the greatest generators of waste.

3.7 The area surrounding Whiteparish has already a high concentration of waste sites, there are

currently eight sites in the area.

3.8 Any new waste sites close to the County boundary will lead to further increases in importing

waste into the County, contrary to the criteria of the Waste Plan.

3.9 The A36 is already seriously congested on its access into and out of Salisbury.

Predicted figures indicate up to 200 additional lorry movements per day on the A36 and

surrounding roads.

3.10 No attempt has been made in determining the Area of Search for the use of rail to transport

waste. This is Government’s preferred option.

3.11 An Integrated Waste Management facility with energy recovery will be an industrial complex for

which a rural location is inappropriate. This should be on a brown field site.

3.12 The Government’s preferred option is for Combined Heat and Power Plants fuelled by waste.

Such a facility cannot be sustainable in a rural location.

3.13 Special sites of Scientific Interest (SSSI’s) and Protected Areas in the "Area of Search" have

been ignored.

3.14 Wiltshire County Council admit that they will have no control over the commercial operator

once a licence has been granted. Waste could be transported from anywhere.

3.15 The proposed Integrated Waste Management Facility would be westerly of Whiteparish. The

prevailing winds are westerly/south westerly. Pollution and smells would be inevitable.

3.16 Within the next five years it is probable that the New Forest Boundary will include the area

being proposed for the Integrated Waste Management Facility.

3.17 The Integrated Waste Management Facility would have a chimney polluting the area, the height

of which could be 80m.

– "Whiteparish has been dumped on enough".

The Whiteparish Preservation Group have considered the document with local and

professional expertise. This section provides answers to all the questions below, with positive

constructive suggestions.

We would like to thank Jean Saunders Swindon Friend of the Earth for some detailed

information as well as members from the Whiteparish Preservation Group.

We believe that "The Wiltshire & Swindon Waste Local Plan 2011" is inaccurate, refers to

previous and out of date legislation and guidelines and does not take up "a way for waste" as

issued by the DETR in 1998 and subsequently on 21 July 1999. Any council who omits to

use the way for waste document and guidelines is showing basic mal-administration in

fulfilling its obligations to the community it serves for waste management.

Indeed the 2011 document focuses too much on the end result of waste and not enough on the

prevention and EC and DETR objectives.

All but 3 questions out of 55 are closed so that a points system can be validated in favour of

the policies suggested. The principles are waste management biased and therefore we feel

that the WCC is either omitting or not putting due consideration of the environment and

quality of life in Wiltshire as the over-arching objective. We see this document as a direct

deception to the public and it does not provide an adequate consultation and options

discussion document to meet the issues.

The methodology of selection is flawed and the admission that vital information was not

considered including SSSIs, part of New Forest, Botanical knowledge from previous

planning.

We therefore expect nothing less than the area of search to be withdrawn and a consideration

of an alternative as suggested in section 4.3 below.

The following is detailed consideration of each section and question.

4.1.1 This section is extremely out of date and I would refer you to "a way for waste" issued

in 1998 by the DETR and revised in July 1999. Section 2.2.2 suggests 75/442/EEC as

amended is the document, but indeed there are two further documents 91/156/EEC and an

adaptation 96/350/EC which totally supersedes this document. Indeed there are several other

important documents as identified in a way for waste section 6.4 and Part 2c the document

fails to identify.

4.1.2 Section 2.2.3 speculates that reductions in landfilling of biodegradable municipal waste

will have to be reduced. However, this is more to do with the packaging being created than

how it is disposed of which clearly the document should have emphasised.

4.2.1 Again this section is out of date and shows ignorance against a way for waste

document. Therefore this section is currently invalid. Section 2.3.3 BPEO used is a 1996

document that has since been updated and amended see Part 2c a way for waste. We would

also suggest that PPG23 now PPG23a and PPG10 are under a considerable change process

and can as they say only be used as guidelines not as policy documents.

Principle answer NO

4.3.1 The reason we answer NO, is that we fundamentally disagree with the way WCC have

interpreted the EC proximity principle guideline identified in a separate section of this

document. There should be an over-riding set of principles that protect the environment and

the quality of life. This will eventually cause less cost and more benefit. Bad planning of

waste management to accommodate the needs of the operators or those that have to discharge

their duties is seen as mal-administration by any authority, ultimately ending up in a higher

cost. This has been attempted before by several councils who have ended up shutting down

many incinerators across the country because they are either dangerous or cannot meet the

standards, never fundamentally checked at the time of commissioning.

4.3.2 We are sure you will agree that Wiltshire is very different from many other counties in

that it has very little heavy industrial industry, is sparsely populated and contains a great deal

of MoD land. Thus there are only a few "brown field sites" and we would argue that many of

these are not true ones.

4.3.3 The solution therefore is to look at negotiating with other counties and through the dTI

and DETR. The emphasis should be to control the creation of waste and ensure that this

waste will naturally decompose. This means to make EC targets, the government must

legislate to stop the kinds of packaging and waste creation that the Environmental Agency is

woefully lacking in containing after the horse has bolted. All other kinds of waste should be

transferred by rail to other counties such as the Mendips or other really hazardous waste areas

that are already polluted.

4.3.4 For Salisbury District Council the current process is to transfer waste from Thorny

Down to Compton Bassett with this taking an average of 4 or less lorry loads per day. If

waste creation was reduced or maintained then transferring to say Marchwood incinerator

now in the planning stage or even a minimum increase in landfill say at Porton Down or East

Chitten would be sufficient and meet the sustainability principles which clearly the Area of

Search at the A36 would not.

4.3.5 We do not support these principles but would add the PRECAUTIONARY

APPROACH as a key guide-line. The Precautionary Principle: was established in the 1990

White Paper on the Environment, 'This Common Inheritance', and subsequently endorsed in

the UK Sustainable Development Strategy, Agenda21/The Rio Declaration, and the

Government's guidance on risk assessment and management.

4.3.6 The precautionary approach is explained in PPG23 (paragraph 1.12): The

Environment White Paper stressed that the Government's approach to pollution issues is a

precautionary one. Where there are significant risks of damage to the environment, pollution

controls will take into account the need to prevent or limit harm, even where scientific

knowledge is not conclusive. This "precautionary" principle applies particularly where there

are good grounds for judging either that action taken promptly at comparatively low cost

may avoid more costly damage later, or that irreversible effects may follow if action is

delayed".

Again there must be an overarching set of principles that maintain the environment and the

quality of life before you consider these waste principles alone.

4.4.1 Paragraph 2.7.11 - the least favoured option on the ladder should be amended to

reduce the plan's need for "final disposal" rather than an emphasis on landfill/landraise which

would also be reduced as a result of the aim. Landfill waste can generate energy. Final

disposal will be to landfill or to the atmosphere.

4.4.2 Paragraph 2.7.13 states that as far as recycling, composting and energy recovery are

concerned "each has an equal place in the hierarchy". This statement is inaccurate and we

strongly object to its inclusion in the Plan. Energy recovery is viewed below the ranking of

the other two options in Government strategy. It states in paragraph 2.7 of A way with waste

- a draft waste strategy for England and Wales (Part one - June 1999, DETR) in the section

that examines the waste hierarchy:

4.4.3 Within this framework "Less Waste: More Value" proposed that incineration with

energy recovery should not be considered without consideration first being given to the

possibility of composting and material recycling. This approach to the hierarchy received

widespread support, with the overwhelming majority who expressed a view agreeing with the

Government’s suggestion. The Government therefore reiterates its support for the waste

hierarchy, within which recycling and composting should be considered before recovery of

energy from waste.

4.4.4 As such Government strategy should be reflected in the Plan and is clearly not

4.5.1 Key objective 5 - paragraph 2.7.18 is "to reduce the adverse impacts of waste

management on the natural and built environment and on people's quality of life" which we

would assume would include health considerations.

4.5.2 Question 3 relates to residential amenity and, as such, the list could be extended to

include other matters that are highlighted under air, water and land quality elsewhere in the

consultation document but which also relate to health risks.

4.5.3 The obligation under the Waste Management Licensing Regulations (Paragraph

4(1)(a), Schedule 4, Waste Management Licensing Regulations 1994, SI. 1994/1056) is to:

"ensure that waste is recovered or disposed of without endangering human health and

without using processes or methods which could harm the environment and in particular

without -

4.5.4 There are no questions regarding sustainable options for waste management with

regard to public health. As such we suggest that this matter is added to the policy area in

question.

4.6.1 Although rail is mentioned there is absolutely nothing in this document that shows how

rail will be utilised. We refer you to our answer in section 4.3. A revision therefore needs to

be made to actually show and demonstrate how rail would be utilised.

4.6.2 For each of the designated areas identified for waste management including the area of

search no mention has been made of how these set of principles would be fulfilled.

4.7.1 These principles are biased towards waste management not the maintenance of

agricultural land. If they were used for building houses we would have no agricultural land

left?

4.7.2 In the case of Salisbury District as an example agreement should be made based on the

operation of the Local Plan, which should supersede any waste management objectives. It is

clear that the local authority will have a greater understanding than at the Wiltshire level,

especially for agricultural land.

4.8.1 Again this policy is too biased towards waste management and should be maintained

and counselled using the area’s Local Plan. The erosion of the Green belt both for housing

and movement to brown field should not be dealt with or even suggested by WCC in this

document. This policy is made at governmental level and with the DETR and should be kept

separate from any waste planning.

Again there must be an over-arching principle that protects the environment and the quality

of life. What happens when you reach the bottom of the hierarchy? By applying this

criterion you have chosen an inappropriate area of search for Salisbury District. Again we

refer you to our answers in section 4.3. The way these principles are written they are too

biased towards waste management.

4.10.1 We support the proposal to allow for different levels of protection dependent on the

designated status of the site and, we would add, that candidate sites would receive similar

protection. We would also include a policy that protects endangered species (and their

habitats) under the Biodiversity Action Plan that do not necessarily fall into the policy area

proposed by Q11.

4.10.2 However we object to paragraph 3.9.2 regarding SPAs and SACs that states "waste

management proposals will only be permitted where they do not adversely affect the site’s

integrity". This conflicts with the EU Birds and Habitats Directives that calls for ultimate

protection against development of internationally designated sites.

4.10.3 Note that the European Commission announced on 11 January 2000 that the UK is to

be targeted with further infringement actions over failure to comply with the 1992 EU

Habitats Directive. A court case will be launched against Britain for failure to nominate a

complete list of areas to become part of the Natura 2000 network of protected sites. The UK

have only nominated 340 sites to become part of the Natura 2000 network. The EU

executive complains that the list is insufficient. This applies to "nearly half" the relevant

endangered habitat types and wildlife species listed in the 1992 directive, based on the

presence of which a full list of sites should have been nominated by 1995. It is likely that

more SSSIs of biological importance will be brought forward to meet the Directive. As such

policies for SSSIs designated for their wildlife quality should be afforded the protection of

internationally protected sites.

4.10.4 The UK is proposing new legislation under the Wildlife Bill that is, as yet, to be

drafted. This will ensure that SSSIs are offered greater protection against damage. The Plan

should reflect that there is future guidance in the offing to increase protection and

enhancement of the UK’s best wildlife sites.

4.11.1 Surely, this demonstrates WCC previous lack of commitment to waste management.

We cannot see how you can blight areas and put forward proposals unless you have a good

handle on what you are managing.

4.11.2 For Salisbury District a figure of 55000 tons has been mentioned but neither does the

document offer statistics or suggest target tonnage year on year until 2011. This again shows

ignorance within this document.

4.11.3 Again section 4.4 is woefully out of date with no information being produced for some

4 years ago.

4.11.4 Recycling facilities are behind in the United Kingdom but even more so in Wiltshire,

accounting for less than 13%. Yet, there is no real submission in this document for how this

will be addressed.

4.11.5 Figure 4.3 Location of Landfill/Landraise Sites at June 1999 shows Whiteparish Chalk

Quarry and Moor Farm as Large sites- Non Inert Waste. In fact, Whiteparish Chalk Quarry is

only licensed for inert waste and Moor Farm is not licensed but has planning for inert waste

of a non-hazardous nature. Neither are large sites.

This section kindly supplied by Jean Saunders Friends of the Earth Swindon:

4.12.1 We believe that the waste reduction targets are not only achievable but could be

exceeded and draw attention to good practice elsewhere that is used without promoting

energy recovery. It is well documented that waste diversion (recycling plus composting)

rates are rising rapidly across the Western World, with national rates now reaching over 30%

in the U.S. and Germany. At the state and city level, the trend toward ever-higher rates is

even clearer. In the U.S., 7 states with a total population of over 55 million residents now

have rates of over 40% and there are similar numbers from German states as well. At the city

and county/region level, the leading jurisdictions are now above 50%, 60% and even 70% -

e.g. Alachua County, Florida (population 182,000) is at 74%;

between 65%-75%;

above 60%; and the cities of Seattle, Washington and San Jose, California (populations

totalling over 1,300,000) are both at 50%.

4.12.2 What can be seen over the last decade's development of recycling and composting is a

process whereby smaller towns and cities lead the way in testing new techniques, thus

proving that higher rates are possible and cost-effective with the new systems, before they are

taken up on a wider regional and national scale. In the same way - but with a significant time

lag - the UK's national rate of 8% is expected to begin its climb toward higher rates, now that

smaller U.K. communities, such as Wye in Kent (60%) and Bury-St. Edmonds (40%) are

showing the way. For example recent applications of more intensive recycling and

composting techniques in London have lifted its rate from 6% to nearly 12% in a year.

4.12.3 In contrast, the share of all waste managed through both incineration and landfill is in

decline. 'Energy From Waste' rates in the U.S. have fallen from 12% to 9%, and landfill rates

have fallen from 80% to 61% whilst recycling rose from 8% to 30% over the past decade.

4.12.4 This same process can be seen by looking at the recycled percentage in major

manufactured materials, as the expansion and conversion of these industries must proceed

apace in order to reprocess these materials. World steel production is already more than 50%

from recycled scrap/cans/etc.; and world pulp and paper production now uses more than 40%

recycled content.

4.12.5 The size of the recycling and composting industry have grown accordingly and

nations which have aggressively pursued the path of waste diversion have reaped enormous

economic gains. e.g. A November 1997 report from Dresdner Kleinwort Benson found that

the revamped German waste/recycling industry not only employed more than 150,000

employees, and was not only larger than "sectors such as telecommunications and

engineering" but that it now "dwarfs the retail and steel sectors." This massive, world-wide

transformation has not only changed the face of waste management, it has changed many

material manufacturing sectors, and it has brought large-scale, measurable economic benefits

to nations such as Germany, the U.S. and Canada.

4.12.6 On the waste reduction front, similar progress has been made, with the German

producer responsibility legislation stimulating remarkable reductions in packaging; and the

Canadian Packaging Protocol achieving its goal of 50% recycling, reuse and reduction by

1996.

4.12.7 Most of the figures above are not just for household waste, but include large sections

of other waste streams. The process of change tends to focus on residential waste because: it

is the most publicly visible portion of the waste stream. However for each tonne of consumer

packaging there is, on average, 10-20 tonnes of waste created in its

mining/logging/reprocessing stages.

4.12.8 Dozens of detailed household waste composition studies recently completed in

London have found that more than 40% of waste is classified as "easily recyclable"; with

nearly another 40% classified as "compostable". The remaining 20% is made up of materials

which can be re-used, recycled using more complex systems, reduced through producer or

consumer changes, or which must be disposed of.

4.12.9 Waste coming through other channels and from other sectors is actually easier to

divert. For example, large amounts of green waste are taken to Civic Amenity Sites and it is

largely clean of other contaminants. A diversion system for these materials is therefore quite

simple: good site management to control where materials are dropped; containers for the

source-separated material; a transportation system; and a composting site somewhere within

hauling distance.

4.12.10 Another example is office waste, 70%-90% of which is office paper. The

"Green Workplace" system developed in Ontario requires very little separation by staff, and

has been found to achieve 70%-90% diversion very rapidly. Two pilot local authority

buildings in Bexley and Haringey, London, implemented a basic version of this system in

1997, and achieved 63% and 70% measured diversions from their first week.

4.12.11 At the level of industrial waste, large-scale diversion can be even more rapid

and more cost-effective, for a number of reasons. Such firms tend to have very large

quantities of materials flowing through; in-house staff with time and responsibilities which

enable a concentrated approach to change; a clear financial benefit, both from reducing waste

disposal costs, but more importantly from increasing productivity and reducing purchases of

material inputs. While there are thousands of industrial examples to choose from world-wide,

the Green Industrial Analysis and Retrofit Programme in Ontario produced 80% reductions in

solid waste, along with 20% energy savings and 30% water use reductions, for a minimal

cost, and with paybacks to the firms involved of less than 18 months.

4.12.12 Construction and demolition waste is a major portion of U.K. waste going

to landfill by tonnage - although rather less important in terms of its potential negative

environmental effects. The Danes appear to be the world leaders in transforming this waste

stream, as they have now reduced it by more than 70%. These materials can be reused onsite,

recycled for use elsewhere, crushed at central sites, etc.

4.12.13 The changes taking place in the non-residential sectors can perhaps be best

illustrated by looking at some of the global firms in California, where front-line

media/entertainment companies such as Disney and Warner Brothers have now put in place

recycling systems to rival those of more obviously "green" firms such as Xerox. In an

increasingly global economy, and with corporate access to leading-edge information soaring

as a result of the internet's growth, companies everywhere can benefit almost instantly from

techniques and systems developed anywhere.

4.12.14 We hope we have demonstrated what can be achieved without a reliance on

incineration. As such we support the suggested policy areas in Chapter six although we

believe that there should be more attention paid to kerbside collection potential and

community composting.

4.13.1 We refer specifically to the current 62% imports and the location of the designated

areas. This policy would allow operators to justify location based on imports. Indeed

we feel that the area of search A36 has been specifically chosen to enable the operator

to benefit from imports from boundaries of Hampshire and Dorset.

4.13.2 Emphasis should be on reducing imports and as said by WCC officials this cannot be

policed.

4.14.1 The EC directives that mention proximity do not mention such small areas. Indeed

they talk of regions, which for the UK include England, Wales, Scotland and Northern

Ireland. They do not seek a smaller designation.

4.14.2 Wiltshire is not a big area especially when you take the use by the MoD of the land

available.

4.14.3 We believe that sticking to false boundary areas causes more problems than looking at

a topology based on rail or where the fossil fuels may be least impacted.

4.14.4 Future developments of housing and infrastructure may cause such designations to be

false and indeed if there is no commitment to a large integrated waste facility is not

necessary.

4.15.1 The major issue is that Wiltshire County Council in this proposal do not understand

the fundamentals of waste management and are not making enough investment in really

understanding what needs to happen. Learnings from other councils and overseas

demonstrate that there are other methods and ways of managing waste, but WCC has not

investigated these to have a degree of knowledge to tackle some of the problems identified in

this section.

This section kindly submitted by Jean Saunders Friends of the Earth Swindon.

4.16.1 In order that the land-use strategy is successful, it also needs to be flexible and to

allow communities and businesses to adjust. Waste management systems can change

dramatically as new best practice options come on stream. A reliance on a system with

massive start-up capital costs (such as mass-burn technology) can fail as a result.

4.16.2 For example most London Boroughs have chosen to start with weekly, kerbside

collections using an open-top box. This system allows instant feedback to households on

quality control, enables the community to make recycling a regular part of their lives,

produces visible and tangible results, and doesn’t require expensive centralised MRFs to start.

They are already achieving participation rates of 60%-90% across London, from Hackney to

Hounslow. Over time, more materials can be added to the boxes, the number of separate

categories operatives sort materials into can be reduced as MRF capacity is built, etc.

4.16.3 Some composting systems are similar in that they are quite easily managed by

households with gardens, and can produce large-scale diversion at very low cost to the local

authority. More complex and expensive kerbside collection of organics can then be

considered for the remainder, once system are set in place, and the public well-educated in

the importance of keeping materials clean.

4.16.4 It also needs to be noted how quickly systems can change. The speed with which a

city or county can change its waste management practices is much faster than a decade ago,

when most systems were being created from scratch. The first kerbside boxes, MRFs and

multi-compartment vehicles were created less than 15 years ago. Nowadays, many variants

on these systems exist and are readily available. They are backed up with detailed training

and promotional materials, and markets are growing daily. Some small communities in

North America are now able to go from minimal recycling rates all the way to 60%-70%, in a

matter of less than 2 years.

4.16.5 Nonetheless, the U.K. is just now beginning its period of explosive growth in the

recycling sector, with a whole range of pieces being put in place, and it is inevitable that

these will require more time than just 24 months to be fitted together. These tools include:

small electric collection carts for urban areas; new paper mill expansions in Bridgewater,

Shotton and Aylesford; steady planned increases in disposal taxes; the new Producer

Responsibility and Packaging Recovery Note (PRN) schemes; landfill tax rebates; new

doorstep collection methods for estate housing; new office recycling systems; expanded

central composting sites and markets; the availability of training and employment subsidies

through the New Deal; etc.

4.16.6 In other words, recycling and composting in the U.K. is entering a period of

extremely rapid growth - similar to that found in Germany and Canada and the US from

1986-1995 - and communities can look forward to a wide range of economic, environmental

and community gains, but it will probably take any community 2-3 years to first reach 25%,

then another 3-5 to reach beyond 50%. Each community in the U.K. will probably follow a

slightly different timeline, and use somewhat different methods - but together, the momentum

and critical mass required for Britain to catch up and even surpass the results from other

nations now appears to be coming into place.

4.16.7 We believe that energy savings should be explored further under transport. For

example the segregated recovery of waste is more efficient in energy and resource terms than

bulk recovery followed by dirty MRF' recovery or bank collection. The benefits of kerbside

collection schemes include:

recycling purposes and providing authorities with the best price from waste

merchants

See section 4.3 above

4.19.1 We do not believe that technically any Integrated Waste Management Facility is a

going concern unless it can replace a power station. Again we refer you to the detailed

Coopers & Lybrand report submitted and Annexed summary in the way for waste document.

This suggests that integrated waste facilities will only be viable when the basic packaging and

collection of mixes of waste has been carried out. That generally takes more time and

investment up front, but often leads to not needing such facilities.

4.19.2 This leads to 55,000 tons and going down for Salisbury in an small area which is

environmentally rich and only transporting 4 lorries daily to Compton Bassett. We would

submit without high levels of imports and against some of the earlier policies, this would not

be economically viable and would dramatically affect the environment and quality of life for

Salisbury.

4.19.3 We believe we have answered this in section 4.3.3. The solution therefore is to look at

negotiating with other counties and through the dTI and DETR. The emphasis should be to

control the creation of waste and ensure that this waste will naturally decompose. This means

to make EC targets, the government must legislate to stop the kinds of packaging and waste

creation that the Environmental Agency is woefully lacking in containing after the horse has

bolted. All other kinds of waste should be transferred by rail to other counties or to the

Mendips or other really hazardous waste areas that have already polluted areas.

4. 19.4 For Salisbury District Council the current process is to transfer waste from Thorney

Down to Compton Bassett with this taking an average of 4 or less lorry loads per day. If

waste creation was reduced or maintained then transferring to say Marchwood incinerator

now in the planning stage or even a minimum increase in landfill say at Porton Down or East

Chitten would be sufficient and meet the sustainability principles which clearly the Area of

Search at the A36 would not.

types of areas listed above? NO

4.22.1 Again the over-arching principle should be towards the environment and the quality of

life principles. Existing facilities being upgraded to take on non inert substancies means a

complete new planning and discovery cycle. Current legislation and the Environmental

Agency do not have a positive track record for upgrading existing sites.

4.22.2 The principle should be to plan and discover how to fulfil this need not to blinding

upgrade or focus on upgrading existing sites.

4.24.1 Firstly, the area of search as identified contains part of the New Forest Heritage Area

in the Titchborn barns lower left corner. Within the next five years it is likely that the

New Forest boundary will most likely include this area

4.24.2 The SSSIs protected areas in the area of search have been ignored. WCC officers have

admitted that they had omitted 3 SSSI’s for Dean Hill in the preparation of this

document.

4.24.3 Most of the development of Salisbury is happening North of Salisbury.

4.24.4 See Botanic response, but several applications have been rejected due to rare wildlife

in this area

4.24.5 Transportation see response, but there is no rail that could be utilised in this area.

4.24.6 Officers of WCC have admitted that they cannot control importing waste and the area

of search represents an optimum location to attract imported waste at a far greater

tonnage than required for the Salisbury area to make the site economically viable.

4.24.7 The proposed facility would be westerly of a village with a population of 1500 people

and some 6000 in the area. The prevailing winds are westerly/south westerly,

pollution would therefore be unavoidable. This is currently being seen with the lack

of commitment and resolution by the Environmental Agency to gaseous odours from

the existing Biffa site. This also demonstrates the non control of policing capability of

WCC after an installation is operational

4.24.8 An integrated waste management facility is a factory and an industrial complex for

which a rural location is inappropriate. This should be located on a brownfield site

and in an industrial location and is contrary to the Local plan.

4.24.9 All residents of Whiteparish and the immediate areas object strongly to any such

facility and are supported by Robert Key MP, Gerard Downes WCC, Roger Duncan

SDC, Trevor King PC.

4.24.10 The method of reaching the area of search is suspect. See section

The solution therefore is to look at negotiating with other counties and through the dTI and

DETR. The emphasis should be to control the creation of waste and ensure that this waste

will naturally decompose. This means to make EC targets, the government must legislate to

stop the kinds of packaging and waste creation that the Environmental Agency is woefully

lacking in containing after the horse has bolted. All other kinds of waste should be

transferred by rail to other counties or to the Mendips or other really hazardous waste areas

that have already polluted areas. For Salisbury District Council the current process is to

transfer waste from Thorny Down to Compton Bassett with this taking an average of 4 or less

lorry loads per day. If waste creation was reduced or maintained then transferring to say

Marchwood incinerator now in the planning stage or even a minimum increase in landfill say

at Porton Down or East Chitten would be sufficient and meet the sustainability principles

which clearly the Area of Search at the A36 would not.

4.26.1 You have not used a detailed sustainability criteria as outlined in this document in

Appendix 22. Your suggested preferred area options and facilities must have explicit

justifications which the officers have neither identified nor justified. We cannot

comment on existing facilities, but it is clear that the officers have not used

sustainability criteria and this section is seen as providing a less comprehensive

methodology.

4.26.2 We would see the WCC as committing mal-administration if it adopted this policy.

on designated employment land be resolved. No Comment

appropriate? NO. What are your views on the criteria suggested for assessing

such proposals

4.28.1 Again there must be an over-arching environmental and quality of life set of

principles. The ‘do’, no matter the consequences as proposed in this policy does not

resolve the real issues.

4.28.2 We would strongly object to a policy containing clause 1 or 3 which had no real

planning and discovery process. We refer you to section 4.3

4.49.1 A way for waste identifies that legislation and forthcoming legislation which will

make this an obligation.

Please read our critique of mass-burn incineration with energy recovery section. We

maintain our strong objection to this.

It is clear the officers of WCC are not qualified to make such proposals.

Section 7 provides different ways of waste disposal. The majority are neither

environmentally friendly nor technically viable. I refer specifically to incineration, anaerobic

digestion, gasification, and pyrolysis. The latest not mentioned being anaerobic degradation.

Each of these methods is suspect in that it relies heavily on getting the waste into a state

where what you burn or what is provided is non toxic. We are a light year away from this in

Wiltshire at this point in time and should focus more on the earlier stages of waste

management to ensure the waste created contains no toxins or dioxins. This can only be done

with co-operation with the government.

4.52.1 Until the technology which still in its infancy is proven we cannot consider supporting

such a proposal.

4.53.1 We share concerns about the restoration of mineral workings with waste. This would

depend on the nature of the waste, the porosity of the mineral worked and the proximity to

groundwater vulnerability zones.

4.53.2 We are totally opposed to the disposal of untreated waste to mineral voids in

permeable geological strata that can lead to contamination of groundwater. It is impossible to

adequately engineer a landfill liner (either man-made material or of clay) to contain waste

and prevent pollution. Friends of the Earth can provide you with a critique of landfill liners if

you are interested. As such we support the WPAs move to restrict non-inert materials going

to landfill - this reflects EU policy.

4.53.3 We are extremely concerned of the ability of the Environmental Agency to upgrade

licenses without the appropriate public consultations as has happened at the Whiteparish

Chalk Quarry. We are really concerned with the existing odours and the lack of management

or control from Biffa, the EA and WCC.

4.54.1 The submission by CSG of Whelpley Farm Landraise within the proximity of the Area

of Search and was withdrawn by CSG, but still rejected by WCC. We would expect the

reasoning to be applied to all landraise sites.

4.55.1 Please clearly look at a way for waste document and look specifically at the EC

legislation. We would suggest that all special waste should be exported from Wiltshire via

rail.

4.56.1 We support the suggested policy area but suggest that the majority of land-use

planning relevant to special waste (as identified in the legislation) is subject to Environmental

Impact Assessment. The definition in the EIA regulations refers to the "deposit" of special

waste and this includes temporary storage and waste transfer. We attach a copy of a letter

from GOSE (5 May 1995) that directed that an EIA should accompany a proposed waste

transfer station at Culham, Oxfordshire tat would handle small amounts of special waste.

Environmental Impact Assessment - this is a policy area that we believe has been omitted

and which requires attention.

4.58.1 We do not see WCC having created a WPA that is capable of fulfilling such duties.

When the WPA has the right capability, is certified and regulation is considered then we

would be able to comment.

5.1 "‘The Proximity Principle’ as defined in the Department of Environment Transport and the

Regions (DETR) document "A Way with Waste – A Draft strategy for England and Wales – Part

One" dated June 1999 states, (item 2.8)

"The proximity principle suggests that waste should generally be disposed of as near to

its place of production as possible. As Less Waste: More Value explains, this is in part

to ensure that problems are not simply exported to other regions or countries. It also

involves recognition that the transportation of wastes can have a significant

environmental impact. A network of facilities would enable these environmental impacts

– and in many cases financial costs - to be reduced. The Government reiterates its

support for this principle".

5.2 In the "Wiltshire and Swindon Waste Local Plan 2011 – Consultation on Issues and Options"

document section 2.7.9 states

….."In practise, the Proximity Principle may result in some waste being imported into

the Plan Area, particularly to sites that are close to the County or Borough Boundaries".

5.3 In Section 2.7.5 it states:

"It is important to consider the management of waste flexibility, so that flows of waste

across administrative boundaries are accommodated where this is the most sustainable

option. The Plan Area is also at the periphery of the South West Region and therefore

some waste is imported from nearby areas within the South East Region".

5.4 Section 2.7.6 states:

….. "Facilities that would primarily serve other counties should only be permitted where

this is the most sustainable option".

5.5 Section 4.4.6 states:

….." In the Salisbury Area, 62% of the waste deposited in licensed landfill/landraise

sites is currently imported from outside the Plan Area. In the Plan Area as a whole,

28% of deposited waste is imported". Whiteparish Preservation Group

A considered response to Wiltshire and Swindon Waste Local Plan 2011

Consultation on Issues and Options

Report/February 2000

5.6 If one considers the "Area of Search" South East of Salisbury along the A36 corridor the

immediate observations are:

5.6.1 The Area of Search is close to the Hampshire border and as 62% of waste in the Salisbury area

is imported from Hampshire, then any Integrated Waste Facility is ideally situated to

accommodate imported waste in order for a facility to be a "sustainable option".

5.6.2 The majority of household waste generated in the Salisbury area must be in areas of the

greatest housing density. Present and planned housing development is to the North East of

Salisbury.

In order to accord with the "Proximity Principle" therefore, "in order to minimise the impact of its

transportation on the environment " (Section 2.7.8 of "Issues and Options") the area of search

should be to the North and North East of Salisbury. This would also alleviate the number of

vehicle movements on the already congested A36 to the South East of Salisbury converging on

the College Roundabout.

5.7 At meetings held at Whiteparish and Landford, Wiltshire County Council representative’s state a

radius of 5-10 miles from the centre of Salisbury for the transportation of waste. No mileage

radius is given in the DETR document "A way with Waste", this is purely a WCC figure and

could, as acknowledged by WCC representatives, be extended to cover an area west of

Salisbury.

6.1 Wiltshire County Council state in answer to a letter from residents of Whiteparish that

……"in 1 year the people of Salisbury generate approximately 50-55,000 tonnes of

household waste per year. This amounts to roughly 19 dust cart loads of rubbish per

day".

6.2 At all of the presentations WCC representatives stated that this annual tonnage of waste was all

that was being considered for disposal by an Integrated Waste Facility within the area of search.

However, as already stated above in items 5.3 and 5.4 in order for a facility to be a "sustained

option" then it may accept waste from "across administrative boundaries".

If this were the case then a facility in excess of handling 55,000 tonnes per annum would be

built.

6.3 In Appendix 3 of the Issues and Options document the Area of Search between Alderbury and

Newton states "Potential Uses:

"An integrated waste management facility is proposed, possibly including composting,

landfill and energy recovery".

At all of the public meetings at Whiteparish and Landford this has been stated and re-stated.

6.4 Considering energy recovery, section 7.2.10 of the Issue and Options document states:

"Incineration without energy recovery is not generally considered to be an acceptable

method of waste management. However, where it includes energy recovery it is a more

sustainable option".

6.5 The DETR document "A Way with Waste" states in Chapter 2:

6.6 In the DETR document "A Summary of the Responses of Less Waste more Value" (June 1999)

it states (P22):

"Many respondents urged that when considering incineration with energy recovery

facilities combined heat and power (CHP) schemes should be followed, as should

plants which fully segregate waste, removing any recyclables prior to burning. Tax

incentives could be offered to achieve this end

6.7 Speaking at the Combined Heat and Power Association industry annual conference at the end

of November 1999 the Environment Minister, Michael Meacher, said that "CHP – which

generates both heat and electricity, usually from the incineration of waste material – is a win-win

situation for Britain. Meacher said that industry will win because power from CHP can be

cheaper than from conventional sources. Lower costs mean lower prices for the consumer and

the environment wins because burning waste means less landfill, less waste, less pollution and

more chance of this country honouring its Kyoto Protocol goals".

The subject of less pollution is debatable, a subject which we will cover in more detail later in

this document.

6.8 An article which appeared in Professional Engineer on 9 December 1998 states:

"The CHP market has strengthened its position greatly over the past decade. Since

1988, the UK’s CHP capacity has doubled to close on 4,000MW. That equates to a

£500 million saving in energy costs and a reduction in CO2 emissions of some five

million tonnes a year".

"Meacher believes CHP’s potential is still largely untapped and wants to see those

figures double again over the next 10 years, to the stage where CHP supplies two-thirds

of all industrial electricity".

"According to a survey undertaken by the Environmental Technology Support Unit,

ETSU, CHP certainly seems to possess the potential to deliver the goods. ETSU

claims CHP could generate up to 10GW of power by 2010".

"This is, Meacher admits, going to demand a serious amount of capital investment - £5

billion if ETSU is correct – but the government has thrown its backing heavily behind the

CHP initiative so long as proposed plants meet certain criteria. First, any plant has to

attain a significantly higher level of efficiency – well over 70% in most cases – than a

conventional coal or nuclear plant. The second criterion is that nearby heat uses are

clearly identified, and third, a CHP plant should have an in-built flexibility to be able to

export spare electricity".

"Meacher reassures companies considering CHP units that the Government will

undertake to provide long-term access to fair market prices"

Also in the 12 January 2000 Professional Engineer an article on "Beyond the Emission

Statement" states:

"The Government plans to introduce a range of "regulatory, fiscal and other policy

instruments, including the climate change levy" to promote the take-up of CHP plants as

well as to encourage business to use energy more efficiently. The levy is an additional

tax on business use of gas, coal and electricity. The debate continues as to what the

rate of levy should be and the Government’s decision will be announced in the 2000

finance bill, which is expected in April".

"Use of renewable energy sources is the obvious choice to decrease CO2 emissions

and the Government wants them to provide 10% of UK electricity supplies by 2010. In

1998 they accounted for 2.6% of the UK’s electricity and an interim target of 5% has

been set for 2003. That would require 1998 levels to almost double in five years. Large

scale hydro generation schemes made up the bulk of this sector in 1998, while other

large renewable sources were landfill gas and municipal solid waste combustion, up

29% and 45% respectively on 1997 figures".

"Until the recycling market is strong enough, waste will have to be incinerated", says the

Department of the Environment, Transport and the Regions. "Everybody has to take

more ownership of their waste. This way we can make it a resource and get some

energy out of it, as well as reducing landfill and cutting down on methane".

6.9 In the DETR document "A way with Waste" Chapter 3, item 3.13 states:

….." The scale of the challenge is crystallised in the new Landfill Directive, which sets

targets for diversion of biodegradable municipal waste from Landfill. In 1995, we

landfilled around 85% of the 27 million tonnes of municipal waste we produced. By

2020 the UK will need to divert at least 6 million tonnes of waste from landfill, and if

arisings continue to grow, as much as 33 million tonnes".

Item 3.14 states:

….."Meeting this challenge will require substantial increases in recycling, composting

and recovery of energy from waste".

Item 3.19 states:

….."The Regulatory Impact Assessment for the Landfill Directive suggested that,

assuming recycling at 25%, around 8-33 million tonnes of incineration capacity (this

equates to 28-165 new incinerators, assuming an average capacity 200,000 tonnes)

might be needed to meet the final target in the Directive (to reduce biodegradable

municipal waste to 65% of 1995 arisings).

The goal proposed in this draft strategy is for a third of household waste to be recycled by 2015.

Even at that level, modelling suggests that around 8-26 million tonnes capacity (40 – 130 new

incinerators averaging 250,000 tonnes) might be needed".

An Integrated Waste Management facility as proposed handling 50-55,000 tonnes of waste will

not meet the Governments aspirations for a renewable energy strategy as a plant of such size

would only export into the National Grid approximately 3MW of electricity, enough to feed 5,000

homes.

6.10 From a commercial viewpoint, this size of plant is not viable and therefore in order to meet the

Governments targets as outlined above, pressure will be exerted for a facility to be in excess of

55,000 tonnes per annum, probably as outlined in item 6.9) this will be 200,000 tonnes per

annum. All evidence as stated above points to this in order for a facility to be a "sustainable

option".

6.11 As stated earlier in item 6.6) respondents to the DETR document "A summary of the Response

of Less Waste More Value" stated that CHP plants should be favoured and as can be seen by

items 6.7) and 6.8) this is the Governments preferred option also.

If this is the preferred option then where will the generated surplus heat from an Integrated

Waste Management facility in the rural countryside go to? Also where will the generated power

go to as the existing 11kV and 33kV networks in the Area of Search may not be capable of

accepting power from rotating generating plant.

If such a facility is to be commercially considered then this should be on a "brown field" site

which is not in the "Area of Search", so that exported heat and power can be usefully used.

For a new CHP plant to be viable then it needs to be part of a planned development for new

housing or commercial properties where the surplus heat can be utilised.

6.12 Two salient factors arise in considering added value to a facility for exporting heat and power.

Capital cost and consistency of heat source and demand. In the Area of Search a substantial

domestic or business/commercial district heating scheme would be required. Both have a

marked seasonal profile which limits revenue and would require reversion to direct cooling in the

summer months.

6.13 At the public meetings in Whiteparish and Landford the WCC representatives also suggested

the energy recovery could be obtained by emerging technologies such as Pyrolysis and

Anaerobic Digestion.

6.14 In ‘A way with waste’ – part two published by the DETR in June 1999 chapter 4.0 item 4.55

states:

6.15 With regard to anaerobic digestion item 4.57 of chapter 4.0 states:-

6.16 In a paper published by Hampshire County Council on Project Integra, it states that facilities

below 100,000 tonnes per year are not economic for mass burn incineration and that plants for

Gasification and Pyrolysis are expensive and these technologies have to establish a sound track

record of performance at commercial scales of operation, which is in excess of 100,000 tonnes

per year. Whiteparish Preservation Group

6.17 Considering the above therefore, the new emerging technologies for energy recovery at a

commercial operation, have yet to be established and that at the moment there is only one

sustainable option to meet Government guidelines. This is incineration, or if Pyrolysis is

considered, the burning of tyres.

6.18 The mention therefore by WCC representatives of consideration of new emerging technologies

for an ‘Integrated Waste Management System’ with energy recovery is futile.

6.19 In chapter 4 of ‘A way with waste’ – part two states, item 4.43 "Incineration without energy

recovery of power or heat is categorised as waste disposal and is not an option that the

Government would generally wish to encourage as part of a move towards greater sustainability"

6.20 Unless the A36 corridor adjacent to the New Forest Heritage Area is going to be developed into

an industrial area complete with housing, which is completely out of the question, then the

positioning of an Integrated Waste Management System facility with energy recovery located in

the Area of Search is completely in the wrong place. It should be on a brown field site. There is

no brown field site in the Area of Search.

6.21 In Section 4.0 of the "Issue and Options" document item 4.6 it states for Central and West

Wiltshire Area:

"Large volumes of waste will have to be re-cycled, composted or recovered for energy if

targets are to be met".

For the Salisbury Area (Item 4.6.5)

__ "Very high levels of imported waste – currently 62% of total recorded waste deposited in

1996/97".

__ "Volumes of waste required to be recycled, composted or recovered for energy to meet

targets will be lower than in the other two areas".

6.22 If the volume of waste for Salisbury is lower than the other two areas and as Central and West

Wiltshire Area require large volumes of waste to be "recycled, composted or recovered for

energy if targets are to be met", is there not an argument for combining Salisbury, Central and

West Wiltshire which will accord with the "Proximity Principle". Whiteparish Preservation Group

A considered response to Wiltshire and Swindon Waste Local Plan 2011

Consultation on Issues and Options

Report/February 2000

6.23 A facility strategically situated West of Salisbury serving Salisbury, Central and West Wiltshire

could:

a) accord with Proximity Principle

b) give opportunities for rail transportation

c) reduce vehicle movements

d) give sustainability to a commercial facility.

If the above points are considered a totally different centre-point for the application of the

"Proximity Principle" will be reached (perhaps not far from the existing site at Chitterne which

has capacity for expansion). A facility in this position would best serve West Wiltshire, Kennet

and the Salisbury District.

7.1 An Integrated Waste Management facility with energy recovery will require a chimney or "stack"

which would be the dominant feature of the plant. Stack profile and structure is governed by

ground conditions and wind loadings. The stack height and diameter are a function of efflux

velocity and mass flow dictated by the boiler design and also the local topography.

Likewise the size of a plant is dictated by the sizes of boiler, turbines, heat exchangers etc.

7.2 The standard design reference for stacks is HMIP’s (now the EA) Technical Guidance Note 01

– "Guidance on Discharge Stack Heights for Polluting Emission". This guidance note is based

on the requirements of the Environmental Protection Act 1990. The guidelines are concerned

with the plume dispersion over the local topography and incorporate adjustment factors to

theoretical minimum height to account for local features such as hills (Pepperbox and Dean Hill)

valleys, flat areas, buildings or other structures.

7.3 For sites where there are no adverse topographical features one would expect a minimum stack

height of 40 to 50 metres based simply on the need to ensure that the plume does not linger or

migrate to ground level. For a facility in excess of 100,000 tonnes per annum located within the

Search Area the stack height would be in the range of 80 – 100m.

7.4 What we are now talking about is a large industrial complex with a chimney height of 80m plus

in a rural environment close to the New Forest, the National Trust site at Pepperbox Hill and

several SSI sites. Is this really the way forward in such a rural sensitive position?

8.1 With any facility incorporating Integrated Waste Management System with energy recovery will

come the problems of daily vehicle movements.

8.2 A facility with energy recovery will require to be in operation twenty four hours a day, seven

days a week in order to feed it, or in the case of a plant accepting deliveries five/six days a

week an area large enough to store waste.

8.3 Studies have shown a 200,000 tonne plant will attract 200-250 vehicle movements a day

involving HGV lorries.

Likewise the lorry movements for a 100,000 tonne plant will be 100-125 and for a 50,000 tonne

plant 50-60 (not 19 as stated by WCC representatives).

Figures published for the South East London Combined Heat and Power Plant (SELCHP) which

is a 400,000 tonne capacity plant indicate 400 vehicle movements per day.

8.4 The A36 is already heavily congested as everyone using the road daily from West Wellow to

Salisbury can vouch for. Additional HGV traffic of 200-250 movements per day will create even

more problems in pollution, congestion and also safety.

8.5 The positioning of an Integrated Waste Management facility along the A36 corridor will

therefore generate major and unacceptable traffic congestion.

Traffic will also use the A27 from Romsey through Sherfield English and Whiteparish. The

‘Street’ in Whiteparish is not wide enough to take large articulated lorries carrying waste from

Hampshire or even further afield.

Common Road in Whiteparish is the location of the village school, lorries would be tempted to

divert down Common Road to the A36. Common Road is already congested at School start

and finish times, further traffic will endanger the lives of the schoolchildren.

A riding stable is also located along Common Road which has already had one bad experience

with an HGV vehicle.

8.6 In Chapter 5 of Wiltshire and Swindon Waste Local Plan 2011 – Consultation on Issues and

Options it states in item 5.1.1.

"Locating waste management facilities where they have suitable access to the transport

network including potential opportunities for rail transport".

Also in item 3.7.2 it states:

"The volume of road transport can be reduced by encouraging the use of more

sustainable forms of transport such as rail to transport waste…."

The DETR document "A way with Waste" parts one and two also encourage the use of rail to

transport waste.

8.7 Within the "Search Area" there is no such opportunity to transport waste by rail.

Surely every effort must be made to find a site that can be served easily by rail in order to cut

down the pollution of HGV lorries and the number of vehicles on our roads. No effort has been

made in determining the "Area of Search.

8.8 In the Issue and Options document it states in Section 5 item 5.1.10:

"Government policy and Wiltshire Structure Plan policies support alternative modes of

transport to road. In Wiltshire and Swindon the most realistic alternative for waste

transportation is likely to be rail, although water may also be an option. The WPAs

consider that potential opportunities for the transport of waste by rail should be a factor

when identifying suitable areas for waste management. Applicants should consider the

potential to transport waste using rail as an alternative to using the road network".

8.9 No such consideration for rail transportation has been given in choosing an "Area of Search"

around the A36 corridor.

Swindon Friends of the Earth are generally in support of the proposed policy areas proposed

by the Waste Planning Authorities. We believe that in order to plan for more sustainable

waste management there needs to be flexibility in the Plan. The UK lags behind many other

countries who have achieved far higher recycling and composting rates which we describe in

response to question 21. As such we would urge caution against suggesting options that

involve great initial capital expense and might have limited value in the long term. Waste

management policy is changing rapidly. Recycling is put at a disadvantage by a change in

the market value of a waste material. However the intrinsic value of the material with regard

to resource use remains constant and markets can change overnight.

We have already submitted a written response to the key issues summary booklet and an

extensive critique of mass-burn incineration with energy recovery to which we are

vehemently opposed. We have explored a few of the questions raised in the main

consultation document where we feel that we can make useful comment.

1.1 We support these principles but would add the PRECAUTIONARY APPROACH as

a key guide-line. The Precautionary Principle: was established in the 1990 White Paper on

the Environment, 'This Common Inheritance', and subsequently endorsed in the UK

Sustainable Development Strategy, Agenda21/The Rio Declaration, and the Government's

guidance on risk assessment and management.

1.2 The precautionary approach is explained in PPG23 (paragraph 1.12): The

Environment White Paper stressed that the Government's approach to pollution issues is a

precautionary one. Where there are significant risks of damage to the environment, pollution

controls will take into account the need to prevent or limit harm, even where scientific

knowledge is not conclusive. This "precautionary" principle applies particularly where there

are good grounds for judging either that action taken promptly at comparatively low cost

may avoid more costly damage later, or that irreversible effects may follow if action is

delayed".

2.1 Paragraph 2.7.11 - the least favoured option on the ladder should be amended to

reduce the plan's need for "final disposal" rather than an emphasis on landfill/landraise which

would also be reduced as a result of the aim. Landfill waste can generate energy. Final

disposal will be to landfill or to the atmosphere.

2.2 Paragraph 2.7.13 states that as far as recycling, composting and energy recovery are

concerned "each has an equal place in the hierarchy". This statement is inaccurate and we

strongly object to its inclusion in the Plan. Energy recovery is viewed below the ranking of

the other two options in Government strategy. It states in paragraph 2.7 of A way with waste

- a draft waste strategy for England and Wales (Part one - June 1999, DETR) in the section

that examines the waste hierarchy:

Within this framework "Less Waste: More Value" proposed that incineration with energy

recovery should not be considered without consideration first being given to the possibility of

composting and material recycling. This approach to the hierarchy received widespread

support, with the overwhelming majority who expressed a view agreeing with the

Government’s suggestion. The Government therefore reiterates its support for the waste

hierarchy, within which recycling and composting should be considered before recovery of

energy from waste. .

2.3 As such Government strategy should be reflected in the Plan.

3.1 Key objective 5 - paragraph 2.7.18 is "to reduce the adverse impacts of waste

management on the natural and built environment and on people's quality of life" which we

would assume would include health considerations.

3.2 Question 3 relates to residential amenity and, as such, the list could be extended to

include other matters that are highlighted under air, water and land quality elsewhere in the

consultation document but which also relate to health risks.

3.3 The obligation under the Waste Management Licensing Regulations (Paragraph

4(1)(a), Schedule 4, Waste Management Licensing Regulations 1994, SI. 1994/1056)is to:

"ensure that waste is recovered or disposed of without endangering human health and

without using processes or methods which could harm the environment and in particular

without -

3.4 There are no questions regarding sustainable options for waste management with

regard to public health. As such we suggest that this matter is added to the policy area in

question.

10.1 We support the proposal to allow for different levels of protection dependent on the

designated status of the site and, we would add, that candidate sites would receive similar

protection. We would also include a policy that protects endangered species (and their

habitats) under the Biodiversity Action Plan that do not necessarily fall into the policy area

proposed by Q11.

10.2 However we object to paragraph 3.9.2 regarding SPAs and SACs that states "waste

management proposals will only be permitted where they do not adversely affect the site’s

integrity". This conflicts with the EU Birds and Habitats Directives that calls for ultimate

protection against development of internationally designated sites.

10.3 Note that the European Commission announced on 11 January 2000 that the UK is to

be targeted with further infringement actions over failure to comply with the 1992 EU

Habitats Directive. A court case will be launched against Britain for failure to nominate a

complete list of areas to become part of the Natura 2000 network of protected sites. The UK

have only nominated 340 sites to become part of the Natura 2000 network. The EU

executive complains that the list is insufficient. This applies to "nearly half" the relevant

endangered habitat types and wildlife species listed in the 1992 directive, based on the

presence of which a full list of sites should have been nominated by 1995. It is likely that

more SSSIs of biological importance will be brought forward to meet the Directive. As such

policies for SSSIs designated for their wildlife quality should be afforded the protection of

internationally protected sites.

10.4 The UK is proposing new legislation under the Wildlife Bill that is, as yet, to be

drafted. This will ensure that SSSIs are offered greater protection against damage. The Plan

should reflect that there is future guidance in the offing to increase protection and

enhancement of the UK’s best wildlife sites.

21.1 We believe that the waste reduction targets are not only achievable but could be

exceeded and draw attention to good practice elsewhere that is used without promoting

energy recovery. It is well-documented that waste diversion (recycling plus composting)

rates are rising rapidly across the Western World, with national rates now reaching over 30%

in the U.S. and Germany. At the state and city level, the trend toward ever higher rates is

even more clear. In the U.S., 7 states with a total population of over 55 million residents now

have rates of over 40% and there are similar numbers from German states as well. At the city

and county/region level, the leading jurisdictions are now above 50%, 60% and even 70% -

e.g. Alachua County, Florida (population 182,000) is at 74%;

between 65%-75%;

above 60%; and the cities of Seattle, Washington and San Jose, California (populations

totalling over 1,300,000) are both at 50%.

21.2 What can be seen over the last decade's development of recycling and composting is a

process whereby smaller towns and cities lead the way in testing new techniques, thus

proving that higher rates are possible and cost-effective with the new systems, before they are

taken up on a wider regional and national scale. In the same way - but with a significant time

lag - the UK's national rate of 8% is expected to begin its climb toward higher rates, now that

smaller U.K. communities, such as Wye in Kent (60%) and Bury-St. Edmonds (40%) are

showing the way. For example recent applications of more intensive recycling and

composting techniques in London have lifted its rate from 6% to nearly 12% in a year.

21.3 In contrast, the share of all waste managed through both incineration and landfill is in

decline. 'Energy From Waste' rates in the U.S. have fallen from 12% to 9%, and landfill rates

have fallen from 80% to 61% whilst recycling rose from 8% to 30% over the past decade.

21.4 This same process can be seen by looking at the recycled percentage in major

manufactured materials, as the expansion and conversion of these industries must proceed

apace in order to reprocess these materials. World steel production is already more than 50%

from recycled scrap/cans/etc.; and world pulp and paper production now uses more than 40%

recycled content.

21.5 The size of the recycling and composting industry have grown accordingly and

nations which have aggressively pursued the path of waste diversion have reaped enormous

economic gains. e.g. A November 1997 report from Dresdner Kleinwort Benson found that

the revamped German waste/recycling industry not only employed more than 150,000

employees, and was not only larger than "sectors such as telecommunications and

engineering" but that it now "dwarfs the retail and steel sectors." This massive, world-wide

transformation has not only changed the face of waste management, it has changed many

material manufacturing sectors, and it has brought large-scale, measurable economic benefits

to nations such as Germany, the U.S. and Canada.

21.6 On the waste reduction front, similar progress has been made, with the German

producer responsibility legislation stimulating remarkable reductions in packaging; and the

Canadian Packaging Protocol achieving its goal of 50% recycling, reuse and reduction by

1996.

21.7 Most of the figures above are not just for household waste, but include large sections

of other waste streams. The process of change tends to focus on residential waste because: it

is the most publicly visible portion of the waste stream. However for each tonne of consumer

packaging there is, on average, 10-20 tonnes of waste created in its

mining/logging/reprocessing stages.

21.8 Dozens of detailed household waste composition studies recently completed in

London have found that more than 40% of waste is classified as "easily recyclable"; with

nearly another 40% classified as "compostable". The remaining 20% is made up of materials

which can be re-used, recycled using more complex systems, reduced through producer or

consumer changes, or which must be disposed of.

21.9 Waste coming through other channels and from other sectors is actually easier to

divert. For example, large amounts of green waste are taken to Civic Amenity Sites and it is

largely clean of other contaminants. A diversion system for these materials is therefore quite

simple: good site management to control where materials are dropped; containers for the

source-separated material; a transportation system; and a composting site somewhere within

hauling distance.

21.10 Another example is office waste, 70%-90% of which is office paper. The "Green

Workplace" system developed in Ontario requires very little separation by staff, and has been

found to achieve 70%-90% diversion very rapidly. Two pilot local authority buildings in

Bexley and Haringey, London, implemented a basic version of this system in 1997, and

achieved 63% and 70% measured diversions from their first week.

21.11 At the level of industrial waste, large-scale diversion can be even more rapid and

more cost-effective, for a number of reasons. Such firms tend to have very large quantities of

materials flowing through; in-house staff with time and responsibilities which enable a

concentrated approach to change; a clear financial benefit, both from reducing waste disposal

costs, but more importantly from increasing productivity and reducing purchases of material

inputs. While there are thousands of industrial examples to choose from world-wide, the

Green Industrial Analysis and Retrofit Programme in Ontario produced 80% reductions in

solid waste, along with 20% energy savings and 30% water use reductions, for a minimal

cost, and with paybacks to the firms involved of less than 18 months.

21.12 Construction and demolition waste is a major portion of U.K. waste going to

landfill by tonnage - although rather less important in terms of its potential negative

environmental effects. The Danes appear to be the world leaders in transforming this waste

stream, as they have now reduced it by more than 70%. These materials can be reused onsite,

recycled for use elsewhere, crushed at central sites, etc.

21.13 The changes taking place in the non-residential sectors can perhaps be best illustrated

by looking at some of the global firms in California, where front-line media/entertainment

companies such as Disney and Warner Brothers have now put in place recycling systems to

rival those of more obviously "green" firms such as Xerox. In an increasingly global

economy, and with corporate access to leading-edge information soaring as a result of the

internet's growth, companies everywhere can benefit almost instantly from techniques and

systems developed anywhere.

21.14 We hope we have demonstrated what can be achieved without a reliance on

incineration. As such we support the suggested policy areas in Chapter six although we

believe that there should be more attention paid to kerbside collection potential and

community composting.

22.1 We have sympathy with the planning authorities with regard to dealing with spare

capacity in landfills and pressures to accept waste from outside the County. However the

forthcoming landfill legislation that will ban the disposal of putrescible waste should ensure

that more green/paper/agricultural/sewage waste etc is disposed of by composting/anaerobic

digestion or, in the case of paper, by recycling by the relevant authorities.

22.2 The landfill levy is now having a positive and marked effect on reducing, for

example, construction waste to landfill.

22.3 Whilst we support the proximity principle, it is only fair that Wiltshire should

anticipate that they will provide for final disposal of some waste from outside the County

albeit at a lower level than in the past.

24.1 In order that the land-use strategy is successful, it also needs to be flexible and to

allow communities and businesses to adjust. Waste management systems can change

dramatically as new best practice options come on stream. A reliance on a system with

massive start-up capital costs (such as mass-burn technology) can fail as a result.

24.2 For example most London Boroughs have chosen to start with weekly, kerbside

collections using an open-top box. This system allows instant feedback to households on

quality control, enables the community to make recycling a regular part of their lives,

produces visible and tangible results, and doesn’t require expensive centralised MRFs to start.

They are already achieving participation rates of 60%-90% across London, from Hackney to

Hounslow. Over time, more materials can be added to the boxes, the number of separate

categories operatives sort materials into can be reduced as MRF capacity is built, etc.

24.3 Home composting systems are similar in that they are quite easily managed by

households with gardens, and can produce large-scale diversion at very low cost to the local

authority. More complex and expensive kerbside collection of organics can then be

considered for the remainder, once system are set in place, and the public well-educated in

the importance of keeping materials clean.

24.4 It also needs to be noted how quickly systems can change. The speed with which a

city or county can change its waste management practices is much faster than a decade ago,

when most systems were being created from scratch. The first kerbside boxes, MRFs and

multi-compartment vehicles were created less than 15 years ago. Nowadays, many variants

on these systems exist and are readily available. They are backed up with detailed training

and promotional materials, and markets are growing daily. Some small communities in

North America are now able to go from minimal recycling rates all the way to 60%-70%, in a

matter of less than 2 years.

24.5 Nonetheless, the U.K. is just now beginning its period of explosive growth in the

recycling sector, with a whole range of pieces being put in place, and it is inevitable that

these will require more time than just 24 months to be fitted together. These tools include:

small electric collection carts for urban areas; new paper mill expansions in Bridgewater,

Shotton and Aylesford; steady planned increases in disposal taxes; the new Producer

Responsibility and Packaging Recovery Note (PRN) schemes; landfill tax rebates; new

doorstep collection methods for estate housing; new office recycling systems; expanded

central composting sites and markets; the availability of training and employment subsidies

through the New Deal; etc.

24.6 In other words, recycling and composting in the U.K. is entering a period of

extremely rapid growth - similar to that found in Germany and Canada and the US from

1986-1995 - and communities can look forward to a wide range of economic, environmental

and community gains, but it will probably take any community 2-3 years to first reach 25%,

then another 3-5 to reach beyond 50%. Each community in the U.K. will probably follow a

slightly different timeline, and use somewhat different methods - but together, the momentum

and critical mass required for Britain to catch up and even surpass the results from other

nations now appears to be coming into place.

24.7 We believe that energy savings should be explored further under transport. For

example the segregated recovery of waste is more efficient in energy and resource terms than

bulk recovery followed by dirty MRF' recovery or bank collection. The benefits of kerbside

collection schemes include:

recycling purposes and providing authorities with the best price from waste

merchants

It is difficult to predict waste arisings and disposal in Wiltshire (particularly if Wiltshire is a

net importer of waste). Predictions could fall short as government targets and the landfill

levy regulations bite deeper. The latter has had a significant impact on construction waste

(1995-6) as Fig 4.1 of the consultation document shows. However we are concerned that

high GDP per head of population is also a significant factor in generating more waste. Poor

people throw away less waste than rich, particularly if the nil waste minimisation/recycling

option is included.

We do not wish to comment at this stage on the suitability of the preferred areas for the waste

management options. This requires detailed study of the areas concerned and Environmental

Impact Assessment of the waste management option selected. We might well support

anaerobic digestion at the site selected in West Wiltshire or in Area of search for Salisbury

but not incineration with energy recovery. Similarly anaerobic digestion in conjunction with

sewage waste could be a viable option for Barnfield Road/Sewage Treatment Works in

Swindon. We might support landfill on clay but not on mineral workings of chalk, gravel and

sandstone. We are likely to support a MRF in conjunction with landfill management or a

local recycling/composting centre that reduces the need to travel and makes use of a

brownfield site.

With regard to Swindon, we agree that multiple sites are required in order to reduce travel

under the current system. However if kerbside collection of separated waste from

commercial premises and households is implemented, then Barnfield Road site has the

greatest potential for development of a MRF and the preferred sites at Faraday Road and

Radway Road may not be required.

Please read out critique of mass-burn incineration with energy recovery previously

submitted. We maintain our strong objection to this.

We agree the suggested policy area for other energy recovery systems and this should include

landfill - it doesn’t need to be a separate policy area. Include support for heat recovery as part

of combined heat and energy recovery where appropriate.

We support the suggested policy area (see 45). Mention potential of direct heat use locally

(ie combined heat and power).

We share concerns about the restoration of mineral workings with waste. This would depend

on the nature of the waste, the porosity of the mineral worked and the proximity to

groundwater vulnerability zones.

We are totally opposed to the disposal of untreated waste to mineral voids in permeable

geological strata that can lead to contamination of groundwater. It is impossible to

adequately engineer a landfill liner (either man-made material or of clay) to contain waste

and prevent pollution. We can provide you with a critique of landfill liners if you are

interested. As such we support the WPAs move to restrict non-inert materials going to

landfill - this reflects EU policy.

The Environment Agency believe that landraise is preferable to landfill. Contamination of

groundwater is easier to control and detect. We tend to agree in view of our concerns about

using filling mineral voids with active wastes (Q47).

We support the suggested policy area but suggest that the majority of land-use planning

relevant to special waste (as identified in the legislation) is subject to Environmental Impact

Assessment. The definition in the EIA regulations refers to the "deposit" of special waste

and this includes temporary storage and waste transfer. We attach a copy of a letter from

GOSE (5 May 1995) that directed that an EIA should accompany a proposed waste transfer

station at Culham, Oxfordshire tat would handle small amounts of special waste.

Environmental Impact Assessment - this is a policy area that we believe has been omitted

and which requires attention.

Thank you.

Yours sincerely

Jean Saunders

Co-ordinator

Enc