Warrington Clinical Waste Treatment Centre Appeal Proposed Outline Evidence of Alan Watson

Residual Commercial and Industrial Waste

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18.Residual Commercial and Industrial Waste:

    1. The WCS makes provision for the recovery of between 43,000 – 73,000 tonnes/year of C&I waste diverted from landfill by 2020. The WCS makes no distinction between different types of recovery, nor, being a strategic document, does it consider details of the waste types or the specific suitability of waste for different processes.

    2. The Planning Statement76 states:

Gloucestershire also requires up to 200,000 tpa of new residual waste treatment capacity for C&I waste”.

    1. The Appellant says77: “The WCS takes a very simplistic approach to calculating the recovery capacity gap. Nonetheless UBB acknowledge that the Inspector examining the draft WCS accepted the Councils approach to estimating C&I capacity. However, he also noted, at para 42 of his report, that he did not consider that the figures presented in the WCS represented the actual arisings within the County for which the WCS should make provision i.e. he recognised that there was likely to be more C&I residual waste arisings in the county than the C&I residual waste recovery capacity figure stated in the draft WCS”.

    2. What the Inspector actually said was78: “I consider therefore that GCC has made the best use of the available data in these circumstances although I do not consider that it represents the arisings within the County for which the CS should make provision”. There is no suggestion that more provision needs to be made than is suggested in the WCS. This was made clear by the Inspector at the pre-inquiry meeting.

    3. It follows that CD1.6 §2.4.5 is not correct when it says:  “Clearly, in light of the above, the 375,000 tonne figure is not an accurate reflection of quantities of C&I waste produced in Gloucestershire. Conversely, the Defra National C&I Waste Survey data is used extensively in waste planning throughout England and is considered to give the most robust estimate of C&I waste arisings. Thus, the actual C&I waste arisings in Gloucestershire should be taken as 526,188 tonnes in 2009” [my emphasis]

    4. The appellant has, however, presented no evidence of the proportion of the currently landfilled C&I waste in Gloucestershire which would be appropriate for incineration nor has the appellant provided any justification to support the very long-term growth rate assumptions.

    5. It is well established that C&I waste is much more sensitive than MSW to price signals and can be shipped long distances for treatment and disposal. It is therefore very important that evidence is provided showing that any proposed facility would represent genuine provision for local waste. A good indicator of this is the willingness of an applicant to accept planning conditions or a planning obligation restricting any waste treated at a proposed facility to local wastes.

    6. In 2008 GCC included a table of the capacity of licensed waste facilities in Gloucestershire in the Preferred Options consultation79 for the waste core strategy.

    1. At that time it was suggested the arisings were:

Waste Stream

Base Year*

Total (‘000 tonnes)




C&I (including metals)



    1. Although Table 2 is quite confusing table it can be simplified so that the totals of the relevant capacity (in 1,000 tonnes) can be seen more clearly:

Waste Facility

MSW Capacity

C&I Capacity

Total Capacity

Windrow Composting




In Vessel Composting




Household Recycling Centres



C&I Re-use/Recycling



C&I Recovery/Treatment (including transfer)



Metal Recycling Sites







    1. It is apparent from this table that the commercial waste treatment capacity is very much greater than the arisings, even when the arisings were much greater than they are today. There is some uncertainty in relation to the 160,000 tpa transfer/ recovery capacity, but even in the extremely unlikely case that this was all transfer capacity then the commercial waste treatment capacity would still significantly exceed even the larger C&I arisings at that time.

    2. A significant proportion (41%) of the capacity was for metal recycling and it would have been helpful if this was better matched to local arisings by providing a more detailed breakdown and waste analysis of the commercial/ industrial waste arisings from Gloucestershire.

    3. There had been dramatic reductions in the quantities of waste disposed to landfill disposal in the county in the late 90’s (1996/97 data was not available) largely due to the landfill tax:

    1. In spite of the trend the WCS was based on the premise that there would be no further reduction in commercial and industrial wastes arisings. This approach was hard to understand at a time when disposal costs were rising at a much faster rate than at any time previously and when it was well known that commercial and industrial waste was far more sensitive to price changes that MSW.

    2. When the total non-inert, non-restricted landfill in Gloucestershire is plotted against with MSW landfill it can be seen that there has been a steady reduction in MSW landfill from about 229,000 tonnes in 2001 to c.150,000 tonnes last year – a reduction of about 35%. Whilst there is a slightly smaller proportional reduction in C&I the trend is much less smooth. It is clear from this data that the application80 is (and was then) wrong to claim that “Gloucestershire ….is presently sending nearly 500,000 tpa of waste to landfill”. Landfill in Gloucestershire has steadily reduced since 2009 and the total landfill is just over 300,000 tonnes. It is known that about 155,000 tonnes of MSW is being landfilled leaving around the same quantity of C&I waste currently being landfilled:

    1. This data is consistent with the latest updates from the Environment Agency showing that 299,000 tonnes of non-hazardous waste was landfilled in Gloucestershire in 2012. The MSW section above shows that just less than half of this was MSW after allowing for the c.8,500 tonnes of that was rubble which is included in the MSW totals:

    1. When plotted regionally, which removes much of the influence of waste travelling into and out of the region the trends are much more smooth and it is can be seen that the total tonnage of C&I waste landfilled in the whole region is about 1 million tonnes. If it was assumed that the C&I waste was landfilled in the same proportions as total waste throughout the region then The population of the SW region was 5,289,000 in 2011 and Gloucestershire 858,300 so if waste was landfill in a similar ratio to populations then approximately 160,000 tonnes would be landfilled from Gloucestershire. This validates well with the estimate from the county graph above.

    1. It can be seen from the latest Environment Agency data81 that of the 27.595 million tonnes of non-inert landfill capacity in the South West 21% (5.799 million tonnes) is in Gloucestershire. This disproportionately high capacity is likely to currently attract waste into the county from the North and from the Bristol area where there is a relative paucity of landfill capacity (1.459 million tonnes).

    2. The graph for England shows the reduction in C&I waste to landfill more smoothly still and again confirms that the total quantity of C&I waste to non-inert landfill is approximately equal to the quantity of MSW landfilled:

    1. It is also notable that there is no evidence of a reduction in the rate of the fall of landfill use. This is consistent with the HMRC data which shows how the UK has almost certainly already met the 2020 targets for diversion from landfill of biodegradable municipal waste82.

    1. The extended 2012/13 bar is not the waste landfilled in that year but a scaled indicator to help demonstrate the point at which the 2020 target would be met. This is when the trend line reaches the top of the hatched bar. The full data from which this is derived shows that 119 councils landfilled 5,216,000 tonnes of BWM against 2012/13 allowance of 7,377,000 tonnes for the those councils. Compared to 2020 target this is only 43,000 over allowance. They have beaten the 2019 target by 273,000 tonnes. Another way of looking at it is that at on 31 March 2013 the authorities were less than 2 moths away from meeting 2020 target assuming the trend line continues through 2013.

    2. The raw HMRC landfill tax data can also be used to show the profound reduction in the landfilling of both MSW and C&I waste. When the MSW is subtracted from the data it gives a clear indication of the dramatic fall in C&I residual waste over the past decade. This is, of course, expected as C&I waste is so price sensitive.

    1. Deducting the 8,776,000 tonnes of MSW landfilled in 2012 from the total standard rate tonnage shows that c.10,211,000 tonnes of C&I waste was landfilled nationally in 2012. It is notable that the HMRC data indicates less landfill than that from the Environment Agency. In principle the tax based data should be more accurate as it is more carefully audited. Furthermore any C&I waste which is being landfilled without payment of landfill tax is very unlikely to be diverted to an expensive incinerator as an alternative.

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