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



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8.The Waste Hierarchy


    1. Article 4 of the revised Waste Framework Directive 2008/98/EC (CD7.3) includes a hierarchy of options for managing wastes. This gives top priority to preventing waste in the first place. When waste is created, it gives priority to preparing it for re-use, then recycling, then other recovery such as energy recovery, and last of all disposal (for example landfill).

    2. The questions of sustainability are largely addressed in relation to the waste hierarchy through the Waste Strategy for England29, the DEFRA 2011 Review30 and PPS10.

    3. The Government also supports the waste hierarchy in relation to biomass and the UK Bioenergy Strategy31 which States32: “The amount of residual waste from municipal and commercial sources is expected to decline gradually to 2030 as policies to encourage better environmental and energy outcomes succeed (i.e. waste prevention, reuse and recycle)…”

    4. The Bioenergy Strategy promotes the maximizing of energy recovery “consistent with the waste hierarchy, and re-use for traditional and new wood products before energy recovery in order to promote sequestration”[p.58] and with energy recovery “only when other uses are exhausted or it forms the best environmental outcome”[p.58]. The use of end-of-life materials for energy can be an “optimum use of biomass”, whereit maximises carbon and cost effectiveness, and where it is consistent with the waste hierarchy” [p.8]. The use of “the entire tree for bioenergy is undesirable as it is generally associated with sub-optimal carbon scenarios and can result in increased greenhouse gas emissions” [p.30].

    5. PPS1033 states: “By more sustainable waste management, moving the management of waste up the ‘waste hierarchy’ of prevention, preparing for reuse, recycling, other recovery, and disposing only as a last resort, the Government aims to break the link between economic growth and the environmental impact of waste

    6. Finally it is noted that local authorities have a duty, under Regulation 12 of the Waste (England and Wales) Regulations 201134 to apply the waste hierarchy. Regulation 12 requires the waste hierarchy in Article 4 of the Directive to be applied as a priority order. If the appeal was to be granted then it would undermine the ability of the County Council to pursue its duty under Article 12, and in line with the DEFRA Guidance on the matter, pursuant to Article 15 of the Waste (England and Wales) Regulations 2011.

    7. Recovery of energy from waste currently landfilled in Gloucestershire would be just one step up the waste hierarchy from the current landfilling of residual waste. It is clear form the above, however, that EU, Government, and local Policy strongly encourages the treatment of waste as high as possible up the hierarchy.

    8. Waste which is burned for energy recovery cannot also be recycled, composted, reused or reduced. As it is essentially only plastics which can burn but not be composted or digested it is vital to ensure that residual treatment capacity, and particularly incineration, is sized so that the movement of waste up the hierarchy is not undermined – either because a) there waste is needed to ‘feed’ the incinerator; b) contractual arrangements effectively penalise the diversion of waste from the incinerator to better options; or c) the cost of the residual disposal dominates the waste treatment budget so that investment in more sustainable alternatives becomes unaffordable.

    9. Gloucestershire has not performed particularly well in diverting BMW from landfill. Nationally, however, the UK has done much better and has now almost certainly met the Landfill Directive’s 2020 diversion targets, certainly for municipal waste (see the ‘Need’ section below).

    10. The Landfill Allowance Trading Scheme (‘LATS’) has, in any case, become redundant and has been stopped. This removes many of the pressures which were previously placed on the authority – and particularly the possible burden of having to buy expensive LATS credits or to pay fines.

    11. This development allows breathing space to carefully consider more sustainable alternatives, as GCC is now doing through a committee looking at ‘Plan B’ alternatives to the incinerator. It also gives GCC the benefit of being able to match residual treatment capacity much more closely to the lower end of the waste need range to allow for higher recycling and waste reduction levels in the future. It is important to ensure, therefore that provision is made only for truly residual waste which cannot be reduced, recycled or composted over the operational life of any incinerator.

    12. This would be consistent with the WCS 'spatial vision'35 for waste management in Gloucestershire over the period to 2027:

The ‘residual’ municipal and commercial waste that cannot reasonably be re-used, recycled or composted is seen as a valuable resource that is likely to be managed through a number of waste recovery sites.

The Waste Hierarchy and the Circular Economy.

    1. The Europe 2020 Strategy and it’s flagship initiative on "A Resource Efficient Europe” has been driving a powerful resource efficiency agenda as outlined in European Commission communications COM(2011) 21 and 571. These communications make clear the imperative with regard to use of resources that will drive strategy and legislation: “The pressures on resources are increasing... Continuing our current patterns of resource use is not an option.”

    2. One of the measures identified to help deliver a resource-efficient Europe in this document firmly indicates the objective with regard to waste: “a strategy to make the EU a 'circular economy', based on a recycling society with the aim of reducing waste generation and using waste as a resource”. COM(2011) 571 presents a roadmap to a Resource Efficient Europe.

    3. This process progressed and on 24th May 2012 the European Parliament passed a resolution36 by a large majority37 on a “Resource efficient Europe” which sets Europe on a course towards zero waste.

    4. The resolution38 calls on the European Commission as a priority action to: “streamline the waste acquis, taking into account the waste hierarchy and the need to bring residual waste close to zero”, and to phase-out “by the end of this decade [2020] ... incineration of recyclable and compostable waste” and “to make proposals by 2014 with a view to gradually introducing a general ban on waste landfill at European level

    5. More recent work has refined the definition of the circular economy as one which : “seeks to rebuild capital, whether this is financial, manufactured, human, social or natural. This ensures enhanced flows of goods and services. The system diagram illustrates the continuous flow of technical and biological materials through the ‘value circle’39:



    1. The emphasis, consistent with the hierarchy is to minimise the use of energy recovery and landfill as waste treatment and disposal options.

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