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



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5. Need




    1. Government policy on the need for and development of new electricity generating infrastructure, including biomass fuelled generating stations, is set out in the overarching National Policy Statement for Energy46 and the National Policy Statement for Renewable Energy Infrastructure47, designated by the Secretary of State on 19th July 2011 under the Planning Act 2008. Nothing in this evidence should be taken as challenging the need for renewable generating capacity. It is clear that if the UK and EU targets are to be met then significant additional renewable generating capacity will be required.

    2. However this evidence does challenge the claims made by the appellant in relation to the availability of waste, and particularly waste generated in Gloucestershire, in sufficient quantities to meet the needs of this proposal.

    3. The proposed Javelin Park incinerator is designed to recover energy from 190,000 tonnes of Gloucestershire's residual waste. A key point at issue between GlosVAIN and UBB is the definition and assessment of future residual waste arisings. It is agreed that residual MSW and residual C&I Waste should be waste that is currently sent to landfill. There is less agreement about how the potential for increased reuse, recycling, digestion and composting should be taken into account in the assessment.

    4. I consider that Policy is more closely aligned with a definition whereby only waste which cannot reasonably be reused, recycled, digested or composted should be considered to be residual waste and this is clear from the WCS48. Similarly EN-1 provides that only waste that cannot be re-used or recycled with less environmental impact, and would otherwise go to landfill, should be used for energy recovery49.

    5. The alternative approach promoted by the appellant50 that “residual waste” is simply “waste that is not sent for reuse, recycling or composting” would means that the incinerator could certainly burn large quantities of reasonably recyclable waste contrary to the waste hierarchy and to policy. This has been the approach in other areas such as Hampshire with damaging consequence for recycling and composting. As a result of this approach Hampshire is struggling at the bottom of the county recycling league table (see below) and is constrained from improving by punitive contracts and the need to feed three waste hungry incinerators.

    6. It is hoped that lessons have been learned from these past mistakes and the appallingly low recycling rates which are found around many of the early incinerators including SELCHP – where the recycling rate for Lewisham was just 18.75% in 201251 - will be avoided in future. There remains, however, a serious risk that even the (now modest) 60% recycling target is put at risk by this proposal and that the WCS aspirations to achieve 70% would be doomed not only because of the need to feed the incinerator but because such a high proportion of the GCC budget is committed to the residual waste contract that promotion of more sustainable alternatives will be very difficult.

    7. The need for residual treatment capacity to divert waste from landfill and the size of any facility is essentially a function of:

  1. The quantity of residual MSW (i.e. waste that cannot sensibly be recycled or composted).

  2. The growth rate of this waste stream over the period being considered.

  3. If C&I waste is to be treated as well then the quantity of this waste which cannot reasonably be recycled or composted which can be secured by the facility may also be relevant, together with the growth rate for C&I waste.

  4. The level of relevant provision for treatment already made, or likely to be made, by others.

    1. I will address these issues in more detail below. Before doing so, however, it is important to consider the context and relevance of the Gloucestershire Waste Core Strategy52 (‘WCS’).

12.The Gloucestershire Waste Core Strategy


    1. The WCS covers the period 2012 to 2027 and was adopted on 21st November 2012. The WCS is the principal policy document in the Development Plan relevant to the proposed incinerator.

    2. This is important because even though the WCS has only recently been adopted the waste data upon which it is based is older, generally dating from before 201053. The approach adopted for data54 was that GCC “relied on the WDA for MSW arisings data”. This was a sensible approach in so far as the WDA holds the most reliable historic data about waste disposal. It presented some difficulties, however, given the clear agenda of the WDA has been to promote their residual waste contract and, as shown in the evidence of Sue Oppenheimer, this has meant supporting incineration over the period during which the WCS was developed. Furthermore the WDA has a demonstrably poor record of predicting future trends and I return to this below.

    3. There is now more recent information available about the trends in arisings and potential need for the treatment and disposal of local waste.

    4. One example would be the MSW recycling rate about which the WCS says55: “The rate achieved in Gloucestershire in 2009/10 was 42% so there is still some way to go”. The recycling rate is already c. 15% higher than this and so the gap has closed significantly. Perhaps even more significant are the now demonstrably incorrect assumptions about waste growth made by GCC and which underpin important aspects of the strategy. I will also return to this below.

    5. The capacity requirements identified by the WCS are summarised in Table 3:



    1. The WCS56 says that there is currently no residual waste recovery capacity in place for municipal waste and that; “Although the WCS will run for 15 years from adoption (to 2027), the WDA is looking to procure capacity from 2015 for a period of 25 years. The WDA currently estimate that provision needs to be made for between 112,000 – 170,000 tpa by 2040 of residual municipal waste (waste that cannot reasonably be recycled or composted)”.

    2. Whilst MSW is relatively well quantified and trends can readily be established from quarterly annual returns C&I waste is more difficult to assess, and presented a greater challenge for the development of the WCS. Not only are arisings less well measured than for MSW but simply providing capacity in a certain area will not provide for the needs of any local waste arisings. It may instead simply encourage ‘waste tourism’ with waste being shipped into Gloucestershire - possibly over very long distances.

    3. This would clearly be contrary to Policy WCS6 which requires that: “any proposals for waste recovery are for Gloucestershire’s waste needs unless it can be demonstrated, through a supporting statement, to be the most sustainable option to manage waste arisings from outside of the county at that facility”.

    4. There was no supporting statement with the application suggesting that waste from outside the county could be managed at the Javelin Park incinerator but it is disturbing that UBB are resisting a planning condition, consistent with WC6, restricting their waste to Gloucestershire. If they are confident about the need for the facility they should be happy to fully meet policy requirements of the WCS.

    5. The appellant indicates that from 2015 until 2025, which is approximately the period covered by the WCS, between two thirds and three quarters of the waste treated at the facility would be residual MSW i.e. 125,000 to 143,000 tonnes. The remainder - 37,000 to 65,000 tonnes - would be residual C&I waste. The proportion of residual MSW treated is then predicted to slowly increase.

    6. It is therefore necessary to carefully consider first the need for residual MSW treatment in the light of the most recent data and in the context of the WCS.




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