CPRE Logo           CPRE GLOUCESTERSHIRE BRANCH

POSITION STATEMENT ON WASTE INCINERATION

CPRE Gloucestershire Branch has drawn up this statement to set out its position on waste incineration as part of an overall strategy for managing waste in Gloucestershire, and its position on a possible major incinerator at Javelin Park.

Background

In April 2008 the seven local authorities in Gloucestershire (the County Council and the six District Councils) signed a Joint Municipal Waste Management Strategy. The time horizon is 2007 – 2020. The Strategy is guided by the principles of the Waste Hierarchy (described below) which CPRE fully endorses. The Strategy was produced as a Government requirement and covers the management of municipal waste. This is primarily (96%) household waste but also includes street litter and street sweepings; and some commercial waste.

Over the past ten years, the amount of municipal waste to be managed has increased by about 3% a year, although the rate of increase has decreased in the recent past. In 2006/07 the county produced 324,000 tonnes of municipal waste, of which 302,000 was household waste equating to 1,220kg per household. If waste continued to grow at 3% a year, the amount produced would double over the next 25 years. Upward pressures include population growth and smaller household sizes (smaller households produce more waste per capita than larger households).

In addition to municipal waste, commercial and industrial waste adds another 462,000 tonnes to the waste to be disposed of, although much of this is scrap metal. The need is to consider the totality of waste produced in the County in an holistic way and plan and manage accordingly. Any long term strategy should be addressing municipal, industrial and commercial waste, together with waste from construction, minerals operations and also hazardous waste. Gloucestershire County Council is partly addressing this need through its planning responsibilities where work is in progress towards Minerals and Waste Core Strategies as part of the Local Development Framework process, but more could be done. Waste is waste no matter where it originates, and municipal waste is a minority arising in terms of the total volume of waste being produced.

The immediate priority, largely dictated by European and UK government policy and cost considerations, is to dramatically reduce the amount of waste ending up in landfill sites. The EU Landfill Directive sets a strict and ambitious target for the diversion of biodegradable municipal waste (BMW) from landfill. By 2020 the intention is to reduce diversion to landfill to 35% of 1995 levels. To achieve this, landfill allowances (declining year on year) and a landfill allowance trading scheme have been introduced for England, and there are severe financial penalties on local authorities if targets are missed.

Currently, the majority of municipal waste in Gloucestershire is still deposited in landfill sites located in the County but more is now recycled or composted and the latest issue of Wastelines reports that the rate of recycling and composting in Gloucestershire reached 42% in the year ending March 2009 and an impressive rate of 61% in Cotswold District.

The Challenge

The challenge is to reduce the amount of waste produced in the first place across all sectors and to further increase the amount of waste that is re-used, recovered and recycled and to deal with the remaining waste in a way that minimises the amount that finally has to be dumped in landfill sites.

It is a concern that the Joint Municipal Waste Strategy only foresees growth in municipal waste being reduced to zero by 2020. Yet work for the National Assembly of Wales [ref1] looking at best practice shows that recycling rates for domestic waste can be as high as 90%. There are also indications that Government pressure is beginning to bring results, for example all supermarkets have announced programmes to reduce packaging. Given this background, we believe that Gloucestershire is not setting itself ambitious enough targets both to prevent further growth in waste and to further increase recycling rates.

Looking at various scenarios for municipal waste based on the 2006/07 figures:

  1. Were waste volumes to continue to grow until 2020, municipal waste would increase to about 400,000 tonnes per annum (tpa). At 2006/07 recycling rates this would imply some 272,000 tpa having to go to landfill or other disposal by 2020.
  2. Were waste volumes to continue to grow as above but recycling rates be increased to 60%, there would only be some 160,000 tpa to be otherwise disposed of.
  3. Were waste growth to be brought to zero by 2013 (i.e. in half the time envisaged by the local authorities), there would be only about 350,000 tpa of waste to be disposed of. At a 60% recycling rate this would reduce to 140,000 tpa.
  4. Increasing the recycling rate to 90% would reduce the amount to be otherwise disposed of to 40,000 tpa in the worst case.

CPRE is concerned that because the County Council is working on pessimistic scenarios for containing waste growth and for improving recycling rates it sees large scale incineration as an easy and essential option to achieve quickly major reductions in the amount of waste which needs to go to landfill. We believe this approach is misguided because it is financially and technically inconsistent with promoting waste minimisation or a best practicable environmental options strategy.

Once built, a large scale incinerator would need to be run continuously and fed with large amounts of waste to be financially viable. It would require a long term contact, which would have the effect of closing off alternative options for dealing with waste for many years ahead. This would provide a disincentive to further improve recycling rates, an excuse to maintain current levels of waste on the grounds that it was helping to provide renewable energy, and shut off consideration of advances in technology for treating waste which are bound to come forward. As a consequence, despite the possibility of some energy recovery, it is unlikely to lead to a significantly reduced carbon footprint. A large scale incinerator would also be difficult to accommodate in the county because of its environmental impact, in particular impacts on the landscape, impacts from vehicle movements, and possible issues around emissions.

Discussions about a possible incinerator at Javelin Park, considered below, indicate that the County Council envisage that up to 170,000 tonnes a waste a year could be processed through such a facility. As can be seen from the analysis above, in all but the most pessimistic scenario this would exceed the amount of municipal waste remaining for disposal to landfill. This is obviously an absurd situation.

The place of waste incineration as part of an overall strategy for managing waste

CPRE sees incineration as an essential element of long term waste disposal facilities in Gloucestershire but not through large scale incineration such as is envisaged at Javelin Park.


Incineration has to be seen in the context of the accepted waste hierarchy, namely:

  1. Minimising the amount of waste produced in the first place from all sources.
  2. Re-using directly as much waste as possible either for its original purpose or for a new purpose.
  3. Recovering and recycling waste, for instance recycling metals, paper, plastic and building rubble, and composting and/or anaerobic digestion of household and commercial organic materials such as household and commercial food waste, garden waste, and other biodegradable arisings.
  4. Converting waste to energy, for instance by burning in a power station to produce electricity, or by producing waste derived fuels, e.g. via gasification or pyrolysis.
  5. Finally, when all the above have been exhausted, dumping waste in landfill sites with or without recovery of methane or incineration of specialised wastes.

Incineration may have a place in the hierarchy but only when options higher in the hierarchy have been fully exploited.

CPRE could support carefully located small-scale incineration plants which are clearly linked to dealing only with residual waste, particularly if such plants were combined with energy generation through combined heat and power systems. There is merit in this being a requirement to be considered for all new major housing/commercial/industrial projects.

What CPRE would like to see

The overall aim should be:

Javelin Park

CPRE has argued above against major incineration plants as part of any strategy for dealing with waste in Gloucestershire and has noted that a large scale incinerator would be difficult to accommodate in the county because of its environmental impact, in particular impacts on the landscape, impacts from vehicle movements, and possible issues around emissions. Issues around impacts on the landscape would be particularly acute at Javelin Park.

Our assessment of landscape impact, summarised in Annex 1, is that a large tall structure at Javelin Park would be visually highly damaging from a number of significant view points. It would also further erode the important stretch of open countryside separating Gloucester and Stonehouse.

References

1. Eunomia Research and Consulting, for National Assembly of Wales, 2007

2. Scotland’s Zero Waste Plan, public consultation, The Scottish Government, 2009

CPRE Gloucestershire Branch

September 2009

Annex 1

Javelin Park – Landscape Impact Assessment of Development

Introduction

Javelin Park is a large semi-derelict site close to junction 12 of the M5 on the south-western side of the junction adjacent to the B4008. Next to the site is a large garden centre whose prominent roofs can be seen from a considerable distance and act as a visual marker to the site. The garden centre is a relatively low building.

I assessed the nature of the landscape and the impact of major development on the site from the Cotswolds escarpment starting at Painswick Beacon and moving to Haresfield Beacon, then from various points in the Vale approaching Haresfield and finally from the small hills (Hockley Hill) on the western side of the Gloucester – Sharpness Canal. All view points were publicly accessible locations such as footpaths or minor roads.

Assessment

From the escarpment one has long panoramic views across the Severn Vale to the Forest of Dean to the west with a foreground of the escarpment tumbling unevenly to the vale. One is conscious looking due west and to the north west of the sprawl of Gloucester and the many industrial buildings near Quedgeley. However, as one turns to look in a more south westerly direction the landscape is much less interrupted by urban development and has a fine panoramic setting as far as the Severn Bridge. Javelin Park sits in this view and while the roofs of the garden centre are clearly visible they are not too obtrusive and there are no tall structures to intrude upon the view. The views from the Cotswold Way are however frequently and for quite long stretches obscured by a thick belt of trees on the top of the escarpment. This is particularly true of Haresfield Beacon where the views are only to the south towards Stonehouse. If one descends one of the not infrequent paths or lanes which drop down the escarpment then the view opens out again. From all these view points large buildings are very prominent because one is looking down on them.

Once in the vale itself, the landscape changes. What from above had looked flat is now seen to be undulating with frequent copses, small valleys and open fields. One moves therefore from small intimate rural scenes with distance obscured by the crest of a small hill or trees to more open, long views but restricted in breadth. This means that Javelin Park frequently can not be seen even when quite close but when it can be seen a large building would be very dominant but seen only intermittently.

Crossing the canal at Quedgeley one comes to a very rural area of isolated farms with fields rising up Hockley Hill which itself is well wooded. The area is seamed with footpaths. From any of these footpaths and from the lanes looking east one is first very conscious of Quedgeley industrial estate. But this comes to an abrupt visual end and looking due east and to the south there is a wonderful open view with the Cotswold escarpment rising in the background. One can not see the Garden Centre adjacent to Javelin Park as there is a small ridge just before the M5. However it is clear that a tall structure would be visually very intrusive and spoil the break from the unremitting industrialisation experienced further north. I am quite sure that views from the Forest of Dean ridge would be the mirror image of those from the Cotswolds escarpment.

It is interesting to note that while the noise of the M5 is intrusive from all the above viewpoints, it is difficult to see the road itself because it is mostly sheltered by trees or undulations in the land.

I concluded that a large tall structure on the Javelin Park site would be visually very intrusive and damaging, sitting prominently in views which are otherwise very rural and largely unspoiled. Such a development would emphasise the spread of Gloucester in a southerly direction into as yet reasonably undeveloped countryside.

Nick Dummett

August 2009

Back to top of page          Back to What we are doing