Peterborough City Council - Questions and answers

Questions and answers

The following are the questions that the city council has received from the public and the answers the council has given in relation to the council's proposals on its integrated waste management strategy.

These are placed on the council's website so that you can see what questions have been raised and what answers the council has given. Questions have been amended slightly so that they are impersonal for publishing on the website.

If you have any questions or queries that you wish to raise with the council you can do this by email to yourwasteyourview@peterborough.gov.uk or by sending a letter to Your Waste Your View, Peterborough City Council, Bridge House, Town Bridge, Peterborough, PE1 1HU. We will update this Question and Answer sheet as we receive and answer questions.

You can download these questions and answers or you can ask us to provide you with a hard copy by emailing yourwasteyourview@peterborough.gov.uk or writing to the address above.

Q1. Why has the council been so pessimistic concerning its projected increased waste? The graph as shown on page 7 of the Agenda Report for the Cabinet Meeting is clearly incorrect. It predicts an increase of 35% whilst it predicts a population growth of only 25%. But currently waste tonnages are actually starting to fall. And predictions from waste experts are that they will continue to fall with such legislation as the EU Packaging Directive. A more realistic figure for Peterborough would be +20% would produce a figure 15,000 tonnes lower than the council figure.
I believe there is a further mistake with the graph. It does not appear to include the additional 20% recycling which is proposed. Current recycling stands at 17.5%. It is obvious that the recycling segment does not reach 37.5% even by 2020. If it was shown it would reduce the sector labelled "fines paid on this element" considerably (which is far too large anyway, as previously described). Is there a reason why the increased recycling/composting figure up to 65% is not included?

A. This graph is intended to show the situation should no further effort be put into waste management, other than to continue the same schemes and offer them to all residents. It is in fact a "Do Nothing Scenario" graph intended to indicate the scale of the problem faced if nothing is done to tackle growing waste, increase recycling and divert waste from landfill. Waste growth figures are a conservative estimate based on joint work undertaken with RECAP, based on genuine experience within Peterborough and Cambridgeshire. Waste has indeed fallen in Peterborough since the introduction of the alternative weekly collection and composting of garden waste. However these reductions are normally limited to the change over period of the scheme, and once more materials are separated for recycling there is the potential for other wastes to be placed into black bins. In no way does this detract from the work needed to be done on waste minimisation, which is part of the integrated strategy being proposed.

Q2. Does the council consider that it has carried out sufficient public consultation regarding its proposal to construct and operate an incinerator? Before 22/01/07 very few people were aware that the PCC was even considering an incinerator within its proposals. What mechanisms will be available to allow the people of Peterborough to express a viewpoint? We are further concerned because we have learnt from a councillor that the site which may be selected will not need planning permission which would remove another democratic avenue.

A. As can be seen from the report there has been a considerable amount of public consultation on the issue of recycling and waste management. A range of ideas and initiatives have been discussed by respondents and focus groups throughout the RECAP process and the more recent Peterborough specific consultation. Both sites being proposed would in fact require full planning permission and therefore any proposed development would be open to full and detailed consideration by the public and the wider community. The sites are both contained within the Waste Local Plan, and therefore are protected for use as major waste management facilities but do not have specific permissions. Any site selected for such a facility would require a full planning application to be submitted. Also either of the proposed sites would of course require IPPC permits from the Environment Agency; once again this is a fully public process.

Q3. Has the council considered the use of an anaerobic digestion with MBT process to treat its waste material? Norfolk County Council has concluded that the biogas produced will bring in a useful income.

A. The working group has visited a wide range of sites, offering a number of waste management processes. They have also received presentations from both waste management companies, and independent consultants acting on behalf of the Department for the Environment, Food and Rural Affairs (Defra) under its local authority support programme. A number of Mechanical Biological Treatment (MBT) processes were visited during the EU study tour undertaken on 3 to 5 December 2006. These included both aerobic and anaerobic based processes. All of the options considered have been investigated for operating costs and also for potential income generation.

Q4. Has Peterborough City Council carried out a comparison of the capital and revenue costs for an incineration plant compared to an anaerobic digestion within MBT plant?

A. Capital costs, revenue costs as well as infrastructure development costs have all been included within the detailed process undertaken by the working group. The option being proposed, in fact, is considered to offer the best value for money for the council and its resident's.

Q5. Is the council aware that Norfolk County Council will be backing anaerobic digestion within MBT rather than incineration? A unanimous decision by all party county councillors has declared it "better value for money".

A. In 2004 Norfolk County Council invited companies to submit proposals for the treatment and disposal of 150,000 tonnes of residual waste per year. The county council's Cabinet selected the waste-to-energy solution proposed by Waste Recycling Group (WRG) as its preferred option in December 2005 and commenced detailed negotiations. WRG's preferred bidder status was withdrawn in July 2006 when land acquisition issues were not resolved within a set deadline and exclusive negotiations then commenced with the reserve bidder, Sustainable Resource Management (SRM). These negotiations continued until the end of November 2006, following which both bids were re-evaluated. In January 2007 the county council's Cabinet accepted a recommendation from the board overseeing the project to select SRM as the preferred bidder and WRG as the reserve bidder as the revised SRM bid was better value for money. SRM is a public-private partnership consisting of Norfolk Environmental Waste Services Ltd (the privately-operated local authority waste disposal company), May Gurney and Innisfree. The MBT solution proposed by SRM does not burn any waste but it does create a stabilised material which SRM is intending to use for quarry restoration.

Q6. Does the council consider the capital cost of an incinerator at £38 millions plus an annual operating cost of £4.75 millions to be good value to Peterborough council tax payers?

A. Of all the issues considered by the working group, capital and revenue costs were of course a significant part of the assessment. Technology risk, land costs, capital costs, revenue costs and a number of other issues were involved in the group's recommendation. This recommendation shows the best value option that meets the needs of the residents and community at large within the city of Peterborough.

Q7. With regard to the alternatives to incineration, I would like to know what level of investigation has the council carried out with regards Mechanical and Biological Treatment (MBT) technologies. With which companies and personnel has it had meetings? Has it, for instance, contacted Mr Michael Cheshire of 'Greenfinch plc' who is reckoned to be one of the UK's top experts in this field?

A. The council and its members have visited a wide range of sites, offering a number of waste management processes. They have also received presentations from both waste management companies and independent consultants acting on behalf of Department of Food and Rural Affairs (Defra) under its local authority support programme. A number of MBT processes were visited during the EU study tour undertaken on 3 to 5 December 2006. These included both aerobic and anaerobic based processes.

Q8. How will the council dispose of the ash from the waste incinerator which it may construct and operate? If the council uses the Cyclerval technology the waste material fed into the plant will only be reduced by 70 to 75% (This information received from Mr Ian Crummack, MD Cyclerval on 06/02/07). Thus in 2020 the council will need to dispose of 26,000 tonnes of very hazardous fly ash and bottom ash wastes per year! Also there are only 12 sites in the UK which are able to accept this type of waste.

A. Based on these figures it suggests that about 104,000 tonnes of waste is to be treated in the proposed facility, calculating backwards from 26,000 tonnes. This is incorrect as current estimation, based on 65% recycling and current population growth figures, makes it approximately 65,000 tonnes input and therefore 16,500 tonnes of ash. Of this material the bottom ash element is currently classed as non-hazardous (Environment Agency website), and previously was never considered special waste. It contains glass and metals which are available for further recycling, and the inert remainder can be used for replacement aggregate or other building materials. As the material is not classed as hazardous waste, and is intended for recycling, it will not be restricted to the limited number of hazardous waste landfill sites in the country.

Q9. Is the council aware that it is becoming more and more difficult to dispose of incinerator wastes? Historically some incinerator wastes have been used for Secondary Aggregate Replacement for roads. However, following several recent problems a study has been commenced to investigate the suitability of this material and that it may well conclude that it is unsatisfactory.

A. Officers are aware that the Environment Agency has commissioned work regarding the suitability of such ash for existing treatment and disposal methodologies. The Environment Agency clearly states that only in the event of uncertainty regarding the validity of the results from the approved WM2 desktop testing methodology, for incinerator bottom ash, will there be a requirement for direct testing of samples of ash. If desktop testing proves that no materials of an ecotoxic nature are present, then there is no need to consider direct sampling and testing in a laboratory. Therefore the work being undertaken is to ensure the robustness of testing regarding this material, to ensure individual sources are compliant with the recycling or disposal method chosen.

Q10. Is the council aware that an incinerator is liable to produce 10,000 tonnes of greenhouse gases from fossil fuel sources per year (i.e. from sources which have locked away carbon for millions of years)? The total CO2 emitted, including biogenic carbon will be of the order of 40,000 tonnes per year. If embedded carbon is also taken into account the figure is even higher. Is the council concerned about the effect that this will have in terms of exacerbating climate change?

A. The council is fully aware of, and committed to reducing, the effects of global warming from fossil fuel usage. By using a facility within the city, following the closure of local landfills, transport fuels use is minimised allowing a reduction in CO2 emissions. By maximising the generation of electricity and heat through a Combined Heat and Power system the council is ensuring the sustainable treatment and recovery of maximum value from the non-recyclable residues left after intensive kerbside recycling and composting. All electricity exported from the facility will displace energy currently generated from fossil fuel sources, therefore reducing the carbon dioxide emissions from power stations. Also those companies taking heat from the plant will cut gas, oil and coal usage for their heating needs, further reducing the emissions entering the atmosphere from businesses in the city of Peterborough.

Q11. Has the council carried out a thorough investigation of the feasibility and costs of increasing recycling? I have carried out a study. I believe Peterborough could quite easily achieve 78% recycling for a fraction of the costs of running an incinerator (which is predicted to be £120 millions to the council tax payers over a 20 year period). If Peterborough recycled 78% of its waste it would still be within its LATS targets for 2020, its landfill capacity would last for a further 20 to 25 years, it would be environmentally sound and it would emit very little greenhouse gases.

A. The working group has committed to aspiring to achieve in excess of 65% recycling and composting. If more can be achieved then the council would strive to achieve these stretched targets. If 78% could be achieved then that would be excellent news and much less material would require final treatment. The running costs quoted appear to be nothing like those figures officers have had presented by Government advisers, or have found through research. However, it should be noted that even with a huge increase in recycling and composting performance, due partly to the time lag involved in getting schemes up and running, it is unlikely that much life could be added to existing landfill sites and certainly not 25 years as quoted. Increasing recycling will increase the need for transport and energy use through the processing of the material. This too has an impact on the environment and requires careful consideration in light of the integrated scheme being proposed.

Q12. A request for information about the proposed sites and copies of the minutes of the Waste Recycling Working Group.

A. The council cannot provide site details other than those already available in the public domain i.e. the site at Fourth Drove, Fengate, that is owned by the council. The reason is that information on the sites, not in council ownership, is commercially sensitive. Copies of the minutes of the Working Group's meetings held on 4 November 2006 and 9 January 2007 were provided.

Q13. I am very concerned that we still do not have an economically encouraging council policy towards school recycling. Surely if we are to change attitudes, making it easy for schools (if not impossible not to) to get their communities to reduce, reuse and recycle is absolutely crucial.

A. The cross-party waste and recycling working group agree that it is very important to make sure that our children receive the message of reducing waste and recycling from an early age, and that this is backed up by putting it into practice in schools. As part of the proposals for an integrated waste management solution we will be continuing with our education work, which includes tours of the Materials Recycling Facility, assemblies and education packs. However the working group is also very keen to introduce more recycling in schools. In the past this has been difficult to achieve because of the costs involved, but it is now seen as a priority, and is something that the group will be investigating in more detail in the coming months.

Q14. Wouldn't one quick way to reduce our landfill be to stop importing waste from outside the county, as we import huge amounts of landfill from London? London does not pay any fees for using our landfill sites and I am sure would not contribute to any fines that were imposed on us by the EU.

A. The issue of importing waste from London is a contentious one, and unfortunately one that Peterborough City Council do not have direct control over. At the moment, although some household waste from London is currently being landfilled in the Cambridgeshire area, we are not aware of any going to sites in Peterborough, so it does not affect the rate at which our local landfill is running out.

If, in the future, waste from London does have to be landfilled in Peterborough, this would not count towards Peterborough's landfill quota, but towards the quota of the local authority it came from. Therefore Peterborough will not have to pay any fines on waste coming from London.

The following questions and answers which were received by the Council before the deadline of 12 noon on 28^th February 2007 (along with those questions that had previously been received) were brought to the attention of all Members of the Council prior to the Council meeting held on 28 February 2007.

Q15. I am concerned that if we incinerate our remainder rubbish, there will be a temptation to not worry so much about maintaining or increasing the fraction that we do recycle. What safeguards will you put in place to ensure this does not take place? - bearing in mind that it is always harder to get people to recycle into separate containers than to put it all into one bin.

A. Peterborough's residents have already shown that they are keen to recycle and happy to make the extra effort to separate out waste. This is demonstrated by the exemplary recycling rate of around 42% which has already been achieved. As part of the recommendation for an integrated waste management solution for Peterborough there are several safeguards in place to make sure that recycling in the city does not take a backwards step, but instead continues to move forward. The recommendation proposes that Peterborough commits to strive for a recycling rate of over 65%, which would be achieved by:

Providing two Householders Recycling Centres one for the North of the city and one for the South;
Upgrading the Materials Recycling Facility to accept additional materials such as glass and a wider range of plastics;
Expanding the Electrical Appliance Recycling Programme to take additional household white goods;
Expanding composting and developing a facility that treats kitchen waste.

To support this investment we will be continuing to work hard with members of the public to make sure that our recycling systems are used to the maximum. This includes work with schools, businesses and the general public at events such as roadshows.

The cross-party working group which developed the proposals will continue to be closely involved in improving recycling in the city. One option currently under consideration is using incentives or fines to encourage people to use their green and brown bins more and their black bins less.

In addition the local authority partnership RECAP (Recycling in Cambridgeshire and Peterborough), is currently running a consultation to find out how we can encourage people to minimise waste and recycle more. This is looking at options such as promoting the use of fewer disposable products, buying more second hand goods and recycling different materials. This consultation will help us to focus our efforts and get the most out of recycling.

Finally, the amount of waste which can be sent to the proposed facility will be limited, as it will be sized to allow for waste under the control of the local authority, and for achieving over 65% recycling. This gives us an extra motivation to divert material away from the black bin.

Q16. Is there really no possibility of providing a new landfill site for the reduced volume of waste that would remain after maximum reduction, reuse, recycling, composting and food waste treatment? An MBT facility would reduce the quantity of residual waste to be disposed of still further. We would probably need landfill anyway for the large amount of ash that would be produced by incinerating waste as there is no real market for ash based aggregates.

A. The nature of Peterborough as a local authority with a small geographical area, a large part of which is built up, makes it very difficult to provide landfill facilities within the area. However, the possibility of new landfill sites is considered in the Cambridgeshire & Peterborough Waste Local Plan (WLP) (2003), which sets out sites in the area to be protected for waste management purposes. There is one site within Peterborough which the WLP says will be considered favourably for putrescible landfill (the type of landfill which household waste has to go to) - this is at Eyebury Quarry. However the planning permission for landfilling at this site is due to elapse very soon, so this is not currently considered a viable option. The WLP plan does not identify any further sites in the area which are considered suitable. Although it is theoretically possible to have a landfill site at another location, this is not considered feasible due to the extra difficulties and costs involved in getting planning permission for a landfill which is not detailed in the WLP. Instead, the council believes it is a better option to eliminate the need for landfill as much as possible through using an ERRF. This fulfils the principles of sustainable waste management by treating the waste locally and recovering materials and energy. In addition, it provides a net carbon benefit over landfilling the residual waste, as supported by the Stern Report:

"Waste is currently responsible for 1.4 GtCO2e/year, of which over half is from landfill sites and most of the remainder from wastewater treatment. Reusing and recycling lead to less resources being required to produce new goods and a reduction in associated emissions. Technologies such as energy-recovering incinerators also help to reduce emissions."

It must also be remembered that there is an additional driver for reducing landfill in Peterborough on top of the lack of available void space. This is the requirement set by the EU through the Landfill Directive to reduce the amount of biodegradable waste being landfilled. Officers have calculated that, even with the exceptionally high levels of recycling and composting proposed, Peterborough will exceed its quotas in the future, and will face millions of pounds worth of fines if it doesn't find an alternative. The main reason that it is so difficult for Peterborough to meet this requirement is that the limits set by central government do not take account of the planned population growth for Peterborough of around 25% by 2021.

The Members Waste & Recycling Working Group have considered in depth the potential to treat residual waste in different types of MBT facility, and have also visited a number of these plants. However they have come to the conclusion that the proposed ERRF is a better option for Peterborough. This decision took into account environmental factors, cost factors, and the risks involved with the different technologies, in particular the markets for the residues produced by the different markets. The members considered that there was a greater risk of not being able to find a market from MBT residues than for ash from an ERRF facility. In addition, they considered that any ash from the ERRF for which no market could be found would not count against the EU landfill quota, whereas MBT residues have an uncertain degree of biodegradability which could lead to Peterborough exceeding its landfill quota.

Q17. Is the Council satisfied that the proposals contained in this report are consistent with the aspiration expressed in its Community Strategy that Peterborough should become recognised as England's Environment Capital?

A. The working group are happy that the proposals indeed support the council's aims to build on its existing reputation as an Environment City, and hopefully become the Environment Capital of the UK. By minimising waste for landfill, reducing transport and maximising recycling whilst also reducing the city's dependence on fossil fuels the aims of an Environment City are well supported.

Q18. Will the Council guarantee that it will not proceed with an energy from waste incineration solution unless the operators of such plant give a legally binding commitment that they will never import waste for incineration in Peterborough even if waste reduction and recycling policies achieve massive cuts in the volume of residual waste, as other cities have done?

A. It is not possible to give such assurances although the type of plant and scale proposed is that of only having a capacity of around 65,000 tonnes, which we believe is adequate for Peterborough's needs.

Q19. Were the councillors who prepared this report and those of the Environment Policy Overview Committee made aware of the findings of the December 2005 study The Health Effects of Waste Incinerators published by the British Society for Ecological Medicine?

A. Councillors have not been given a copy of this report, as we believe the report is misleading and inaccurate. The Health Protection Agency has indicated that the report has misinterpreted the evidence. A critique of the report is available in PDF format The Health Effects of Waste Incinerators

Q20. Has the Council sought advice from its risk management and public liability insurance advisors regarding the potential scale of personal injury claims that it may face in the event of medical and mortality impact upon individuals whose health may be affected by PM 2.5 emissions from an incinerator of the type proposed for Peterborough?

A. This issue would of course be dealt with during the Environmental Impact Assessment (EIA) part of the planning and Pollution Prevention Control (PPC) applications, where detailed studies are undertaken on a wide range of issues, air pollution and possible health effects included. To state that there will be claims against the council suggests that you feel there to be a risk, when there is evidence to suggest this is negligible.

Q21. Has the Council considered following the lead of other cities in Europe and North America which achieved a reduction of more than 60% in domestic waste by educational and inspirational programmes, which significantly reduce the need for waste incineration?

A. The council is an exemplar for waste management which is recognised for Beacon status, our proposals includes a commitment to reduce waste through education and working with central government and local retailers, alongside an aspiration for high recycling and composting rates. In doing this the group proposes to minimise the need for residual treatment, with less than 35% of waste requiring processing.

Q22. Do you have figures for the PM2.5 particulates emitted from the chimney of the Cyclerval incinerator at Grimsby which was referred to in the Evening Telegraph as a model for the new incinerator planned for Peterborough?

A. A detailed response to this question is included in the section Information and reference.

Q23. Does the Council have details of the number of occasions on which emissions from the Cyclerval incinerator at Grimsby have exceeded WID (Waste Incineration Directive) safety levels since it was commissioned?

A. This information is freely available from the Environment Agency, which is responsible for regulating this type of facility. Such information can be obtained from the following website: www.environment-agency.gov.uk.

Q24. Has the Council or its Waste and Recycling Group sought guidance from its Director of Public Health regarding the detailed analysis of the impacts of PM2.5 particulates upon persons living within the footprint area of an incinerator of the type proposed in this report? Details of the impacts of these particulates on cardiac mortality, cardiopulmonary mortality and myocardial infarctions are given in the December 2005 report The Health Effects of Waste Incineration published by the British Society for Ecological Medicine.

A. This issue would of course be dealt with during the Environmental Impact Assessment (EIA) part of the planning and Pollution Prevention Control (PPC) application, where detailed studies are undertaken on a wide range of issues, air pollution/ health effects included.

To state that there will be claims against the council suggests that you feel there to be a risk, when there is evidence to suggest this is negligible; more than one source of information can be provided upon request. The Health Authority will be consulted directly for its observations during this process. However the council has already sought general guidance from the Health Authority.

A critique of The Health Effects of Waste Incinerators report is available in our Information and reference section.

Q25. What emissions to air and to the land emanate from the Dogsthorpe Star Tip landfill site?

A. Emissions to air: the anaerobic decomposition of biodegradable waste which occurs in a landfill site such as the Dogsthorpe site leads to the production of methane and carbon dioxide. Due to the composition of the decomposing waste, there are also other compounds present in this methane, including sulphur and nitrogen containing compounds.

Emissions to land and water: modern landfill sites such as the parts of Dogsthorpe site currently in use are designed to have minimal direct emissions to land and water.

Other issues: other environmental concerns surrounding landfill include the potential for litter and vermin problems.

Q26. I understand that the Dogsthorpe Star Tip (and all landfill sites constructed during the last 10 years) have been lined to prevent leachate. Also that features are included which allow the collection of methane gases for its re-use. Please confirm.

A. The parts of the Dogsthorpe site currently in operation have indeed been lined to prevent leachate escaping into the surrounding soil and water table. Typical landfill liners consist of several layers of fabric, plastic or clay to try to prevent escape of leachate even should the first layer be breached.

As the leachate cannot be allowed to escape into the surrounding soil, it must be pumped out of the site and disposed of in an appropriate manner. Typically, landfill leachates are transported of site and treated by sewage works.

Modern landfill sites such as the Dogsthorpe sites do indeed have infrastructure to collect and use the methane gases produced. However due to the logistics of running a landfill site, these can only be put in place on a given section once that section is completed and capped. It is not possible to capture methane while a section is being actively tipped, but unfortunately this is the time when decomposition is most rapid and therefore large quantities of methane escape during this time.

Modern sites such as Dogsthorpe typically burn the methane gas to drive engines and produce electricity. Often this happens on or close to the landfill site. There is typically no clean up system to remove other compounds from the gas before it enters the burners, and typically no clean up system on the outlet from the engines. Therefore the emissions from the engines will tend to include compounds such as sulphur dioxide and oxides of nitrogen as well as the expected carbon dioxide.

Q27. If there are emissions [from the landfill site] what are the effects to human health and the environment?

A. Modern landfill sites are designed and operated to minimise effects on both human health and the environment. As with all waste management, this is not a 'zero risk' option.

A study by Defra called 'Review of Environmental and Health Effects of Waste Management: Municipal Solid Waste and Similar Wastes' found:

"A detailed study of landfill sites has identified a possible link between living close to a landfill site, and the occurrence of some birth defects. The study also considered the occurrence of unusually low birth weight. This study was not able to say whether the associations are causal, or whether they might be reflecting other factors which the study could not address fully. The observation is a small increase in the risk of a birth defect happening in babies born to families living near landfill sites. The increase is much smaller than other factors which influence the likelihood of birth defects, and the numerical results cannot at present be reliably used."
"A detailed UK study was carried out to investigate whether there is any indication that living close to landfill sites results in an increase in the occurrence of cancer. This study did not detect an increase in the occurrence of cancer."
"The most important environmental impact reported in scientific research is the effect on global warming of emissions of greenhouse gases (most importantly, methane) from landfill of municipal solid waste. Methane is generated at all landfill sites accepting municipal solid waste, and the contribution of methane emitted from landfills to global warming is important. As a result, alternatives to landfill for municipal solid waste are often viewed as having a positive effect on global warming by reducing the need to landfill biodegradable waste which generates methane. As the Landfill Directive is implemented, the amount of biodegradable waste being landfilled will reduce. Collection and combustion of landfill gas will also become much more widespread, although it is never possible to collect all the methane generated at a landfill site."

Q28. How much energy is/will be expended by:

a) current landfilling (say per 100 tonnes)

b) current recycling

c) increasing recycling from the current 49% to 78%

d) incineration (including transportation of waste/ ash residues)

e) MBT/anaerobic digestion (including transportation of waste/ inert residues

A. Unfortunately due to the highly technical nature of this question it is not possible to provide a detailed and satisfactory answer at short notice. However this issue will be addressed in the Environmental Impact Assessment for the proposed facility. It should also be noted that, in order for the Environment Agency to grant a PPC permit, operators must show that they have considered alternative options and demonstrate that the chosen technology fulfils the requirements of BAT (Best Available Technique). These studies will entail comparisons of the options mentioned above, including energy aspects.

Q29. How much energy is required to power an incinerator and from what source would it be derived?

A. Under normal conditions incinerators require no external power to operate. That is, the combustion process itself is self-sustaining above the temperature required by law. Additional equipment is powered by the energy produced on site from the generator, with significant amounts of power remaining available for export.

Under start-up, shut-down and other abnormal conditions it is necessary to supplement the heat provided by the combustion of the waste itself by a secondary fuel. This ensures that the temperature remains above the legal limit, and that there is complete combustion of the waste. The secondary fuel is typically gas, although other fuels may also be used. Secondary fuel is automatically added to the system in the case of falling temperatures to ensure that they never drop below the legal limit.

Q30. How much ash waste will be produced by the incinerator which the Council is proposing to use? I understand from discussions with the MD of Cyclerval that the incinerator which is operational in Grimsby produces between 25% and 30% waste. I also understand the Peterborough incinerator may be designed to burn 60,000 tonnes of waste per year: it will therefore produce 15,000 tonnes of ash waste. Please confirm.

A. This estimate seems reasonable, however the exact amount of ash produced will of course be dependent upon the actual throughput and the operation of the plant, which is proposed to be around 65,000 tonnes.

Q31. A proportion of the ash waste is classified as dangerous waste. How will this and the remaining waste be disposed of?

A. The ash produced by the air clean-up processes, often called fly ash, is classed as hazardous. This fly ash is typically about 3-5% by weight of the inputted waste. Most fly ash produced is currently disposed of in specialised hazardous waste landfills, which are very highly controlled. However, due to the alkaline nature of the fly ash, it is also possible to recycle it as a feed stock for other processes, particularly in the treatment of acidic materials.

The remaining ash is bottom ash, and is considered non-hazardous and inert. It is often used as a secondary aggregate.

Q32. According to Cyclerval 35% of the waste in Grimsby is being used for hardcore below roadways and in building block manufacture. Presumably Peterborough is considering a similar disposal route? However an investigation is currently underway to ascertain the suitability of this material due to the air voids within and its toxic contamination. If this end use is ultimately prohibited where will Peterborough dispose of this waste?

A. In order to make sure that as much of Peterborough's waste is recovered as a usable resource as possible, the options for recycling bottom ash in uses such as those mentioned above will indeed be preferred to final disposal. Officers are aware that the Environment Agency has commissioned work regarding the suitability of such ash for existing treatment and disposal methodologies. The Environment Agency clearly states that only in the event of uncertainty regarding the validity of the results from the approved WM2 desktop testing methodology, for incinerator bottom ash, will there be a requirement for direct testing of samples of ash. If desktop testing proves that no materials of an ecotoxic nature are present, then there is no need to consider direct sampling and testing in a laboratory. Therefore the work being undertaken is to ensure the robustness of testing regarding this material, to ensure individual sources are compliant with the recycling or disposal method chosen.

Q33. How much CO2 will be emitted by the incinerator which the council is proposing to use:

a) from fossil fuel derived sources ( eg plastics, synthetics, textiles, composites etc)?

b) from biogenic sources ( eg paper, card, plant, cloth, wood, rubber etc

c) due to embedded carbon?

(60,000 tonnes of waste per year may produce 15,000 tonnes of ash per year. Of the remaining 45,000 tonnes of waste which will have been incinerated 40,000 tonnes is liable to be carbon based. When carbon combines with oxygen to form CO2 its weight triples. Thus the fossil+biogenic portions will be in excess of 120,000 tonnes. Please confirm).

A. The CO₂ emissions associated with the proposed facility will be dependent upon the following factors, amongst others:

Waste composition;
Operation of the specific plant;
Amount of electricity and heat produced and the ratio between the two;
Whether biogenic carbon is included in the analysis (the intergovernmental panel on climate change currently recommend exclusion of biogenic carbon from lifecycle analyses as it is short-cycle and therefore absorbed by regrowth);
Whether net or gross calorific values are used;

The calculation to find the amount of CO₂ emitted overall per year is extremely complex and involved; however a typical approximate figure is given in the report 'A Changing Climate for Energy From Waste' by Eunomia for Friends of the Earth. This assumes 10% efficiency for electricity generation, 55% efficiency for heat generation, the emissions per kWh generated from the proposed facility would be of the order of 322 g CO2/kWh if biogenic CO₂ is not taken into account as prescribed by international guidance. The UK average emissions associated with electricity generation as a comparison is 497g CO2/KWh.

Over Landfill EfW on average saves 675 kg CO2 /tonne waste disposed and as a comparison MBT with reject recovery or incineration saves less, this being 585kg CO₂/ tonne waste disposed.

It would not be scientifically correct to determine the impact of EfW on climate change through an analysis which focuses on the molecular weight of carbon, carbon dioxide or any other element or compound.

Q34. If the Council adopted an increase recycling strategy combined with MBT/anaerobic digestion (which produces a much smaller amount of almost completely inert residue than the incinerator proposal) by how much longer would the life of Dogsthorpe Star Pit be extended? Figures obtained by PFoE indicate that the first waste treatment route would produce about 7,500 tonnes of inert waste compared with the incinerator which would produce between 15,000 and 18,000 tonnes of ash. If you disagree with PFoE findings please provide calculations for PCC figures.

A. The lifespan of the remaining void space at the Dogsthorpe landfill site would not be significantly affected by choosing an alternative technology. This is because a proposal for any waste treatment facility, including MBT with anaerobic digestion, would require significant time to be expended in procurement, acquiring planning permission and a PPC permit, construction and commissioning. Although lead times vary to a degree between technologies, it is unlikely that any plant could be fully up and running before 2011. By this stage the Dogsthorpe site would be nearing completion already, and so there would be little opportunity to extend its life.

MBT anaerobic plants recover a number of fractions from the inputted waste. According to information from the Defra New Technology Supporter programme, typically around 4% is recovered as recyclate (mostly metals). Many MBT plants are then set up to produce a compost-like output (CLO).

All MBT plants produce a residual fraction after recyclates and CLO are removed. Many MBT plants are set up so that the majority of this is processed into RDF and used to generate energy, but we shall assume here that this option is not considered favourable. In this case, the entire residual fraction would have to be landfilled. According to information from the Defra New Technology Supporter programme, this would be between 65-70% of the waste. If we base the calculations on a throughput of 60,000 tonnes per year (the same assumption as was made above for an incinerator), this gives between 39,000 and 42,000 tonnes per year to landfill.

Having established this, the amount of CLO produced must also be found. Typically this is around 25-30% of the inputted waste by weight. This gives between 15,000 to 18,000 tonnes of CLO which must be disposed of. This CLO cannot be used on agricultural land because it comes from a mixed waste source. Instead, options include using it to remediate brownfield land or landfilling it. Markets for using the CLO in remediation are currently weak, which means there is a high risk that this fraction will also end up in landfill. Unfortunately this material cannot be considered 'inert', as it has a degree of residual biodegradability. This degree must be determined by the Environment Agency for each plant; however a reduction in biodegradability of 50% is a typical figure which can be used for estimation purposes. This means that, for every 100 tonnes of CLO which is landfilled, 50 would count against LATS limits. In this calculation, about 7,500 to 9,000 tonnes will count against LATS. This partially biodegradable fraction would also be producing methane in landfill.

Q35. How can the Council justify investing in an incinerator which is based on technologies of the last century? Although PFoE believe there are better options for dealing with our waste we do accept that the design submitted by Global Olivine last year for incinerators/ PEMs (plasma enhanced melters)/vitrifiers was far superior. We do have to accept that the GO proposal may well be given an approval by the Department of Trade and Industry at the end of this year. Does Peterborough really need 2 incinerators? If the PCC built its own incinerator would it really continue to use it when nearby there is an incinerator which operates far more efficiently and produces much less pollution per tonne of waste treated?

A. The council is not aware of any evidence to show that the current proposals are more polluting than those proposed by another company. However this will be tested through the PPC permitting, independently inspected and regulated by the Environment Agency and the procurement process. As to the Global Olivine proposal the council as the waste authority is unable to comment.

Q36. How can Peterborough as an Environment City propose a solution for its waste problem which is so damaging to the environment? Following the publication of the Stern Report a number of prominent IPPC scientists have declared that their research shows that the Antarctic and Greenland ice sheets are imminently danger of fracturing which will cause sea levels to rise by between 4 and 6 meters and that we must restrain all unnecessary emissions of greenhouse gases (see New Scientist 10/02/07). Other nearby local authorities such as Norfolk, Cambridge and Nottingham and possibly soon Northaptonshire have rejected the incinerator option. Why hasn't Peterborough taken the same route?

A. The issue of the climate change impact of waste management is indeed of paramount importance, but it is also very complicated to assess as there are so many different factors to take into account. Unfortunately there is currently no 'zero emission' solution to dealing with waste, so we must instead make our comparisons against the current practice of landfilling. In this case it is clear that an ERR facility is preferable for a number of reasons:

It would prevent the emission of methane gas from landfill sites methane is 21 times more potent than carbon dioxide as a climate changing gas
It would prevent the emissions caused by transporting waste to landfills outside the city when the site in Peterborough is full in a few years time.
It would displace energy generated by conventional means (coal, oil and gas), by generating electricity and hot water in the proposed Combined Heat and Power (CHP)
It should be noted that international guidance states that short cycle carbon dioxide (carbon of plants, paper and card etc) should not be included in the calculations as these emissions are reabsorbed during new growth.

Overall a traditional "standard" energy from waste facility, generating electricity only, shows a slight improvement over landfill disposal with methane gas collection and combustion. The council's proposals are for a high efficiency CHP facility which extracts more energy from the waste, even further improving the carbon benefit.

The following quote from p. 218 of the Stern Report may be of interest:

"Waste is currently responsible for 1.4 GtCO2e/year, of which over half is from landfill sites and most of the remainder from wastewater treatment. Reusing and recycling lead to less resources being required to produce new goods and a reduction in associated emissions. Technologies such as energy-recovering incinerators also help to reduce emissions."

Every council has different circumstances and pressures, and therefore each council has a plan that best suits its circumstances and the needs of its population. Cambridgeshire council along with Norfolk and Luton are currently investigating combustion of residues from MBT processes from their waste treatment facilities.

Q37. Peterborough FoE have calculated that by increasing its recycling rate to 78% it could comply with the Government's LATS requirements, even in 2020. Total waste generated would be 105,794 tonnes. 82,519 tonnes would be recycled/composted. Residual waste would be 23,275 tonnes. The biodegradable portion of this would be 15,827 tonnes. The LATS maximum amount for 2020 is 16,000 tonnes. (Note that the proposals by PFoE are actually for 83% recycling). Surely this is a much more environmentally friendly and more economic than the current proposed incinertor route. Comments please.

A. The working group has committed to aspiring to achieve in excess of 65% recycling and composting, if more can be achieved then the council would strive to achieve these stretched targets. If 78% could be achieved then that would be excellent news and much less material would require final treatment. Unfortunately even if 78% recycling of kerbside material were achieved, there are other waste streams handled by the council which are not as easy to recycle. This means that we won't be able to meet the LATS requirement without further treatment. In any case, landfill capacity within the city will run out within the next few years, so either the waste must be treated within the city, or we must transport it out to somewhere else. Treating the waste locally is seen as the more sustainable option.

Q38. How can the PCC claim that an incinerator is carbon neutral, perhaps even positive? It is obvious that an incinerator will cause the emissions of vast quantities of CO2.

It would prevent the emission of methane gas from landfill sites methane is 21 times more potent than carbon dioxide as a climate changing gas
It would prevent the emissions caused by transporting waste to landfills outside the city when the site in Peterborough is full in a few years time.
It would displace energy generated by conventional means (coal, oil and gas), by generating electricity and hot water in the proposed Combined Heat and Power (CHP)
It should be noted that international guidance states that short cycle carbon dioxide (carbon of plants, paper and card etc) should not be included in the calculations as these emissions are reabsorbed during new growth.

The following quote from p. 218 of the Stern Report may be of interest:

"Waste is currently responsible for 1.4 GtCO2e/year, of which over half is from landfill sites and most of the remainder from wastewater treatment. Reusing and recycling lead to less resources being required to produce new goods and a reduction in associated emissions. Technologies such as energy-recovering incinerators also help to reduce emissions."

Q39. An incinerator for Peterborough would destroy valuable materials. It requires three times as much energy to manufacture a new piece of paper than the energy retrieved by burning it, 5 times for plastic and 6 times for textiles. It is much more energy efficient to recycle a material than it is to burn it.

Q40. Incineration undermines recycling potential. An incinerator needs a high calorific fuel source. It needs to be supplied with paper, cardboard and materials derived from fossil fuel sources. Experience in other parts of the country has shown that an incinerator severely reduces the ability of a town or city to increase recycling levels.

A. The proposed facility is being sized appropriately for the needs of the waste under the control of the council and will not be bigger than is necessary. It will be sized so that we will not have to put recyclable materials in the facility to keep it running, but can instead work towards our goal of over 65% recycling and composting, which can not be seen to be low by any comparison. Although in the past some areas have not placed enough emphasis on recycling, there is plenty of evidence from countries such as the Netherlands that high recycling rates can be achieved along side such facilities.

Q41. An incinerator would be an expensive option to the council tax payers of Peterborough. The capital cost of an incinerator will be approx £38 millions and the running cost will be £4.75 millions p.a.

Q42. Incinerators have a very poor track record. There are many hundreds of documented accidents and incidents at incinerators around the country and around the world. Many have been forced to close. The incinerator in Nottingham has had 32 emission breaches in the last 4 years, including 5 during December 2006.

A. Incinerators run to modern standards under the PPC permitting regime are much cleaner and safer than much of the older technology that is no longer in operation within the country.

Q43. Best option is to increase recycling and reduce the amount of waste generated per household. New EU legislation re overpackaging and manufacturers changing to materials which can be more easily recycled will assist the recycling rate to climb and the waste stream to reduce. There are already many examples of recycling rates of over 70% around the world and the UK. For instance some regions of Italy are already recycling in excess of 80%. Other countries, regions and cities have adopted zero waste goals, for example Bath and Somerset in the UK.

A. The proposals are indeed for a high recycling and education led strategy. The council will continue to work with central government and retailers to reduce packaging, but some of these issues are outside of the scope of the council's control. With RECAP (Recycling in Cambridgeshire and Peterborough) and other partners the council continues to work to change shoppers' attitudes through the smart shopping and slim your bin campaigns.

Q44. The people of Peterborough are angry about the proposed waste plans. We have been treated disgracefully and we do not want a mass burn facility, as must be abundantly clear to every Councillor. There has been no meaningful consultation with residents, we have been given partial and sporadic information presented with an obvious political bias and with the use of the term incineration carefully avoided, and it appears that even members of the Focus Groups were misled by poor information about what the term waste to energy might imply, into putting forward preferences that would have been very different had they known they were giving support to an incinerator.

The Council has had five years to come up with its proposals and there is absolutely no excuse for ignoring the known views of the general public on incineration and wasting time and money promoting its waste to energy proposal. The public have not once been invited by the Council to express an opinion on this until within two or three days of tonight's meeting and even now must be largely unaware of the possibility of making representations to Councillors in respect of tonight's meeting. I can only conclude in all the circumstances that the outcome of such consultations as there have been, have been pre-determined, and that we have been manipulated in such a way that the outcome would appear to reflect our wishes. Now that it is out in the open that the plans include incineration the Council has experienced the inevitable and fully deserved backlash via the local media.

It should not be difficult to divert biodegradable waste from landfill as required under EU regulations, or indeed, even more of it than the regulations require, given that the Council is planning by various means to increase recycling of biodegradable (as well as other) materials to as high a level as possible and collect and treat kitchen waste separately. The need to divert biodegradable waste from landfill has, however, been presented unremittingly as justification for a mass burn facility.

Those who have spoken out against the proposed facility in the pages of the local press, at the PECT debate or elsewhere have not challenged the need for a change in the way we deal with our waste, but have simply disagreed that the proposed facility should be a part of our plans. We are concerned about CO₂ emissions and their contribution to the dangerous problem of climate change. We are unconvinced by the energy evaluation arguments that have been put forward. We are unwilling to accept the health threats posed by toxic emissions, whether through inhalation or the consumption (by humans and livestock) of contaminated foodstuffs. We are concerned that the existence of such a facility might undermine recycling efforts. And we are troubled by the high building and running costs.

I am not aware that anyone has disagreed with a waste to energy plant per se, but the citizens of Peterborough have made it very clear that we do not want this kind.

Quite apart from the above considerations, it is the case that waste incinerators produce a large amount of ash - hazardous material that needs to be disposed of safely, either by landfilling or by other means. It is claimed that the ash and unburnt waste ("clinker") resulting from incineration can be processed into aggregates for road making. However, the secondary aggregates market is poor, and always has been, and I understand the Environment Agency is in any event currently reassessing the appropriateness of this method of disposing of these hazardous residues. It may therefore not be possible to rely on this as a solution over the longer term and we need to allow for the possibility that landfill may be necessary. I believe that every effort should be make to locate a new landfill site for post-treatment residues, whichever route the Council decides to take.

There are one or two statements attributed to Mike Brown on the Council's website that I should like to respond to, as well as statements in a letter to the press.

1. Mike Brown has claimed that an energy resource recovery facility would "result in a reduction in dioxin emissions because the electricity and heat it produces would displace that produced by conventional power stations and the transport of fossil fuels". This assertion is nonsense. The output of the power station and the transportation of fossil fuels are not about to be decreased when many new homes are being built and you certainly cannot reduce anything by adding to it. The best that alternative sources of energy can do in these circumstances is help to slow the rate of increase in dioxin emissions, although even this is debatable in the case of incineration.

Figures have been produced to show the relative amounts of dioxins emitted by incinerators, power stations, steel works and central heating. These show that dioxin emissions from incinerators are less than those from each of the other sources. I should like to know if these figures reflect the concentration levels for each source, the size of the plant concerned or the fact that there are far fewer incinerators than power stations, steel works and homes with central heating? Do they take into account the fact that incinerators have often exceeded statutory limits? What are predicted airborne dioxin levels in the immediate vicinity of a power station plus a local authority incinerator plus the possible massive PREL incinerator which could all exist almost literally side by side in the Fengate area?

2. "There are well-documented reports from a wide range of authoritative organisations that the proposed process will reduce our dependence on fossil fuels, provide energy from a sustainable source and have a beneficial impact on carbon emissions. The Health Protection Agency also says that it 'is not aware of any consistent or convincing evidence of a link with adverse health outcomes' involving these facilities."

The word "sustainable" has an environmentally friendly ring about it but is not a word that can be applied to the burning of waste, which could be considerably reduced over a period of time as a result of increased recycling, reuse and any waste reduction measures such as the recent packaging legislation, but more importantly, because CO₂ emissions contribute to climate change as well as having been linked by the medical profession to health problems amongst those living near incinerators.

The fact that the health impacts are not yet known to the HPA does not mean that they have been proven not to exist. I note that Mike Brown fails to add to his statement the HPA's rider that "it is accepted that the lack of evidence of adverse effects might be due to the limitations regarding the available data.")

I should like to know what factors have been taken into account in assessing the effect of the proposed facility on our dependence on fossil fuels. Has Mike Brown taken into consideration, for example, the fact that plastics are oil-based and will have to be replaced if we are unable to recycle them?

How does he arrive at the conclusion that the proposed process will have a beneficial impact on carbon emissions?

3. I would suggest that several comments in Mike Brown's letter to the Evening Telegraph published on 5 February do not stand up to scrutiny and fly in the face of known chemistry and physics laws. I am told that it is a fact that methane, like carbon dioxide, is a natural gas but is not more harmful ecologically; that according to the second law of thermodynamics, energy from burning waste, or indeed from any other heat-based energy source, cannot produce more energy than is expended to produce it (except in the case of nuclear energy); that his argument about the creation of energy from energy is further flawed in light of Boltzmann's law on entropy; and that, as has been well documented, any emission resulting from the incineration of dioxins and heavy metals (especially the mercury and chromium-6 present in unsorted waste) will always carry a health risk until a proven process for filtering out nano-particles is achieved.

The good news is that there are better solutions to our waste problems.

For example, some form of mechanical-biological treatment (MBT), perhaps with anaerobic digestion, is a more environmentally friendly way of dealing with our residual waste and would be far less expensive. Methane, a useful energy source, could be captured and marketed. The right MBT process could also produce a useful soil enhancing compost. The residues remaining to be disposed of at the end of the process would represent a significant reduction in the amount of the original volume (by weight) of waste feed and could be landfilled as a relatively inert material. This process would have none of the disadvantages associated with a mass burn facility. (More information about MBTs and anaerobic digestion may be obtained from the websites listed below.)

We could go further.

I wonder if Councillors are aware of the concept of "zero waste" - what it means, how to achieve it (or something close to it) and who has already adopted it as a goal to work towards? (For the convenience of anyone who is not familiar with the term, I have attached a brief description of this progressive concept from the Foreword to Robin Murray's book, Zero Waste.)

New Zealand is the first country to have committed itself to working towards the zero waste goal, and several major cities have done the same, e.g. San Francisco, Canberra and Buenos Aires. In this country, Bath & NE Somerset has aligned itself to the concept. Energy from waste is by no means excluded from the zero waste option, but the preferred choice is via a mechanical-biological treatment, whilst incineration is ruled out completely. (Further details available from the websites listed below.)

Why should Peterborough opt for an outdated and dirty process that will dent our reputation as an Environment City when we could have a cleaner, cheaper, state of the art integrated waste solution with none of the disadvantages of an incinerator?

I trust Councillors will see fit to reject this proposal - or at least postpone a decision until they have much more information than everyone appears to have been given to date.

Zero Waste - Information Sources

www.green-alliance.org.uk The concept is well discussed in the joint IPPR/Green Alliance report published in November 2006: A Zero Waste UK. A substantial read.

www.greenfutures.org.uk (select Supplements Rubbish or Resource 2020 visions and a zero waste world) Maggie Thurgood offers a most interesting vision for the future which includes a piece on zero waste. A relatively short read.

MBT / Anaerobic Digestion

www.greenpeace.org.uk Pages 20-23 of "How to comply with the Landfill Directive without incineration: a Greenpeace blueprint" gives some information on MBTs and offers reasons why landfill of separated, stabilised waste is better than incineration.

www.foe.co.uk FOE's November 2004 Anaerobic Digestion Briefing gives a useful explanation of what this process entails. About 5 pages and an easy read.

A brief description of Zero Waste

Stephen Tindale, Greenpeace Executive Director, in his Foreword to Zero Waste by Robin Murray (publ. Greenpeace 2002) describes Zero Waste as follows.

"The term Zero Waste has its origins in the highly successful industrial concept of total quality management It is influenced by ideas such as 'zero defects', the extraordinarily successful approach whereby producers like Toshiba have achieved results as low as one defect per million. Transferred to the arena of municipal waste, Zero Waste forces attention onto the whole lifecycle of products.

Zero Waste encompasses producer responsibility, ecodesign, waste reduction, reuse and recycling, all within a single framework. It breaks away from the inflexibility of incinerator-centred systems and offers a new policy framework capable of transforming current linear production and disposal processes into 'smart' systems that utilise the resources in municipal waste and generate jobs and wealth for local economies.

The right question to ask... is not (yet) whether Zero Waste can be achieved, but how can it be used as a policy driver, to free us from the disposal cul-de-sac and break through the currently perceived limits to minimisation and recycling?"

A. The strategy has been developed over the past five years and this has involved repeated opportunities for public consultation. In particular, a 'Your Waste Your View' questionnaire was distributed to all households with the August 2006 issue of Your Peterborough, the city council's newspaper. The priorities identified by respondents were: reduce pollution; reduce waste for landfilling; generate electricity from waste; reduce climate change; minimise cost to the council/tax payers; cope with future legislation changes; include extra recycling; and is of a size to treat waste only from Peterborough. These priorities helped shaped the recommendations that the all-party working group presented to the city council.

The fundamental objective of the strategy is to minimise waste by encouraging householders to reduce, re-use and recycle materials. It aims to recycle and compost over 65 per cent of municipal waste, a level that has never been achieved by any UK local authority to date. For example, the strategy includes arrangements to extend kerbside collections to include glass and kitchen waste, and the latter may be treated in an anaerobic digestion system in order to recover more energy. However, householder waste forms only about 20 per cent of the total waste being generated in Peterborough and the city council's strategy includes a process for diverting commercial waste away from landfill. There will, however, still be a requirement for a solution for non-recyclable waste.

The city council's working group received extensive education from experts approved by the Department for the Environment, Food and Rural Affairs (Defra) and made numerous site visits to consider the options for a 'final treatment' solution. Members visited facilities that employed MBT (Mechanical Biological Treatment) with both aerobic and anaerobic digestion. However, it was noticed that one plant was stockpiling its residual 'Refuse Derived Fuel' (RDF) because there was no available market for this material and the operator was considering building an energy-from-waste plant to burn it.

The Chartered Institute of Water and Environmental Management (CIWEM) acknowledges that many people have concerns about 'incinerators' but says that these concerns are based on misconceptions and an incomplete understanding of modern technologies. Among other comments it says: CIWEM considers that energy recovery from waste has a legitimate role to play in the portfolio of sustainable waste management measures. CIWEM supports wider use of combined heat and power (CHP), which represents the most efficient method of energy recovery from waste and encourages consideration of the role that it could play in reducing our reliance on conventional fossil fuels.

The CIWEM also says: Waste incineration is highly regulated at a number of levels. The Environment Agency regulates releases to the environment in England and Wales (as does SEPA in Scotland and DOENI in Northern Ireland). The EU Waste Incineration Directive 2000 introduced tight emissions standards for waste incinerators. The Directive aims to minimise the impact of negative effects on the environment and human health resulting from emissions to air, soil, surface and ground water from the incineration and co-incineration of waste, and is implemented largely via the existing permitting requirements of the Pollution Prevention and Control (England and Wales) Regulations 2000.

On the matter of 'health threats posed by toxic emissions' the CIWEM further says: Consequently, levels of dioxins and other pollutants from incinerators are now amongst the lowest when compared to other common air pollution sources such as house or forest fires, or fireworks. This is supported by Defra commissioned research on environmental and health effects of waste management which has concluded that health risks posed by incineration of waste are small in comparison with other known risks faced by most people in their daily lives. As you write in your letter, the Health Protection Agency's document 'Municipal Solid Waste Incineration' says it is not aware of any consistent or convincing evidence of a link with adverse health outcomes. The whole document provides additional comments on this topic.

Clearly, in a society where demand for energy is static, the production of energy from waste through combined heat and power will displace the generation of electricity through the burning of fossil fuels. There will also be additional pollution reduction benefits if a local energy resource recovery facility obviates the need to transport fossil fuels to power stations. Obviously, though, if people continue consuming ever increasing amounts of energy, the volume of energy production will also rise with a consequent impact on the environment.

Methane, which is emitted from rotting rubbish in landfill sites, is many times more potent as a greenhouse gas than carbon dioxide. This is one of the reasons behind the European Union's Landfill Directive.

With regard to the ash produced during the incineration process, officers are aware that the Environment Agency has commissioned work regarding the suitability of such ash for existing treatment and disposal methodologies. The Environment Agency clearly states that only in the event of uncertainty regarding the validity of the results from the approved WM2 desktop testing methodology, for incinerator bottom ash, will there be a requirement for direct testing of samples of ash. If desktop testing proves that no materials of an ecotoxic nature are present, then there is no need to consider direct sampling and testing in a laboratory. Therefore the work being undertaken is to ensure the robustness of testing regarding this material, to ensure individual sources are compliant with the recycling or disposal method chosen.

City council officers have held talks with Bath and North-East Somerset council, in particular with regard to treatment technologies for kitchen waste. It is apparent from this talks that Bath and North-East Somerset council is also considering an energy recovery facility along the lines of the process undertaken by Peterborough City Council.

Q45. Will the council heed to the concern of Councillor Nick Sandford 'Never before have we seen such a major decision pushed through with so little consultation or assessment of the environmental consequences'? [The Evening Telegraph: Tuesday, February 27. 2007 page 15].

A. The consultation process in Peterborough dates back to 2001 when RECAP began consultations on waste management and recycling. The more recent consultations have examined which aspects residents see as most important when considering waste treatment, and the results of this were taken into account by the cross-party working group in making their recommendation. There will be further opportunity to engage with the public during planning and permitting processes. Equally, the environmental impacts of all viable treatment options were taken into account in the process of coming to a recommendation. These issues will be examined further in the Environmental Impact Assessment for the proposed facility, and this information will also feed into the planning application and the PPC permit application.

Q46. Will the councillors agree that the web-posting for questions was unacceptably brief and quietly done?

A. The website referred to was made available on Friday 23^rd February, along with the email address for sending questions in. There have since been further additions of useful information and updates to the questions & answers page. Although noon 28^th February was the deadline for questions to be answered and discussed at the Full Council meeting of the same day, the email address will remain in use and further questions will still be answered.

Q47. Why did the web-site fail to offer the working group's report referred to?

A. The report is available on the council website via the page 'Council minutes, agendas and reports' at www.peterborough.gov.uk/page-86. Choose the link to the site www.minutes.org.uk, select Peterborough City Council, then on the next page select the option 'Reports' and then choose 'Council' from the selection list, and click start the search. The report comes up as 'WasteReport'. It has recently been updated so that the images are visible.

Q48. The web-posting concludes 'I encourage all residents to consider the information and evidence that has been made available so that they understand the facts of the issue.' How does the council match its statement on 26 February with the realistic possibility that residents had the chance to respond in any meaningful way?

A. There will still be plenty of opportunity for residents to consider the information and evidence and get to understand the facts of the issue after the Council meeting of 28^th February, and residents will still be very welcome to respond by emailing or writing to the 'yourwasteyourview' team.

Q49. Why is the council not being offered options, with pros & cons?

A. The cross-party working group which prepared the recommendation has considered a variety of options and their associated pros and cons in coming to their conclusion. They considered a large number of factors, including the views of residents expressed through consultations, the environmental impacts and cost implications of the options. The report to full Council details the options considered and the reasons for choosing the proposed options.

Q50. Is there indeed no plan B if the present proposal is turned down?

A. If the present proposal is turned down the council will return to the other options detailed in the report and reconsider these options.

Q51. A combined heat and power energy resource recovery facility is spoken of without proper analysis of type, size number or location. Should not such details be available for public comment before deciding to proceed on that path?

A. As detailed in the report, the proposal is for one facility only, at one of two potential locations. One of these locations is the council-owned site on Fourth Drove, Fengate; the second is in the south of the city but has been kept confidential for commercial reasons. The plant will be sized appropriately for the waste produced in the city. The final size is not expected to be more than 75,000 tonnes per year. The matter of the specific type of plant will be addressed in the procurement process, and it would be inappropriate to name a specific technology type at this stage.

Q52. Will the Council exercise the precautionary principle, on behalf of the residents, rather than adopt the Health Protection Agency's position that it 'is not aware' of health implications?

A. In fact the full sentence from the HPA's position statement that these words are extracted from reads rather differently "The Agency has considered studies examining adverse health effects around incinerators and is not aware of any consistent or convincing evidence of a link with adverse health outcomes."

Q53. Will the council acknowledge that there are no safe levels of such pollutants as dioxins which are highly persistent and that any extra/increased sources are against the public interest?

A. Substances such as dioxins are acknowledged to be potentially harmful even at very low concentrations. However, the Environment Agency and other bodies have established that there is an acceptable level called the Tolerable Daily Intake (TDI), which is 2 picogrammes per kg of body mass. 1 picogramme = 10^-12 grammes, or one million millionth. A typical actual annual exposure is 0.9 picogramme per kg of body mass. This is evidently vastly smaller than is considered tolerable. Dioxins are emitted from many processes, including diesel engines and cooking in the home, and the levels from the proposed facility will be exceedingly small it is expected that there will be no significant increase upon background levels in the area.

Q54. Will the council agree that as a small rural city Peterborough now has reasonable air quality compared with major industrial conurbations and hence addition of hazardous air-born pollutants is not to be taken lightly?

A. The council agrees that maintaining good air quality within the city is very important. Emissions from the proposed facility will be very strictly controlled by the Environment Agency incineration process emissions are more tightly controlled than any other industry. The Environmental Impact Assessment that will be carried out will consider the issue of emissions generally and specifically also the impact upon local air quality. This assessment will feed into both the planning application and the PPC permitting process.

Q55. As an Environment City, which comes first: The health of its citizens or a quick fix in adopting the current fad for incinerators?

A. As an Environment City there is no "which comes first" from health against an alleged quick fix for a waste problem. The proposal is for an integrated solution including a commitment to one of the highest aspirational recycling and composting targets country wide. This can not be considered to be a "quick fix" as it is the result of over 5 years of work by the group. A well run modern facility of this nature poses no risk to the population, and is regulated to such a degree that this will remain the case, throughout its operational lifespan.

Q56. At the PECT meeting a speaker from Nottingham made clear that incinerators are not the slick economic solution that the industry would like us to believe. Has the council really done its homework sufficiently? For instance will the energy generation really pay back the economic investment?

A. Peterborough City Council can not comment on the specific economic position of a facility run by a private operator in another city, as costs and income streams will be specific to their individual case. However the business case for the overall integrated waste management system includes both savings from avoided landfill charges and taxes, along with income from materials recycled and recovered through all of the facilities proposed to be a part of the long-term plan.

Q57. Will council members recall that past brickwork high chimneys did not disperse emissions for dilution at altitude, but too often the emissions came down to ground within a short distance to be breathed in by the residents, workers and visiting shoppers? (average GB pollution levels are meaningless at local level).

A. The facilities proposed will be operated to the highest modern standards, and as such no comparison can reasonably be drawn with brickwork kilns operating a number of years ago.

Q58. Will the council recognise that the effect of emissions and fall-out on wildlife is unknown? (the district has important wildlife conservation interests, and some species of wildlife are much more sensitive to pollution than others, and in comparison to man).

A. The council fully understands the importance of the potential effect that emissions can have on both the population, and the wider environment, including wildlife. As such any Environmental Impact Assessment, or Environmental Statement, drawn up for a proposal will have a considerable amount of information on this subject. For example it will cover, but not be limited to, traffic effects, visual impact, emissions to air/land and water, climate, material assets, cultural heritage, humans, flora and fauna, geography and the landscape, and interactions of these areas. In addition it will cover the techniques used to minimise these impacts and more. This process is an open and public process and the council will encourage all people who wish to get involved.

Q59. Why not agree to raise the level of Dogsthorpe landfill to allow time to reach public agreement on the longer term strategy?

A. The site at Dogsthorpe is already subject to an application for over tipping and therefore, should this be approved, no more space could safely be made available for tipping of more waste.

Q60. Noting that parts of the city authority area will be below sea level by the end of the century, and that serious worries about flooding will grow, why not use non-hazardous waste to build up land as flood defence and, once settled makes provision for land uses that would otherwise be impractical.

A. Unfortunately the use of this type of waste (household waste) for this purpose is not allowed. This is because, although the waste is classed as 'non-hazardous' there are still many potential issues, such as leachate from the built up land escaping into watercourses, pockets of explosive gases collecting under buildings and uneven settling posing a hazard for any construction on the site

Q61. Has the council properly considered the economics of energy production from methane bled from landfill?

A. The landfill site which the council uses already captures the methane produced and uses it to generate electricity. However the landfill site is run by a private operator, so unfortunately the council does not receive revenue for this.

Q62. Will the council accept that it is confusing importance with urgency (Yes, the issue is important and deserves full meaningful public consultation, but it is not over-ridingly urgent)?

A. The council believes that this matter is both important and urgent. It is urgent because of the constraints on landfill that the city faces:

Landfill in the city is due to run out in the next few years. We urgently need a solution to treating waste within the city if we are to avoid the costly and unsustainable process of transporting waste large distances outside the city to other sites.
European legislation imposes tight restrictions on the amount of biodegradable waste which is allowed to be sent to landfill. If the council exceeds its quota it will face annual fines starting at around £1 million in 2009/10 rising to £6 million in 2019/20.

We need to make sure that we have a treatment facility in place soon so that we can deal with our waste without having to landfill.

Q63. I would like to express my point of view about the waste problem: I recently moved to this country and although the UK is one of the richest nations in the world, I find it really bad as a recycler as everywhere else in Western Europe/US/Canada you find separate big bins for each product (glass/paper/metal/ plastic) but here we only have that big green bin for everything which is also impractical as it will require someone to go through all the garbage and separate what is what which implies cost of hiring people and time spent unnecessarily. Furthermore, I feel awful for throwing away items that are not accepted like plastic and I find this opportunity to express my point of view that this town should concentrate all its efforts into recycling and that was Peterborough will also serve as a (good, green) example to be followed by other towns along the nation.

A. The Members Waste & Recycling Working Group considered a range of options when choosing the current green bin recycling system. They chose the green bin because it is simple and easy to understand. This leads to high numbers of people recycling and good capture of recyclable materials.

Another consideration is the practicality of having lots of containers for different materials. Many of the houses in Peterborough are small terraced houses which do not have much space to store additional containers. By having just one container for all recyclable materials we will be able to start collecting additional materials without having extra containers and taking up more space.

Although the system we use means that the materials must be separated at the Materials Recycling Facility, much of the work is done mechanically rather than by hand. There is, however, some requirement for manual separation. There is cost and time involved in sorting the materials, but there is also a cost to providing many separate containers to residents and cost and time impacts to providing separate collections or specialised vehicles for keeping materials separate. Councillors took all of these factors into account when choosing a recycling system for Peterborough.

We very much appreciate that many residents in Peterborough would like to be able to recycle more materials than is currently possible. We are very happy that people are so conscientious. We are always looking at ways to introduce more materials for recycling, and this is part of the integrated waste management strategy recently approved by the council. In particular we hope to be able to take glass in the green bin sometime later this year, and are also closely investigating the possibility of taking more types of plastics.

Q64. I should like to know when the new pages on the Council's website in relation to the waste proposal, PECT meeting and tonight's Council Meeting first appeared - including the long awaited and long overdue invitation to the public to send in their comments and questions in connection with the agreed proposal by noon today? How and when were the public alerted to the new pages?

A. The pages on the website, along with the email address for questions, were originally posted as a pdf document on Thursday 22 February and expanded as separated web pages on Friday 23 February 2007. A press release was issued on Monday 26 February. All question received by 12 noon on Wednesday 28 February, together with answers, were made available to all councillors prior to the council meeting that evening. The council is continuing to answer and publish questions and answers on the website.

Q65. How come the plan for a greener, energy making incinerator plan proposed by Global Olivine last year was so profoundly opposed, when now you have rushed through plans that you want to do exactly the same thing. Surely the plans from last year would have been so much better for the environment and the people of the Peterborough area?

A. The plans for an integrated waste management strategy for Peterborough, which includes the proposal for an Energy Resource Recovery Facility were put together by the Members Waste and Recycling Working Group after over four years of deliberations. They have had presentations from representatives of Defra, visited plants in the UK and Germany, and seen detailed work carried out by specialist consultants. The final proposal was the end result of a large body of work.

The plans for an Energy Resource Recovery Facility (ERRF) are considered to be beneficial for the environment because they will greatly reduce our need to landfill waste, which releases large quantities of methane to the atmosphere methane is much more potent than carbon dioxide as a greenhouse gas. It also eliminates the need to transport waste outside of the region when the landfill sites are full, therefore preventing vehicle emissions. The ERRF will also provide an additional benefit by generating heat and electricity which could be used locally.

The city council, as a Waste Authority, is unable to comment on an application for planning permission made by Global Olivine. The Global Olivine application was considered by the city council's planning committee as Local Planning Authority on planning grounds, including issues such as archaeology, the presence of water voles, transport, the flood plain, and Flag Fen. The city council's views were then submitted to the Secretary of State for Trade and Industry, who is responsible for deciding the Global Olivine application.

Q66. The way in which the Council's notes on the PECT meeting are presented shows a clear political bias, e.g.

i) Choice of words to describe the utterances of different speakers:

Mike Brown is reported to have "made presentations, said, described, explained, produced figures", whilst those who opposed the inclusion of an incinerator in the Council's waste proposals are reported to have "claimed, remarked, demanded to know etc". I seem to remember that Mr Brown made a few claims of his own but does not refer to them as such.

ii) Exaggeration and misrepresentation:

It is not true that John Sweeney "rebutted many of the statements made by Mr Beresford". He disagreed with some of them.

Mr Beresford did not claim that incinerators give out "over 1,000 poisons". I do not recall his exact words, but "over 200 chemicals" as reported by the Evening Telegraph sounds about right.

Andrew Plummer did not say that it would be "helpful" to have one coherent technical document setting out independent advice. He said this was "essential".

iii) Omissions:

It was evidently inconvenient to report Mike Brown's stated belief that emissions from the type of incinerator that is being proposed are "invisible, clean".

It was reported that Jon Sweeney (Environment Agency) "pointed out that currently waste was tipped into landfill and presented a risk of contamination of groundwater sources while the treatment being discussed would incinerate the waste." I note that Mr Sweeney's incorrect and unchallenged later comment that furans and dioxins are produced by landfilled waste was not reported.

A. The notes on the PECT meeting on the website were taken by council officers who attended the meeting and have been provided to allow members of the public who were not able to attend to get an overall impression of the proceedings of the evening, so that they could avail themselves of the same information and form their own opinion on the proposals.

i) Choice of words: With regard to the use of words such as 'claimed', this type of language has been used to distinguish between facts and figures for which a specific source was quoted and those for which none was given and which are therefore more difficult to substantiate. The notes aim to treat all parties equally.

ii) Exaggeration and misrepresentation: In order to make the account as accurate as possible, it was collated from the notes of a number of attending officers, and has been reviewed by others, including parties external to the council. All were happy that the notes provided a fair and representative account of the evening.

iii) Omissions: It is important to remember that the notes are not a verbatim account of the evening, and therefore some specific comments or points may not be included. However the council believe that the notes constitute a fair and accurate representation of the proceedings. With regard to the particular examples given:

Mr. Brown's comments of 'invisible' and 'clean' referred specifically to the visual impact of the proposed facility, and the fact that the picture on the poster advertising the meeting was not representative of a modern facility.

Mr. Sweeney's comment that furans and dioxins are produced by landfill is not, in fact incorrect. These compounds are present in municipal solid waste from sources such as food, and they can escape from the landfill through a number of pathways. In addition, the combustion of untreated landfill gases may result in the further production of dioxins and furans.

Neither of these comments is mentioned in the account as they were not considered significant to the overall debate.

Q67. The consultation process has been a complete shambles from start to finish and members of the public do not feel they have been represented in the decision to include an incinerator in the proposals.

A. The consultation process dates back to 2001 when RECAP began consultations on waste management and recycling, and has included a questionnaire distributed across the whole of the city as well as focus groups where representatives from all areas of Peterborough were invited to express their views. Only recently following the long process undertaken which included a large amount of extensive work, consultation, visits and presentations has the working group been in a position to form and finalise its recommendations. For the working group to have formed an opinion prior to the completion of this exhaustive process would have been inappropriate. It was also not possible to consult on a specific type of waste treatment process before this had been agreed upon. However, now that the proposals have been passed by council, there will be plenty of opportunity for residents to express their opinions, particularly through the planning and permitting processes. In addition, the council will continue to take questions through the 'Your Waste Your View' email address and post responses on the website.

Q68. Peterborough residents were not made aware until very recently (and after the proposals were agreed) that the Council's integrated waste policy could include incineration and we have been misled since. Council officers have been very selective with the information given to residents courtesy of the local press and even now are reluctant to acknowledge publicly that the waste to energy process involves incineration. The piecemeal information we have been provided with is insufficient and misleading and shows evidence of political bias. Smear tactics have even been used on a Councillor who opposed the proposals in the local press.

A. Peterborough residents were made aware of the proposal for the integrated waste management strategy, including the proposal for the Energy Resource Recovery Facility as soon as possible after the recommendation was finalised at a meeting of the cross-party Members Waste & Recycling Working Group on Saturday 20 January 2007. A press release detailing the plans was issued on 22 January 2007 and was used in an article in the Evening Telegraph on the same day. It is important to emphasise that, at this stage, the proposals were still only a recommendation from the working group, and had neither been agreed by cabinet nor passed by council. We have attempted to provide all relevant information through a number of means, including press releases, radio interviews, postings on the council website, answering questions from members of the public, and attending the public meeting held by PECT. There has been no political bias in the decision making process or in the release of information to the public this is demonstrated by the fact that the working group was made up of one member from each political grouping. All but one was in agreement on the proposals. Similarly, the proposals received support from all but one group when they were voted on at council on 28^th February.

Q69. Residents need to be confident that Councillors have been given all the information needed to make a decision on this issue that is fair to the public.

A. The councillors on the working group have received a thorough grounding in waste management in general and waste treatment technologies in particular over the past four years. They have received presentations from Defra's appointed consultants (Enviros), visited a representative selection of waste treatment plants and been presented with the results of detailed work carried out by specialist consultants Atkins. They have also taken into account the estimated financial costs of the options, the environmental impacts, and the views of residents expressed through the consultations held to date. All of this information has enabled them to make an informed recommendation to the council on the way forward for waste management in Peterborough.

In voting on the recommendation at full council on 28 February, all councillors were aware that those who had made the recommendation were well informed and in a good position to make a suitable recommendation. All members were given a report which contained the details of the proposal, a document containing the information provided on the website, including the questions & answers section, and the presentation and notes from the PECT meeting. A supplement was also provided containing the questions received through the website up until 12 noon that day, and the responses. In addition, a pack was provided to each political group containing full details of the work leading up to the proposal including:

The Strategy for dealing with Municipal Solid Waste in Cambridgeshire and Peterborough;
Peterborough's Recycling Plan from the Joint Municipal Waste Management Strategy;
The Cambridgeshire and Peterborough Waste Local Plan;
The Landfill Allowance Trading Scheme Position Statement;
The Landfill Allowance Trading Scheme Trading Policy;
Consultations;
Deliberations of the Working Group.

Q70. Council officers and some Councillors appear to be desperate to ensure that Peterborough gets its proposed waste to energy facility. I am wondering if Chris Williams (PREL) may have been right when he suggested at the PECT debate that this proposal was being recommended to Councillors in an attempt to head off Global Olivine's attempts to build a mass burn facility in Peterborough. (If this is the case, such a plan could backfire badly because we might end up with two incinerators, both unwanted by residents.) Or perhaps it is a question of the easy option being the first choice?

A. The city council as a Waste Authority is formulated its own plans and these are entirely independent of Global Olivine's application. It is possible, depending on the outcome of the planning process, that two waste treatment facilities may be sited in the area.

Any planning application for Global Olivine's facility is likely to be dealt with by the Secretary of State and the Environment Agency will deal with licensing the plant. The city council as a planning authority has no control over whether Global Olivine's plans come