11 Waste

Comment

Representation ID: 11014

Received: 20/09/2021

Respondent: Mr Richard Carter

Waste management needs to be simplified and less restrictive. In addition to maximising the amount of waste that is recycled, re-used and recovered, greater emphasis is needed on converting waste to heat and energy; the output of which could be used in district heating systems (as an alternative to installing electric boilers. Sources of bio-mass include garden waste, which should not be charged for, and vegetation obtained from copicing all areas of woodland, recreational land and wasteland and the collection of leaves from all areas including the streets. CO2 emissions etc can be controlled using capture systems.

Comment

Representation ID: 12353

Received: 01/10/2021

Respondent: Christine Leahey

Document Ref. Strategic Allocation WSA3, Site WAH237/ WAH235

There are no existing drainage amenities suitable for such an extensive development and any development will directly contradict your principles of delivering landscape, biodiversity and amenity benefits.

Comment

Representation ID: 13634

Received: 28/10/2021

Respondent: Gloucestershire County Council - Strategic Infrastrucure (Minerals & Waste)

Minerals and Waste Policy officer comments

All of the details set out within this section are made by officers on behalf of Gloucestershire County Council in its capacity as the Mineral and Waste Planning Authority (MWPA): - Gloucestershire County Council in its capacity as a WPA is supportive of the Black Country authorities overall ambition to update their local planning policy framework (including for waste). However, this
position is subject to the retention and/or inclusion of local policies that would not have a detrimental impact on the existing capacity of local hazardous waste management infrastructure, particularly to accommodate the usual trend in hazardous waste being received from within Gloucestershire. Should this not be the case as the new Black Country Plan evolves, Gloucestershire County Council may not necessarily raise an objection. However, the County Council would be very keen to enter into dialogue with the Black Country authorities in an attempt to reach a mutually agreeable planning strategy for the
future.

Recommended action - N/a
Conditions recommended by officers on behalf of the MWPA (if advised) -N/a

Comment

Representation ID: 18902

Received: 25/09/2021

Respondent: Mr Richard Carter

Waste management, energy and district heating have been included in the discussion on industrial strategy because:
• Direct correlation exists between the three subjects. That is, an efficient, standardised and all-encompassing waste management strategy provides a substantial amount of the fuel required to produce both energy and district heating.
• Waste management should already be a highly co-ordinated and efficient industry- but it isn't!

Throughout, the word "recycle" and its derivations should be taken as meaning a generic term that encompasses three distinctly different, but mutually compatible ("R" based) elements:
• Reuse: taking an item in its current form and using it again for the same purpose, e.g. glass milk bottles.
• Repurpose: taking an item, changing it to some degree and using it for another purpose, e.g. turning a tennis racket into a serving tray.
• Reprocessing: taking an item and turning it into something else, e.g. turning CO2 into
Calcium Carbonate or Carbon and Oxygen.

It is recognised that the UK has an aversion towards waste incinerators. However, providing that all incinerators are linked to waste to energy and heat systems, and are fitted with efficient emission capture and reprocessing technology, they become an important component of all waste management strategies. At some point, there will always be combustible material that cannot be recycled and, in all such cases, only two other alternatives exist:
• Place it in land-fill. Land-fill sites and their emissions have to be managed and, additionally, land-fill places restrictions on use of the land for other purposes, e.g. it cannot be built on.
• Pay another country to dispose of it. Shipping waste to other countries increases waste disposal costs, increases harmful emission and is a pointless exercise primarily because, in all probability, the recipient country will use the waste to fuel their own waste to energy and heat plants.

Along with many other areas of responsibility, waste management will only be fully effective upon the introduction and implementation of national policies and strategies. Local authorities cannot, on their own, enact and enforce standardised recycling strategies that have broader scope and appeal and that are likely to succeed and be of benefit to the whole of society.

The following situation serves to illustrate what is meant by this statement. Local authorities can sporadically install plastic, metal and (possibly) glass beverage container recycling points which
may or may not be used. Only national policies can incite beverage manufactures, retailers and the general public to (once again) become involved in recycling schemes whereby:
• Only 100% recyclable (reuse or repurpose) materials are used in the production of beverage containers.
• A small deposit charge is included in the price of all glass and residual plastic beverages - the details of which are printed on the beverage container.
• Recycling points are installed in shopping centres, supermarkets and other suitable retail outlets.
• The recycling points print vouchers; the value of which is determined by the deposit value of each container processed (assessed by barcode lookup), which are accepted as part payment for shopping.
• Less recyclable waste is collected from households etc because beverage containers have already been processed at the recycling points.
• Less litter is deposited.
• The need for local authorities to collect litter is reduced because others, who wish to benefit from the deposit scheme, will have collected the beverage containers already.

Waste Collection:


Currently, waste collection throughout the WMCA is a complete mess and it's no wonder that fly• tipping is rife. Someone can move 100 yards to the next street and have a completely different regime thrust upon them - identifying which authority is responsible for waste collect is also an issue. For example:
• WV14 7NA (Bilston):
• Wolverhampton postcode.
• Waste collection administered by the City of Wolverhampton Council.
• Grey bin = recycling, collected alternate weeks, e.g. week 1.
• Green or brown bin= general, collected alternate weeks, e.g. week 2.
• Purple bin= garden, collected with grey bins, February to December, cost £35.
• Bins must be available by 07:00.
• WV13 2HP (Willenhall):
• Wolverhampton postcode.
• Waste collection administered by Walsall Council.
• Grey bin = general, collected once a fortnight.
• Green bin = recycling, collected once a fortnight with the grey bin.
• Brown bin= garden, collection starts in April, cost unknown (can't find the information on the website!).
• Bins must be available by 06:30.


Additionally, too many restrictions are placed on the type of waste that will be collected and under what circumstances the waste will be collected. For example, Walsall's requirements are:
• Bins must be placed at the edge of your property.
• They will not collect bins if they are too heavy or contaminated with the wrong items.
• All rubbish, recycling or garden waste must be in the correct bin with the lid fully closed, i.e. they will not collect anything placed on top of, or beside, a bin.

And with regard to Wolverhampton Council, you can't place textiles (worn out clothing) in recycling bins. Yet it is unclear as to
whether textiles can be placed in general
bins. Situations such as these create confusion that can only be answered by contacting the council, and possibly arranging collection at additional cost, or by making the assumption that a trip to the nearest recycling centre will be needed.

This later point creates two other problems. Firstly, if you wish to use a trailer, pickup truck of van, a permit has to be obtained first and, secondly, what happens if you have no easy means of taking the items to the recycling centre - especially when it needs to be considered that "pedestrians are prohibited from carrying waste onto this site"? The answer to that second conundrum is in the picture above! [See attachment for images]

Waste collection needs to be standardised throughout the WMCA and, preferably, throughout Britain. In addition, methods need to be employed that make waste collection more cost effective (also taking into consideration the cost of clearing up fly-tipping), easier to administer and easier for everyone to understand and that help to reduce the levels of detritus found in the streets.

Even the simple remit of placing a waste bin at every bus stop would have a positive effect on the environment.

Where space allows, communal waste collection points; which utilise high capacity Molok (or similar) containers in place of individual household bins, can provide a cost effective, environmentally friendly, flexible and proven means of collecting waste (as long as the British can be bothered to use them correctly and travel a few extra yards from their front door and vandals can refrain from setting them alight).
https://www.molok.com/benefits-and-principles/ As can be seen from Molok's website:
• 60% of the container is housed underground (this saves on space, reduces odours and compacts waste),
• Emptying involves no heavy manual labour (this improves operator safety and reduces spillage),
• The containers are water resistant and durable, reduce the number of operatives required (they can be retrained for single man operation),
reduce vehicle fuel consumption and reduce CO2 emissions.
[See attachment for images]

In addition to the advantages listed above, communal waste collection points result in more efficient and cost effective use of manpower. Currently, it takes 3 or 4 collection operatives a good 5 to 10 minutes to empty (say) 30 general waste bins. In that same time, a single operative could empty the general waste containers for an entire street. The other operatives could be retrained into single operative mode, e.g. the required drivers license etc.

If sufficient Molok containers are installed, waste can be pre-sorted into:
• Bio waste: food waste, including food that has gone bad, coffee grounds, kitchen paper, fruit peels and garden waste (produces biogas, compost and heat for energy and district heating systems).
• Paper: newspapers and magazines, advertisement leaflets, envelopes etc.
• Cardboard and cartons: milk cartons, food containers, cardboard boxes (flat-packed) etc.
• Glass: bottles and jars.
• Metal: items which are predominantly metal (but not electrical items).
• Plastic: empty food packaging, detergent and shampoo bottles, plastic bags etc.
• Mixed waste: combustible items used a fuel for waste to energy and heat plants.
• Hazardous waste: fluorescent lamps, energy-saving light bulbs, broken mirrors, ceramics, chemicals etc.
• Batteries: small and large household batteries, mobile phone batteries etc, no car batteries.
• Electronic equipment: small electric or battery-powered devices and toys etc.
• Textiles: bedding, curtains, clothes, etc. Separate containers can be provided for worn and reusable items (worn textiles can be washed and used as hobby material or to make rugs).
• Shoes.


In order to satisfy a broader range of waste management requirements, the flexibility of the
Molok containers can be augmented by 10ft (563cf), key code lockable shipping containers. These would be used for other items such as furniture, domestic appliances, mattresses, used oil, car batteries, tyres etc.

With regard to what can and can't be recycled, even building rubble and porcelain can be washed, crushed and used for footpaths, as aggregate in "building blocks" (more research required) and as foundation material etc.


https://www.agg-net.com/resources/articles/recycling-waste/building-a-brighter-future-for•
recycled-a n d-seconda ry-aggregates


Recycling Centres:
[See attachment for images]

In the UK, there is a need to redefine the term "recycling centres". Such centres need to become exactly what their name implies, i.e. centres for recycling rather than places where all forms of detritus can be deposited.

To maximise the potential of all waste collected, and items collected from other sources, e.g. factories, household clearances, donations etc, large scale, not-for-profit recycling centres (that are aligned with waste collection depots and waste to energy plants) should be established. These would capitalise on and further develop existing initiatives such as those identified in the links below:
https://www.greenwastecompany.com/
https://disposalknowhow.com/reuseful-uk/

In order to gain maximum benefit, these recycling centres will need to become a highly recognisable high street brand. Rather than directly competing with existing recycling and fund raising outlets, such as those established by the major charities, the recycling centres will providesuch outlets with a free source of marketable material. Additionally, by instituting manufacturing and refurbishing workshops etc, they will provide training and employment opportunities and free handicraft materials etc for schools. An example of such an enterprise can found in the following link.

https://www.kierratyskeskus.fi/in_english

Kierr~tyskeskus (Finnish for Recycling Centre) is a household name in the Helsinki Capital Region of
Finland. In addition to the main collection, manufacturing and retail outlet in Nihtisilta (in the Espoo municipality) it can be seen that they have shops in 8 different locations within the Region. Their services include:
• The collection and sorting of household items, furniture etc from businesses and scrap materials. All household items are checked for value and high value items are sold on to specialist retail outlets, such as antique shops, or sold via auction.
• The sale of reusable items: clothes, toys, sports equipment, musical instruments, bicycles, books, records and CD, electrical items etc. All electrical items are fully tested (and computers are reimaged) before resale and most electrical items are sold with a limited 3 month warranty.
• Manufacturing of handicraft materials. For example, off-cuts of upholstery material are packaged for sale and card is cut and
turned into greetings cards.
• Refurbishment of furniture and bicycles etc. Regarding bicycles, many are collected from periodic apartment building bicycle store clear-outs. Current residents are given advanced notice to identify and mark their property. Any items that aren't marked after (say) one month are collected and taken to Kierr~tyskeskus.
• Manufacturing of jewellery etc from a variety of items.
• Manufacturing of bespoke clothes from end of line material.
• Repurposing items, e.g. turning damaged drums into coffee tables, broken tennis rackets into trays and paper and cardboard into note books.
• Supporting society with training and "net revenue" finance.

The picture above shows Kierr-tyskeskus at the "Recycling Fair" in Helsinki on 25" April 2015.

The photographs below depict handicraft sales goods that I personally prepared from scrap material, including artificial flowers, while working for Kierratyskeskus as a volunteer.
[See attachment for images]

The concept of holding "Recycling Fairs" (not industry targeted expos, seminars and conferences) that are open to the general public and which allow businesses that produce recycled goods to sell their products, also appears to be innovative in Britain.

Waste to Energy & Heat:


In 2012, The Department of Energy and Climate Change (Emissions from Heat: Statistical
Summary, 13" January 2012) estimated that:
"In the domestic sector, the majority of heat related activities were from gas and electricity use (61.0 MtCO2e and 14.4 MtCO2e respectively), from a total of 86.9
MtCO2e.
This was almost entirely in relation to space heating (64.0 MtCO2e) and water heating (18.6 MtCO2e)."
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment data/f ile/140095/4093-emissions-heat-statistical-summary.pdf

On 5"February 2021, Statista published a report that identified the "Net CO2 emissions from transport in the United Kingdom (UK) 1990-2019 (lan Tiseo, Feb 5, 2021, accessed 10/02/2021). This report stated that:

"Carbon dioxide emissions from transport in the United Kingdom increased by roughly nine percent between 1990 and 2017 (2007) to 136 million metric tons of carbon dioxide equivalent (MtCO2e). Emissions from this sector began to decline in the following years,
and by 2013 had fallen to a low of 118.8 MtCO2e. Although emissions started to rise again,
by 2019 they had fallen to 120.8 MtCO2e. During this period, transport CO2 emissions fell by 3.7 percent, whilst total UK CO2 emissions experienced a reduction of 40 percent."
https://www.statista.com/statistics/311522/transport-co2-emissions-in-the-uk/
From these statistics; and it needs to be considered that emissions from domestic heating will probably have increased in the last 9 years, it can be seen that domestic space and water heating CO2 emissions are only 37.2 MtCO2e less than the total transport related CO2 emissions (82.6 boiler to electric boiler scheme, none of the political parties included domestic CO2 emission reduction in their recent 10 Point Climate Change Plans. Individual house are still being built with individual boilers and, chances are, even though this is a viable option, little action is being taken to ensure that existing gas boilers are hydrogen gas ready.
One obvious answer to the problem is to build scalable waste to energy and heat plants, in conjunction with improved waste collection facilities, and to require all new developments, domestic or otherwise, to include district heating in their design. In parallel, existing properties can either be retro-fitted with district heating or replace existing natural gas or oil fired boilers with electric boilers or hydrogen ready units.
With regard to waste to energy and heat plants, Woima Finland Oy's modular plant (see the link below) is capable of producing (from 150-200 tons of solid waste per day):
• Steam: 17 tons/ h (400C @ 40 bar(g)) OR
• Electricity: 3.3 MWe (gross)/ 2.5 MWe (net) OR
• Electricity: 2 MWe (net) and Thermal Energy 10 MWt. https://woi macorporation .com/techn ica I-solution/
What do these figures mean in reality?


A waste to energy plant, such as Rambol's plant in the municipality of Vaasa in Finland, is capable of processing 150,000 tonnes of household waste from 400,000 inhabitants annually and, while doing so, producing 15 MW of electricity and 45 MW of heat. This output satisfies the electricity demand of 7,000 households and 25 per cent of Vaasa's district heating demand.
https://ramboll.com/projects/re/vaasa wte
Vantaa hosts the largest waste to energy facility in Finland. This plant burns 374,000 tonnes of unusable waste per annum, meets approximately half of the city's annual district heat needs and
30% of its electricity demand, has reduced fossil fuels use by 40% and has reduced Vantaa's CO2
emissions by 20%. Vantaa's population is similar to that of Wolverhampton (233,775 versus an estimated population of approximately 262,000).
In all cases, harmful emissions are kept within EU limits.
A slight problem exists with this proposal, however. Most of the brown field sites that could be used for these purposes are being underutilised for poorly planned and executed housing or employment developments.
In addition to general waste, the heat used in district heating can be obtained from a wide variety of sources, e.g.:
• Bio waste (bio-mass), e.g. waste food, shredded vegetation, leaves, garden waste, farm waste etc.
• Gases, e.g. methane (land fill and bio-mass decomposition), hydrogen.
• Geothermal heat.
• Solar panels.
• Air source heat pumps.
• Waste heat captured from local industry, e.g. computer data centres.
Some of the additional benefits of using waste to energy and heat technology include:
• Increased employment and revenue.
• Reduced landfill.
• The residual "burn residue" can be used for building paths or in the production building materials.
• Recyclable metals.
• Compost and soil.

Comment

Representation ID: 21231

Received: 11/10/2021

Respondent: The West Midlands Resource Technical Advisory Body

WMRTAB notes that that no explicit mention is made about how the management of waste can contribute to the mitigation of climate change and, in light of national policy (and plan making legislation), suggest that this is an area in need of attention. A review of the policies to ensure they are aligned with this agenda is recommended. Such a review might consider how energy from waste facilities could be required to ensure that use of heat produced, as well as electricity, is maximised.

Policy CC5 on Flood Risk, identifies waste (and mineral) facilities as the only types of development where all such proposals would require a flood risk assessment and surface water drainage strategy. While proposals for certain types of waste facilities may need such assessment, WMRTAB suggest that the BCAs check whether this blanket approach is justified.

Comment

Representation ID: 21669

Received: 11/10/2021

Respondent: Leicestershire County Council

There are no strategic constraints that I can identify as to why these movements will not continue into the future.

I agree that the strategic levels identified are appropriate. However, I do not consider a Statement of Common Ground to be necessary in this situation.

Comment

Representation ID: 22436

Received: 26/01/2022

Respondent: Essex County Council

Please note, Essex County Council (ECC) respond to data requests with information pertaining to the administrative area covered by ECC only. Therefore, the information below does not include the unitary authorities of Southend-on-Sea and Thurrock. Any agreement with those authorities will need to be pursued separately.
ECC have compiled the data pertaining to inert, household, commercial & industrial, and hazardous waste movements from Essex to the Black Country in three tables below using the Environment Agency’s Waste Data Interrogator 2020 (2019 data) and the Hazardous Waste Data Interrogator 2020 (2019 data). From this investigation, ECC has established that the movements of waste originating in Essex to the planning area covered by the Draft Black County Plan are as follows:

There were no identified strategic inert waste movements to Dudley, Sandwell, Walsall, and Wolverhampton originating from Essex County Council WPA (totalling 5563.14 tonnes)

• There were strategic HIC waste movements to Dudley, Sandwell and Walsall originating from Essex County Council WPA (totalling 5974.77 tonnes)
• There were strategic hazardous waste movements (according to the Hazardous Waste Data Interrogator 2020 (2019 data)) to Sandwell, Walsall and Wolverhampton originating from Essex County Council WPA (totalling 3416.51 tonnes)
The guideline thresholds used to define the strategic movements of waste (above) for the purposes of duty to co-operate in the East of England (EoE), including Essex, have been agreed by the EoE Waste Technical Advisory Body. These are as follows:
Waste Type

Strategic Threshold (tpa) EoE WTAB
Total Hazardous Waste 100
Total HIC Waste 5,000
Total Inert Waste 10,000

Comment

Representation ID: 45954

Received: 11/10/2021

Respondent: The West Midlands Resource Technical Advisory Body

Best available evidence WMRTAB notes that the BCP waste policies are supported by a waste needs assessment that utilises data derived from 2017. Unless this assessment is updated it seems likely that at the time of submission of the BCP, this data could be over four years out of date and WMRTAB suggest that an updated waste needs assessment be prepared using the latest available data that may at least include that from 2020.