Introduction

The first step for the States of Guernsey is to define an objective for the waste disposal strategy, which may not be the same as the objective identified in 1994. At that time the primary goal of the Waste Strategy was to conserve landfill space. It could be argued that other goals, such as the conservation of natural resources, or the minimisation of emissions of greenhouse gases, that reflect our Island’s global responsibility, would be more appropriate corporate aims.

Having agreed on the objective(s), alternative options can be measured against these.

Escalating cost

In 1998 the Board of Administration told the States that the Energy from Waste plant would cost £14.6 million, and process waste at £56 per tonne. At that time they were instructed by A&F to find a Design/Build/Fund and Operate contractor, but by the time they returned to the States in 2002 that had changed to a Turnkey Operator. The States were told in 2002 that £25 million had been set aside for the project. In 2003 the tenders that were received were in the order of £100 million, so then the Board had to decide to ignore many of the strictures set by the Planning Enquiry, for example on the appearance and siting of the plant, and make compromises on the incinerator specifications that the States had agreed upon, and on the operating risks and procedures, in order to reduce the tender price down to £80 million.

Changing criteria

The Board of Administration’s Energy from Waste plans changed direction many times over the last 6 years, responding to new circumstances and situations, and given what we now know about the financial consequences of the decision of the States in 1998, we should consider taking another change of direction, possibly going back to the original instruction for a design/build/fund and operate contract, possibly putting more emphasis on waste minimisation, separation, sorting, reuse and recycling.

Waste Heirarchy

The internationally accepted Waste Hierarchy is well recognised. In descending order, waste should be dealt with initially through waste minimisation techniques; then Reuse – which is where the Civic Amenity sites come in; then Recycling – the glass, aluminium, paper and aggregate recycling, and the Materials Recovery Facilities; then waste Reduction by compacting, or heat treatment with energy recovery, and finally disposal of the residue. So an important part of the heat treatment, or incineration, process, is pre-sorting. All modern incinerators have some sort of pre-sorting front-end machinery, except that planned for Guernsey. It was specifically excluded from ours – (see the Board’s tender brief on September 2003 Billet page 1783, para 3.1: “No front end sorting line”). The reasons may be linked to our high employment, but even that situation is now changing; and automated pre-sorting machinery is technically available.

Producing Enough Waste

The amount of waste that we produce is strongly linked to population numbers, and the accepted international average within the western world is one tonne of waste per person per year. From this the Board calculated that the amount of combustible waste we produce is around 50,000 tonnes per year, and this is the figure they have projected for 2006. 50,000 tonnes per year is at the extreme bottom end of commercial operating viability for mass burn incinerators. The smaller the incinerator capacity, the greater the pollution control element of the cost, as a percentage, and the less efficient the process. So for 70,000 tonnes per annum upwards, mass burn incineration with energy recovery may be accepted as the best available technology; however for volumes less than this, other types of energy from waste incinerators, those with mass produced modular systems, are more efficient and more appropriate. Juniper has acknowledged this in their report circulated by the BOA in 2002.

We believe that the Island will struggle to reach waste levels that would justify a mass burn incinerator. Martin Engineering Systems has thrown doubt on the calculations of the calorific value of the waste – not by speculation, but by measuring it at Mont Cuet. The BOA have not published any reports on calorific values, or detailed any of their research in this area. If the figures produced by MES are correct, this mass burn incinerator of Lurgi’s will not work efficiently, and the running costs will escalate.

Disposal Costs

The Board is justifying the steep increase in refuse disposal costs as a Polluter Pays charge. It is not. The Polluter Pays mechanism is an instrument to encourage people to pollute less, allowing them to offset charges by, in this instance, producing less waste. But under the proposed charging system, you will pay the same refuse rates as your neighbour even if you recycle all your waste, and he puts out two bags at each collection. And in fact, if everyone goes the extra mile and cuts down on the refuse they put out for parish collection, the operating costs of the incinerator will go up, and charges to ratepayers will actually increase.

There is also the issue of Who is the Polluter? There seems to be an assumption that the polluter is the end user, who has to dispose of the product or material. We would argue that responsibility should also be accepted by the manufacturer, the importer, and the retailer, as well as the user (and re-user).

Where people have no choice about the products they buy, and the accompanying packaging, they do not have a choice to avoid creating waste. There should be financial advantages in choosing to use products and materials that are recyclable or non-polluting, that do not put a strain on the ecology of the Island or demand resources to deal with their disposal. But if there is no choice, the refuse rate is merely a tax, not a polluter pays charge, and can not be used to reduce waste production.

Recycling incentives

Linked with these issues is the need for government encouragement to reuse items wherever possible, by creating the necessary facilities to do so, and promotion of the use of recycled products in order to encourage recycling markets.

There is no financial incentive under the current proposals for anyone to cut down their waste, and no way to avoid refuse rates forecast to double or treble current rates. The obvious disposal route that avoids charges of £100-£145/tonne is to dump it down a cliff, or in a field when no-one is looking. Fly tipping is already blighting our island, and the Control of Pollution legislation relies on being able to identify the dumper, which is fraught with difficulties. Uncontrolled garden and commercial bonfires will also proliferate, pouring toxic emissions into our environment and upsetting whole neighbourhoods.

Running the Incinerator

The Waste Management Plan claims to aim to encourage recycling in order to avoid expanding the incinerator at some time in the future. The problem is that the Special Purpose Committee set up to run the incinerator will have different priorities from our society – the more waste they burn, the cheaper it will be to run. The States has already agreed to the principle of waste reduction within the agreed Waste Hierarchy. In 1998 the States directed the Board to get on with composting, recycling, reuse and materials recovery, in line with the Waste Hierarchy. We need to start implementing the recycling parts of the Solid Waste Management Plan as soon as possible. At the same time we must reassess whether we really do have enough waste to keep a mass burn incinerator running, and if not, what other forms of thermal treatment may be more appropriate.

Public Facilities

In order for the public to give appropriate priority to reuse and recycling, the composting, Materials Recovery and Civic Amenity facilities need to become part of the local culture well before the throw-away mentality of incineration is introduced.

Putting the Cart before the Horse

We want to avoid any delay that reduces the landfill capacity for residue disposal, but even so we would suggest that it is madness to specify the size of incinerator we need before we have a Solid Waste Management Plan in place.

Alternatives

In 2000 Juniper produced a major report on Pyrolysis and gasification in which they forecast that advanced thermal technology is set to replace mass burn incineration by 2008, and that more than 200 new plants will be built between now and then, typically dealing with more than 100,000 tonnes of mixed domestic waste a year.

There is currently a surge of interest in developing alternatives to mass burn incineration, and the reason runs deeper than the unpopularity of incinerators with the general public. In hard economic terms, the financial commitment of commissioning and operating a mass burn Energy from Waste plant is a heavy burden on a community. Sustainability is not only an ecological goal, it is also an economic one, and the main problem with small scale conventional incinerators, such as that proposed by the Lurgi, is that the emissions cleaning equipment is proportionately a very significant part of the financial cost of the whole scheme. Emissions cleaning equipment is itself a rapidly changing and developing market, and although the wet scrubbing system that is intended is currently one of the most effective, there are still several unresolved difficulties with the waste residues: namely the issues relating to the toxic fly ash, and the problem of how to deal with all the contaminated waste water and sludge that the wet scrubbing system generates. We should remember that whichever system we decide on will be financed by future generations, and we should keep firmly in mind the financial burden we will be leaving to our children if our currently buoyant economy should ever dip.

One of the attractions of the alternative technologies is the built-in safeguards in having a modular system. Each factory-built unit in the module is identical, and we can start with 6, 8 or more units as necessary, we can use individual modules for selected waste streams such as clinical, sewage sludge or tyres, or we can mix it all together if we prefer, and if one unit has to be closed down, the remaining units will continue processing waste. The Mass Burn Incinerator is expected to guarantee 90% availability over a year’s operation. This allows for 5 weeks of down time per year. With a modular system there is much less risk of the whole process being shut down at the same time, and the modular design means that we do not need to test multiple units in tandem when we know that all the units are identical. We can tailor the amount of units we run to the amount of waste we produce, and it is hoped that we can, through Waste Minimisation and Producer Responsibility initiatives, eventually start to reduce the amount of waste we produce.

From an environmental point of view the new technologies also appear to be less polluting, partly due to more extensive front-end sorting. There are opportunities offered by this new technology of increased recycling, where it is economically and environmentally justified, with bolt-on, off-the-shelf, automated front end separators. We note that the Board preferred to exclude any front-end separation of waste, but the best environmental option requires that as responsible global citizens we recover and reuse materials wherever possible. Other points which make the new systems more attractive are the smaller footprint, the higher emission standards, less toxic waste to dispose of at the end of the process, quicker commissioning period and cheaper overall price and running costs.

If these newer technologies are not sufficiently proven at this time, it may be that export to a European incinerator for 3 - 5 years would buy us enough time to ensure that we decide on the best solution for Guernsey in the end. Exporting to feed these large incinerators would help to optimise their efficiency, and allow their emission control equipment to operate to higher standards.

Aesthetics

Our final point is on the appearance of the plant. The States were shown a scale model of the original architectural concept, which they approved in 2002. Many members did not appreciate to what extent that concept had changed before the endorsement of that decision in 2003. The architectural design no longer complied with most of the recommendations of the Longue Hougue Outline Planning Brief. It would be useful for the Review Panel to take a look at the Billet D’Etat V 2002, Wednesday 24th April 2002, which is the Planning Inspector’s report to the Island Development Committee on the Longue Hougue Land Reclamation site, particularly Amendment Schedule No.1.

The section ‘Achieving Good Design’ was a particularly important element of the decision to proceed with the incinerator at this location, yet almost all those recommendations have subsequently been ignored in an effort to save costs. The Island Development Committee had grave reservations over the final design, which the Committee was unable to enforce due to the strategic nature of the incinerator. Friends of the Earth believe that the Review Panel should revisit the design and consequential implications on the eastern ‘gateway to the Island’, and seek to ensure that, whatever processing plant is ultimately decided upon, it complies with the principles of good design and integration with the character and heritage of the eastern coast.

Michelle Levrier

Waste Co-ordinator, Friends of the Earth Guernsey