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Objections filed by CLAG

Below are the objections filed by CLAG. Objections 1 to 5 concentrate on a report by Jacobs Babtie on which SEERA's recommendations are based. This report seems seriously flawed. A third of the area around London, including Essex, Hertfordshire and Bedfordshire is missing from the analysis and, according to the authors of the report, most of the data used is inaccurate. Objections 6 to 10 are more general in nature and these could help form the basis of your own comments.

1/
Support or oppose: OPPOSE
Policy No. : W3
The authors of the Jacobs Babtie report ‘Towards a Methodology for Apportionment of London’s Exported Waste (final report; 2005)', on which W3 recommendations are based, state in their conclusions, section 5.1, that the methodology developed is a ‘working methodology’, that the results are provisional, and that changes in data and assumptions ‘may be made should new or better quality information become available’. The authors state in section 5.15 and 5.16, that further refinement to baseline data and sensitivity tests are recommended. Evidently, therefore, the report should not be relied upon, especially given the potential environmental impact of the greatly increased level of exported waste proposed.

2/
Support or oppose: OPPOSE
Policy No. : W3
Policy W3 recommendations are based largely on The Jacobs Babtie report ‘Towards a Methodology for Apportionment of London’s Exported Waste (final report; 2005)'. However, the authors of the report state that much of the data supplied was of poor accuracy. For example, data on void capacity and forecast arisings is described as of ‘limited accuracy’ (section 3.11). Furthermore, the report states that the assumptions required to model proximity data and sustainable transportation ‘introduce a potentially significant margin of error’ (sections 3.3 and 3.37). Together, these criteria account for 72.5% of the overall weighted suitability index on which the recommended apportionment of waste is based. Only the data supplied from the Environment Agency was described as of high quality. Yet this accounts for only 37.5% of the overall weighted suitability index (section 4.9). Without doubt, the Jacobs Babtie report is statistically very unreliable and should not be relied upon as the basis of policy W3.

3/
Support or oppose: OPPOSE
Policy No. : W3
The Jacobs Babtie report ‘Towards a Methodology for Apportionment of London’s Exported Waste (final report; 2005)', on which W3 recommendations are based, does not represent a holistic model in that a third of the hinterland of London - including Essex, Hertfordshire, Bedfordshire and UA Thurrock – is not included in the model. This means the waste targets set for the 10 SEERA WPAAs are unfairly high compared with those given above. It is illogical and unsystematic to exclude Hertfordshire and Essex from the model, and yet include the Isle of Wight. Similarly, UAs Portsmouth and Southampton are excluded, while Brighton and Hove is included.

4/
Support or oppose: OPPOSE
Policy No. : W3
The Jacobs Babtie report ‘Towards a Methodology for Apportionment of London’s Exported Waste (final report; 2005)', on which W3 recommendations are based, specifically excludes a key EiP criterion concerned with the availability of and potential for alternative recovery and disposal methods (Methodology; item 3.3). This means there is no consideration in the Jacobs Babtie model of the beneficial effect that alternative recovery and disposal technologies would have on reducing exported waste levels. WPAAs must be put under pressure to pursue alternative waste recovery and disposal – especially London.

5/
Support or oppose: OPPOSE
Policy No. : W3
The Jacobs Babtie report ‘Towards a Methodology for Apportionment of London’s Exported Waste (final report; 2005)', on which W3 recommendations are based, is not only based largely on unreliable data (see our comments above), but it then uses weightings which appear to have been chosen arbitrarily. According to the report conclusions, and Policy W3, Hampshire is expected to take 8.4% of the forecast for London’s exported waste (table 18). Yet from table 1 of the Jacobs Babtie report, Hampshire has 0% surplus void space. Where is the exported waste supposed to go? West Sussex, on the other hand, scored 8th, 4th, 6th and 7th lowest out of 10 in each of the four criteria used in the model (in other words, towards the bottom end of the group). Further, it has very limited void space available (none by 2015 section - 5.11). Yet West Sussex has been placed 4th in the apportionment of exported waste (table 17) and is expected to take 10.1% of the forecast for London’s exported waste (table 18). Therefore, the model and/or results must be flawed.

6/
Support or oppose: OPPOSE
Policy No. : W3
The projected volumes of exported waste from London to West Sussex increase the amount of waste West Sussex would need to accommodate by almost 50%. This does not appear to be achievable given the limited availability of suitable sites.

7/
Support or oppose: OPPOSE
Policy No. : W3
Rather than increasing exports of waste to the SEERA regions, London should be put under pressure to do all it can to deal with its own waste by deploying a variety of waste recovery and processing technologies. The Draft SEP summary states that recycling rates have increased by 50% over the last 5 years, and there is nothing to suggest this will not increase by at least the same rate, if not more. Policy W3 does not take this into account.

8/
Support or oppose: OPPOSE
Policy No. : W3
If West Sussex and other SEERA Waste Planning Authorities are forced to provide landfill capacity which ultimately is not needed, the over-provision of landfill will cause on-going, possibly long term problems with the filling and completion of sites. This would counteract initiatives to deal with waste more sustainably and lead to the import of waste from other areas. In both the general SEP summary and the more detailed D6 document, much is made of the requirement to reduce growth in the level of waste generated (prevent - re-use – recycle - recover) . How can this happen if we keep making accessible landfill an easy option?

9/
Support or oppose: OPPOSE
Policy No. : W3
Regarding the transportation of waste in West Sussex, very few parts of the county are accessible via good quality roads. Traffic levels are high and rising rapidly. Road congestion is increasing, and rail links are over-stretched. Therefore it would not make sense to transport large volumes of London waste into the heart of West Sussex.

10/
Support or oppose: OPPOSE
Policy No. : W3
The South Downs is a large Area of Outstanding Natural Beauty. It is, of course, unlikely that landfill sites would be located in this AONB. Nevertheless, the chances are that much of the exported waste would have to be transported through or near the AONB. This would have adverse environmental effects.