TRANSPORT AND TECHNICAL SERVICES
GREEN WASTE COMPOSTING
POSITION STATEMENT
Purpose of the Report
The report explains progress on developing a modern composting facility for the recycling of green and garden waste and gives options available for relocating the public green waste reception facility from La Collette.
Background
The Ministerial Decision (MD-T-2007-0113) of 17th December 2007 on Green Waste Composting provides explanation of the identification of La Collette as the preferred location for commercial reception and composting facilities and for the recommendation of Compound 6 Bellozanne Valley as the preferred location for a temporary public green waste site.
Progress on an Enclosed Composting Solution for La Collette
In September 2007, the Connétable of St Helier threatened to judicially review the States Public Health Department’s enforcement of the Statutory Nuisances (Jersey) Law (1999) in relation to alleged odour nuisance from the existing “open-windrow” composting operation at La Collette. As a result TTS was issued with an Abatement Notice (Ref. 08/07) on 22nd November 2007 requiring the alleged odour nuisance to be abated in 150 days.
TTS has maintained that this odour reduction could only be achieved by developing an enclosed composting facility and appealed the notice on 11 December 2007. On 28 February 2008, it was agreed that the abatement notice should be put in abeyance whilst the Public Health Department determined what acceptable odour levels around a composting facility should be.
On 7th December 2007, the Waste Strategy Steering Group - (a joint States Member / Officer working group overseeing the implementation of the 2005 Solid Waste Strategy major capital projects) considered the technology options available for the selected La Collette site.
It was observed that the key issues for the choice of composting technology were whether the chosen technology;
- was able to substantially reduce odour,
- would be affordable within the allocated £4.212 Million budget, and
- would offer value for money, given the likely limit on land tenure at the La Collette site of 10 years –in anticipation of the forthcoming East of Albert redevelopment.
The technology also needed to have the capability to be expanded to compost kitchen vegetable material in the event that a sustainable outlet for this material enabled this to be collected for composting on the Island.
The two favoured composting technologies likely to meet these combined objectives were observed to be “clamp” and “tunnel” systems. It was agreed that, given the highly sensitive nature of the site, Officers would visit example facilities and then arrange for visits by the WSSG members to suitable sites to see for themselves what was being proposed.
On 24th – 25th January 2008, the Waste Strategy Team visited three enclosed composting sites in London - two “clamp” composting systems and one “tunnel” system. The visit confirmed that all three sites and both types of system had experienced odour problems and neither “clamp” nor “tunnel” composting system was likely to be affordable.
This information was conveyed back to the Waste Strategy Steering Group on 8th May 2008, indicating that the site tours for WSSG members would be postponed until such time as the Public Health Department confirmed the odour limits that the site would have to work within to avoid causing a statutory nuisance. This was necessary as it would be impossible to select a composting technology without confirmation that it could comply with regulatory requirements.
On 22 August 2008, after a period of internal review, the Public Health Department met with the Waste Strategy Team to confirm their intention to propose changes to the statutory nuisance legislation to enable the Public Health Department to require evidence directly from site operators that they were employing “best practicable means” rather than this being referred for determination by the Royal Court. The Public Health Department confirmed further that the method for an operator of a waste site to demonstrate “best practicable means” would be likely to be proving that the operation was being carried out in compliance with Waste Management Licence provisions.
Any new composting facility would have to obtain a Waste Management Licence to operate and any condition within such a licence would almost certainly have to be based upon achievable licence conditions for operational composting sites. This undertaking from the Public Health Department gave greater confidence that an enclosed composting facility could be developed that would operate within statutory nuisance requirements. However, the Public Health Department remain in discussion with the Waste Regulator within the Planning and Environment Department regarding how odour limits should be precisely defined.
In September 2008, following the confirmation from Public Health, the Waste Strategy Team reviewed again which composting technologies were likely to offer a substantial reduction in odour to the limits to be defined within a waste management licence. The only technology that appeared to meet all of these requirements was “enclosed windrow” technology which would be able to utilise the existing composting infrastructure at La Collette, and which was also affordable.
This is a less expensive technology than “clamp” or “tunnel” based systems, but had previously been discounted because it does not retain waste within “vessels” – instead confining windrow’s within an enclosure - and is usually only partially enclosed and therefore would have less certainty of odour reduction. This would mean that it would be unlikely for any supplier of such technology to provide performance guarantees linked to defined levels of odour reduction, which the Department would have normally sought, given the particular concerns about odour in Jersey.
It is the case that green garden waste is normally composted in open “windrows” like those already in operation at La Collette, as this is accepted world-wide as an affordable means of low-technology composting. Investment in enclosed composting technologies is usually employed only to treat green garden waste mixed with kitchen vegetable waste (rather than just green waste).
The Waste Strategy Team has identified examples of “enclosed windrow” applications employed to reduce odour, that may be affordable and that would be able to utilise the existing La Collette composting infrastructure. However, development of this solution would be on a bespoke basis and would not be linked to guaranteed odour reduction.
The solution would involve enclosure of the existing composting operation within a steel-framed, poly-ethylene fabric covered pavilion. The turning of the windrows, a major source of odour generation, would occur within the building. The pre-shredding and post-screening operations, which can also generate odour, would also be fully enclosed. All active enclosed composting areas would be operated under negative pressure with all air extracted via bio-filters to absorb and minimise odours.
A number of factors remain to be fully investigated for this “enclosed windrow” technology, as there are few operating examples. Composting facilities are notoriously corrosive environments and the marine environment at La Collette is also demanding. It has yet to be confirmed whether this building type and technology can withstand these dual requirements. There are also clear health requirements in relation to protection of operators and other sensitive receptors from bio-aerosol hazards that can occur at composting facilities that require greater investigation. The Department has committed to undertake a full Environmental and Health Impact Assessment for the facility at planning stage and it will be necessary to establish that the “enclosed windrow” technology will be robust under such assessment. The detailed cost of developing such a facility, in particular specific air-handling technology, also requires greater consideration.
The advantages of this “enclosed windrow” technology are that it does offer a potential means of substantially reducing odour within the available budget and within the constraints of the La Collette site.
The alternatives are:
- To stop composting. This would be against the Solid Waste Strategy 2005 approved by the States of Jersey and against best environmental practice around Europe and the developed world. It would pose considerable problems in the period until the La Collette Energy from Waste facility is operational as the current Bellozanne facility is reaching the end of its useful life and does not have sufficient capacity to dispose of the 12,000 tonnes of waste per annum managed within the current La Collette windrow composting facility. As waste is anticipated to increase over time, inclusion of green waste within the La Collette Energy from Waste facility capacity would mean that this facility would be likely to be under-sized well within the 25 year operational life. There are no other facilities on the Island available to manage this amount of waste.
- To continue windrow composting at La Collette whilst actively seeking land elsewhere on the Island to designate for a permanent enclosed composting facility. It must be recognised that any location for a proposed compost facility is likely to be strongly resisted, that land would have to be purchased (possibly compulsorily purchased) and therefore it is unlikely that this would come to fruition in the short-term or to be affordable within the current available budget.
- To seek additional funding to be able to procure a composting system with greater certainty of achieving odour reduction. It must be accepted that this may take considerable time and is likely to be politically controversial. The selected technology is likely to be less flexible than the proposed “enclosed windrow” technology and development at La Collette is likely to involve writing off some of the asset value early if the anticipated East of Albert development comes to fruition.
- To offer opportunity for private sector operators to provide a service to receive and compost green garden waste. Whilst several private sector operators publicly stated interest in operating such a service, none responded when the Department issued its expression of interest for providing such a service in December 2006. Any operator would have to obtain planning permission including full Environmental and Health Impact Assessments and a Waste Management Licence in accordance with all current regulations. Operators would expect to receive a “gate fee” for the amount of material received and processed and would expect the cost of the use of their land to be accounted for. The Department has demonstrated, within its site evaluation process, that if more than one site was required this would be less cost-effective than operating a single site as is proposed.
In the light of these alternatives, the views of the Minister are now sought as to whether the recommended means of progressing the development of an “enclosed windrow” composting solution are acceptable and should be progressed.
It is also recommended that the Minister visits enclosed composting technology to see at first hand the capabilities and restrictions of different technologies.
Public Green Waste Reception
The Solid Waste Strategy (2005) envisaged that a public reception site for collecting green garden waste for composting would be co-located either with the composting process itself or with the Re-use and Recycling Facility proposed within the Strategy. A budget of £1.4 Million for funding the development of a permanent Re-use and Recycling Facility has been earmarked for 2010.
The Department progressed the development of the proposed enclosed compost facility identified within the Solid Waste Strategy on the assumption that permanent public and commercial reception facilities could be co-located with the composting plant. The Waste Strategy Team has considered over 40 locations for public green waste collection sites since the Solid Waste Strategy was approved as is set out within the Ministerial Decision (MD-T-2007-0113).
The increased understanding of risk of a Vapour Cloud Explosion following the Buncefield incident in December 2005 means that it is no longer possible to retain a public green waste reception facility at La Collette. Industrial uses are treated differently under major hazard legislation elsewhere and it has been demonstrated that the enclosed composting facility and commercial reception facilities can be safely located at La Collette. Therefore, following confirmation of the La Collette site as the location of the permanent enclosed composting facility in December 2007, the Department has been committed to the removal of the existing facility from La Collette. This is also a requirement for the timely progression of the Energy from Waste facility.
The assessment process carried out by the Department recommended that three sites (Field 298, in St Peter - the former composting site (S1), Field 827, Trinity - Howard Davis Farm (S4) or Field 1277, St Helier - Warwick Farm (S11)) would be worth further investigation as a possible permanent public green waste reception facility co-located with a Re-use and Recycling Facility.
None of these sites were considered ideal for public green waste reception due to their location within the Countryside zone and proximity to residential properties. The assessment therefore proposed that the current Refuse Handling Plant at Bellozanne should also be assessed as a potential public green waste reception site/ Re-use and Recycling Facility. This site, (adjacent to the current temporary Re-use and Recycling Facility), was excluded from the potential sites assessed initially as it is not available until completion of the Energy from Waste Project in 2011, but the site would have scored highest if its availability to be discounted.
Interim Public Green Waste Reception Sites
An interim site at Compound 6 / Field 1491 in Bellozanne Valley (area north of the Sewage Treatment Works adjacent to the road), was proposed in September 2007 as suitable until a permanent site was identified and made available in 2010 / 2011. This site had the advantages of being in a central location and being close to the existing Re-use and Recycling Centre, which would enable those using both facilities to reduce the number of journeys undertaken. The site is States owned and is designated as Countryside in planning terms.
The site required minimal capital and revenue investment to become operational. It was estimated that approximately £56,000 of civil works would be required and twelve custom-made collection containers purchased. As a result £100,000 was earmarked within the Energy from Waste budget for relocation works in May 2008. The site was subject to public consultation in December 2007, which identified a number of residents concerns, chiefly related to increased traffic in the area.
As a result of these concerns, the Minister supported a report and proposition by Deputy Ben Fox (P7/2008/Com) for the resources necessary to establish further site(s) for public green waste reception elsewhere on the Island. This proposition was not successful in the States.
The Department then consulted with the Comité des Connétables in June 2008 as to the best way to collect green waste until a permanent Re-use and Recycling Centre could be established when capital allocation is available in 2010. The Department suggested possible locations that had been considered in each Parish and proposals for collecting at multiple sites, for example from garden centres. The Comité was sympathetic to the Department’s predicament, but only one site was offered as a possibility. Unfortunately, the location of this site required considerable infrastructural investment due mainly to the access provision off the main road and meant it could not be considered as a suitable alternative.
In August 2008, the previous Minister for Transport and Technical Services instructed the Department to consider alternative interim public green waste reception sites. Of the four identified in the site evaluation process, Warwick Farm was preferred by the Minister as offering a central location and probable least investment cost for establishment.
Consideration was given as to which capital budgets could be employed to do so as the allocated £100,000 would be insufficient for any of these sites. The only potential budget was the £220,000 of works identified within the Energy from Waste enabling works budget for Commercial Green Waste reception. It was the case that this cost would have had to be found from the enclosed compost facility budget in the event that the chosen location was not La Collette and so this element of funding could be used to support the cost of the relocated interim public green waste reception site giving a total budget of £320,000.
In September 2008, the Director of Property Holdings indicated that any interim public green waste site at Warwick Farm could only be considered for a three-year period, due to the need to retain flexibility for land-use during the development of the revised Island Plan.
Feasibility designs were developed by the Waste Strategy Team’s technical adviser between September and October 2008 to identify a solution that could be modified in future to create a permanent Re-use and Recycling Facility if appropriate. However, no site with such potential could be developed within the budget available for the works.
Therefore a minimised design has been developed by the Waste Strategy Team, effectively to replicate the public green waste reception facilities currently offered at La Collette at Warwick Farm. It is understood that this design can be developed within the available budget.
The design involves removal and replacement of poly-tunnels currently used by the Department’s Parks and Gardens service and the creation of a low-grade access to a reception slab, where the public would deposit their waste into collection bins. These bins would be collected periodically by collection vehicles and transferred to La Collette for subsequent composting. No shredding or treatment of waste would be undertaken on site and all collected waste would be removed at the end of each operational day. The site would be landscaped to minimise visual intrusion. Containment in collection bins would minimise any dust, noise or odour impacts.
The site is likely to be controversial, as any new waste management site will be. There may be a need for further traffic assessment before any planning application could be submitted. Although an Environmental Impact Assessment would not be required, a waste management working plan would need to be developed and a design statement for the planning application produced. It would be advisable to consult with local residents about the proposals before submitting the application.
This recommended Warwick Farm design is available for Ministerial review (MD-T-2007-0113) and could be submitted for planning within a month of Ministerial consent.
Assuming an application were submitted in January 2009, the earliest an approval could be granted would be April 2009. Construction of the facility would take approximately 6 weeks meaning the earliest that the facility could be available for operation is June 2009.
The Minister is recommended to agree the design indicated within Appendix 1 and the preparation of a planning application for an interim public green waste reception facility at the Warwick Farm site.
Temporary Public Green Waste Facilities
The need to relocate the current public green waste facility from the middle of January 2009 means that there is a need for a temporary green waste operation at Bellozanne until the proposed Warwick Farm planning process can be determined. Bellozanne is the only site available to the Department with consents for reception of waste for this relocation.
As previously indicated, the Compound 6 site within Bellozanne Valley can be developed with minimal investment to the required timescale. Alternatively, provision can be made within the current Re-use and Recycling Facilities on working days and within the Bellozanne incinerator tipping apron at the weekends for collection of public green waste although this option may be more confusing to the public and runs the risk of causing queues if the site has to remain operational into the summer.
As a result of these concerns, it is recommended that the Minister agree the temporary establishment of public green waste reception facilities at Compound 6 (Gate 15), Bellozanne Valley.
To reduce costs, it is proposed to employ staff from the commercial green waste reception at the busy weekend period but this will require that the commercial green waste operation is not available on Saturday mornings as currently. The introduction of either temporary operation is likely to prove controversial with local residents, but no alternative sites can be developed within the timescale required.
The revenue implications of operating Warwick Farm and Compound 6 are similar involving approximately £97,000 for staff, £22,000 for non-staff costs and £52,000 for leasing costs of vehicles giving a total of approximately £170,000 subject to a review of efficiencies. The costs required to operate these sites will have to be met from January 2009 from existing Transport and Technical Services budgets.
Proposals
The Minister for Transport and Technical Services is recommended to:
- agree the recommended means of progressing the development of an “enclosed windrow” composting solution are acceptable and should be progressed
- visit examples of enclosed composting technology to see at first hand the capabilities and restrictions of different technologies.
- agree the design indicated within Appendix 1 and the preparation of a planning application for an interim public green waste reception facility at the Warwick Farm site.
- agree the temporary establishment of public green waste reception facilities at Compound 6, Bellozanne Valley only until planning approval for an alternative interim site is forthcoming.
Reason(s) for Recommendations
To progress the development of capital projects approved within the Solid Waste Strategy 2005.
Actions Required
The Director of Waste Strategy Projects is to:
- Progress the development of a full environmental impact assessment, health impact assessment and planning application for the preferred site - the La Collette Industrial Area - for a permanent “enclosed windrow” compost facility, seeking a further Ministerial Decision before submitting the planning application
- Progress the development of a planning application for the interim public green waste reception facility at Warwick Farm, seeking a further Ministerial Decision before submitting the planning application.
- Progress the implementation of temporary collection facilities for a temporary public green waste reception facility at Compound 6, Field 1491, Bellozanne Valley.
Written by: | Will Gardiner - Director of Waste Strategy Projects |
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Approved by: | John Richardson - Chief Officer Transport and Technical Services |
Attachments:
- Appendix 1 - Design proposal for interim public green waste facility at Warwick Farm.
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