Lifetime Recycling Village

This article about a proposed local incineration plant was originally published in 2011. I'm putting it out now for it's detailed analysis on incineration - a controversial topic at the best of times

Somewhere in a leafy suburb near Glasgow, something is stirring. The natives — as they say — are becoming restless. The reason for this was because a proposal had been put forward to build the largest industrial waste processing plant in Europe. Costing £640 million and located near Newton Mearns on the M77, the Lifetime Recycling Village (LRV) would have created 700 jobs. But campaigners pointed out that similar plants operating in the US were operated by about 100 personnel. The aim was to get the plant up-and-running by 2014 in time for the Commonwealth Games, which Glasgow hosted. But on 4 September 2011, the local community staged a major protest against the proposal.

So, was this just a bunch of middle class suburbanites kicking up a fuss? On the face of it, it would appear that the project would have benefited the local community. The plant would after all incinerate combustible waste, providing electricity for around 100,000 homes. And there was also a plan to incorporate a Combined Heat and Power (CHP) system, which would introduce district heating into the area. So it did appear to be an environmentally friendly formula that would certainly reduce CO2 emissions and possibly reduce local fuel bills.

But one of the concerns of campaign groups was the fact that the 1 million tonne capacity of the plant (down from an original 1.5 million tonne estimate) would be fed by lorries trundling into the plant at a rate — it is claimed — of 1 every 3 minutes. If one does a back-of-the-envelope calculation, then this estimate is actually quite reasonable. Working on the assumption that each lorry would carry 15 tonnes of waste each, it works out to 182 lorries a day coming in and out of the plant. So this then raises the question — how much CO2 does that entail. In other words, how many tonnes of diesel do you have to burn to combust x amount of waste?

Such calculations are beyond the scope of this article. Emissions from Heavy Goods Vehicles (HGV) will depend on age and engine efficiency. Vehicle emissions are determined by the EU Fuel Quality Directive.

But the main thrust here is on the pros and cons of the waste sorting system that will require 1m tonnes of waste a year to be sorted with some incinerated and the rest processed. Some of the waste can be reclaimed, whilst toxic residue from the burnt waste called fly ash will be vitrified. It has also been revealed that the waste burning will be supplemented with about 170,000 tonnes of virgin woodchip. I contacted LRV and ‘eventually’ received a reply from Managing Director, Neil Gallacher:

Dear Barry,

Many thanks for your emails and interest in this project and we congratulate the work that you are doing… to promote sustainability. We indeed do hope to be a good neighbour and believe that this project would play an important part in building a sustainable infrastructure for Scotland’s future. We are also keen to maximise education and community facilities on the site as well as provided a new, skilled source of employment to this area. We are working closely with our technical and environmental experts to refine and develop our application, ensuring that possible impacts of the development are fully assessed and reported. With regard to wood chip, if a small amount were needed to blend with the biomass fuel — and waste stream analysis at the moment suggests it might not be — it would of course be sourced sustainably. Environmental concerns are at the heart of these proposals. The waste that we will be dealing with is already travelling in lorries on our road system, currently going to lots of different transfer stations and landfills. So it is already moving around, we would be tackling that waste rather than creating it. We will also have a strict routing strategy in place maximising the use of the strategic road network. We hope that this is helpful and many thanks for your questions.

Best regards, Neil Gallacher, Lifetime Recycling Village

There were other factors which raised eyebrows though. The CEO of the LRV was Brian Kilgour, who was convicted of dumping waste illegally in 2007. LRV hired law firm Dundas & Wilson as planning consultants, who’s claim to fame was helping Donald Trump secure his controversial golf course in Aberdeenshire. Other clients included Royal Bank of Scotland (RBS).

Willy Findlater, the project architect was the chief development officer. He presented the project to East Renfrewshire council. He told them that up to 900,000 tonnes of waste would be incinerated. Apparently the project isn’t an incinerator and in response to concerns he said ‘When is an incinerator an incinerator? ‘I would have thought that if something is incinerating something, they are probably incinerating it in an incinerator’.

It would appear that there was a ‘rogues gallery’ behind the project. Indeed according to Patrick Harvie, Green MSP:

‘We’re nowhere near convinced that ‘energy from waste’ is anything other than a rebranding of incineration to make it look renewable, which in this case might be a ploy to get round planning problems’.

Apparently normal planning permission wasn’t required. The Scottish Government, rather than local authorities usually makes decisions on whether to approve power stations.

Campaigners responded by enlisting a QC along with planning law firm Brodies to challenge the project.

Looking at the project within a wider context, on 9 June 2010, the Scottish Government rolled out Scotland’s Zero Waste Plan. The aim of the Plan is to reduce the amount of waste sent to landfill to just 5% by 2025. 70% is the target reduction, which will leave about 25% that will require processing. Most of this will probably be incinerated.

Overall all of Scotland’s waste will be processed and will follow the principle of the waste hierarchy as set out in the European Waste Framework Directive (WFD). With waste prevention the ultimate goal, this is defined by the WFD as measures, taken before a substance, material or product has become waste, to reduce:

• the quantity of waste. This includes the re-use of products, the extension of the life span of products, reductions in packaging etc;

• the adverse impacts of waste on the environment and human health;

• the content of harmful substances in materials and products.

This effectively means restrictions being placed on what can be incinerated. Energy from Waste (EfW) should also accompany incineration.

As stated in the Zero Waste Plan Report:

[The] Scottish Government will lay regulations under the Climate Change Act waste provisions which will enable SEPA to require waste producers, waste management companies and other waste holders to provide information on the wastes that they generate, hold or manage. In addition to this, the Scottish Government will consider along with its Zero Waste Scotland Delivery Programme partner how information obtained by SEPA on commercial and industrial waste can be supplemented by compositional analysis.

It also states:

EfW has an important role to play and can make a positive contribution to both renewable energy and climate change targets. However, in order to achieve the high levels of prevention, reuse and recycling outlined in the Zero Waste Plan it is imperative that materials that could be reused or recycled are not directed to mixed waste treatment facilities such as EfW facilities.

The following diagram illustrates the waste hierarchy:

Thermal Treatment plants are regulated by SEPA under the Pollution Prevention and Control Regulations 2000:

In order to support Scottish Government policy, SEPA’s Thermal Treatment of Waste Guidelines 2009… now apply to all municipal (MW) and commercial and industrial waste (C&I) with the exception of special (hazardous) wastes. The practical implications of these Guidelines will be that thermal treatment plants handling waste should:

• Take only residual waste after segregation (residual waste is the waste that remains after recycling separation has taken place and could be either mixed waste or segregated waste biomass);

• Be part of an integrated network of recycling and composting and other waste management facilities; and

• Recover and use the energy derived from waste efficiently.

CHP is a requirement as stipulated in the EU Waste Incineration Directive.

The establishment of an accreditation scheme would assist operators of EfW installations to ascertain whether the waste arriving at their gate had undergone sufficient pre-treatment to be considered residual. This work will be taken forward by Zero Waste Scotland and SEPA. The following diagram illustrates the process:

Another important consideration within the Zero Waste Plan is location:

Relevant considerations in the siting of installations will include access to the transport network, including road, rail and waterways. All decisions regarding the location of waste management infrastructure should take into consideration how wastes and end products are transported to and from the site, minimising unnecessary travel.

As with all other types of development, proposed waste management facilities should be located in sites where potential impacts on the human, built and natural environment can be minimised. There may be a requirement under the Environmental Impact Assessment (Scotland) Regulations 1999 for an Environmental Impact Assessment (EIA) to be prepared to assist in the consideration of any potential likely significant environmental impacts.

As part of this process consultation would be required on any proposals:

Members of the public and community groups have an important role in the planning system and are encouraged to get involved in the development planning process and planning applications. When responding to plans and applications it is important that they ensure that responses are focused on planning issues as in this way they may be considered a material consideration. Responses should take in to consideration both the local and strategic waste management needs. SEPA have provided fact sheets on some of the key waste management and treatment processes required to meet Zero Waste objectives which may help in understanding plans and proposals.

One clear point emerges from this discussion. Waste management will be strictly regulated at both European and National level, although following Brexit it is likely that the main focus will be on national regulations. In Scotland this will involve the Scottish Government working with SEPA. There will also be links with the Environment Agency (England & Wales). On the basis of this, there is no reason in principle that would reflect any health & safety risks from the LRV.

But although the plant itself wouldn’t pose a risk, the issue of transporting waste to and from the plant remained a point of debate. What would be the environmental impacts of HGV’s thundering up and down the M77 every few minutes? The obvious next question is — was this the best location for a plant like this? Wouldn’t rail freight be a better option? Transport Scotland is clear on this issue:

Rail freight produces only 10% of the emissions per tonne that road-based distribution produces.

This was clearly a contentious issue, with key parties being involved in the debate. One organisation that has had important involvement in waste related issues is Friends of the Earth Scotland (FoES). They endorsed the Zero Waste Plan and have made no secret of their objections to incineration.

With many of these issues, there is no need to re-invent the wheel. During the consultation phase of the Zero Waste Plan, the Scottish Government investigated other international initiatives. One initiative of particular interest to the Government was the Waste Management Policy in the Flanders region of Belgium, which had made great progress with waste management and prevention.

The Government made reference to 13 waste strategies around the world — including Flanders — offering guidance to the Zero Waste policy.

The result of the Government’s work on this was the release of the EIA Scoping Report (pdf), which outlined the proposals in detail. In keeping with the Environmental Impact Assessment a Scoping Opinion was put out following publication of this report, in which interested parties could record their comments relating to the project.

There are elements within the report that needed raising. It noted that:

A Transport Assessment (TA) will be prepared as a stand-alone document, and will include information on the likely environmental effects associated with traffic generated by the proposed development. It will assess existing traffic flows using the site, and future flows based on current and proposed site use. It will assess the significance of the traffic increase and the suitability of the existing junction with the A77 to take additional traffic. A Sustainable Transport Strategy for the proposed development will be developed and construction traffic demand will be assessed for input into the CEMP [Construction Environmental Management Plan].

The Scoping Opinion started off with the relevant legal requirements of the project:

[It] requires Scottish Ministers’ consent under section 36 of the Electricity Act 1989. Schedule 9 of the Act places on the developer a duty to “have regard to the desirability of preserving the natural beauty of the countryside, of conserving flora, fauna and geological and physiological features of special interest and of protecting sites, buildings and objects of architectural, historic or archaeological interest”. In addition, the developer is required to give consideration to the relevant Scottish Planning Policy and National Policy Planning Guidance, Planning Advice Notes, the relevant planning authority’s Development Plans and any relevant supplementary guidance.

Under the Electricity Works (EIA) Regulations 2000, Ministers are required to consider whether any proposal is likely to have a significant effect on the environment. In terms of these Regulations, we must consult the planning authority, Scottish Natural Heritage and the Scottish Environment Protection Agency as well as other relevant consultees.

Of note is the reference of fuel used in the plant:

The Environmental Statement should set out the type of fuel(s) and form of fuel (wood pellets, chips, meals. cakes,logs, bales etc) the developer intends to use; if proposing to use more than one fuel type the developer should define the proportion of each type of fuel proposed. The plant’s annual fuel requirements should also be set out within the proposal accompanied by detailed and robust fuel sourcing plans, together with the transportation delivery method for each fuel type.

Clearly once the final ES is produced, there’s going to have to be more detail than that contained in the email response above. Further:

applicants should consider the finite nature of the domestic supply of wood fibre; the potential demand on the Scottish and UK timber harvest should be set out by the developer within a robust fuel supply plan covering the life span of the proposal. Proposals which rely on importing large proportions of their raw material from overseas supplies should consider energy security risks and issues.

In considering sustainability; most timber supply in Scotland is FSC certified as being sustainable but globally the situation is greatly variable; applicants should produce a Sustainability Statement covering all necessary requirements.

With respect to transport impacts:

The Environmental Statement should include a Traffic Assessment to provide information relating to the off site traffic impacts. The scope of the TA should cover the temporary effects during construction and the effects in normal day to day operation of the plant covering vehicle size and quantum of road movements of fuel, waste workforce etc. The Environmental Impact Assessment should address issues such as stress points at junctions, approach roads, bridges, etc.

Where potential environmental impacts have been fully investigated but found to be of little or no significance, it is sufficient to validate that part of the assessment by stating in the report:

• What work has been undertaken, e.g. transport assessment;

• what this has shown i.e. what impact if any has been identified;

• why it is not significant.

A total of 38 consultees were contacted by the Scottish Government and asked to comment on the proposal. I’ll note below the comments of a few of the key parties.

1. East Renfrewshire Council: They are concerned about visual impacts and the integration of the plant within a greenbelt environment. Also of great concern is transport impacts: ‘The transportation element of the scoping report is scant on detail and refers to the Transport Assessment for answers and vice verse. This is not considered to be acceptable in this instance. The EIA needs to take account of all the environmental issues associated with transportation. Section 5.7.2 indicates that the development will result in an increase and change in the volume and composition of traffic accessing the site, both during the construction and operation phase. Given the current use of the land this is inevitable however the change/increase in traffic needs to be qualified and quantified to assess the environmental effects. There is no reference to safety records or assessment or indeed a Travel Plan to influence travel behaviour.

   A Traffic Assessment is required to be produced in line with Government guidance and will require traffic counts to be taken at specified junctions across the network (to be agreed with the Council’s Roads and Transportation Service). The ES should take full account of the potential effect of all modes of transport and travel impacts resulting from the proposed development’.

2. Glasgow City Council had this to say: ‘The scoping report identifies that the main emissions to air associated with the development are likely to be associated with the renewable biomass plants and the increase in traffic movements to and from the site. It has been proposed that an air quality impact assessment is carried out to assess potential impacts on human health from combustion emissions associated with the development, and the local air quality impact from associated transport. To date, Glasgow City Council has declared 3 AQMAs [Air Quality Management Areas] for NO2 and the city centre has also been declared an AQMA for PM10. Environmental Health has produced an Air Quality Action Plan to improve air quality in these 3 areas. The introduction of the new 2010 18µgm-3 target for PM10 increases the likelihood that more AQMAs for PM10 will be required in Glasgow in the future. Whilst we understand that a single biomass boiler is unlikely to affect air quality outside of its immediate vicinity, the cumulative effect of a number of biomass boilers could potentially raise background levels of air pollutants (particulates). It is also possible that biomass installations in neighbouring local authorities could have an impact on air quality in Glasgow. We would, therefore, like to advise the developer that increases to background levels and transboundary air quality effects should be considered in the air quality assessment, and that any significant issues are flagged up.

   The scoping report also identifies the M77 and future M74 extension as transportation routes to the proposed development site. Changes to the volume and composition of traffic on the M77, M8 and M74 have the potential to directly affect air quality in Glasgow. We would therefore request that the air quality assessment considers the effect the proposed development will have on local air quality management in Glasgow, and the Council’s ability to meet air quality objectives or limit values. Where transport emissions, as a result of this development, are assessed as having an adverse impact on Glasgow’s air quality, including that of our Air Quality Management Areas, then mitigation measures should be specified.’

3. Friends of the Earth Scotland in conjunction with local group Glasgow responded: ‘We recognise that planning for the future of waste management in Scotland is complex, involving multiple factors, especially an overarching aim to reduce carbon emissions significantly over the time frame of any major development now being planned, and an aim to reduce real waste — for which landfill is currently the only practicable option — to zero. FoES contention is that these aims will be optimally met by minimising actual waste arisings and maximising source separation of waste categories, so that the different types remain uncontaminated, and can be most easily recycled and/or re-used. However, we recognise that effective source separation at all possible sources (domestic, agricultural and commercial) requires very significant changes in behaviour and that there may be some scope for facilities that treat mixed waste in ways which otherwise meet the carbon reduction and zero waste production aims. Since such facilities will never be the ideal solution, we would want the ‘bar’ for their a acceptance to be set high on other criteria. Existence of such a facility should not act as a disincentive to source separation schemes.

   The waste would arrive by road. No figures were available on journey distances, and this is clearly important in terms of carbon emissions. The yearly waste input to the facility was presented to us as 2–3% of Scotland’s current total waste.

   A possible adjunct to the facility is a greenhouse development to produce vegetables such as tomatoes and peppers, using “waste” heat from the facility to maintain growing temperature. We regard this as an important feature which would significantly enhance the facility’s acceptability, since it would not only use the waste heat but also assist the aim of reducing Scotland’s dependence on produce transported from afar. The Scoping Report makes clear that the overall environmental impact of the facility cannot be assessed until several detailed studies have been carried out, some but not all of which have already been commissioned.

   The key studies are:-

• A carbon balance analysis (recently commissioned): LRVL claim that the facility’s carbon footprint will be small because the biomass used for the fuel will be recently generated material, not based on fossil fuels (no plastics are to be gasified). A key variable, as noted above, will be the distance travelled by the waste to reach the facility.

• Landscape and visual amenity: study to be carried out. Impacts may be considerable, dependent on the heights of stacks and design of the buildings. The site is rural, but there are neighbours, including a popular golf course, who will be affected.

• Ecology: a phase 1 Habitat Survey has been done. An impact analysis based on the information collected has yet to be carried out but there are an SSSI and five SINCs within 5 km.

• Water Resources and Flood Risk: assessment of flood risk has begun but needs modelling work.

• Ground conditions: some assessment has been completed, for use in the Construction Environmental Management Plan.

• Air quality: potential impact of the facility to be modelled and discussed with SEPA. This will include both emissions from the facility itself and from associated vehicles. From our perspective, a significant feature of the facility’s design should be the elimination of toxic emissions.

• Noise and vibration: assessment of impact of both construction and operation of the facility to be carried out.

• Transportation: assessment to be done. There may be significant problems associated with adding traffic to the M77 which is very busy at peak times.

• Socio-economic: the developers contend that these impacts will be positive, both in generating employment (construction and operational phases) and in educational terms — the facility will have a visitor centre. The developers plan a socio-economic study as part of the overall environmental assessment.

  It is obvious from the number of studies yet to be carried out that it is premature for an organisation such as FoE Glasgow to come out either for or against the proposal. All we can say at present is that the range of assessments being undertaken is appropriate, and that we look forward with interest to the results. For us, a key consideration is the waste heat proposal: using the heat well could significantly enhance the efficiency of the facility. We would hope that this aspect of the proposal would be more fully integrated prior to going forward for planning permission’.

4. Transport Scotland: ‘The Environmental Statement should provide information relating to the preferred route options for the movement of heavy loads and anticipated construction staff movements via the trunk road network during the construction period. In addition, information must be supplied identifying potential environmental impacts on the trunk road once the development is operational, together with any required mitigation measures.

   Potential trunk road related environmental impacts such as noise, air quality, safety etc should be assessed. In the case of the Environmental Statement the methods adopted to assess the likely traffic and transportation impacts on traffic flows and transportation infrastructure, should comprise:

   Determination of the baseline traffic and transportation conditions, and the sensitivity of the site and existence of any receptors likely to be affected in proximity of the trunk road network; Review of the development proposals to determine the predicted construction and operational requirements; and Assessment of the significance of predicted impacts from these transport requirements, taking into account impact magnitude (before and after mitigation) and baseline environmental sensitivity.

   It is noted that a stand-alone Transport Assessment (TA) is to be prepared for the development and it is indicated that information from this study will be used to inform the ES and the preparation of Construction Environmental Management Plan. This approach is acceptable and we would recommend that early consultation is undertaken with ourselves to agree the scope of the TA with regard to Trunk Road issues.

5. Zero Waste Delivery Team. They have by far offered the most critical scrutiny of the project: ‘I note that the scoping report states that cognisance has been given to the Zero Waste Plan but from my reading of it the exact opposite is true. The mass balance attached at Annex B appears to be in error as the system diagram does not actually balance — the moisture loss at stage one (9,520 tonnes) appears to be grossly understated as does the biomass derived fuel tonnage (187,680) — If you add both these figures to the small tonnages of recyclate you get nowhere near the 1.5 million tonnes input so something is wrong with the presentation of the figures.

   By my deduction (workings attached) it would appear that they plan to burn over 1 million tonnes of waste and recover circa 45,000 tonnes of recyclate at stage one. This amount of recyclate represents approximately 3% of the total waste inputs and this depends on them actually finding markets for the aggregates, mixed textiles and mixed plastics recovered from the residual waste (black bag waste) — that is by no means certain as the material is invariably contaminated as you will imagine. If my deductions are right then this proposal represents the antithesis of our Zero Waste policy which sets out to establish high quality recycling in line with the revised Waste Framework Directive. We aim to implement this by introducing legislative measures requiring separate collections of recyclable materials and food waste and have just launched a consultation on this.

   In addition to the above it is not clear whether a plant of this size (> 1,000,000 tonnes capacity) will be able to get anywhere near the levels of efficiency required. In order to achieve the high levels of efficiency demanded by SEPA provision would need to be made to utilise heat off-site and I suspect that would not be a viable proposition given the size of plant proposed, location and the amount of heat that would be produced’.

Clearly there is still work to be done and the final assessment of this project can only be made once the ES has been produced. Until then the LRV website is nothing more than a marketing forum.

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Since the original publication of this article, the project has fell through. Any links to the project are no longer available. Indeed, it is recorded by Companies House that the company was dissolved on 20 February 2015 via a compulsory strike-off.

It would also appear that the Environmental Statement never surfaced. In November 2021, the Scottish Government announced a moratorium on incineration.