MEMORANDUM BY GREATER MANCHESTER WASTE
LTD (DSW 10)
Greater Manchester Waste Ltd (GMW) is a wholly
owned arms length company of the Greater Manchester Waste Disposal
Authority (GMWDA). The company manages 1.4 million tonnes of municipal
solid waste per annum arising in the nine districts served by
the GMWDA, namely Bolton, Bury, Manchester, Oldham, Rochdale,
Salford, Stockport, Tameside and Trafford. GMW operates a range
of reception and processing facilities throughout Greater Manchester
and provides transportation by road and rail to final disposal
points, contracted by GMWDA until 2006 for the provision of these
services.
In response to changing legislation and policy,
GMW has developed a range of recovery and recycling techniques
which, in conjunction with recycling activity conducted by the
district councils, are making significant progress towards meeting
the targets. The company has also diversified into kerbside collection
of recyclables and is seeking to expand its operations into refuse
collection. This will deliver truly integrated waste management
through greater co-operation between the associated Waste Collection
Authorities (WCAs) and the GMWDA.
DELIVERING SUSTAINABLE
WASTE MANAGEMENT
The Sub-committee wish to examine whether the
Government's waste strategy, as it applies to the Government,
local authorities and other public and private bodies will result
in:
A. More efficient use of resources and a
consequent reduction in the amount of material entering the waste
stream.
The principal emphasis of the strategy is the
effective management of wastes through recycling and recovery
and not the efficient use of resources. This area is briefly mentioned
within the strategy, but not discussed at any length nor incorporated
effectively in actions or policies. The summary of Government
actions on wastes places specific emphasis on producer responsibility
initiatives. While such initiatives can be effective at precipitating
an increase in recycling and recovery, they do not target waste
minimisation and resource use.
Section 4, Part 1 of the strategy outlines the
requirements of businesses to meet the demands of the strategy.
This includes the setting of targets for waste reduction and the
reporting on progress which will be required of the top 350 companies.
These larger organisations will have the resources and the demand
from stakeholders to carry out these measures. However, the real
challenge lies in the Small and Medium Size Enterprises (SME)
sector, many of which do not have the staff, funds or inclination
to look at reducing waste and resource use. The strategy does
not place sufficient emphasis on these areas and will not, in
itself, result in more efficient use of resources.
In encouraging recycling and investigating new
markets, the Government is to be commended for implementing the
Waste and Resources Action Programme (WRAP).
However, the remit of this body as listed in
the strategy does not specifically include reference to efficient
use of resources. The formation of this body provides an opportunity
to develop strong links with the work on waste minimisation of
the Environmental Technology Best Practice Programme (ETBPP) and
build up awareness within the SME sector.
The emphasis on household waste minimisation
is similarly lacking in emphasis. Therefore, the strategy is unlikely
to greatly influence efficient resource use or the amount of materials
entering the waste stream. However, it will result in a growing
awareness of recycling and recovery and an increase in these activities.
B. An increase in recycling of waste particularly
by greater development of markets for recycled materials (including
compost) and use of producer responsibility initiatives.
An increase in levels of recycling is likely
to occur, as this is the main focus of the strategy. The setting
of interim targets for 2003 will provide additional momentum.
However, the strategy fails to make clear what sanctions, if any,
will be introduced for those local authorities not delivering
the desired increase. Sanctions must be clear and also suitable
in order to remove any inertia to recycling that remains in some
areas.
In relation to alternative markets, the Government
is to be commended for introducing WRAP and including market development
within its remit. There remains an element of scepticism over
the use of secondary raw materials by some manufacturers which
is stifling market development. Therefore, the work of WRAP must
occur swiftly to overcome this or any increase in collection of
recyclate will be restricted by a lack of available markets. WRAP
should also consult with the established trade research bodies,
such as ESART, to build on and replace present research into these
areas.
The level of increase in recycling activity
that can be achieved by local authorities is limited by available
funding. The recent spending review announcement of £140
million over three years at first sight appeared to be a step
in the right direction. However, calculations undertaken by GMW
indicate that, in the long term, an investment of up to £2
billion in waste infrastructures will be necessary to meet the
2010 targets if waste arisings continue to grow at 3 per cent
per annum. This is further reinforced by the Environmental Services
Association, who have demonstrated the £140 million to be
equivalent to less than 2p per person per week for development
of recycling initiatives. In order to deliver the levels of recycling
needed to meet the strategy, a significantly higher level of funding
is required, in order that other essential local authority services
are not affected.
As stated previously, the main emphasis of producer
responsibility initiatives is to encourage recycling and recovery.
Wider use of these initiatives will potentially result in increased
recycling activities. However, from the experience of the Packaging
Regulations, more effective enforcement and regulation is required,
to ensure that implicated companies achieve the required levels.
C. Increased use of incineration as a waste
disposal/recovery option—the Sub-committee would also wish
to examine what the implications of such an increase would be.
GMW believe that modern energy from waste technology
has a valid role to play as a recovery option (not a disposal
option) within the context of an integrated waste management strategy
that utilises a range of technologies. This is particularly so,
where value can be recovered from residual wastes remaining after
recycling and recovery have occurred in the form of heat, power,
metals and construction materials.
There is likely to be some increase in the number
of thermal recovery facilities within the UK, in particular to
meet the diversion targets of the Landfill Directive. However,
this is unlikely to be on the scale indicated in the consultation
document, A Way with Waste. This is due to the level of
public opposition to incineration, the time involved in the planning
process and also a lack of local authority finance for such facilities.
It is disappointing to note that the recycling
of incinerator ash is no longer included in the household waste
recycling targets. The recycling of ash into construction materials
provides significant levels of diversion from landfill and also
reduces the requirements for virgin aggregate ie it conforms to
the principles of sustainable development. The incentive to recover
further value from residual wastes by this method has now effectively
been removed.
D. A reduction in the amount of waste sent
to landfill—in this context, the Sub-committee would welcome
views on the effect of the Landfill Tax and its associated credit
scheme.
By virtue of increasing recycling rates it is
likely that there will be a decrease in the amount of waste sent
to landfill. At the present point in time it is not possible to
comment upon the likely effectiveness of the proposed tradable
permit system the Government is planning to introduce for local
authorities to restrict the landfill of biodegradable municipal
waste (BMW). The Government plans to consult on these proposals
and also on what sanctions and enforcement measures will be appropriate.
Until this consultation has been conducted, it is unclear as to
how effective this system will be in diverting waste from landfill.
In previous consultation exercises, the industry
etc indicated a preference for WCAs as being the party ideally
suited to hold permits as they are the interface with the public
and best able to influence segregation and collection schemes.
The strategy does not indicate which local authority body ie WDA
or WCA, will have the permits imposed upon them. The final details
of how the scheme will work also need to be detailed to enable
collection systems and segregation measures to be implemented.
Any further consultation must be conducted and concluded as soon
as possible to enable the development of these measures.
Any reduction in the amount of wastes going
to landfill that has been observed is unlikely to have been due
to the Landfill Tax encouraging waste producers to recycle/recover
that waste. The level of taxation is too low to cause the major
change in attitude that will be necessary to cause a significant
reduction in landfill disposal. An area of particular concern
is the increase in diversion of "inert" waste to exempt
activities such as landscaping schemes. This activity is largely
unregulated and offers an alternative outlet to the less scrupulous
waste producers and carriers.
For the Landfill Tax to work effectively, the
level of taxation must be higher to give the necessary incentive.
The additional funds should be utilised in developing markets
for waste materials and also to fund additional Environment Agency
staff and resources to increase regulation and enforcement of
waste management activities.
The strategy details an extension of the current
approved project list for Landfill Tax funding to include research
and education on market development. The scheme will also be extended
to include recycling and reuse activities for non-profit making,
non-public bodies eg community recycling groups. This is a step
forward in that funds will be available for research into new
markets and also for funding community groups which play a valuable
role in engaging the public and raising awareness. However, the
strategy still does not discuss the availability of Landfill Tax
funds for local authority recycling schemes where large increases
in recycling can be achieved. Local authorities have consistently
raised concerns over lack of funds for expanding recycling and
questioned the availability of Landfill Tax moneys for this purpose.
The only commitment in the strategy is to "explore"
this possibility of using Landfill Tax funds to assist local authorities
to raise recycling levels. This must be acted upon and the details
made clear to enable long term planning.
E. A reduction in and better management of
hazardous wastes.
As stated previously, the principal emphasis
of the waste strategy is on household waste. However, the list
of actions the Government is proposing to reduce the hazardous
nature of waste is to be commended. It is particularly important
that the impact of the Landfill Directive on managing hazardous
wastes is determined as soon as possible. In tandem to this is
the requirement to determine the BPEO for various hazardous wastes
and to establish markets for reuse of these materials. All of
these items are included within the actions in the strategy and
should result in a decline in hazardous wastes. As to whether
we will see better management of hazardous wastes, the outcome
of the various actions listed above is required before any appraisal
can be made. A starting point to initiate alternative management
techniques would be the banning of landfilling of these wastes.
In order to manage the almost five million tonnes of hazardous
wastes, the majority of which is landfilled, urgent action and
change is required.
F. Significant action to improve the example
set by the Government in exercising "green" procurement
policies.
It is important that the Government take the
lead in developing green procurement policies and GMW support
the proposal for pilot arrangements for other public bodies detailed
in the strategy. This should be implemented into local authorities
as soon as possible as an example to local businesses and others.
Many major companies that have an environmental
management system, such as ISO 14001, will have green procurement
policies as part of the system. This again links back to the dissemination
of these practices to SMEs via WRAP and the ETBPP, as these smaller
organisations may not be aware of the benefits that may arise
from these policies. There is therefore a need to raise the profile
of these activities amongst this sector and there is clearly a
role for this activity to come under the remit of WRAP.
G. Sufficient action to educate the public
about the importance of sustainable waste management.
The strategy details a number of initiatives
to encourage and educate the public in relation to sustainable
waste management including the National Waste Awareness Initiative
and Are You Doing Your Bit campaign. The DETR Are You Doing Your
Bit Campaign is making use of innovative techniques through the
use of personalities in television advertising. However, the roadshow
which recently came to Manchester was poorly advertised and as
a result will not have made the impact it should have. These events
must be publicised fully and receive the necessary support from
all parties if they are to be successful.
Similarly, the National Waste Awareness Initiative
seems to be well covered in the waste management press but not
so in national papers. As a result, the essential messages are
not reaching those people who need to be made aware of sustainable
waste management and the part they can play.
The use of the www.useitagain.org.uk website
is also commendable in the way it is using modern technology and
in the way it presents the waste issue. However, the site would
benefit from advertising to make people aware of its existence.
A successful waste awareness initiative which
serves as an example of best practice in Manchester is the Schools
Waste Awareness Initiative (SWAC) run in partnership by Waste
Watch and Stockport Metropolitan Borough Council. This involves
waste audits in schools, site visits to GMW facilities and hands
on practical work on recycling and waste management. This initiative
raises awareness of waste in children at school, thus raising
awareness in the home. This initiative is receiving recognition
through the Beacon Council open days operated by Stockport MBC.
There is the potential for WRAP to compile a data base of similar
schemes and disseminate this best practice.
The strategy must focus these initiatives, potentially
through WRAP, to ensure they reach the attention of those people
and elements of society that are not well informed at present,
rather than just those who are already involved in recycling their
waste.
GENERAL COMMENTS
The Government has announced the setting of
interim statutory performance targets in order to develop a national
recycling rate for England of 17 per cent by 2003. By implication,
a statutory performance target implies that there will be sanctions
against any authority which fails to deliver. The strategy does
not detail in any way what form these sanctions will take. If
the Government is looking towards statutory instruments to provoke
a national increase in recycling, the strategy must specify exactly
what these statutory measures are and the penalties involved.
Without this information, the strategy lacks the legal teeth to
provide any form of deterrent against continued inertia from local
authorities not to develop further recycling activity.
The strategy stresses that the Government will
monitor progress in headline indicators over time, and where a
trend is unacceptable, will "adjust its policies accordingly".
Exactly what form this adjustment will take is not detailed. Does
this imply legislative intervention, fiscal instruments, sanctions
against local authorities? The strategy calls for the waste industry
and other parties to be flexible and innovative, and in the face
of this potential for sudden policy change, flexibility will most
certainly be a requirement. The long term nature of waste management
and substantial investments involved in new facilities requires
clarity in policy from Government to enable effective planning
and provision. For the Government to say it will adjust its policies
accordingly does not give enough information regarding the options
for that change to enable effective long term planning. The strategy
is supposed to deliver a vision for waste management for the next
20 years, therefore an indication of the possible policy changes
would be beneficial.
In conclusion, the waste strategy does define
some of the actions required to increase sustainable waste management
and goes beyond the detail in A Way with Waste. This is
demonstrated in the statutory recycling requirements, changes
to the Landfill Tax Credit Scheme and announcement of the introduction
of tradable permits.
However, the level of detail on several of these
points is insufficient to enable long term planning to meet the
requirements of the strategy. Several sections of the document,
in particular those dealing with sanctions, permits and funding,
are particularly light on detail or require further consultation.
The document, therefore, comes across as a further consultation
exercise as opposed to a cohesive strategy setting out the way
forward for the next 20 years. Whilst it is recognised that to
some degree, flexibility must be built into any long term strategy
to account for changing circumstances, the future of waste management
and what must be achieved over the next 20 years is abundantly
clear from the Landfill Directive, Packaging Directive, Incineration
Directive etc. These pieces of legislation provide a clear framework
of what must be achieved and it was anticipated that the waste
strategy would provide the detail and clarity needed. Instead
it provides some of the detail and is clear in some areas, whilst
in others it is merely a further consultation exercise. It must
be hoped that the outcome of any further consultation is concluded
and assimilated rapidly so that action can occur to increase the
sustainability of waste management.
September 2000
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