MEMORANDUM ON THE UK GOVERNMENT'S WASTE
STRATEGY AS DEPICTED IN WASTE STRATEGY 2000 (WS 2000) AS TO HOW
IT PROGRESSES THE AIM OF DELIVERING SUSTAINABLE WASTE MANAGEMENT
AS OUTLINED IN ITS OWN REPORT ON THAT SUBJECT PUBLISHED IN JUNE
1998
Cylch is a member network organisation representing
about 50 waste minimisation, re-use and recycling organisations
operating in Wales.
Cylch has discussed and collaborated with other
member networks of the community sector in preparing this submission.
Notably the Community Recycling Network, the Community Composting
Network and the Furniture Recycling Network. Cylch member organisations
have also contributed to this submission as well as sending in
their own.
This submission supports those of fellow networks
and seeks to identify points not raised in their submissions or
emphasised in the same way. We support the points our colleagues
made in respect of:
— Social Exclusion—Employment
and Social justice not addressed.
— Jobs—Potential to create large
numbers of jobs across the range.
— BPEO—should be scrapped until
a well-consulted methodology is agreed.
— Data—The need for some—past
data is totally unreliable.
— PFI—Should be withdrawn as
inappropriate.
— Incineration—unnecessary by
and large—a red herring.
— Deposit Bottles—an obvious
omission.
— Variable Charging—should be
signalled as inevitable at some stage.
— Composting Exemption—well overdue
to encourage development.
Cylch welcomes this review and is particularly
eager to make these comments because the Government of Wales Act
has enshrined the concept of "sustainable development"
in the governance of Wales and feels that "sustainability"
cannot be achieved in any meaningful sense unless waste is dealt
with in this manner. Waste and its consequent pollutions are,
after all, the ecological footprint that we leave for future generations
to deal with.
NB. The word Recycling is used colloquially
and always implies re-use.
1. INTRODUCTION
Cylch welcomed WS2000 and the public statements
made by government ministers at the time of its launch. At long
last it seemed that materials' recovery was to receive a boost
in the form of statutory recycling targets.
In particular we welcomed the assurances that
materials recovery and composting efforts would not be constrained
or limited by plans to build Energy from Waste (EfW) incinerators.
There was concern about this after the publication of the final
DETR consultation document "A Way with Waste" that seemed
to recommend that large numbers of incinerators be built as a
solution to the "waste problem" depicted therein.
We support the Waste Hierarchy and the proximity,
producer pays and precautionary principles that underlie it but
believe that waste minimisation should be emphasised more and
that materials' recovery should be on a rung higher and separate
from energy recovery.
2. GENERAL COMMENT
WS2000 cannot possibly be viewed as achieving
sustainable waste management because the target set for materials'
recovery and composting is only 33 per cent which means that the
plan is to continue to dispose of (destroy) 67 per cent plus of
waste by means which are recognised as not sustainable.
Landfill is demonstrably polluting. Leachate
to groundwater and gases that contribute to global warming to
air. Incineration produces toxic outputs also and emits dioxins
in fly ash and particulates through stack emissions. Bottom Ash
has also been demonstrated as polluting.
However Cylch believes that in the light of
recommendations made below any discussion about disposal options
is academic. If 85 per cent plus waste reduction is achieved these
discussions become irrelevant. This is why we believe that Zero
Waste should be the aim with percentage targets merely the necessary
benchmarks to measure progress.
3. WS2000 FAILS
AS A
MEANS OF
ACHIEVING SUSTAINABLE
WASTE MANAGEMENT
ON FOUR
MAIN COUNTS
1. Lack of vision.
2. The strategy focuses on waste disposal
when it should focus on collection.
3. WS2000 Patronises the community sector,
overlooks the operational role it is currently playing and ignores
its expertise.
4. Resources are available but not accessed
by the strategy.
1. LACK OF
VISION
Whilst materials' recovery systems in other
parts of the world achieve high percentages, WS2000 reprinted
the much-criticised data and forecasting of "the practical
limitations to materials' recovery" first seen in "A
Way with Waste" (AW3) and, as a direct consequence, significantly
overestimated the need for incineration to replace landfill as
a disposal option. It still cites 25 to 36 per cent as the highest
diversion percentage achievable and is satisfied with the meagre
target of 33 per cent (eventually) as an aim. We believe that
the government is over-influenced by those in the waste industry
that want to maintain waste as a commodity for commercial reasons.
That WS2000 panders to that lobby in an outrageous manner and
is therefore open to severe and fundamental criticism (ridicule
even) as a serious document.
Cylch believes that much higher percentages
of materials' recovery and composting are achievable and that
a much higher aim should be cited. Many believe that the only
sensible aim is zero waste if sustainability is to be achieved
and that this is not only possible but essential.
Sixty per cent plus could be achieved by the
removal and local processing of the organic fraction (including
paper) alone. This fraction, as CCN points out, is the only fraction
that is not subject traditionally to market constraints, can and
should be processed locally and removes most of the gas problems
associated with landfill. It is also subject, of itself, to statutory
reduction targets contained in the EU Landfill Directive.
Recommendation 1
That a vision be articulated and that a statutory
target of no less than 85 per cent materials' recovery and composting
be cited as the eventual aim. Interim targets could be detailed.
Recommendation 2
That the strategy should emphasise the composting
hierarchy (Home—Community—Centralised) as being able
to play a lead role in achieving waste reduction rapidly.
2. THE STRATEGY
FOCUSES ON
WASTE DISPOSAL
WHEN IT
SHOULD FOCUS
ON COLLECTION
WS2000 assumptions are based on the poor data
and analysis cited above. The focus is therefore on seeking an
alternative to landfill as a disposal option. Any strategy that
purports to be seeking to maximise materials' recovery for re-use
and reprocessing should first identify the need for a revised
collection system. Materials' merchants and re-processors require
uncontaminated material and delivering these requires that the
materials are separated at source or as close to source as possible.
Recommendation 3
That the strategy should recommend separation-at-source
as the fundamental pre-requisite of achieving sustainability and
achieving high reduction targets.
[Cylch has devised its own community based waste
strategy for Wales called CLEANSTREAM—Total Resource Recovery
Systems and offers it as a more achievable process to aspire to
and reach the targets suggested herein.]
3. WS2000 PATRONISES
THE COMMUNITY
SECTOR, OVERLOOKS
THE OPERATIONAL
ROLE IT
IS CURRENTLY
PLAYING AND
IGNORES ITS
EXPERTISE
Whilst recognising that the community sector
has a valuable role to play in the strategy WS2000 continues to
relegate that role to one of public education.
Member organisations in the sector operate large-scale
materials' collection services serving over 1.5 million homes
and collectively are bigger players than any commercial operator.
Yet this fact is repeatedly overlooked in government documents
that still portray the sector stereotypically as "projects
using a few volunteers to collect a few tonnes of paper or glass
for charity."
This is patronising in the extreme but more
importantly it has denied the government access to people who
have acquired a quite different expertise and view of materials'
recovery than those from the waste industry to whom the government
has always turned for "expert advice".—It shows
in all the consultation documents and WS2000 itself.
Recommendation 4
That resourcing and implementation of the strategy
be overseen by a cross-sectoral body that draws its members from
the public, private and community sector in equal numbers (one
third each).
Recommendation 5
That the role of the community sector and the
expertise of its principals be formally acknowledged.
Recommendation 6
That someone from the sector be appointed as
a Sustainable Development Commissioner in Jonathan Porrit's team
to safeguard SD Headline Indicator 15—the better use of
natural resources.
4. RESOURCES
ARE AVAILABLE
BUT NOT
ACCESSED BY
THE STRATEGY
The 1990's saw the last government introduce
several financial measures that were aimed at encouraging recycling.
All manifestly failed to do so but are still available for strategic
use if adjustments were made.
— Packaging Recovery Note revenues.
— Landfill Tax Credits Scheme.
Recycling credits (Environment Protection Act
1990)
Payments made to third party collectors that
can demonstrate that they have diverted material from disposal
(usually landfill). The payment should represent the highest marginal
cost of waste disposal that applies where the waste arises. At
present these are voluntary.
Recommendation 7
That the payment of Recycling Credits to accredited
collectors be made mandatory.
Packaging Recovery Notes (PRN's—Prunes)
(Producer Responsibility—Packaging regulations 1996)
Values that are attributed to weighbridge tickets
that prove that companies have complied with their packaging recycling
obligations under this legislation. An estimated £75 million
per annum was generated but no extra re-processing capacity was
created and none of the revenues reached the recyclate collectors.
Targets were reached too easily because they were soft and compliance
has been achieved by light-weighting packaging. (The targets are
measured by weight.)
Recommendation 8
That the recovery targets be hardened and the
threshold for compliance be dropped to include more companies
more rapidly.
Landfill Tax (1996)
Introduced as the first green tax. Two rates
£7 per tonne for controlled waste and £2 per tonne for
inert waste. (The £7 was raised to £10 in 1999 and will
increase by £1 per annum until 2004.) The tax was introduced
to make disposal to Landfill relatively more expensive in order
to adjust the economic argument in favour of more recycling. It
also affects the value of Recycling Credits (above). Revenue of
£500 million is generated for the Treasury. Materials' market
prices decreased in line with Landfill Tax increases—the
re-processors therefore acquired extra revenues (profits) and
no increase in recycling was engendered.
Recommendation 9
That consideration be given to using some of
this revenue (in addition to the LTCS below) for waste reduction
investment measures until such time as certain targets have been
reached.
Landfill Tax Credit Scheme
Landfill operators can claim a tax rebate of
90 per cent of any money they allocate to registered organisations
to spend on projects approved by Entrust, the regulator, as achieving
one or more of six "approved objects." This generates
nearly £100 million per annum.
However the regulations were so badly conceived
by the previous government that the LTCS is now nothing more than
a massive PR budget for the waste industry whose commercial interest
is to maintain waste. This is obviously contradictory and amuses/bemuses
foreign observers as well as frustrate recyclers. It seems that
the government and its officials are the only ones unaware of
the fact that they have been subjected to an elaborate confidence
trick. The scheme was designed for abuse.
The scheme was so poorly regulated at the outset
and in the early years of its operation that damaging precedents
were set that have led to an almost universal abuse—certainly
that major waste companies have benefited and continue to benefit
from the scheme contrary to the regulations.
The Chief Executive of the Environmental Services
Association has declared publicly that his members (the landfill
operators) cannot be expected to put money into projects that
damage their interests. He is right—they cannot, under company
law—do so.
Local Authorities—essentially the organisations
that pay the tax in respect of controlled waste have faced an
increase in disposal costs that has paradoxically disabled them
from investing in recycling schemes even if they had wanted to.
The scheme has thus had the opposite effect on municipal recycling
that the introduction of the Landfill Tax was designed to achieve.
Recommendation 10
That the scheme in its present form be abolished
because it is so poorly conceived. That the regulations be re-written
and the new scheme announced in the next budget speech by the
Chancellor. That the decision as to where LT Credits are allocated
is removed from the landfill operator Entrust resources for adequate
monitoring and regulation are now in place so the new scheme would
be more effectively policed.
OR
The money allocated as an annual fund to augment
the proposed £140 million challenge fund, the Waste Resources
Action Programme (WRAP) and the National Waste Awareness Initiative
(NWAI).
OR
That the number of approved objects be reduced
so that landfill operators have no choice but to support waste
reduction (they can therefore act legally).
OR
That any money expended on other categories
must be matched by contributions to the new category c—waste
reduction. (Thus ensuring a 50 per cent LTCS spend on actual waste
reduction.) Cylch preference on this would be that this spend
should be targeted at Local Authority and Community Sector CLEANSTREAM
partnership development—thus maximising community benefit.
September 2000
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