MEMORANDUM BY WASTEPACK GROUP (DSW 14)
This inquiry and our submission follows the
Government's publication of the National Waste Strategy (the "Waste
Strategy") and whilst acknowledging that many of the drivers
are emanating from emerging European legislation, we believe that
the Government must be praised for its progressive stance towards
achieving a sustainable waste management strategy.
Our response to the Committee's inquiry follows
the sectoral approach set out in the Waste Strategy:
1. LOCAL AUTHORITIES
Local authorities and the effectiveness of the
relationship between collection and disposal authorities will
be crucial to the development of more sustainable waste management
in the UK.
The introduction of statutory performance standards
for recycling by local authorities in England and the setting
of reduction and recycling targets in the Waste Strategy creates
a major challenge, not least in the tight timescale (eg recycling
or composting 25 per cent by 2005). The previous administration's
25 per cent recycling target was never clearly defined and eventually
became "aspirational". As such:
— Wastepack would welcome the reform
of the recycling credits scheme to extend obligatory payments
to all third parties carrying out recycling of domestic waste,
and not just the collection authorities.
— We believe that the intent to explore
possible changes in legislation to support closer working between
collection and disposal authorities will be vital to overcome
one of the major obstacles to more benign environmental waste
activities.
— Indications are that there may be
a release of funds for Local Authority recycling. We believe that,
whilst the timing is right in terms of the public debate, political
demands and environmental imperatives, such money should be released
in a controlled manner possibly through a bidding public/private
sector partnership process. The alternative could result in a
proliferation of inappropriate and inefficient collection and
sorting systems, material over-supply resulting in collapsing
markets and, ultimately, public disenchantment.
2. PUBLIC EDUCATION
AND PARTICIPATION
TO REDUCE
HOUSEHOLD WASTE
Government has decided to pursue four schemes
to encourage public education and participation.
— We believe that there is a very strong
case for a model city project which would demonstrate best practice
for collection and Material Recovery Facilities (MRFs—domestic
and commercial) with linked economic development, delivering consumer
information and behavioural change.
— Wastepack has already had an approach
by one city to explore this idea. As waste cannot be divorced
from the whole sustainability issue this could be linked to local
Agenda 21 initiatives and could deliver a whole range of sustainable
development outputs.
— We believe that public education
on waste cannot possibly work without cultural and behavioural
change in society's attitudes towards the environment as a whole.
Sustainable waste education will help society to understand the
broader issues of sustainability and vice versa.
— Wastepack will be able to explore
this in more detail with the Committee and with the Government.
3. LANDFILL DIRECTIVE
The targets for reduction of biodegradable municipal
waste to landfill create a serious challenge for UK plc and will
require significant changes in behaviour within quite tight timeframes.
— To meet the reduction targets the
UK proposes to introduce tradable permits for local authorities
based on allocations linked to population and households. Local
authorities will be able to buy extra permits to landfill more
or invest in other waste management systems.
— As there is no compulsion to participate
we are uncertain how this could work—the worst performers
would not take part.
We understand that Government will be going
out to consultation on this issue and we believe that it is an
issue which the Committee should note.
4. WASTE DISPOSAL
AUTHORITIES (WDAS)
Wastepack welcome the Government's statement
that WDAs will be given the powers to require certain wastes to
be delivered to them separate from other wastes so that they can
be recycled and that targets will be introduced for achieving
pre-defined recycling/composting rates.
— However, the Committee should note
that it is unclear as to what the penalties would be for non-achievement
of these targets.
— Wastepack would be able to work with
WDAs to enable such waste to be sorted and recycled.
5. THE WASTE
AND RESOURCES
ACTION PROGRAMME
This will be a company limited by guarantee
to include DETR, DTI, devolved administrations and private sector,
its brief is to overcome barriers to promoting recycling and re-use.
— Wastepack believe that this body
should include fresh and radical thinkers and not the usual contemporary
players. However, the Committee should note that caution may need
to be extended with regard to a DETR/DTI sponsored body bidding
for landfill tax credits.
6. THE MARKET
DEVELOPMENT GROUP
SET UP
BY DETR/DTI
Wastepack believe that Government should use
economic instruments to promote demand for recycled materials.
This would follow precedent set in other areas, for example, the
VAT rate of 5 per cent on solar panels.
— The Committee should note that the
Government will be taking forward a number of the recommendations
plus pilot arrangements for a scheme to require public procurement
of certain recycled goods, starting with paper. However, unless
Government departments are legally able to specify UK sourced
recycled paper from UK sourced recovered paper, we believe it
is likely that public procurement will simply use continental-sourced
recycled office paper.
— The Committee should note that the
DETR/DTI £1.4 million programme to fund projects which increase
use of recycled materials was oversubscribed by around £50
million.
This highlights the innovation and entrepreneurial
opportunities which are awaiting exploitation with appropriate
funding mechanisms in place.
7. PACKAGING
The Government is considering what recovery
and recycling targets should apply from 2001 to 2006. We believe
that this is recognition that adequate investment has not taken
place and that the PRN system needs overhauling.
— In addition UK producers are also
having to pay for the Green Dot to go on their packaging for up
to seven separate green dot schemes in Europe. For example one
of our members has reported a pro rata cost in Eire of 25 times
the cost of UK compliance.
— We believe that the Wastepack model
of direct involvement in recycling using producer responsibility
funds is the only way forward for the United Kingdom to meet the
targets. We would be happy to explain this in more detail to the
Committee.
8. JUNK MAIL
We suggest that all junk mail should carry the
address of the Mailing Preference Service so that people can opt
out.
9. TYRES
The Committee should note that the industry-led
Used Tyre Working Group explored statutory producer responsibility
and levy arrangements but favoured a free-market approach to meet
the forthcoming landfill ban. No final decisions have been made.
— Wastepack believes that there ought
to be some independent representatives on the Used Tyre Working
Group to contribute their views on the development of this subject.
10. BATTERIES
There is a proposal to replace the existing
Directive and propose collection and recycling targets for spent
consumer, automotive and industrial batteries. The Committee should
note that:
— 600 million consumer batteries are
thrown away each year.
— When these are disposed of from households
they are not deemed to be special waste. When disposed of from
businesses batteries become special waste, as a result it may
be the case that some businesses may be in breach of Special Waste
Regulations.
— Technologies exist for treatment
and recycling of all battery types.
— Barriers in the UK are cost of collection,
sorting and recycling.
— There are no facilities in the UK
despite instructions on the batteries for them not to be disposed
of in the household waste stream.
11. WASTE ELECTRONIC
AND ELECTRICAL
EQUIPMENT (WEEE DIRECTIVE)
Whilst supporting the producer responsibility
concept, it is Wastepack's view that Government should avoid the
"packaging waste" approach to this issue. Wastepack
has applied for membership of the Industry Council for Electronic
and Electrical Equipment Recycling and looks forward to delivering
industry solutions on this issue.
12. TEXTILES
AND CLOTHING
— Between 550,000 and 900,000 tonnes
per annum of textile and clothing waste is generated in the UK.
— There is currently 25 per cent recovery
of post consumer textiles (this still leaves 75 per cent not recovered).
— Textiles and clothing could easily
be part of the innovative Wastepack "Pink Bag" collection
model for domestic waste. We would be happy to explain this idea
to the Committee in more detail.
13. AGGREGATES
LEVY
— Wastepack is in support of the levy—the
Committee should also consider the case for hypothecation of the
revenue towards aggregate substitution (glass, construction and
demolition waste).
14. COMPOSTING
An increase of 500,000 tonnes of central composting
took place between 1997 and 1998 of which 92 per cent was sourced
from civic amenity sites and parks and gardens—only 7 per
cent from kerbside.
It appears that local authorities may be using
parks' and gardens' green waste to offset their targets. Also
water companies are using sewage sludge treatment (traditionally
land spread after about a month of treatment) as "composting"
possibly with local authorities as partners.
— About 5 per cent of UK households
have a local authority composting bin funded from the local authority
budgets.
— We believe there will be an increased
emphasis on central composting because it gives local authorities
and Government the ability to measure performance. In economic
and environmental terms home composting is the best solution but
this would involve even more education of the public.
— The Committee should note that the
EU has indicated a possible Composting Directive.
15. WASTE TO
ENERGY
The Government view is that this will have to
play a full and integrated part in waste solutions but incineration
without energy recovery is no longer an option.
— The Committee should note that local
communities are often hostile to Waste to Energy developments.
— Waste to energy plants require waste
material as their "feedstock"—there is a danger
that the development of Waste to Energy will not incentivise the
public to modify their behaviour and reduce the amount of household
waste that they produce.
16. LANDFILL
TAX CREDIT
SCHEME
We believe that this could provide the lever
for substantial change providing that wise expenditure takes place.
— The Landfill Tax Credit scheme system
has received criticism and needs to operate more transparently.
— Under Wastepack's auspices an Environmental
Body (Pishiobury Trust) is being formed which will be applying
for landfill credits to expedite further projects, including pilot
plants, and Government co-operation within this area is sought.
We would be happy to provide the Committee with more details if
this would be of interest.
17. COST
Clarification is still required of how the implications
of the Waste Strategy are to be paid for.
— If, as there are indications, the
Treasury may release funds for the delivery of the National Waste
Strategy, spending the money wisely will be the challenge.
— Wastepack, with its track record
of innovation and efficiency, is prepared to assist Government
in identifying the best way forward. We would be happy to speak
to the Committee in more detail about the ways that this could
be developed.
September 2000
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