MEMORANDUM BY CARMARTHENSHIRE COUNTY COUNCIL
(DSW 19)
More efficient use of resources and a consequent
reduction in the amount of material entering the waste stream
Whilst we agree with the thinking behind the strategy
there is little evidence to show how this is to be achieved in
practice.
The Case Study in relation to plastic bottle
recycling at Rushdon states that local authorities could increase
plastics recycling with little investment based on the Rushdon
method, however it does not indicate what infrastructure was already
in place. Could the same statement be made in relation to a local
authority with no kerbside collections in place, without any material
reclamation facility and with no processing locally. We think
not and consider the statements made in this case study to be
misleading. RECOUP have done little to assist local authorities
with infrastructure developments and in particular assistance
with regard to providing the necessary financial resources in
order to enable developments to materialise has not been forthcoming.
It would be fair to say that this is true for most of the potentially
recoverable materials in the waste streams of Wales.
Collection authorities have to cover large areas
and therefore the costs of collections are great. If as the strategy
indicates more and more wastes will require to be collected separately,
who will pay for this additional financial burden, and how will
it be financed? No account is made of escalating fuel prices anywhere
in the strategy. The costs of transporting collected materials
on to processors is making collections financially unviable. The
government needs to tackle this issue with utmost urgency in order
to make the strategy achievable. The strategy needs to be specific
in how the costs of collection and onward costs to processors
are to be met in a fair and equitable manner.
An increase in recycling of waste, particularly
by greater development of markets for recycled material (including
compost) and the use of producer responsibility measures
An increase in recycling will only be achieved
when the necessary infrastructure is put in place. This includes
the development of markets for secondary materials. Producer responsibility
and the PRN system has had no impact on this authority. We have
not received any additional financial support to assist us in
developing the infrastructure we need to enable the separate collections
of materials. Further more the producer responsibility measures
could hinder development of sustainable waste management practises
in authorities with large rural areas as the producers no doubt
are concentrating on areas where large volumes of wastes are being
generated. This makes it an inequitable system and could deny
householders the opportunity to participate if they were living
in a rural area for example. The strategy does not make adequate
provisions for the special circumstances that rural authorities
face in relation to the provisions of waste (and other) services
to the public.
We also consider the present system of monitoring
the effectiveness of the packaging directive to be inadequate,
and relies too heavily on obligated companies providing the necessary
information. The government needs to reconsider how this can be
better measured.
The bottle back scheme has had a detrimental
effect on this authority as our commercial waste services lost
valuable contracts to the private sector. Another example of obligated
companies only being interested in economies of scale in relation
to collections of materials.
Increased use of incineration as a waste disposal/recovery
option and its implications
We would consider that unless adequate infrastructure
is put in place to deliver the strategy by means of increased
financial resources to provide for collection, sorting and processing
of wastes for recovery by reuse or recycling then there is a real
danger that the only other perceived option to deal with wastes
in accordance with some of the directives would be to opt for
incineration. The danger with this is that the opportunity to
reuse or recover would be lost forever since the capital investment
required to finance such plants would need secure long term assurances
that a certain minimum tonnage of wastes would be made available
for this. This could deny the opportunity to invest in the necessary
research and development as described under the Waste Resource
Action Program and a conflict of interest could develop between
different sectors within the waste management industry. Adequate
measures need to be put into place to ensure that local and regional
strategies take into consideration the long term impacts of the
options chosen. This is currently lacking in the strategy.
Whilst we note that the strategy indicates that
information needs to be managed, it does not clearly indicate
how information management is to be carried out or who will do
it.
A reduction in the amount of waste sent to landfill
and the effects of the Landfill Tax and associated Credit Scheme
We are concerned with the monitoring and review
group's role. How will they gather the data? How will the reduction
measurements be made? Parts of the strategy are quoted as volumes,
and other parts quote tonnages. An example of this is the statement
that the perception in relation to the amount of plastics waste
in the household bin is greater than 11 per cent. If measuring
volumes then this perception is probably correct, however it is
probably not correct if measuring by weight. Consistency in monitoring
waste arisings and disposal would be assisted if it were a mandatory
requirement for the whole of the waste management industry, to
collate data on the weight of waste collected through on board
weighing mechanisms and to charge for its disposal by weight and
not by volume.
How is the landfill directive in relation to
the reduction in biodegradable waste disposal going to be monitored.
We have no knowledge how much this is now therefore how can comparisons
be made in the future. The household waste stream needs to be
monitored to provide the necessary data to make meaningful interpretations.
Credits in relation to savings in disposal should
be made mandatory to local authorities to enable them to ring
fence savings to make investments to deliver their local waste
strategies. Currently, all too often these savings are considered
as corporate efficiency measures and disappear into the corporate
kitty. Landfill tax credits through the Entrust scheme needs to
be more accessible and more closely monitored to ensure that they
are distributed for projects that truly satisfy the regulations.
A reduction in and better management of hazardous
waste
Whilst we agree with the principles described,
again there is little evidence to indicate how these measures
are to be financed and who will pay for them. For example, with
a significant amount of agricultural wastes to be classed as special
wastes under the extension of waste management controls, who will
be responsible for financing the consignment fees? Will there
be provisions made to offset additional financial burdens to those
in agriculture that are already experiencing financial difficulties?
Inadequate fiscal measures to help farmers with added costs of
consigning special wastes could result in an increase in illegal
and irresponsible disposal of such wastes and work against the
very system that is being designed to reduce this. We would suggest
that the government treat this issue with the greatest of urgency
particularly in the light of recent events.
We would have liked to see the inclusion of
"sanpro" wastes within the category of clinical waste
on the basis that we could never be sure how healthy our population
is, together with adequate financial resources to dispose of this
appropriately through waste to energy plants. Disposing of this
type of waste through landfill should be discouraged, and other
methods of minimising it encouraged through finance or tax allowances
being made available to new parents for example to encourage them
to use real reusable nappies instead of disposable ones.
NHS Trusts should encourage the use of reusable
nappies by using them on the wards and by promoting them through
their ante natal and parenting classes.
NHS Trusts should also examine ways in which
they can reduce their wastes disposal costs. It is our experience
that hospitals are using the yellow clinical waste sacks and service
to dispose of office wastes including paper and other consumables.
Significant action to improve the example set
by Government in exercising "green" procurement policies
The delivery of the UK's strategy and targets
would be made easier if the remit of the Best Practice programme
were expanded to include local authorities and NHS Trusts. This
would be of enormous benefit as the lead by example regime would
be evident on the doorsteps of local business and householders.
Local authorities offer services to businesses through their economic
development functions and the Best Practice messages and support
could be delivered through these mechanisms. Similarly, assistance
could be given to voluntary organisations and other groups associated
with service provisions local authorities facilitate.
We consider this to be an action that would
have significant positive impacts on delivering the messages to
the wider community with the minimum of resources and in the most
effective and efficient manner. It may be of value if this were
piloted and audited.
Sufficient action to educate the public about
the importance of sustainable waste management
There are too many ineffective initiatives currently
ongoing, such as Going for Green themed months whose literature
arrives so late it is of little use, and the Buy Recycled campaign
whose material is lacklustre, and the Environment Agency's themed
months, and the NAWAI campaign as well as the Anti litter campaigns
such as Gum Busters, Urban Blooms etc Why not reduce duplication
of effort and have one fully co-ordinated campaign for the whole
country. This would ensure consistency of message, clarity of
message and measurable outcomes. A body needs to be identified
that will deliver this and also act as a focal point whereby advice
and information can be obtained in relation to funding for local
initiatives to make environmental improvements that will have
a positive environmental impact on local waste management issues.
Too many people are currently involved in doing too many things
and efforts are disjointed and uncoordinated. The stakeholders
need to get together and formulate one single strategy that will
be adequately resourced and provide the momentum for local action.
For example, how many of the soaps on TV ever have anything in
them about waste? I would suggest that if the Chief Executives
of terrestrial television were briefed with a request for assistance
to include these real issues assistance would be given. Simple
measures often provide great benefits. As a Welsh authority, little
regard is given to the requirements of the Welsh Language Act
by national campaigns and more often than not the material supplied
cannot be used as it stands as it is not in a format acceptable
for use by Welsh local authorities. This means that local authorities
in Wales have to either not use the material or must pay for additional
materials to be produced locally after translations. An example
of this is the recent Gum Campaign that we promoted with the Tidy
Britain Campaign. None of the promotional material was available
in Welsh and we had to resource this ourselves. Adequate finances
need to be in place for issues such as this so that local authorities
in Wales do not have to foot this additional financial burden.
As a summary, in relation to annex B16, whilst
in agreement with the sentiments as stated, we cannot emphasise
strongly enough that without the adequate financial resources
to invest in capital plant, equipment and associated infrastructure,
including processing and markets, targets will never be met regardless
of the challenge and regardless of the willingness of the public
at large to participate.
We cannot emphasise strongly enough that adequate
resources must be set aside to make these necessary investments.
To date none of the fiscal measures outlined in the strategy have
had adequate impact on the ability of this authority to make progress.
September 2000
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