MEMORANDUM BY THE WEST MIDLANDS LOCAL
GOVERNMENT ASSOCIATION (DSW 23)
By way of introduction, the West Midlands Local
Government Association (WMLGA) is an association of the County
and Shire District Councils of Shropshire, Staffordshire, Warwickshire
and Worcestershire; the Metropolitan Districts of Birmingham,
Coventry, Dudley, Sandwell, Solihull, Walsall and Wolverhampton;
and the Unitary Authorities of Herefordshire, Stoke-on-Trent and
Telford & Wrekin. The WMLGA is the regional arm of local government
and aims to provide a coherent voice for the West Midlands Local
Authorities.
The WMLGA welcome the opportunity to comment
on whether the policies set out in the Waste Strategy are sufficient
to deliver sustainable waste management.
The WMLGA's observations are made in respect
of the issues raised:
More efficient use of resources and a consequent
reduction in the amount of material entering the waste stream
The present division of responsibilities between
waste collection and waste disposal authorities does not lend
itself to the maximisation of the potential economies that are
available and does not represent the arrangements that the West
Midlands Local Government Association believe should have been
put in place. The preparation of an Integrated Waste Management
Strategy (IWMS) provides the framework for developing the potential
effectiveness but relies on co-operation between the Waste Collection
Authority (WCA) and Waste Disposal Authority (WDA) where there
are two-tiered arrangements.
The measures necessary to reduce the amount
of waste entering the waste stream and to both recover value from
that waste and to minimise the quantities of biodegradable waste
going to landfill will involve very large sums of expenditure.
This will occur whether there is investment
in capital plant through the Public Finance Initiative (PFI) initiatives
or through revenue expenditure on segregated collections or other
ongoing initiatives. By having two separate authorities the potential
for maximising the necessary investment to bring about the efficient
use of resources and thereby achieve the objective of reducing
the amount of material entering the waste stream, is clearly more
difficult to achieve.
An increase in recycling of waste, particularly
by greater development of markets for recycled material (including
compost) and the use of producer responsibility measures
The various targets for recycling, composting
and recovering value in the Waste Strategy, together with the
reductions in landfilling Biodegradable Municipal Waste (BMW),
are not all complementary. If the authorities meet each of the
targets there will be an over-achievement of some targets.
It will not be possible to meet the targets
for reducing BMW to landfill without the use of Energy from Waste
plants. This will recover value from waste which is missed at
source or for which the optimum Life Cycle Analysis requires the
product to be cleaned before recovery eg tins or paper contaminated
with food. In order to compliment the initiative to reduce the
use of primary aggregate, the use of bottom ash from Energy from
Waste plants should count towards the recycling and/or recovery
of value targets.
The incentive to recycle and recover value from
waste is inextricably linked to secure and financially attractive
markets for the recyclate. The reliance on recycling credits creates
a false market and does not help the industry to become self sufficient
and credible in the medium to long term in the eyes of the public.
If the recyclate market is to be pump-primed
demand should be stimulated by tax credits or another incentive
to use recyclate not a subsidy for producing recyclate. This would
avoid a stockpile of unwanted material and would get the consumer
accustomed to purchasing goods made from recycled materials and
components because manufacturers found it commercially attractive
to make products using recyclate.
The measurement of the amount of waste that
is composted is and will continue to be pure speculation. Where
"home composters" have been provided there is no accurate
means of measuring how much they are being used and the amount
of waste which is being diverted from the collection stream and
being composted.
The development of a market for composted green
waste is important. There must be a quality assured standard for
the products if this is to be achieved and major retailers persuaded
to sell and promote the product. There is no common standard for
"substitute peat", "soil improver" or "mulch".
The results of the trials on farm composting
of supermarket waste that are currently being conducted should
be widely disseminated. Clearly there will need to be rigorous
quality control measures after the dangers arising from the use
of animal by-products leading to BSE and the more recent swine
fever outbreak.
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
The use of incineration with energy recovery
will be essential if the targets to reduce BMW going to landfill
are to be met. As a technique it is cost effective because collection
costs are low. Techniques using low temperature incineration are
being developed which allows recovery of glass bottles and tins
in a clean form. This is a much more sustainable method of disposal
as it maximises energy recovery without reducing the proportion
of material which can be recovered and recycled. In terms of Life
Cycle Analysis it is by far the most efficient technique as it
does not waste energy in the cleaning of the recyclate.
The discharge to air from incineration plants
is tightly regulated by IPPC through the EA. The amount of pollutants
and dioxins discharged from Municipal Solid Waste (MSW) incineration
is much less than discharges from power generation and industrial
processes.
The development of energy from waste plants
is a very expensive exercise in which the investment can only
be recovered over a long period of time thus tying the waste disposal
authority into a long term contract with little flexibility in
the quantity of waste to be supplied. Because of the need for
either the PFI backer or the local authority to obtain a commercial
loan for the development of an energy from waste plant it is necessary
to guarantee the quantity of waste delivered to the plant and
bankers have taken the view that only local authorities are in
a position to give that guarantee. This reduces the opportunities
for local authorities to develop less expensive plants of an optimum
size and minimises the opportunities for industrial and commercial
waste, which often has a high calorific value, to be disposed
of in this way.
The use of bottom ash as a secondary aggregate
can significantly reduce the cost of incineration by developing
a market for the product and a local source of material saving
transport costs. The productive use of the bottom ash will also
avoid landfill charges thus minimising cost to the Council Tax
payer and making airspace available for waste for which there
is no alternative to landfill without creating any new landfills.
It also promotes secondary aggregates from bottom ash thus meeting
another government target to reduce the use of primary aggregate.
A reduction in the amount of waste sent to landfill-in
this context; the Sub-committee would welcome views on the effects
of the Landfill Tax and its Credit Scheme
The landfill tax has diverted significant quantities
of inert waste from licensed landfill sites to exempt sites and
increased the reprocessing of construction and demolition waste
at the point of origin. The practice of recycling construction
and demolition waste on the sites on which it arises is a positive
move to reduce the amount of inert waste going to landfill.
It is too early to assess the impact of the
exemption for restoration materials which has been introduced
to try to address some of the difficulties that arose in restoring
despoiled sites. There has however been a serious problem with
a shortage of inert materials to restore sand and gravel sites
in river terrace locations particularly where the land was grade
2 and 3a in the Ministry of Agriculture classification.
It has not been possible to assess the impact
of the non-inert tax on practices in the non-domestic sector.
The Landfill Tax Credit Scheme has been effective
in diverting money to community projects but the amount of money
being used to aid research and develop new practices in the waste
disposal has been disappointing. The use of this Fund to "pump
prime" local recycling schemes and to encourage more innovation
and publicity would be a beneficial use of the money which the
industry generates.
A reduction in, and better management of, hazardous
waste
There has been no discernible change that we
are aware of in the management of hazardous waste. The implementation
of the European Directive banning the co-disposal of wastes will
have the effect of reducing the problems and potential risks associated
with the landfilling of hazardous wastes alongside other wastes.
Early decisions will need to be made as to which
sites (or parts of sites) will be licensed and managed to accept
hazardous waste. There will also need to be a significant investment
in plant to treat the waste if the anticipated high cost of landfilling
hazardous waste is to be minimised.
Significant example set by Government in exercising
"green" procurement policies
There has been no discernible increase in "green"
procurement policies by central government. A number of local
authorities use recycled paper and publicise the fact on each
sheet.
The use of the Internet to circulate information
has increased awareness in government activity but the printing
of hard copies of press releases etc has probably not, at a national
scale, reduced paper consumption. It has transferred the cost
and use of paper from central government to the user.
Sufficient action to educate the public about
the importance of sustainable waste management
The television campaign "Are you doing
your bit?" has been well promoted. There is very little other
evidence of education initiatives at national level.
Much of the information about waste incineration
focuses on the hazards from discharges and does not present a
balanced picture as to how small a "nanogram" is and
relatively how clean and green a technology energy from waste
is compared with other means of disposal and other processes which
result in discharges to air.
The importance of separating waste at source
and not putting items in a rubbish bin is something which could
be promoted as well as buying recycled goods.
Newspapers could be encouraged to publicise
the recycled content of the paper.
September 2000
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