MEMORANDUM BY TEG ENVIRONMENTAL PLC (DSW
25)
THE SCALE
OF THE
PROBLEM
The Waste Strategy 2000 envisages that by 2015
approximately one third of MSW (household waste) production will
be disposed of by landfilling, one third by incineration and the
remaining third by recycling through composting. The separated
organic fraction of MSW is said to be 65 per cent of the total.
In addition, all organic waste will have to be "treated"
before it is landfilled under the landfill legislation now in
place.
UK Waste Stategy 2000 targets are:
Recycle and compost MSW
25 per cent by 2005
30 per cent by 2010
33 per cent by 2015
MSW production in 1998-99 was approximately
28 million tonnes with annual growth rate of 3 per cent producing
by:
2005 33m tonnes (65 per cent organic
fraction = 21.45m tonnes)
2010 38m tonnes (65 per cent organic
fraction = 24.7 tonnes)
2015 44m tonnes (65 per cent organic
fraction = 28.6m tonnes)
The above only takes account of MSW. Industrial
and commercial activity is also producing organic waste in various
forms, some going to landfill, some to land application and some
still disposed out to sea. These wastes and their disposal routes
will either be closed or subject to much tougher legislation over
the period to 2010.
INCINERATION
There is no prospect that incineration can begin
to play the role anticipated in WS2000 much earlier than 2010.
The planning timescale and public resistance dictate a period
of seven to nine years before a new incinerator could be operational
from the date of application. Witness the recent live debate finding
strongly against the proposed incinerator at Wrexham on Radio
4, a result that is likely to be typical in most areas of the
country.
The promotion of incineration in WS2000 would
seem to be in direct conflict with the Government's welcome approach
to air pollution and to the agreements that they have signed up
to under the Kyoto Protocol.
The recent Government decision that incinerator
bottom-ash re-use will not count towards local authority recycling
targets reduces any perceived attraction of incineration. Additionally,
the forthcoming EU Directive on Incineration which is expected
to become law in the UK in 2002 for new incinerators and 2005
for existing plants will provide a significant increase in the
regulatory burden on non-hazardous waste incinerator operators
and drive a significant increase in costs all presumably to be
borne by council tax payers.
The EU Commission has recognised that there
are innovative developments already available in response to the
demand for the treatment of organic wastes, and to a higher standard,
which are both capital cost competitive and with a lower operating
cost than incineration and are more environmentally friendly.
Alternative solutions will be required if UK
and EU targets are to be met within the prescribed timescale and
in-vessel composting is a viable solution. Windrow composting
within a building and some in-vessel vehicles are a viable solution
for many wastes and thermophilic aerobic composting provides the
solution for the more difficult wastes.
STANDARDS
Composting has a vital role to play for MSW,
sludge and putrescible wastes but it will have to be "effective
composting" in the words of the EU Commission. The standards
of composting and the safety and quality of the end product of
the composting process will progressively be subject to tougher
criteria imposed through legislation.
The forthcoming EU Composting Directive will
require that suitable standards are enshrined in the legislation
of each member state. The Composting Association in the U.K. has
produced recommendations for composting standards to ensure that
the resulting end product from the compost process is fit for
its purpose.
It is believed that the EU Directive on Composting
may involve two standards of treatment for different groups of
waste according to the perceived risk to public health and it
is thought that these are:
Group 1—Green waste from parks and gardens,
wood waste, paper, cardboard, paper mill sludge, waste vegetables
etc. These and similar materials can be composted to produce a
useable soil improver in a low tech composting operation where
pathogen elimination is not a problem.
Group 2—Covers putrescible waste, food
waste from kitchens, canteens, restaurants, fast food outlets
and food processers. These should require the higher "enhanced"
standard of treatment if composting is to be a sustainable method
of recycling such wastes. The higher "enhanced" standard
will, in time, also apply to waste from abattoir, fish, tannery,
dairy, food and drink, distillers and brewers, some pharmaceutical
wastes and, of course, sewage sludge.
I enclose a copy of a letter from the EU Commission
which is positive and fairly unequivocal in its support of "effective
composting".[3]
As you will read, the letter refers to the necessary link or cross
reference between the two forthcoming EU Directives for Sludge
to Land and for composting. It is believed that "effective
composting" refers to "Enhanced" treatment which
is the higher standard in DETR terminology and is the equivalent
of "Advanced" treatment for the same standard in the
draft EU Directive on sludge.
MARKET FOR
COMPOST
All compost products have only one use—land
application. Increased concern over the quality of products applied
to land demand that they be safe—virtual elimination of
harmful pathogens; be acceptable in terms of public perception—free
of unpleasant odour and appearance—be beneficial—of
real value to the land; and should have low emissions in harmony
with the Kyoto Protocol.
The disposal route of all composted material
is preferentially to land. The increased production of composted
material will be competing for the available landbank of receptive
farmers, growers, landscape contractors etc. The quality and value
of the compost product will determine its acceptance. Low grade
material even when free of contaminants (plastics, glass etc.)
will only have a value as a soil improver and be competing with
higher quality products which add real nutritional value to the
soil. Finding outlets for low quality compost will be increasingly
difficult as the better quality and value products come onto the
market.
The highest standard for quality in the UK is
now set by the enhanced treatment for sewage sludge and this high
standard will have to be met eventually for all similar organic
wastes which may be perceived to present risk.
SUSTAINABLE
It is necessary that not only should the Waste
Strategy be sustainable but is required of the treatment process.
Therefore note has to be taken of the improved standards that
are required under forthcoming EU and UK legislation and any future
ratcheting upwards of those standards which can reasonably be
anticipated. The following are some of the points which should
be met by a sustainable process.
(1) Guarantees elimination of harmful pathogens.
(2) The end product should be so changed
that there is little or no resemblance to its waste source.
(4) No significant creation of dust.
(5) No harmful emissions—meets Kyoto
protocol objectives.
(6) Low energy requirement.
(7) Clear audit trail in treatment process.
(9) Meet end product analysis to satisfy
optimum safety standard.
It follows that any treatment process of waste
should also be a sustainable investment.
WHO PAYS
The problem of disposing of the organic fraction
of MSW has not just suddenly emerged. It has been a visible and
increasing problem year by year. Failure to tackle the problem
has been the lack of will, the absence of legislation and cost.
Cost is the major reason for doing nothing.
All waste from all sources has historically been disposed to the
lowest cost route and that mentality has not changed. Landfill
has been the dominant disposal route and there is strong competition
between the operating companies which maintains the low cost benchmark
against which alternatives have to compete. One of the major failures
of the landfill tax is that it has been set at much too low a
level and therefore there is a dis-incentive to invest in superior
alternatives. It is my opinion that until the tax level is £25
per tonne for organic waste it will not be effective. Even at
the current level it is damaged as a taxation instrument because
of the dodges that are permitted particularly where noxious wastes
are only taxed on the dry matter content. These wastes are frequently
in a sludge form with a dry matter of 20 per cent giving an effective
landfill tax rate of £2.20 against the £11 which the
householder pays for his or her waste through the council tax
for what is usually a less harmful waste. This is iniquitous.
Rather strangely, the decision on whether this
loophole can be exploited is not in the hands of the Environment
Agency but of Customs & Excise as the tax collectors. It is
difficult to believe they have the appropriate qualifications
to make judgements which can rarely be in the public interest.
The "who pays?" question is the source
of inertia to date. The "polluter pays" principle has
been accepted for most waste production except MSW due to the
reluctance of local government to recover the cost from the producer,
the householder, through the Council Tax regime because of the
possible electoral consequences. This lack of will should no longer
be an obstacle as the Government has set clear targets with dates
for achievement. Local Authorities can recover the cost through
Council Tax and blame the legislation imposed by central Government
and the EU. The electorate however will still be concerned to
see that their money is being spent wisely, in sustainable systems,
that meet the environmental objectives both current and which
can reasonably be foreseen.
The timetable for implementation arising from
Waste Strategy 2000 and other legislation is short and for the
necessary investment decisions it is even shorter.
3 Ev not printed. Back
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