MEMORANDUM BY THE ROAD HAULAGE ASSOCIATION
(DSW 27)
1. INTRODUCTION
1.1 The Road Haulage Association (RHA) was
formed in 1945 to look after the interests of haulage contractors
in various areas of the country, in effect, amalgamating local
organisations that had been established. The association has subsequently
developed to become the primary trade association representing
the hire-or-reward sector of the road transport industry. There
are now some 10,000 companies in membership varying from major
companies with over 5,000 vehicles down to owner-drivers.
Many of the owner-drivers, as well as larger
member companies, are involved in waste in some form, particularly
with regard to tipper operations, transfer stations, recycling
centres and inert landfill sites. Within the RHA there is a Waste
Group which represents approximately 900 member companies, a number
of who have contributed to the enclosed submission.
2. COMMENT
2.1 The Waste Strategy 2000 is a bold attempt
to change the way we manage waste. We agree that waste must be
put to better use, however a waste strategy should include all
wastes. An effective national waste strategy which excludes 40
per cent of waste generated cannot be an effective strategy.
The RHA therefore considers that the final strategy
should include:
— Mines and Quarries waste
— Water Industry—Sewage Sludges
2.2 The national waste strategy must have
Environmental Protection and Enhancement as the main priority,
therefore the cornerstone to the strategy must be Best Practical
Environmental Option (BPEO). It is the lack of imaginative long-term
view that is currently missing. There is no effort or incentive
to produce a limited type of packaging and materials which end
up as a wide variety of waste material. With a limited range of
consistent higher volume material, reuse and recycling would be
simpler and more economic.
2.3 We are broadly in agreement with the
policies and objectives of the Waste Strategy. But we have reservations
concerning its focus on the recycling role of local authorities.
Whilst this is important, even more important is the need to foster
a consumer climate that demands waste reduction and supports a
buoyant market for reusables and recyclables. Without this we
fear that the considerable resources being made available to support
the Strategy will be wasted.
2.4 Our memorandum addresses this issue
of focus first and then provides comment on the specific areas
the Sub-committee has identified as being of interest to it.
3. FOCUS OF
THE STRATEGY
3.1 The RHA agrees with the need to reduce
waste and increase re-use and recycling. We also accept that our
current dependence on landfill needs to be reduced, although we
equally acknowledge that landfill will continue to underpin our
waste management system for many years yet and that in some more
rural areas may well remain BPEO.
3.2 The overarching objective of the Strategy
must therefore be to facilitate a sustainable market for waste
materials. We have concerns that the Strategy's emphasis on targets
and goals for local authorities is somewhat adrift from this.
We recognise that the public sector is one area Government can
directly control, given that waste management in England and Wales
is exclusively a private sector operation. Nor do we seek to denigrate
the crucial role the public sector has to play if the Strategy
is to succeed. But in terms of sustainable waste management the
principal role of the public sector, like that of the waste management
industry, is to be a facilitator. It is the consumer who is able
to ensure that waste reduction and waste reuse and recycling on
the scale envisaged by the strategy will take place sustainably.
3.3 We remind the Sub-committee of the recent
experience of Germany where local authorities, aided by the private
sector, worked with Government to recover and recycle wastes in
advance of a sustainable market for these materials being developed.
The end result, after considerable expenditure, was warehouses
full of unwanted materials which are now being dumped in landfills
throughout Europe. Closer to home the Sub-committee will recognise
the failure of the glass and paper recycling to establish sustainable
markets through oversupply and the supply of inappropriate materials.
3.4 Encouraging greater local authority
participation in recycling is important. But it must take place
at a pace and scale comparable to the development of sustainable
markets for recyclables. Local authorities cannot, in themselves,
create such markets. They can only facilitate their development.
4. EFFICIENT
USE OF
RESOURCES AND
REDUCTION OF
WASTES
4.1 The Waste Strategy proposes four broad
policy instruments as the key to delivering its goals. These are
the Waste and Resources Action Programme; the waste minimisation
requirements of Integrated Pollution Prevention and Control Regime
(IPPC); the Landfill Tax escalator (see 7 below); and limiting
landfilling of waste by use of tradable permits (see 5 below).
4.2 The Waste and Resources Action Programme
(WRAP) has the following functions:
(i) market facilitation including identification
of new uses and applications for recyclate: development of waste
exchanges: removals of institutional barriers: and improving consumer
awareness;
(ii) promotion of investment in recycling;
(iii) research management;
(iv) information management—building
on the Waste Management Information Bureau; and
(v) advice, guidance and technical support.
It will have a budget of £25 million over
three years from DETR and an as yet undisclosed sum from DTI.
4.3 We contend that this remit it too wide,
and consequently inadequately funded, for WRAP to have any chance
of making a far reaching contribution to sustainable waste management.
Far better if WRAP's remit was focused on raising consumer awareness
and inculcating a culture of waste minimisation and reuse/recycling.
In that way, working with all sectors, it could act as a catalyst
for new markets for waste materials.
4.4 To achieve this the work of WRAP will
need to be supported by other measures. The RHA recognises the
crucial roles Producer Responsibility Initiatives and public sector
purchasing policies have to play. These have to take place along
with recycling initiatives as part of developing the market for
waste materials.
4.5 Turning to IPPC and waste minimisation.
If plant and processes are, as they should under IPC, conforming
to the Best Practicable Environmental Option and employing Best
Available Techniques then it is difficult to see what further
scope remains for waste minimisation. Such waste minimisation
is more likely to occur as new markets call for new processes
and plant.
4.6 We do however, via IPPC, see how the
EA can suggest changes to techniques in order to facilitate additional
or the introduction of recyclates into the relevant process. Something
which is not necessarily identified within the role of the EA.
5. MEASURES TO
INCREASE RECYCLING
5.1 Provided it is in parallel with the
development of a sustainable market for waste materials, the RHA
supports the challenging targets set for local authority waste
recycling. But it is important that the enthusiasm (or coercion
through statutory performance indicators) to meet these targets
does not run too far in front of the emerging markets for waste
materials. Otherwise we will repeat on a much larger scale the
already unfortunate experience of paper recycling where oversupply
has almost decimated the market.
5.2 The RHA is drawn to the conclusion that
the introduction of tradable permits owes more to Government's
obligations under the EU Landfill Directive than it does to any
clear appreciation of how a sustainable market for waste materials
is to develop. In this context we equally regard the Landfill
Tax Credit Scheme as a blunt instrument in promoting sustainable
waste recycling.
5.3 We however, as noted above, agree with
Government that public procurement and producer responsibility
initiatives have key roles to play in promoting increased use
of recycled materials. It is in this area where the waste strategy
is weak. Where are the incentives to produce materials which are
easy to recycle on a consistent basis?
We need to start at the beginning if we are
to influence the end.
6. INCREASED
USE OF
INCINERATION
6.1 There is no doubt that the recovery
of energy from waste has a significant role to play in delivering
the Waste Strategy. But we signal our reservations as to how energy-from-waste
is being developed in England and Wales.
6.2 We consider the current average size
of energy-from-waste plants as inimical to both waste reduction
and to the development of a sustainable market for recyclables.
Plants of a throughput of 200,000 tonnes per annum or above require
long-term contracts guaranteeing the calorific value of waste
if they are to be economic at current waste disposal prices. As
such they limit, and possibly preclude, the development of alternatives,
particularly when new opportunities appear.
6.3 To meet the objectives of the Waste
Strategy more, smaller sized, energy-from-waste plants, based
on serving local communities or neighbourhoods, are required.
Plants of 50,000 tonnes per annum are less likely to suppress
other initiatives and be more acceptable publicly.
6.4 Under the climate change programme there
has been identified additional financial incentives in the development
of CHP facilities. It would be of significant advantage if similar
measures were available for both recycling and waste to energy
developments.
6.5 It is recognised that larger waste to
energy plants are required if they are to be economic, however
de-rated and accelerated capital allowance would allow smaller
more publicly acceptable plants to be developed.
7. LANDFILL TAX
7.1 Our experience is that landfill tax
has not reduced the amount of waste being landfilled. (An exception
is "inert" wastes which are increasingly being dealt
with in ways which, if they meet the letter of waste management
licensing, pay little regard to its spirit). This is unsurprising
given the lack of alternative markets for waste and the relative
insignificance of waste management costs to both the public and
private sectors. We conclude that landfill tax has a limited role
to play in delivering the Waste Strategy.
7.2 Whilst acknowledging the many benefits
flowing from the Landfill Tax Credit Scheme, we do not regard
this as an appropriate means of funding reuse and recycling schemes.
As a source of funds it is uncertain, and anyways as landfilling
diminishes substantially, as the Waste Strategy envisages, so
too will the funds available.
7.3 However, the Landfill Tax flow into
the treasury could be utilised to fund accelerated capital allowances.
8. HAZARDOUS
WASTE
8.1 It is the EU Landfill Directive, not
the Waste Strategy, that is the driver for change in the management
of hazardous waste in England and Wales. The almost overwhelming
disincentives to develop, as is required, brand new landfills
for hazardous waste, plus the costs of providing alternative technologies
and facilities in an uncertain market, will inevitably see the
management of most hazardous waste move from the waste management
industry back to the waste producer. Whilst this may prove a welcome
incentive for the reduction in volumes of hazardous waste produced,
it is unclear if it will lead to their better management.
8.2 The slow progress on consultation on
the Transposition of the EU Landfill Directive is of particular
concern to the industry at this time.
9. PUBLIC AWARENESS
9.1 Central to our submission to the Sub-committee
is our conviction that only through increased consumer awareness,
and from that the exercise of demand and choice, will the objectives
of the Strategy be realised. We reiterate our view that local
authorities and the waste management industry can be no more than
facilitators. Demand is from the consumer and the Strategy will
be realised by industry responding to this demand. Supply-side
management will not deliver the Waste Strategy.
9.2 The RHA sees Education as one of the
key challenges effecting the national waste strategy. The will
of the people for more recycling is evident, however public acceptability
for more waste treatment facilities and increased recyclate in
consumer goods is not yet evident.
"Education" is therefore a pre-requisite
to a successful strategy including a full understanding of BEPO,
and the need to influence all procurement practices.
10. CONCLUSIONS
10.1 The RHA welcomes this enquiry into
the hugely important Waste Strategy and the opportunity afforded
to us to give our views.
10.2 The Waste Strategy is both a necessary
and bold leap forward for waste management in England and Wales.
We endorse its vision and support many of its policies. We however
believe that more emphasis should be given to the role the consumer
must play if a sustainable market is to be developed. In this
regard the public sector is, of course, a consumer. We contend
that too much emphasis is placed on forcing local authorities
to recycle, and invest in recycling, without any clear appreciation
of what will happen to the recyclate.
10.3 We remain concerned that there is no
overall "environment" policy as we have particular limited
areas:
— Climate Levy/Energy Tax
It is clear that an energy tax on electricity
consumed will impact negatively on the economics of recycling.
10.4 The RHA would welcome an all encompassing
national waste strategy with a priority of Environmental Protection
and Enhancement the cornerstone of which is Best Practical Environmental
Option.
The main challenges for an economic effective
national strategy are:
Education
— promote responsible attitudes and
awareness of waste and environmental impact.
Planning
— provide an efficient system recognising
regional influence without compromising proximity principles
Economics
— finding the right balance of fiscal
measures to sustainable development which are not disjointed by
other narrow-minded initiatives.
September 2000
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