MEMORANDUM BY PROJECT INTEGRA (DSW 39)
INTRODUCTION
This evidence is submitted by Project Integra,
the public/private sector partnership implementing integrated
municipal waste management in Hampshire. Project Integra was awarded
Beacon Council status in December 1999 as an example of best practice
for dealing with waste in accordance with sustainable development
principles.
OVERVIEW OF
WASTE STRATEGY
2000
Project Integra welcomes the thrust of Waste
Strategy 2000, which reflects a number of the concepts pioneered
in Hampshire. There are two fundamental issues that impact on
the achievement of the vision.
The first relates to achieving the following
changes that are at the heart of the Strategy:
— designing products which use fewer
materials and using processes that produce less waste;
— putting waste to good use, through
re-using items, recycling, composting and using waste as a fuel;
and
— choosing products made of recycled
materials.
The key point arising is that only some of these
changes (those relating to recycling, composting and using waste
as a fuel) fall within the remit of traditional waste managers
and the waste management industry. The agenda the Government has
set out is for the more sustainable use of consumable materials
or resources and this latter link would be much stronger if the
Strategy were badged as a resource management strategy. The implications
of this point go far beyond the name. To address product design
and choice of products made of recycled materials there is a need
to engage a much wider network and across a much broader range
of disciplines than that historically involved in waste management
and take action to reduce the impact of resource consumption at
all stages from product inception to end of life.
The second issue is about the need for good
quality information about the quantities and constituents of the
resources in waste and the availability of effective tools to
aid decision making. The Environment Agency has a key role in
both areas but there are questions about the accuracy of the national
survey of industrial and commercial waste and the usefulness in
resource management terms of the data to be provided in the proposed
strategic waste management assessments (SWMAs). The WISARD life-cycle
analysis model is an important step forward in aiding decision
making but its implementation was delayed and progressive refinement
of the model is required as research and knowledge advances.
Locally in Hampshire, plans are being developed
to establish a community-based vision for resource management
linked to the sustainable development aims of environmental, economic
and social well being. This would be part of the community planning
process and provide a context for an updated waste strategy and
waste local plan to drive a step-change in the way materials and
other resources are managed. This framework would provide a focus
for industry and the basis for the further development and extension
of Project Integra's Beacon Council role by widening its remit
to include the recycling and recovery of commercial waste and
developing local markets for the resulting products. Detailed
research into the constituents of commercial and industrial waste
(to complement the household waste research already undertaken
by Project Integra) would be an integral part of the project.
The problem with getting an initiative like this off the ground
is the perennial one of funding to set up and manage the process
and demonstrate that it works.
The above concepts underlie the thrust of the
Project Integra comments set out below to the seven specific questions
posed by the Committee.
Will the Strategy result in more efficient use
of resources and a consequent reduction in the amount of material
entering the waste stream?
First, we would question the premise behind
the question as it is posed. The achievement in overall terms
of sustainable development could involve more material entering
the waste stream if that material was recycled or recovered. The
fundamental aim in resource management terms should therefore
be to reduce the quantity from which value is not recovered and
for which disposal is the only option.
That said, the aim of reducing resource use
at the supply end is crucial given the most significant impacts
in terms of waste are generally at the production of goods end.
The focus in the Strategy on household waste is therefore somewhat
inadequate, as it comprises a relatively small percentage of the
overall waste stream.
We are not convinced that the proposals in Waste
Strategy 2000 will directly lead to the radical change in culture
and thinking that is necessary. The fundamental issue is putting
sustainable design and consumption at the top of the agenda and
we see nothing in the Strategy that convinces us that a step-change
will be achieved, over and above the normal business pressures
that bring continuous evolutionary improvement.
Measures that the Government could take to assist
this process include more support and funding for research and
development into product design and wider use of producer responsibility
initiatives to encourage manufacturers and retailers to take a
"whole life cycle" approach to the products they produce.
In the local government sphere, local authorities
are well placed—subject to resources—as part of their
community leadership role under the Government's modernising agenda
to engage the community in general and small and medium sized
businesses in particular and get the message over about resource
use, waste and sustainability in a more integrated way. They can
also promote the involvement of a wider network of public sector
disciplines, eg economic development, corporate policy and planning
to make the linkages between resource management and sustainable
development in the context of community plans.
Will the Strategy result in an increase in the
recycling of waste, particularly by greater development of markets
for recycled material (including compost) and the use of producer
responsibility measures?
The Strategy contains a number of welcome initiatives
that should lead to an increase in recycling. These include statutory
recycling targets (collection and processing) and the Waste and
Resources Action Programme (WRAP) (markets).
The adoption of statutory recycling targets
appears to be in conflict with the principle of adopting the Best
Practicable Environmental Option (BPEO), given that they appear
to be conceived in a rather ad hoc way. However, as the targets
are the Government's chosen route, it is important that they are
applied fairly and equitably, ie so as not to benefit current
low achievers and with sanctions applied against those authorities
that do not comply without good reason. Our experience with Project
Integra, covering a population of 1.6 million with a diverse urban/rural
geography, is that an average 25 per cent recycling of dry recyclables
in household waste is relatively easily achievable with best practice
kerbside collections and 35 to 40 per cent is a challenging but
attainable target for the longer term. The key issue is timescale
in terms of putting the required infrastructure and support in
place and in this respect the recycling targets for 2003 appear
very optimistic.
The point about best practice is an important
one. Cost is fundamental to sustainability and the Project Integra
experience indicates that a sustainable waste management system
delivering the Government's targets could be provided for less
than £2 per week (about the price of a pint of beer) per
household if schemes were implemented on business principles in
line with best practice. The absence of specific proposals for
meeting the cost of new initiatives and the absence of any reference
to specific guidance or codes of practice on implementing integrated
waste management are major omissions in Waste Strategy 2000.
The above does of course assume that markets
are available for the materials. Collectors and processors competing
over markets and the prospect of recyclables having to be disposed
of is neither sustainable nor in the wider community's interests.
WRAP is therefore fundamental to the Government's recycling targets
being met. A key focus of the WRAP agenda needs to be developing
the range of products made from reused/recycled materials rather
than just expanding the existing recycling market sectors. An
example is green glass that could be used for a wider range of
containers as well as a raw material for other products such as
building materials, decorative household items, etc. It is too
early to pass a judgement on whether WRAP will succeed but suffice
to say that the task ahead is a daunting one if the Government's
ambitious targets are to be met.
Home composting has sustainability advantages
and should be encouraged. Centralised composting, particularly
of green garden waste, is an area where the adoption of best practice
in the production of a quality product can remove historic barriers
to the use of the process, making it affordable and viable on
a wide scale. Importantly, compost is a local product that is
outside the global market cycle that impacts on many other recycled
materials. There is a strong case for the Government seeking to
promote a rapid expansion of green waste composting as a corner-stone
of its recycling strategy.
In the industrial and commercial sector, producer
responsibility is an important driver in increasing recycling
levels. However, to be effective it must be implemented in a joined-up-way—have
the packaging regulations actually served to increase reprocessing
capacity?—and be policed to ensure compliance. From the
outside, it would appear that the Environment Agency is not in
a position to fully undertake the latter at the present time and
the Strategy fails to provide any assurance that this situation
will be rectified.
The proposals in Waste Strategy 2000 for incentives
to householders to increase recycling are trivial and serve to
undermine the seriousness of the problem and the solutions that
are required. There is no mention of potentially more effective
incentives such as charging for the collection and disposal of
non-recycled waste.
Will the Strategy result in 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.
In our view an increase in the use of energy
recovery incineration will be necessary as part of an integrated
waste management system if the UK is to meet its obligations under
the Landfill Directive. Whilst Waste Strategy 2000 recognises
the role of incineration, it stops short of giving it a "clean
bill of health" or articulating the role that the Government
expects the technology to play over the next decade and beyond.
This lack of leadership will be a hindrance to developers attempting
to implement specific proposals over the coming years.
Given the relative inflexibility and long-term
nature of incineration, there is a case for the Government providing
guidance on a minimum base incineration capacity as a foundation
for planning to meet the landfill directive at a national or regional
level. The extent of the role of incineration is open to discussion
but could by typically 30 to 40 per cent of suitable waste arisings
after allowing for recycling targets. There is a case for aiming
for such a base capability to be fixed, recognising the difficulty
of "predict and provide" in relation to the long lead
times (up to 10 years) associated with this technology. The emphasis
in the Strategy on community involvement and partnership working
is welcomed, but it does not provide any assurance of a positive
outcome to applications for planning consent. This latter issue
is becoming more complex as time goes on, eg the possibility of
additional delay as a result of challenges under the new Human
Rights legislation, but there are no easy or straightforward answers.
The business planning case and logistics for
a minimum new national incinerator network needs to be put in
place now. Such a network would not prejudice recycling objectives
nor would it provide a total solution for non-recycled waste.
It would however provide an important element and give time for
new technologies such as anaerobic digestion (AD) and gasification
to be demonstrated and proven in operational situations. AD in
particular has the potential to sit along side recycling, composting
and incineration as part of a fully integrated system to reduce
the landfill demand to the minimum. The modular nature of the
AD facilities phased expansion to deal with waste growth, something
that is less easy with incineration.
The transfer of waste management operations
to the private sector in the 1990s created a barrier to the development
and demonstration on a commercial scale of new capital intensive
waste processing technologies. Contractors, encouraged by the
conservatism of their financiers, have a natural tendency to adopt
the tried and tested at the expense of the new and innovative.
A coherent Government strategy for waste processing, including
support for the demonstration of new technologies such as AD is
therefore vital to meeting the requirements of the Landfill Directive
at the same time as keeping the use of incineration to a reasonable
minimum. In this regard, Project Integra has been trying for the
past six years to get a demonstration AD project in Southampton
off the ground but this has to date been blocked by problems of
affordability and the rules applicable to the Private Finance
Initiative.
Will the Strategy achieve 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
associated Credit Scheme.
The fundamental thrust of Waste Strategy 2000
is to reduce the use of landfill but much of the detail over implementation
of the Landfill Directive and the application, monitoring and
enforcement of targets is awaited. These details will be crucial
to its effectiveness in reducing landfill.
In our view the key issue is whether the Strategy
is capable of stimulating the rate of change that is necessary
to achieve the targets that the Government have signed up to.
There must, at best, be major doubts over this and indeed whether
or not the proposed targets are realistic given the financial,
planning and implementation issues involved with putting in place
new collection systems, a new processing infrastructure and new
markets. In the case of Project Integra, it will have taken over
10 years of hard work by the local authorities and our private
sector contractor to get to the point where landfill is reduced
to levels in line with the Landfill Directive—assuming planning
permission for two remaining planned energy recovery incinerators
are approved. However, that is not the end of the story as the
waste volumes handled by Project Integra have increased by 230,000
tonnes or nearly 40 per cent to 850,000 tonnes per annum over
that period and are set to exceed 1.1 million tonnes per annum
by 2010.
The Landfill Tax has been a positive influence
in focussing attention on alternatives to landfill but it is too
blunt an instrument to be a fully effective environmental incentive.
It needs to be linked to positive action to ensure alternative
options are practically available to shrug off the image that
it is really a revenue raising exercise in environmental clothing.
It is a major disappointment that Landfill Tax revenues have not
been made available in any coherent way to fund more sustainable
options. For example, the council taxpayers over the Project Integra
area currently pay over £7 million in tax and if this money
had been available to help fund the implementation of Project
Integra then much quicker and more substantial progress could
have been made in achieving our aims.
Notwithstanding the above caveat, the Government's
determination of tax rates up until 2004 has been helpful with
forward planning. There is need for the Government to set out
its intentions for tax levels beyond 2004 and in this respect
there is an argument for progressive increases to a rate of £20
to £25 per tonne for active wastes. This would level the
playing field with more capital intensive options.
We are not impressed by the operation of the
Landfill Tax credit scheme. At best, it can be regarded as a series
of worthy but disjointed initiatives that have some environmental
benefits. The 20 per cent cap on environmental monies is a major
limitation and the current method of operation lacks any sense
of a strategic overview to determine priorities and thus the allocation
of funds to best effect. In this respect, the local authority
members of Project Integra would question whether or not waste
management contractors are the right people to determine the amount
of landfill environmental monies allocated and the environmental
trusts to which monies are directed. A more satisfactory approach
for municipal waste tax monies would be to allow local authorities,
on behalf of their local communities, access to funds directly
to achieve defined targets and objectives.
Looking to the negative impacts of the Landfill
Tax, there is evidence in Hampshire of some increase in fly tipping
of commercial waste and indications that some small traders are
putting their waste through the household waste system. This is
an enforcement issue but currently it is one that falls within
a grey area between the Environment Agency and local government.
Clarification of responsibilities and clear national guidance
is needed to resolve this issue.
Will the Strategy result in a reduction in, and
better management of, hazardous waste?
Hazardous waste can be considered under the
categories of special waste which is subject to a special regulatory
regime and hazardous household waste that is generally diluted
and dispersed in the general waste stream. It is unclear what
impact the Strategy will have on the amounts and management of
wastes in both categories; on face value it will have very little
impact.
The area of hazardous household waste is of
particular interest to Project Integra. We lack a coherent national
strategy to manage such material and this is currently a major
omission. We have been trying for three years to implement hazardous
household waste reception facilities at designated civic amenity
sites in Hampshire but this has been frustrated by regulatory
difficulties with the Environment Agency. National guidance on
such matters is needed.
In the longer term, the way forward on hazardous
wastes would seem to be through producer responsibility and take-back
schemes as part of the overall concept of resource management.
Hazardous content of products and materials needs to be one of
the considerations taken account of in product design as part
of an overall life-cycle analysis process.
Will the Strategy result in significant action
to improve the example set by Government in exercising "green"
procurement policies?
One of the difficulties with green procurement
is the conflicting information and advice about what is best from
an environmental and sustainability point of view. The confusion
is at odds with green procurement and there is an urgent need
for a source of independent, impartial advice on such matters.
Information could be made available via the Internet and the necessary
resources provided from Landfill Tax monies. The WRAP could play
a key role in such an initiative.
There may also be opportunities to direct Landfill
Tax monies to pump-prime markets by offsetting the higher cost
of recycled products where these cannot be reduced to competitive
levels through the normal commercial process.
Further issues are the barriers to innovative
purchasing and resource use presented by traditional materials
standards and specifications. This is crucial and is a topic that
should be addressed as part of an integrated resource management
strategy. In the meantime, it is important that the Government
co-ordinate action with trade associations and professional bodies
to make progress in ensuring the material standards and specifications
are "fit for purpose" and do not discriminate against
recycled materials, etc.
Many public sector organisations are now subject
to Best Value and reviewing the application of sustainable development
principles is an important element in the process. This provides
an opportunity for green procurement to be reviewed over all relevant
activities, including in relation to contracted services.
Will the Strategy result in sufficient action
to educate the public about the importance of sustainable waste
management?
Waste Strategy 2000 is perhaps somewhat unrealistic
as to what public education can achieve in the short term. Our
experience with the Project Integra War on Waste campaign suggests
that local public education and information initiatives do not
offer a "quick fix" in helping to solve the waste problem
or implementing sustainable waste management. It is therefore
unrealistic to expect a major shift in public perceptions or behaviour
in the short term—one needs to look at the other end of
the pipe, ie manufacturing and retailing, to achieve quick action
to those ends.
This is not however to undervalue the importance
of public education as part of the wider debate about sustainable
development, including impacts of our current lifestyles and the
need to change. The point is to recognise the long-term nature
of the task (a generation or more to achieve real change) and
determine who is best placed to undertake it. Our view is that
locally based campaigns are not necessarily the most effective
in terms of value for money and what is needed are national, mass
media initiatives that focus on waste and resources as part of
the bigger picture. The national "Doing Your Bit" campaign
was therefore a welcome innovation.
The national "Buy Recycled" campaign
was an example of a good idea hampered by lack of resources.
The developing National Waste Awareness Initiative
is likely to be a key vehicle for public education as it has multi-sector
commitment and membership. However, to achieve results it needs
to be properly funded with Government and Landfill Tax monies
so as to achieve a high profile.
THE WAY
FORWARD
Project Integra welcomes the thrust of Waste
Strategy 2000 but urges that the vision it sets out be incorporated
in due course into a wider resource management strategy. Our main
specific concerns relate to whether or not the Strategy has sufficient
"teeth" to achieve the changes that are necessary in
the timescales that are required. On balance, we remain to be
convinced and suspect that further drivers based on the concepts
outlined in this memorandum will need to be activated if the Landfill
Directive in particular is to be complied with at a national level.
Local authorities could potentially play a significant
leadership role in advancing sustainable waste management in a
holistic way in their communities as part of the wider concept
of resource management. The key need is for the resources and
support to enable this to happen.
Note: Project Integra is a partnership
between the 11 district councils in Hampshire, Portsmouth and
Southampton unitary authorities, Hampshire County Council and
private waste contractor Hampshire Waste Services Ltd (part of
the Onyx Environmental Group).
September 2000
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