MEMORANDUM BY THE COMPOSTING ASSOCIATION
(DSW 62)
1. INTRODUCTION
The Composting Association is the UK's membership
organisation, researching and promoting best practice in composting
and the uses of composts. It currently has almost 500 members
representing all sectors of the composting industry and acts as
the trade body for the industry.
The Composting Association broadly welcomes
the policy statements set out in the waste strategy for England
and Wales, Waste Strategy 2000 ("the Strategy"), but
is sceptical whether appropriate measures will be set in place
in time to ensure effective delivery.
It is disappointing that many of the technical
issues that underlie the Strategy have not been resolved, nor
does there appear to be a workable mechanism in place to ensure
that these issues are appropriately addressed.
2. TARGETS, GOALS
AND INDICATORS—THE
NEED FOR
MORE COMPOSTING
FACILITIES
The Composting Association welcomes the targets
set in the Strategy and, in particular, the Statutory Performance
Standards proposed for household waste in England. This demonstrates
a clear goal for local authorities to achieve.
In order to meet the Targets and proposed Statutory
Performance Standards, however, there needs to be a significant
increase in the number of composting facilities; additionally,
the Article 5 targets set in the Landfill Directive will necessitate
a further increase.
The Composting Association wishes to draw the
Committee's attention to a number of issues that are currently
impeding the development of the composting industry, in particular,
the development and expansion of composting facilities.
2.1 Strategic regional framework
The publication last year of Planning Policy
Guidance Note 10: Planning and Waste Management has set out various
policy issues on land use planning for waste management facilities
in England. The development of Regional Technical Advisory Bodies
(RTABs) is an important step forward, however, it is doubtful
whether they will ensure the delivery of the appropriate infrastructure
in time to meet the stated aims of the Strategy.
Members of the Association have expressed concern
that the recently established RTABs comprise primarily planning
officers. Instead a mechanism to ensure that representation of
a balanced membership should be created. This could include, for
example, waste disposal officers, waste collection officers, the
waste management industry, compost producers, re-processors, the
voluntary sector, Local Agenda 21 groups and so forth.
A key role of the RTABs should be to ensure
that a site-specific strategy for every region is set in place.
Based on correspondence with the Association, it appears that
RTABs will choose to opt for non-site specific strategies, leaving
decisions down to the constituent Waste Planning Authorities.
At present Waste Disposal Authorities (WDAs)
are seeking to develop and deliver their respective Municipal
Waste Management Strategies; this necessarily results in WDAs
considering disposal options in an insular manner, opting to seek
facilities centrally within the WDA area, rather than at locations
that offer the greatest potential but happen to lie on the periphery
where they would be best shared between WDAs. The key role of
the RTABs should be to ensure that these internal boundaries are
broken down in order to establish an appropriate regional framework.
The current system does not appear conducive towards co-operative
working on a regional basis.
2.2 Land use planning system
The Composting Association receives many correspondences
from members and would-be compost site operators in relation to
planning difficulties. In many cases there appears to be a serious
failure in the planning system, which extends from small-scale
community-based sites, to on-farm operations, through to large-scale
centralised facilities.
Members have reported increasing difficulties
in obtaining planning permission for composting facilities due
to public ignorance. There is therefore a clear need for additional
mechanisms to facilitate the planning process relating to waste
plants and to educate the general public in waste issues.
The Composting Association therefore has reservations
that the land use planning system will not permit the delivery
of the appropriate infrastructure to enable local authorities
to meet the proposed Statutory Performance Standards by 2003,
despite the statements in the Strategy and planning policy guidance.
2.3 Co-operation between WDAs and WCAs
The Strategy calls for effective working relationships
between WDAs and Waste Collection Authorities (WCAs). This would
be necessary if the Statutory Performance Standards were to be
set for WDA areas as initially proposed in the Strategy. The subsequent
proposals by the Government and Audit Commission to include standards
for both the WDA and WCA may lead to further "competition"
between WCAs and result in a lack of an integrated approach.
Additionally, many local authorities realise
that the only way targets can be met will be to collect green
wastes for composting. Rather than actually achieving an increase
in composting, the two tier Standards seem likely to create competition
between the WDA and WCA, resulting in the diversion of green wastes
from WDA operated Civic Amenity Sites to WCA operated collection
schemes. Current difficulties with the Recycling Credits Scheme
seem likely to amplify as a result.
The Association supports the proposal in paragraph
2.40 of the Strategy which states that "Waste Disposal Authorities
will be given the power to require certain wastes to be delivered
to them separate from other wastes so that they can be recycled".
However for this to be effective, clarification on the burden
of collection costs is required.
2.4 Definitions
One of the Strategy's main weaknesses is its
lack of clarity and absence of definitions on key terms. For instance,
recycling and composting are sometimes referred to separately
within the text, whereas on occasion "recycling" is
taken to include composting (for example paragraph 2.40), as quoted
above.
Of particular concern to the Association is
the lack of clarity on the definitions of both the "composting"
process and the resultant "compost". The composting
process means different things to different people (in terms of
the degree of decomposition/level of stability achieved, and the
extent of contamination). Uncertainties have already arisen and
need addressing by both the Environment Agency, with respect to
waste management licensing, and HM Customs and Excise, with regard
to the Landfill Tax. As yet, these are largely unresolved.
The Statutory Performance Standards have set
clear goals for local authorities to meet, however, the way in
which "composting" is carried out has not been clarified.
As discussed above, it is doubtful whether there will be sufficient
dedicated composting facilities in place by 2003 in order to meet
the proposed Standards. Additionally, source separation schemes
take time and resources to implement, therefore, despite the aims
of the Strategy to encourage the separate collection of materials
for recycling and composting, it appears that mixed waste treatment
options may result. Such vagaries will not necessarily result
in the most efficient use of resources and best practice with
regard to composting.
It is the Association's concern that add-on
"treatment" operations for the "organic" element
of mixed household waste will be established adjacent to current
landfill activities to enable local authorities to meet the proposed
Standards. These may be seen as short-term solutions, producing
low-grade materials that can only be used as daily landfill cover.
The use of the term "compost" in this context is inappropriate.
The Composting Association wishes to seek clarification on the
criteria that will be used by the Audit Commission when assessing
the Best Value Performance Indicator for composting.
It is disappointing that the Strategy was published
in the absence of the proposed guidance and interpretation of
the Landfill Directive. It is notable that the definition of "biodegradable",
which underpins the Article 5 Targets, was omitted from the Strategy.
The Landfill Directive will require the pre-treatment
of wastes prior to landfill, which will include aerobic treatment
methods to stabilise the organic fraction of mixed municipal solid
waste. It is the Association's concern that this will be classed
as "composting" and, unless a view is taken by both
Government and the Environment Agency, contaminated low-grade
materials will be produced in significant quantities. Without
additional controls this has the potential to undermine confidence
in the markets for composts, especially if they are applied to
crops that will enter the human food chain.
The Composting Association therefore seeks a
lead by both Government and the Environment Agency to ensure that
appropriate, workable definitions for composting and composts
are established.
2.5 Waste management licensing
Waste management licensing is not specifically
included within the Strategy. However, there are two important
issues that directly relate to the composting industry and decisions
that need to be made by the waste management industry to ensure
the aims of the Strategy are delivered.
The establishment of small-scale composting
facilities, including community-run sites, is currently hindered
by the lack of clarification on waste management licence exemption
criteria. There are currently a number of anomalies within the
existing Waste Management Licensing Regulations that have created
significant difficulties for exempt sites. A consultation document
proposing revisions was due for publication by the DETR last November
(1999), although this has not been published to date. The Composting
Association therefore wishes to see publication of the consultation
document as a matter of urgency.
The role of the Environment Agency in licensing
and regulating composting facilities is key to the development
of the composting industry. There have been considerable regional
variations in the way local licensing officers have dealt with
licence applications and regulated existing operations, which,
in some instances, has resulted in considerable and unnecessary
time and cost implications for the operator.
The Agency has begun to address these issues
by establishing a Composting Advisory Group and developing a Technical
Guide Document, which is due to be published for consultation
in October 2000. It is the Association's understanding, however,
that resources have not been assigned within the Agency to continue
the work of the Group and to ensure that the Guidance Document
remains up-to-date; an important consideration in the light of
the potential rapid development and expansion of the composting
industry. The Composting Association therefore urges the Environment
Agency to continue the work of the Composting Advisory Group and
to ensure that the Composting Technical Guidance Document is kept
up-to-date.
3. MARKETING
COMPOSTS
The Composting Association welcomes the establishment
of the Waste and Resources Action Programme (WRAP) to help overcome
market barriers. The development of sustainable markets for composts
will be fundamental in ensuring the growth of the composting industry
and its ability to meet the aims of the Strategy. At present,
the poor financial returns for composting (which is hindering
the development of the industry) can only be addressed by increasing
the gate fee for waste received and not from increased revenue
from selling compost.
The potential markets for composts are, however,
potentially large and include both agriculture and horticulture;
in particular, the use of composted green wastes is seen as an
important medium to either dilute or replace peat in horticultural
growing media. In order to develop these markets it is vital that
quality composts are produced, which have been derived from source
separated waste materials, so that confidence in the respective
market sectors is not undermined.
The vagaries discussed above in the definition
of composting and composts have the potential to seriously undermine
the existing confidence built up over the past decade by operators
committed to producing and marketing good quality composts. Today's
society has witnessed a number of significant food scares and
the Association expresses concern that unless clarification of
the terminology and uses of composts is made, similar difficulties
may beset the composting industry.
The Department of the Environment, Transport
and the Regions (DETR) initiated discussions on overcoming barriers
towards marketing composts through its Composting Development
Group, which led to the publication of a report in July 1998.
Although the DETR has been working to follow-up on the recommendations
in the report, it is disappointing to note that the work of the
Group was not continued after this date, nor were resources made
available to fund the key organisations referred to within the
report to carry out the necessary actions.
The Landfill Tax Credit Scheme has provided
some financial assistance, however, the lack of co-ordination
of projects by distributing Environmental Bodies and their reluctance
in many cases to fund long-term, strategic projects or support
innovative processes, has prevented a great deal of potentially
useful work being carried out.
The Composting Association urges WRAP to consider
funding strategic, long-term projects to develop the markets for
composts, such as the recommendations made in the DETR's Composting
Development Group's report, in particular the further development
of Standards for Composts.
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