MEMORANDUM BY ENVIROS (DSW 63)
INTRODUCTION
This memorandum is prepared by Enviros in response
to the Sub-Committee's call for comments on the Government's waste
strategy for England and Wales, Waste Strategy 2000 and the progress
that has been made in delivering sustainable waste management.
Enviros is one of the UK's leading environmental
management consultants. A large proportion of our work involves
working with governments and businesses on all aspects of waste
management. Enviros has been at the forefront of establishing
regional programmes in the UK to facilitate the development of
new markets and applications for materials recovered from the
waste stream (the ReMaDe programmes).
Our response is structured around the issues
raised by the Sub-Committee and is limited to eight A4 pages as
requested.
You asked whether Waste Strategy 2000 would
result in:
1. RESOURCE EFFICIENCY
AND A
CONSEQUENT REDUCTION
IN THE
MATERIAL ENTERING
THE WASTE
STREAM
Although the Waste Resources Action Programme
(WRAP) proposed in the Waste Strategy 2000 is likely to reduce
substantially the amount of waste requiring disposal, much of
its activity will, we understand, be focused on the re-use of
waste materials. This will necessarily be after they have entered
the waste stream and would have less effect on waste minimisation
at source.
It is increasingly recognised that more radical
and far reaching approaches need to be considered to tackle waste
at source. Measures include, inter alia:
— Promotion of cleaner technology,
employment of environmental management systems and waste minimisation
programmes in industry;
— Enhancement in product development
and design, possibly based on life cycle analysis, to facilitate
re-use of components, repair and ease of disassembly;
— Systems for the management of packaging
waste and other priority waste streams, including Extended Producer
Responsibility;
— Development of stronger and more
sustainable markets for recycled materials.
Waste reduction through preventative measures
is required to support efficient and integrated waste management
systems. Waste minimisation remains the most important element
in a sustainable waste management policy. The work of WRAP should
seek to deliver the Waste Strategy 2000 through robust means of
achieving waste reduction in households, commerce and industry.
2. INCREASE IN
RECYCLING AND
THE DEVELOPMENT
OF MARKETS
FOR RECYCLED
MATERIAL
Waste Strategy 2000 places considerable emphasis
on the need to divert waste from landfill. National targets for
recycling are set for household waste and these are to be backed
by statutory performance standards at individual authority level.
The main mechanism for assessing local authority performance against
these and other national policy objectives is Best Value. Waste
Strategy 2000 implies that these targets are to apply at the level
of a waste disposal authority, whereas the consultation document
on Best Value and Audit Commission Performance Indicators for
2001-02 sets the performance standards at both waste collection
authority and waste disposal authority level. It is to be hoped
that this will not encourage local authorities to operate in isolation.
Local authorities must continue to work together
to deliver integrated waste management services. The collection
authorities cannot plan recycling services without consideration
of the other authorities in their area and the disposal authority.
The way collection authorities collect recyclables has implications
for the options adopted for sorting and processing, and the nature
and quantity of the residual wastes. There are considerable benefits
to be achieved through joint working together in terms of economics
of scale, access to a wider range of options, and greater strength
in negotiating with reprocessors. Many authorities are well advanced
in developing joint Municipal Waste Strategies and this must continue
to be encouraged. The Strategy also alludes to penalties if targets
are not achieved, but gives no indication of what these might
be.
The latest statistics from the DETR's annual
municipal waste survey indicates that around 30 per cent of households
now receive some form of kerbside collection service for recyclable
materials, yet the average municipal recycling rate in 1998-99
was only 9 per cent. Based on Audit Commission data for 1998-99,
in general terms the authorities achieving the highest rates (20
per cent-37 per cent recycling) are in the relatively affluent
south east (eg Bournemouth, Poole, Eastleigh, Surrey Heath), in
some of the London Boroughs (Sutton, Bexley), and in semi-rural
areas (eg Castle Morpeth, St Edmondsbury). Key aspects of their
success have been a strong local political commitment to recycling,
backed by additional resources. The lowest recycling rates (ie
less than 3 per cent) were recorded in some of the larger metropolitan
authorities and in northern authorities in areas traditionally
reliant on heavy industry and mining. In these areas the pressures
are different—unemployment, urban regeneration and social
need are the priorities both politically and in terms of resources.
Also, in these areas there tends not be a shortage of landfill
capacity locally, unlike the disposal pressures that exist in
London and much of the south-east.
Improving recycling performance
The achievement of the national recycling targets
will require a step change in recycling. To increase our recycling
performance significantly will require:
— More infrastructure for the collection
of source segregated recyclable materials—convenience is
a key factor in achieving high recycling rates.
— Greater focus on the collection and
composting of organics—higher recycling rates will not be
achieved through the collection of dry recyclables alone.
— Much greater investment in public
education and awareness programmes in order to increase participation
rates. Experience from North America suggests that £1 per
household per year is the sort of sum that needs to be budgeted,
eg a budget of £100,000 for a 100,000—household authority—this
is considerably more than many authorities' total budget for recycling.
Furthermore, this level of expenditure and effort has to be sustained
over several years—a single leaflet drop whilst a scheme
is being introduced is not sufficient. The message has to be continually
reinforced.
— Improvement in collection efficiencies—we
now have experience in the UK of a range of different collection
systems and sorting technologies. Recyclable materials are like
any other commodity in that the costs of collecting and transporting
these materials has a significant impact on their value. Maximising
the use of vehicles and improving collection logistics will have
a positive impact on costs.
— Charging householders directly for
waste services—a contentious issue perhaps, particularly
at a local level, but an option that should be considered by the
Government. There is evidence from communities across Europe and
North America that direct charging for household waste services
(often referred to "pay as you throw" or "user
pays") can increase diversion rates substantially and is
certainly critical in achieving diversion rates of over 40 per
cent.
— Effective implementation of the Landfill
Directive—compared with our European neighbours the UK's
interpretation of municipal waste is narrower including waste
under the control of local authorities only and not independently
collected private sector wastes of a similar type.
Improvement in recycling to the level required
by Waste Strategy 2000 will cost money and will increase the waste
management costs of most authorities. Waste Strategy 2000 received
criticism for not addressing funding and financial considerations.
The Government has subsequently announced the results of the 2000
Spending Review. This has made additional funding available:
— £140 million fund to support
recycling, although it is not clear yet how this money will be
allocated to local authorities;
— Waste management PFI credits have
been ring-fenced and allocated for three years (ie up to 2003/04).
They amount to a total of £220 million. DETR's criteria for
the award of PFI credits link strongly to the objectives of Waste
Strategy 2000;
— Increase in the Standard Spending
Assessment (SSA) for Environmental, Protective and Cultural Services
of £1.2 billion over three years (2001-02 to 2003-04). Authorities
have the flexibility to determine how this money is spent locally;
— Waste Resources Action Programme
(WRAP)—DETR is to allocate £25 million over three years;
the contribution from DTI is still to be announced.
Whilst access to some of this funding is dependent
on submitting proposals to central government, the increase in
the EPCS block grant ensures that all authorities receive some
additional funding which is within their control to allocate.
The announcement in the Best Value consultation document that
the upper quartile for collection costs is to be revised will
be welcomed by local authorities, as this acknowledges that the
cost of collecting recyclables is more costly than traditional
collection services.
Development of market for recyclables
The establishment of WRAP to co-ordinate our
efforts nationally to develop new markets for recyclabes is a
positive action by the Government. It is welcomed for a number
of reasons:
— International experience points to
the fact that markets must come first. We must secure outlets
for recyclable materials before they are collected. Furthermore,
end use applications for these materials may impact on how they
are collected in the first place and what level of sorting/pre-processing
is required at the materials recovery facility;
— The national recycling and recovery
targets will not be met through established reprocessors alone.
A move from 9 per cent to 33 per cent recycling by 2015 will require
a four-fold increase in markets. This will have to be achieved
in parallel with increasing the capture rate of these materials;
— A key problem with traditional markets
is that they have been controlled by a few end users, but there
are many suppliers of materials (for example, the glass industry
which has almost every local authority in the country as a potential
supplier but only very few processors). For many materials the
markets and the value of the materials have been unstable;
— New markets are required for materials
recovered from both the household waste stream (in particular,
paper, glass, plastic bottles, "green" garden wastes),
and from commercial/industrial wastes (ie demolition wastes, wood,
plastics).
A key objective of any market development initiative
must be to develop new applications and market for recyclates.
Materials do not need to be recycled back into the same products.
In many cases this may not be feasible for technical or economic
reasons and may not be desirable. For example, glass bottles do
not have to be recycled into more glass bottles, glass silicate
can be used as a construction aggregate or it can be used as an
abrasive. Alternative applications are now being developed in
the UK involving companies such as RMC, but further applications
are required.
Waste Strategy 2000 acknowledges that although
the public sector had adopted the policy of materials recovery,
it is the private sector that must step forward and create the
market for these materials. This is indeed the challenge—how
to convince industry to use recyclate as a feedstock to make a
product rather than virgin material. This is an area in which
WRAP must take a lead. Essentially, the choices available to government
are:
(A) To develop regulatory requirements mandating
the use of recycled materials in certain manufacturing processes:
Prescriptive legislation has been used in other recycling programmes
internationally to help "create" a market demand for
recycled materials. There are examples of legislative mandates
that have served to stimulate response from industry, as well
as examples that have constrained expansion of targeted industries.
(B) To influence the "risk-reward"
balance in favour of recycled materials: At present, the perceived
risks of using recycled materials are relatively high, and the
rewards appear marginal. The risks of using recovered materials
are more numerous than using virgin materials. To overcome this
imbalance governments can either look to increase the reward to
industries using recycled materials, or minimise the associated
risks of using recovered materials. In the UK, the Non Fossil
Fuel Obligation is an example of increasing the reward to industry
of developing alternative power generation schemes. It actively
encouraged the development of a Landfill Gas Utilisation industry
in the UK.
(i) Increase the reward: Financial incentives
to companies that process and incorporate recycled materials in
their operations can be in the form of a price support or subsidy
scheme. There are examples of financial incentives that have created
artificial markets and, in turn, long-term dependency on that
financial support. Use of financial support or materials subsidy
can be effective if there is a clear strategic purpose, the intent
of the support is well focused, and there is a limited length
of time associated with the financial support. Increasing the
financial reward should be considered in the context of a material-specific
strategic plan, and not as an overall approach to solving the
market development challenge.
(ii) Minimise the risks for companies interested
in expanding their use of recycled materials: The potential risks
of using recycled materials currently outweigh the marginal rewards
a company might expect. Additional risks faced by these companies
include:
Technical/processing feasibility.
Risk of product failure to meet performance specifications.
Costs of equipment conversion to incorporate
recycled materials.
Availability of a consistent supply of recycled
material processed to the quality specifications required.
Market acceptance for new product.
Access and price of appropriate capital.
Lack of financial support for new product development.
Costs associated with product testing.
Costs associated with securing BSI and other
approval.
Lack of materials standards.
These various issues will need to be considered
and overcome if the UK is to be successful in developing new markets
for recyclable materials. A number of local and regional market
development programmes—ReMaDe—are now underway around
the UK with the specific objective of assisting local manufacturers
to convert their process into using recycled materials, and to
assisting businesses to develop new applications. Currently there
are local market development programmes in Scotland, Merseyside,
London and Essex. Most of these programmes are partly funded by
landfill tax credits.
3. INCREASED
USE OF
INCINERATION AS
A WASTE
DISPOSAL/RECOVERY
OPTION
Experience internationally suggests that there
is a limit to how much recycling can be achieved through "voluntary"
source segregation of waste materials by householders. This upper
limit is around 40 per cent, although it does depend on the characteristics
of the area and the schemes in place. A recent study completed
by Enviros for the Resource Recovery Forum reviewed recycling
performance in a number of US states and Canadian provinces[35].
This shows that many states appear to reach a plateau in diversion
rates from landfill at between 35 per cent and 40 per cent. Moving
beyond this rate requires system changes which few states and
provinces (with the exception of Nova Scotia in Canada) have been
prepared to take on.
To achieve higher recovery/recycling rates requires
the introduction of other measures to encourage householders to
recycle (such as charging householders for waste collection, as
discussed above), or the adoption of other approaches or technologies
for handling mixed waste.
To achieve the national waste recovery rate
of 67 per cent the development of alternative facilities will
be required: these may include mixed waste processing technologies
or thermal treatment. We are of the view, subject to several qualifications,
that additional thermal treatment capacity will be required in
the UK:
— In all cases, thermal treatment must
include energy recovery.
— We need to think more widely than
mass burn incineration—other thermal treatment technologies
are being developed for mixed waste applications and should become
commercially viable in the medium term. These include gasification
and pyrolysis technologies.
— Facilities must be properly sized
taking account of what it is realistic to recycle; in other words
they must be designed to treat the residual wastes. The public
is fearful of incinerators and has a perception that they require
large tonnages of waste (linked to long term contracts) to be
viable. As a result they are considered to be inflexible and detract
from recycling. However, combustion technology is becoming viable
at a smaller scale, and whilst the level of capital expenditure
required does require longer term contracts recycling and thermal
treatment technologies can form part of an integrated solution.
— Recycling and thermal treatment can
work together. A further study completed by Enviros for the Resource
Recovery Forum involved a review of recycling performance in a
number of European states[36].
Our research concluded that at a national level, significant progress
in reducing landfill and increasing recycling and composting over
and above the underlying growth in municipal waste has been made
in Austria, Denmark, Germany, the Netherlands and Sweden. These
countries have benefited from the rapid development of the recycling,
composting, anaerobic and energy from waste infrastructure. In
terms of incineration with energy recovery, our survey indicated
that only Sweden has stabilised the tonnage of municipal waste
delivered to incineration over the past 10 years. In the other
countries examined an actual increase in the throughput and in
most cases capacity has been evidenced over the past 10-15 years.
For example, in the Netherlands incineration doubled from 1.7
million tonnes in 1985 to 3.4 million tonnes in 1998, over the
same period recycling performance increased from 0.7 million tonnes
to 3.8 million tonnes and landfill quantities declined from 2.9
million to 1.03 million tonnes.
— Efforts must be made to allay public
fears and allowed informed debates to take place. This is too
much mis-information being circulated in the public arena.
We believe that early reports of the order of
140 new incinerators potentially required are excessive. Our estimates
of facilities requirements for an integrated waste strategy range
from 26 to 56 new incinerators of average size 200,000Tpa[37].
The real crunch will come if waste arisings
continue to grow. If increases are not curbed then the targets
become even more challenging and the need for more thermal treatment
facilities will become more of a likelihood. Thermal treatment
and landfill represent the only currently available, technically
proven, large-scale technologies having acceptable environmental
impacts. If more sustainable use of resources is not embraced
then the resulting waste will inevitably have to be disposed of
by one of these means.
4. A REDUCTION
IN THE
QUANTITY OF
WASTE SENT
TO LANDFILL—AND
THE EFFECTS
OF THE
LANDFILL TAX
AND ITS
ASSOCIATED CREDIT-SCHEME
The key policy measures in the UK to reduce
the amount of waste disposed to landfill are the landfill tax
and the soon to be implemented Landfill Directive. The success
of the landfill tax has been mixed; it has:
— generated additional revenues for
central government, but has had a negative impact on funding of
recycling activities at a local level. Local authorities have
had to allocate additional funding to cover the costs of increases
in the landfill tax, resources which it could be argued would
have been better spent on funding local recycling initiatives.
Furthermore, in many areas the cost of landfill including the
landfill tax remains cheaper than developing alternatives.
— reduced the disposal of construction
and demolition (inert) wastes to landfill, and with the introduction
of the Aggregates Levy in 2002 will further encourage the re-use
and recycling of secondary aggregates. Short-term problems of
increased "fly tipping" and abuse of land restoration
schemes have been encountered.
— had a less clear impact on commercial/industrial
wastes disposed to landfill. Due to the charging procedures of
waste management contractors, who typically charge an inclusive
price for the collection and disposal of waste containers (ie
charge per skip or per paladin) irrespective of the weight of
waste in these containers, the cost of the landfill tax to waste
producers is not apparent. This is important given that the landfill
tax escalator is considered by the Government as an incentive
to divert waste from landfill.
5. A REDUCTION
IN, AND
BETTER MANAGEMENT
OF HAZARDOUS
WASTE
The Government has commissioned several studies
into potential changes in the management of Hazardous wastes,
and the effect on them of the Landfill Directive. Enviros has
contributed to these, eg through its report to DETR on Review
of the Special Waste Regulations (July 2000). Waste Strategy 2000
contains a substantial amount of background information on Hazardous
waste arisings and management, but specific proposals are to await
the conclusion of the current deliberations. In the meantime the
proposals on general waste reduction and re-use will also be of
benefit in the management of Hazardous wastes.
6. SUFFICIENT
ACTION TO
EDUCATE THE
PUBLIC ABOUT
SUSTAINABLE WASTE
MANAGEMENT
Waste Strategy 2000 recognises that incentives
and education programmes will be necessary to encourage householders
to participate in recycling and reduce the amount of waste they
produce. The national "framework" campaign—".
. . are you doing your bit?" has been low profile. Other
regional campaigns have been trialled (eg "Slim Your Bin")
and these and other new initiatives are to be rolled out under
a part of the National Waste Awareness Initiative. A strong national
message is important and will provide the context for local initiatives
and campaigns. Many of these are currently suffering from the
lack of a consistent and high profile national campaign.
At a local level, the public has certain expectations
regarding waste collection—it is a high profile local service.
Householders expect their refuse to be collected weekly, they
expect all the refuse they place out for collection to be collected,
and they believe they are paying for this service as part of their
Council Tax. The views and expectations tend to be reinforced
by elected members who are unwilling to challenge these traditional
expectations. Therefore, any proposals to change current methods
of service delivery can be met with resistance especially if a
reduction in the level of service provision is perceived.
The requirements placed on local authorities
by Waste Strategy 2000 will need to be supported by substantial
action to educate the public on waste management issues.
The efforts of the NWAI are critical and many
authorities have made a start by engaging the public in developing
their waste strategies. The Best Value process also will promote
greater consultation with the public. However, the extent of the
task should not be underestimated. Like many educational programmes,
investment is required to get the message across, but the "payback"
period may be long. Effort is required in two areas:
— Waste awareness (nationally driven
and reinforced locally)—general awareness on waste management
issues, including what householders can do to reduce the amount
of waste they produce.
— Waste collection and recycling practices
(these tend to be more local in nature)—if a local authority
is to introduce new collection and recycling services then householders
must be informed of these changes and the reasons for these changes
explained. The message will need to be given several times, and
if householders are not participating correctly this needs to
be explained to them.
September 2000
35 Recycling Achievement in North America. Report prepared
by Enviros for the Resource Recovery Forum, August 2000. This
report is due to be published by the Forum in October 2000. Back
36
Recycling Achievement in Europe. Report prepared for the Resource
Recovery Forum by Enviros, February 2000. This report is due to
be published by the Forum in October 2000. Back
37
Davies JN, 2000. The Impact of the Landfill Directive on the UK's
Landfill and Waste Treatment Industries: Commercial Seminars.
April 2000. Back
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