MEMORANDUM BY SWAP—SAVE WASTE AND
PROSPER LTD (DSW 66)
SWAP welcomes this opportunity to comment on
the Government's Waste Strategy for England and Wales and express
our views on whether it will deliver sustainable waste management.
In making our comments it is worth setting their
context and explaining SWAP's background and perspective on waste
management in the UK. SWAP was first founded in 1977 as the result
of a partnership between the community and Leeds City Council.
Today, SWAP is an independent, not-for-profit company and is a
leading expert in the field of sustainable waste management. The
company, which provides a range of consultancy services, employs
22 staff in Leeds, Bradford and Reading and has 16 trainees at
its computer refurbishment centre in Bradford. Its mission is
to achieve environmental improvement, primarily through the sustainable
management of waste.
The company works with all sectors involved
in the production and management of waste and has a national reputation
for its innovative partnership approaches which develop practical
solutions. Some of the projects and organisations we are involved
with include:
— Byteback Bradford (community based
computer refurbishment project)
— Community Re - Paint (national community
based paint re-use initiative)
— Greening the High Street (retailer
led initiative to look at environmental performance of high street
stores including waste minimisation)
— National Household Hazardous Waste
Forum (cross sectoral industry led forum to look at ways of improving
the management of household hazardous waste [HHW])
— The National Waste Awareness Initiative
(SWAP is working in partnership with Waste Watch to develop this
national public waste awareness campaign)
— Regional Electronics Initiative which
is part funded by the DETRs Environmental Action Fund (REI [featured
in the Waste Strategy] provides a region-wide approach to redundant
computers by helping and co-ordinating the activities of a number
of community computer refurbishment projects based in the Yorkshire
and Humber Region).
SWAP's income comes from a variety of sources
and usually develops combined funding packages for its more innovative
work. Our sources of income include: commercial contracts; the
landfill tax credits system; commercial sponsorship; National
Lottery Charities Board; European funding (ESF and ERDF); Single
Regeneration Budget; Charitable Trusts; DETR Environmental Action
Fund.
SUBMISSION TO
THE COMMITTEE
The landfill tax credit scheme
We believe that in principle the landfill tax
credits scheme (LTCS) is effective in delivering a wide range
of environmental improvements, stimulating new R&D and raising
public awareness. As with any source of funding (and we are aquainted
with a wide range as outlined above), the LTCS has its idiosyncrasies.
There were a number of issues and practical problems in the beginning
but these have been ironed out as best practice is developed,
strategic priorities are identified and ENTRUST's regulatory grip
increases. However, major continuing issues include duplication
of work (particularly R&D, waste minimisation and education),
dissemination of results and lack of strategic direction. ENTRUST
has started to address some of these issues but more is required.
We also feel that so far the LTCS has not sufficiently
addressed waste minimisation, recycling and public education.
In ENTRUST's recent report "Bearing Fruit" Achievements
1999, only 36 per cent of projects fell into the Object C category
(sustainable waste management, R&D and education). Over 48
per cent of projects in 1999 were Object D projects—public
parks and amenities. Whilst we acknowledge that one of the reasons
behind the LTCS was to address the disamenity and environmental
impacts of the landfill industry, one of its core tenets has always
been the development of more sustainable waste management practices.
We would like to see more work in the following areas:
— new or alternative markets for recyclables;
— source separation recycling schemes
eg kerbside recycling;
— community based initiatives to deal
with waste sustainably on a more local basis eg computer refurbishment
schemes like Byteback Bradford;
— waste minimisation initiatives—including
supply chain and cross sectoral initiatives;
— re-use initiatives eg furniture,
play material projects;
— public awareness and education campaigns
eg National Waste Awareness Initiative, Anglian Region Waste Awareness
Campaign (ARWAC) and Rubbish Revolution.
As a funding mechanism for recycling and waste
minimisation projects the landfill tax has enabled a number of
important Global Balance Trust Limited and National Household
Hazardous Waste Forum projects to proceed. Chief among these sustainable
waste management projects are the Community Re > Paint Initiative
(a nationwide paint re-use project) and Byteback Bradford (a community
based computer refurbishment project). Both these projects have
significant local environmental, social and economic benefits—the
win-win-win scenario. Both of them have secured funding from a
variety of sources, but the landfill tax credit system has provided
lynch-pin funding which enabled the other private and public funding
to be drawn down.
The majority of SWAP's projects look at specific
waste streams and particular industrial or commercial sectors
to identify and develop sustainable management solutions. This
work is highly specialised and, because of this, difficult to
fund from sources outside the waste industry. Because the waste
management industry understands the issues, the credits system
has enabled a number of highly original projects to proceed which,
because of their innovative nature, would have been difficult
to fund using any other source.
The system is however dependent on the outlook
and attitudes of the landfill operators or their grant making
bodies. Some are outward looking and enlightened whilst others
are myopic or governed by self interest. However, every source
of public or charitable funding has its own criteria and agenda
and the credits system is no different.
We welcome the news that recycling is now an
approved category under Object C but are concerned how this will
work in practice and whether it will syphon money away from independent
or innovative initiatives.
What the UK waste management industry, in its
broadest sense, could benefit from is an agreed national policy
on how to use the credits strategically for the benefit of UK
plc. This policy should also not ignore the valuable input that
could be provided by the community sector which today provides
professional standard kerbside collections to over 1 million households
in the UK. Many practices now standard within the waste management
industry (eg kerbside) were pioneered by the community sector.
Hazardous waste
Household hazardous waste (HHW) poses a problem
for the environment in the same way as commercial special waste
does. However, household wastes that meet the definition of special
waste are specifically exempt from the controls of the 1996 Regulations,
except for asbestos. We believe that in order to be effective,
the strategy needs to take greater consideration of hazardous
waste generated in a domestic waste setting.
We feel that the work of the National Household
Hazardous Waste Forum needs to be recognised here. SWAP has been
instrumental in the formation and development of the NHHWF, bringing
together a broad spectrum of organisations involved in manufacturing,
retailing and managing household hazardous waste. It is an industry
led forum aiming to respond to forthcoming legislation and policy
and to seek practical solutions to the many problems associated
with the collection, recycling and safe disposal of HHW. SWAP
provides the administrative support to the NHHWF, and carries
out research on its behalf.
The strategy needs to be based on robust data,
and specifically with respect to hazardous waste, this will not
be effectively provided by the special waste consignment note
system, as domestic waste will be excluded. More generically,
we believe that in order to effectively plan for sustainable waste
management, the Department of Environment, Transport and the Regions
needs to obtain more data and information on current arisings
and management. The municipal waste survey and the Environment
Agency's audit of commercial waste go some way towards this provision,
and data has been gathered by individual local authorities, and
through the landfill tax credit scheme. What is needed is the
consolidation of the available information, commissioning of research
to fill the gaps, in order for the strategy to be based on accurate
arisings, in order to justify long-term investment in the provision
of services. Special and hazardous waste presents the greatest
risk to health and the environment of all wastes, and we believe
that the focus of the strategy here needs to be on minimising
the creation of these wastes. Incineration for special waste is
in disrepute, and unpopular with the public. We believe that reduction
has to be the priority.
September 2000
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