MEMORANDUM BY THE INSTITUTE OF WASTES
MANAGEMENT (DSW 70)
INTRODUCTION
The Institute has always supported the philosophy
of a national strategy for Waste Management and during the drafting
and consultation process which led to the publication of the strategy
IWM sought for many issues to be included, primarily mandatory
recycling targets. The strategy, however, does not provide all
the solutions to the difficult areas of Waste Management. It usefully
sets targets and identifies the major players but provides no
positive guidance on meeting those targets, developing recycling
markets, infrastructure planning and delivery, public education
and other strategic issues.
The challenges of the targets within the Landfill
Directive are addressed but no specific solutions are identified.
Indeed, some members have said that the targets and the strategy
have been designed solely to meet the objectives of the Landfill
Directive and not the wider strategic issues. There is little
in the document to encourage waste generators to reduce their
resource use and therefore the waste produced. The Institute feels
strongly that the strategy should revolve around waste reduction,
minimisation and consideration of waste as a resource. This is
fundamental to realising the goals and objectives of a waste strategy
and crucially changing public attitudes.
DEFINITIONS AND
DATA
The Institute considers that the reliance on
poor data is a fundamental weakness of the Waste Strategy 2000
and its successful implementation. Although the Environment Agency's
Commercial and Industrial Waste Survey of two years ago was the
biggest of its kind in Europe, it represents only a partial snap
shot. Funding needs to be made available so that the survey can
be repeated at regular intervals and address the flaws in the
current data set which can have an impact on the ability to achieve
the targets set within the strategy. Regular data gathering is
not being undertaken by industry because it is seen as a chore.
It has also been suggested that the onus on data collection may
need to be shifted away from the Environment Agency, whose regulatory
role may be seen as "complicated" by a data gathering
responsibility. Perhaps there is an opportunity to set up an independent
Statistical Service such as that in the Netherlands, to collect
and make relevant statistics available.
The targets in the Waste Strategy 2000 may also
be influenced by the interpretation of definition of "municipal
waste" within the EC Landfill Directive. This difference
in municipal waste definitions exacerbates the issue of lack of
data since the current definition is convenient in relation to
the data collected by Government on local authority waste collection,
but data on the broader definition of municipal waste in the Landfill
Directive is not generally available.
Other definitions or interpretations require
discussion at an early stage to ensure that interpretation of
the requirements within the Landfill Directive and the objectives
within the strategy are achieved. Whilst it is understood that
this is a waste strategy, the more references there are to waste
as a resource, the easier it is to have this approach adopted
in public attitudes. Similarly, recycling is different to collection
of recyclables and municipal and household waste are not the same
waste streams.
There is an opportunity to approach waste data
collection in a different manner. Estimates of waste production
from household, commercial and industrial sources have been inaccurate.
A more reliable source would be to record the waste at disposal
or treatment point. There are accurate statistics for waste treated,
recycled and disposed at licensed waste management facilities
which leave only those elements of lost waste such as that sorted,
treated or "recycled" through facilities exempt from
the requirement to hold a waste management licence and fly-tipped
waste. It would be difficult using this method to identify waste
quantities from certain waste streams. Nevertheless, total figures
would be more accurate provided that the exemption loophole is
closed. This method could however be used to reconcile various
waste inputs, used by information gatherers to assess the accuracy
of the waste inputs when aggregated.
Care needs to be taken to ensure that definitions
do not hinder sustainable waste management. An example is the
proposal to exclude incinerator bottom ash from the definition
of household waste recycling. This will discourage local authorities
from investing in these activities and lead to needless consumption
of virgin materials.
EDUCATION
The IWM feels that the general public and manufacturing
industry are generally not interested in waste management issues
and that a shift in this type of attitude can only be brought
about through ongoing campaigns that raise society's awareness
to waste generation and resource consumption.
The IWM strongly feels that education campaigns
like "Are you doing your bit" and the National Awareness
initiative should be bolstered and maintained to keep the public
informed on waste management issues. This should be complemented
with school modules, that cover the various age groups to increase
the general level of understanding and responsibility. Only through
such informative methods will waste minimisation become instinctive
to the householder. There is little in the Waste Strategy 2000
to encourage these developments at present.
At present there appears to be a low expectation
of the quality of certain products made from recycled materials
(eg photocopying paper). Education campaigns should also address
this issue. Greater use should be made of the experiences of government
organisations that do purchase recycled products in terms of education.
Government funding for public sector organisations such as Local
Authorities could be dependent on increasing levels of green procurement.
Perhaps the lessons are there to be learned from the vehicle industry
which is now beginning to advertise the fact that cars in particular
are made of significant proportion of recycled product and this
is not only acceptable but is being used as a sales opportunity
by that industry.
By and large waste producers in whatever sector
have been uninterested in waste minimisation and waste avoidance
targets despite some well run and organised Waste Minimisation
Clubs. Neither stick, in the form of Landfill Tax, nor carrot,
in the form of Voluntary Waste Minimisation Clubs, have had a
dramatic effect on waste production. There must be a concerted
effort to educate, inform and persuade industry to take a different
view with regard to resources used and wasted in the production
of their primary products and the cost consequently incurred by
the producer. Public and business education should promote a front
of pipe solution with just the correct amount of resource use
and the minimal waste production at source rather than look to
recycle the end product. It may be appropriate to consider some
more intrusive corporate green taxation to replace the general
taxation on profits of companies to address this issue, such as
a direct tax on the corporate organisation on waste produced or
resource use per unit of output. This type of move may focus the
mind of the captains of industry slightly better than an indirect
tax which they pay on their waste disposal and appear on the bill
for waste disposal rather than a direct bill from Customs and
Excise or the Inland Revenue.
Public education should be widened to explain
that the public themselves are waste producers of household waste
and in the generation of waste products from commercial and industrial
producers. Public education programmes are also required to explain
the necessity for the waste treatment and disposal service facilities
and infrastructure.
The very nature of the developing economy is
that the public look for the most convenient lifestyles which
they can afford because of higher income levels. This philosophy
results in more packaging and short life-span of electrical and
electronic goods which have been addressed through end-of-pipe
recycling policies. It is fair to say that the programmes have
raised public awareness but have not yet changed attitudes significantly.
This will take time and the message must be regularly reinforced.
The general public will remember the failures such as stories
of recycled paper being disposed of to Landfill in times when
supply exceeds demand, and may be more reluctant to "do their
bit" even when the market has recovered.
The purchase of recycled goods appears to be
an accepted proportion in developing countries whereas in developed
countries there is an acceptance and indeed expectation of product
obsolescence. This is particularly the case for white goods and
IT equipment. There is a thriving refurbishment and re-manufacturing
industry for white goods, electronic equipment, furnishings, etc.,
but widespread public acceptability of second hand goods requires
significant encouragement.
WASTE REDUCTION
The IWM feels that the National Waste Strategy
2000 does not encourage waste minimisation. Although there are
suitable action headings, no specific measures are proposed to
encourage waste producers to minimise their arisings. Also, the
government published the Waste Minimisation Act 1998, but has
yet to produce any guidance on how local authorities can implement
it.
Local authorities will need to increase spending
significantly to achieve the recycling and recovery targets and
do so very quickly if the relatively short timescales are to be
met. Guidance on how the extra monies announced in the summer
are be used needs to be issued urgently. The sums announced to
date are less than local government was anticipating and local
authorities will have to make difficult choices as to which services
are to be curtailed to fund increasing spending on waste.
There is a recognised link between economic
growth and increased waste generation. It is time to break that
loop by encouraging waste prevention and better resource efficiency
through Eco-design and re-manufacturing projects. It is a fact
that one tonne of product result from the use of between ten and
eleven tonnes of raw materials. This is a fact which cannot continue.
The Strategy is devoid of any direct guidance on Waste Minimisation
targets and front of pipe solutions.
The waste reduction targets within the document
are set specifically for municipal solid waste, the smaller sector
of waste. Is that because it is the only sector in which the Government
can have a direct influence through local authorities who have
a responsibility for collecting, recycling and disposing of that
waste. There is very little influence the Government can have
directly on commercial and industrial waste short of the stick
and carrot approach as mentioned earlier. Therefore, the strategy
provides very little solution to the increase in the majority
of waste. Initially the targets have been set at Waste Disposal
Authority (WDA) area and that the WDA can dictate the Waste Collection
Authority (WCA) how it delivers those targets. This, by definition,
has a cost on the WCA above and beyond that which might be necessary.
The irony is that the WCA are presently involved to some significant
level in the collection of recyclables, ie achieving the recycling
targets. There should be a greater focus on co-operation and joint
working between collection authorities and disposal authorities
to achieve cost effective solutions.
MARKETS
With regard to the issue of market development,
the Institute considers that the establishment of the Waste and
Resources Action Programme is a positive advance. However, it
is likely that a greater level of funding will be required for
the work to have a major impact, and it is not likely to influence
markets significantly before the first recycling targets are required
to be met.
The Institute applauds the fact that the Market
Development is to be included among the responsibilities of the
Waste and Resources Action Programme and that the amendments to
the Landfill Tax Credit Scheme include Market Development. However,
it looks for that money to be ring-fenced for Market Development
purposes and not used elsewhere.
The bottom line in efficient collection of recyclables
from any waste stream is that this increase in supply does not
necessarily generate demand for the product made from the recyclables.
The IWM believes that green procurement options
have long been available, and that current efforts do not go far
enough. The government, including its network of local offices,
local authorities and QUANGOs could have created markets for products
with a high content of post consumer material, eg paper and other
stationery, or waste derived compost for landscaping and gardening
projects and secondary aggregates for construction.
LANDFILL TAX
The IWM considers the Landfill Tax is an ineffective
driver for changes, indeed, the level at which it is set is too
low to have an impact in choosing alternative waste management
options. Furthermore, the cost of landfilling is still relatively
cheap. The use of the Landfill Tax Credits for Research and Development
and market development of recyclables is an important function
of the tax, but the proportion hypothecated is too low.
The irony of the landfill tax is that in addition
to it being too low to change waste management practices, it is
nevertheless a significant burden to local authorities many of
whom could be investing in more sustainable waste management if
they did not have the tax burden.
The response to the Landfill Tax and indeed
the incremental annual change has been to pay the tax rather than
implement fundamental waste reduction policies. In that respect
the Landfill Tax has had little impact in environmental terms.
There is evidence that outside of London disposal charges have
reduced due to pressure form waste brokers and waste producers
and tax has therefore had less effect. By and large the producer
does not have to consider waste reduction or recycling opportunities
for financial reasons because there is currently the opportunity
to find cheaper landfill and disposal prices.
REGULATION
The IWM is aware of some barriers to sustainable
waste management in the form of inappropriate exemptions in legislation,
(for example from the landfill tax, allowing unsustainable landspreading
practices to occur), and also of instances where new exemptions
are warranted, so as not to penalise those attempting to pursue
more sustainable alternatives to disposal.
There are examples of Environmental Legislation
which are unnecessarily restrictive and its removal would not
have an effect of harming the environment. For example, some of
the restrictions within the Licensing Exemptions relating to composting
hinder this waste treatment opportunity. Similarly some Conditions
and Exemptions are not environmentally or commercially justifiable,
but at the same time, some Operations should not be exempt from
Licensing Regulations. A review of the Legislation in particular
is necessary. Unrealistic Licensing Legislation is stifling innovation
and whilst the Institute does not want to see carte blanche
for all "environmentally friendly" operations there
should be some flexibility whilst protecting human health and
the environment.
To achieve the objectives of the National Waste
Strategy 2000 a lot of research will be needed. However, current
legislation has no provision for researching and trialling new
technology. The EA cannot authorise any new treatment facilities
unless they can obtain either a waste management licence or an
IPPC Authorisation, but you cannot get either of these unless
you are using proven technology.
ENERGY FROM
WASTE
The Institute is aware that incineration or
energy from waste has received the majority of the negative publicity
prior to and subsequent to the publication of the National Waste
Strategy. This is unfortunate as the Institute recognises the
necessity of a role for waste to energy in any sustainable waste
strategy. Every effort should be made to improve public understanding
of the necessity for integrated waste management systems based
upon the Best Practicable Environmental Option (BPEO).
The Institute recognises that no single waste
management solution is "sustainable" on its own, and
the BPEO should be sought. There are a number of factors governing
the most suitable mix of recovery, reduction, treatment and disposal
options for any particular area. In some instances an appropriately
scaled Energy from Waste plant will be the BPEO as part of the
local strategy for waste management, in other situations a different
mix of solutions will be BPEO. The Waste Strategy 2000 allows
for a choice of solutions to meet the targets, and the Institute
views this flexibility as essential.
GREENER FISCAL
INSTRUMENTS
Green procurement has focused on paper and paper
products but identifying compost in any Green Procurement Policy
will be essential to meet the targets. The Government can take
a lead in creating the market through the public sector for this
waste product but have not taken the opportunity this far. Members
have asked how many Government Organisations have undertaken Green
Procurement Policy and what impact has it had. There is a significant
opportunity to effect contracts on best value through a more direct
environmental approach making Green Procurement mandatory or providing
financial incentives.
So far, government policy has generally placed
an emphasis on relying on householders to source segregate waste
for recycling, and on the waste management industry to provide
the infrastructure to collect, treat, and dispose of the waste
generated. With regards to waste minimisation, this type of approach
does not break the proportional link between waste generation
and consumption. Both these groups currently have little or no
influence on the amount of materials which manufacturers generate
in the form of packaging.
A more holistic approach would be one that would
affect manufacturers willingness to produce excessively packaged
goods, and create more favourable conditions for the establishment
of the market for recyclables.
The basic approach would be to increase the
cost of virgin raw materials to the extent that it becomes economically
viable to manufacture materials with a high content of post consumer
materials. Although there are potentially various ways to bring
about this shift, the most effective would be to introduce a green
tax on virgin raw materials. Such a tax should be earmarked to
fund clearer methods of production.
The rationale behind such a tax would be that
manufacturers would find it increasingly more expensive to use
superfluous packaging, and would at the same time encourage them
to use post consumer material, thus closing the loop by creating
a market for recyclable materials.
HAZARDOUS WASTE
It is important to note that Hazardous Waste
is not defined in UK Legislation as such, the legal term is Special
waste. This waste is a very small proportion of the waste production
in the UK, it is managed effectively and has appropriate Legislation,
some of which was ground-breaking in European terms and has been
replicated elsewhere. Unfortunately there is a perception that
this waste stream is a greater risk than others by its very name.
The Institute believes that the long term reduction in the use
of hazardous materials will thereby reduce hazardous waste production.
This is a slow process, but one being undertaken at present. The
management of and reduction in hazardous waste has been and will
be as a direct result of the regulatory regime, its inherent cost
and the direct cost of treatment and disposal of this waste. The
tonne for tonne cost of disposal of hazardous waste is at least
10 times that of municipal waste and at these cost levels the
mind of the waste producer is more focused on reduction and retaining
the materials within the chain of utility.
SUMMARY
Whilst supporting the National Waste Strategy
the Institute is disappointed that the opportunity was not taken
to provide more definitive guidance on achieving the objectives
and the targets within this document.
The Institute is pleased to provide the above
information and will be available to provide verbal evidence to
the Sub-committee should it be required.
September 2000
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