MEMORANDUM BY CLEANAWAY LIMITED (DSW 71)
INTRODUCTION
Cleanaway, as one of the largest waste management
companies in the UK, is involved in the management of all categories
of industrial, commercial and municipal waste. Cleanaway has a
sister company operating in Germany giving a combined turnover
equivalent to over £500 million per annum. The UK operation
benefits from the significant experience gained in Germany of
waste and waste paper recycling.
Cleanaway submitted a memorandum to the previous
Inquiry in 1998 and also provided witnesses for examination. We
are grateful for the opportunity to submit further comments to
the new Inquiry.
GENERAL
The statements made by Cleanaway to the previous
inquiry of the sub-committee generally still obtain. Hence, in
this Memorandum, we have attempted to provide new views and information
to address the themes that the sub-committee wish to examine,
with particular regard to the Government's Waste Strategy for
England and Wales.
An emphasis is placed throughout the waste strategy
on sustainable development and sustainable waste management. Cleanaway
was questioned at the last inquiry on the definition of "sustainable
waste management". Our pragmatic suggestion was "sustainable
waste management practices are those which minimise environmental
impact and the use of non-renewable resources whilst utilising
the best practicable environmental option for each waste type
being managed, having regard to local conditions. We feel that
what is needed in terms of understanding sustainable waste management
is for an agreed protocol for whole life cycle analyses to be
produced on an international basis".
Whilst we continue to see this as the best workable
approach, the terms "sustainable" and "waste management"
are clearly contradictory and we have some sympathy for views
propounded by others at the previous inquiry that there is no
scope for waste in a truly sustainable system. However, the point
we would make here is that everyone recognises this apparent contradiction
and thus, the term "sustainable waste management" may,
in itself, be a barrier to change and progress by setting an unattainable
target. We would, therefore, recommend the use of a term that
is demonstrably more attainable, such as "environmentally
responsible waste management".
The aspirations and targets of the strategy
are clearly stated and welcomed. However, it is our view that
Government has to be far more positive and instrumental in eliciting
change. It seems essential that a large scale education campaign
must be launched to make the general public aware of the mounting
problems and to obtain their very strong support in providing
solutions. Beyond that, legislation may be required to prevent
the misuse of resources either by avoiding the generation of waste
or by ensuring it is recycled.
DETAILED COMMENTS
We now explore the main topics of emphasis of
the inquiry.
1. MORE EFFICIENT
USE OF
RESOURCES AND
A CONSEQUENT
REDUCTION IN
THE AMOUNT
OF MATERIAL
ENTERING THE
WASTE STREAM
The strategy serves to perpetuate inappropriate
attitudes that have developed towards the generation and disposal
of waste. Recycling is strongly promoted but this gives a tacit
acceptance of the generation of waste, provided a component is
recycled. The term "reduce" seems weak and may have
been brought into use because of its alliterative link to other
terms in the Waste Hierarchy. A stronger signal to avoid waste
generation is needed. Though the strategy suggests that the public
should avoid "over shopping" and choose "products
that will create less waste" (Pt.1, 2.11), this is not a
compelling dictate for change. Greater efforts towards waste avoidance
would release finance to promote recycling. The term "minimisation"
is also unhelpful because it is generally applied synonymously
with reduction rather than in the true sense of the word.
The strategy recognises that re-use formerly
played a more prominent role both commercially and in the household:
deposit—refund schemes and doorstep delivery of products
in refillable containers used to be widespread. However, this
implies that such containers are waste, being brought back into
use. Such refillable containers were never previously considered
to be waste or part of the waste stream. They are examples of
waste avoidance not re-use. They were designed for refilling and
their intrinsic value was maintained by the deposit. It follows
that the intrinsic value of a product will determine when it enters
the waste stream.
It is recognised that establishing the most
efficient use of resources is highly complex but it is this complex
analysis that Government should be carrying out. This could then,
for example, determine whether refillable drinks containers are
the best use of resources or whether a particular type of one
trip container associated with a high percentage of recycling
would be more efficient. The life-cycle assessment tool developed
by the Agency would have to be developed further to assess individual
items rather than groupings.
Having established the best option, its use
should be supported by legislation. It might be argued that this
would be restricting the freedom of an individual to choose, but
individuals do not have unrestricted freedoms in a civilised society
and this should be emphasised when the aims are ultimately the
protection of the environment. This approach could also be used
to limit the quantities and types of materials used in packaging
so that the resultant reduced quantities produced could be more
easily recycled. This should extend into the domestic environment
and not be restricted to the commercial application of the Packaging
Regulations. The strategy makes mention of the "bags for
life" approach promoted by supermarkets.
There is no reason why this should not be made mandatory.
There could be no logical argument against it and supermarkets
might even gain by reduction in costs or increased customer loyalty.
2. 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
There are only two types of measures that can
guarantee an increase in the recycling of waste: legislative (as
touched on in section 1), and fiscal. The strategy has included
a series of targets but without accompanying fiscal measures,
no progress is guaranteed.
A target has been established for industrial
and commercial waste:
— by 2005, to reduce the amount of
industrial and commercial waste sent to landfill, to 85 per cent
of that landfilled in 1998.
This target is intended to "encourage businesses
to reduce waste and to put any waste that is produced to better
use" (Pt 1, 2.32).
This is beset with problems. There appears to
be nobody charged with the responsibility to implement the target
and there is no fiscal measure to ensure that the target is met.
It is intended to reduce the amount of waste from these sources
but the target relates only to a reduction in the amount sent
to landfill. So there is no actual requirement to reduce the production
of this type of waste. It is also surprising that the target for
industrial and commercial waste is quite modest compared with
those for municipal and household wastes. Commercial waste tends
to be much more consistent in quality and, therefore, lends itself
more to recycling than household waste. The same would apply to
many industrial wastes that are often generated in relatively
large quantities and again are consistent in quality. This is
illustrated in an example from Germany described below.
With regard to municipal waste, the Government
will set statutory performance standards for local authority recycling
in England. Again, there is no indication of legal or fiscal penalties
for failure to comply, only a vague reference that "sanctions
will be applied" (Pt 1, 3.47). Whilst the strategy includes
initiatives such as "WRAP" to promote markets for recycled
materials, the linkage of supply and demand is so strong that
the two have to grow together though this might be facilitated
by financial encouragements in the market place. True hypothecation
of some of the landfill tax collected could be a valuable use
of such tax revenues.
To assist local authorities in meeting their
targets and standards for recycling, the Government should be
channelling back information obtained from those countries where
waste recycling is much better established. Through our sister
company in Germany, we have obtained statistics for recycling
of MSW and industrial/commercial waste in the City of Hamburg
as follows:
| Tonnes MSW
Commercial/ Industrial
|
| Total | |
| |
| Separately Collected Recyclables | 264,700
| 439,150 | 703,850 |
| Rejects | 41,100 | 14,150
| 55,250 |
| RECYCLED MATERIAL | 223,600
| 425,000 | 648,600 |
| Waste Stream to Disposal | 431,500
| 379,100 | 810,600 |
| TOTAL RECYCLABLES AND DISPOSAL | 655,100
| 804,100 | 1,459,200 |
| Recycled % | 34.1 | 52.9
| 44.4 |
MSW comprises 44.9 per cent of the combined MSW and commercial/industrial
waste stream.
These statistics were derived in 1997 but the 1998 figures
are very similar. They show that excluding inert waste, MSW comprised
44.9 per cent of the total of MSW and commercial and industrial
waste generated. Whilst 44 per cent of the total waste generated
in these categories was recycled, only 34.1 per cent of MSW was
recycled compared with 52.9 per cent of commercial and industrial
waste. This indicates the difficulty in recycling MSW and the
relative ease with which commercial and industrial waste can be
recycled.
The achievements in Hamburg in developing recycling of MSW
depended very heavily on source segregation of the recyclable
materials and a high quality education programme. This shows that
even with significant regulatory support and a comparatively high
recycling base of 18 per cent in 1989, some seven or eight years
was required to achieve the recycling rate of 34 per cent. This
suggests that the Government's recycling targets for household
waste in England and Wales set for 2005, 2010 and 2015 are very
ambitious.
Extensive networks of facilities will have to be provided
in order to achieve the recycling and composting targets. Planning
applications for these facilities are proving to be as unpopular
as for other waste management processes, with both the public
and planning committees. Planning authorities may have to be more
realistic in their approach to proposals to ensure the necessary
infrastructure becomes available without the cost implications
to the applicants of many aborted or appealed applications.
As markets are promoted and developed for recyclable materials,
care must be taken to curb natural enthusiasm to ensure that the
markets use the resources appropriately. For example, the recycling
of glass for use in aggregates for road metalling may seem quite
appropriate, displacing the use of virgin materials supplied by
the extraction industries. However, this would lose the value
of the energy already consumed in the manufacture of the glass,
some of which would be recovered if the glass were properly recycled
into new glass. Again, a fully established life cycle assessment
model would enable the correct decision to be taken. The same
assessment approach would also have to be adopted if markets were
to be stimulated by mandatory minimum proportions of recycled
materials in appropriate new products.
3. INCREASED USE
OF INCINERATION
AS A
WASTE DISPOSAL/RECOVERY
OPTION
The introduction of the Landfill Directive will mean a progressive
reduction in the amount of bio-degradable waste going to landfill
by 2020 to 35 per cent of the total amount by weight produced
in 1995. If the recent 3 per cent growth rate in production of
municipal waste is maintained, the percentage reduction required
in the total bio-degradable municipal waste being produced will
be significantly higher.
If the more easily recyclable materials such as paper, card
and green waste are removed to achieve the recycling or composting
targets of the strategy, then the remaining components will contain
a high proportion of putrescible waste. Using the breakdown of
household waste given in Part 2, para 4.41, if half of the putrescible
fraction were removed (as green waste) and three-quarters of the
paper and card, 65 per cent of the waste would remain and some
form of disposal such as incineration with energy recovery will
be needed. The strategy targets indicate that by 2015, up to 34
per cent of the value of municipal waste could be recovered by
incineration (Pt 1, 2.35-2.38). Indeed, the strategy document
recognises that up to 166 incinerators may be required for the
diversion of waste from landfill (Annex C, Appendix C).
In recent times, there has been a growing adverse public
reaction to the concept of incineration of waste. This has been
founded on fears related to atmospheric emissions which have been
compounded by suggested risks associated with dioxin emissions
based on American research. To this is added the assertion that
incineration discourages recycling because of the financial necessity
to keep a consistent supply to incinerators to ensure power is
generated and a revenue stream is maintained.
We believe that incineration with energy recovery will form
part of an integrated approach to waste management. The technologies
are demonstrably available to ensure that atmospheric emissions
are to a very high standard and that the environment will be protected.
Closely linked to recycling processes, incineration will very
significantly lessen the reliance on landfill. The residuals can
largely be used in the construction industry or if necessary,
disposed of to landfill with a very reduced potential for harming
the environment. It is unclear why Government has decided that
re-use of residuals should not count as part of the total quantity
of waste materials recycled. Incinerators (and treatment processes)
have a finite capacity and cannot readily be extended. Hence,
to accommodate growth in waste and occasional breakdowns, landfill
with its more elastic capacity is still required, albeit with
reduced importance, as part of the integrated approach.
The energy recovered in incineration makes an important contribution
to avoiding the use of non-renewable resources. It also helps
secure the substantial financial support needed for these projects.
It will be unfortunate, therefore, if Government is forced to
exclude energy from waste from the Renewable Energy Obligation
(REO). Further value can be added by supplying the low grade heat
to district heating systems, though this needs major advance planning
as retro-fitting such systems is very difficult and expensive.
If the strategy targets are to be met using incineration
with energy recovery, central and local government departments
have to accept that incineration plants are very capital intensive
and, therefore, demand guaranteed waste inputs. In addition, there
are significant cost and environmental benefits gained through
scale. Larger plants can offer more emission controls with a greater
element of redundancy supported by more specialist staff. Planning
authorities, who are most often the same authorities as those
charged with the responsibility for disposing of MSW, have to
recognise that relatively large areas of land are required for
such plants in locations close to the source of the waste and
the existing transport infrastructure.
Government can do much to smooth the process of gaining the
necessary planning permissions and permits to operate such plants
by ensuring sites are identified in waste local plans. Government
might also usefully take a lead on publicising its views on the
environmental issues so that repeated public inquiries into the
same issues though at different locations can be avoided. The
inquiry procedures add another lengthy delay to an urgent need
for change in waste management methods and the huge element of
uncertainty of success in making planning applications for such
facilities does not help to procure the necessary backing for
such major new investment. The costs of public inquiries to Government
and to the public and private sectors are enormous and such funds
would perhaps be better spent on financing additional recycling
initiatives.
4. A REDUCTION IN
THE AMOUNT
OF WASTE
SENT TO
LANDFILL
The targets for the reduction in the use of landfill are
relatively long term and are far from complete bans. Consequently,
it must be appreciated that landfill will remain a fundamental
part of the waste management strategy for England and Wales for
the foreseeable future. So far, few alternative facilities have
been put in place. Additional facilities and associated recycling
schemes involve a high initial capital outlay and have long lead-in
times. There will inevitably be a significant lag before large
reductions in waste streams going to landfill are achieved or
significant revenues are derived from the recycled materials.
This is one of the reasons why the imposition of the landfill
tax has been slow to influence the diversion of municipal waste
from landfill. Excepting inert and construction and demolition
waste, there does not appear to have been a great impact on the
industrial sector either. This is not surprising since waste producers
in both cases may have little ability or incentive to reduce the
waste they produce. Indeed, the provision of "wheelie bins"
for many households seems to have encouraged household waste production,
making it easier to dispose of large quantities and removing the
incentive to recycle or compost.
The Landfill Directive requires a reduction of biodegradable
waste going to landfill by 2020 to 35 per cent of the 1995 amount.
As already indicated, only financial or legislative incentives
are likely to reduce the amount of wastes going to landfill. The
effect of the legislative controls will also depend on the level
of the sanctions. This will apply both to the statutory performance
standards and to the tradable permits for the limits on bio-degradable
waste permitted to go to landfill. It is impossible to conceive
of a situation where waste is piling up in the streets because
targets have not been met or permit limits have been reached.
The imposition of fines or financial capping would lead either
to a reduction in the availability of funding for recycling initiatives
or the passing of costs directly to the public through council
tax.
The Landfill Tax Credit Scheme has been useful in addressing
the perceived detrimental effect of landfills to the local environment
but its impact on encouraging recycling has, so far, been quite
limited. This is related to the restrictions imposed by regulations
in the use of such funding for research or education purposes
only. Unless direct use of tax credits for recycling initiatives
is permitted or there is hypothecation for this purpose, the tax
will continue to appear to be a very blunt instrument for achieving
recycling targets. Perhaps rebates of tax paid by local authorities
could be made in relation to achievements in recycling.
5. A REDUCTION IN,
AND BETTER
MANAGEMENT OF,
HAZARDOUS WASTE
Government has been slow in making provision by 16 July 2001
for the transposition of the Landfill Directive. With well under
a year left, consultation documents on the fundamental changes
to the arrangements for managing hazardous wastes have yet to
appear. It seems unlikely that legislation and guidance will be
in place in time. Industry still has no confirmed interpretation
of the implications of the Directive and so cannot plan and commit
expenditure to provide the facilities necessary to ensure compliance.
It is already extremely difficult to obtain permissions and permits
for non-hazardous waste landfills or treatment facilities. Even
if companies are prepared to commit the required capital, the
prospects for providing the necessary hazardous waste treatment
and disposal facilities within the Directive timetable seem very
bleak.
6. SIGNIFICANT ACTION
TO IMPROVE
THE EXAMPLE
SET BY
GOVERNMENT IN
EXERCISING `GREEN'
PROCUREMENT POLICIES
In addition to expanding green procurement policies, Government
should ensure that recycled materials are not precluded from being
used, eg the specification for road building materials should
refer to the properties of the materials rather than to the material
types.
Central and local government should make every effort to
use the products of recycling and composting initiatives. We can
site examples of where local authorities have employed recycling
officers yet their parks departments have not been required to
use compost produced from green waste.
7. SUFFICIENT ACTION
TO EDUCATE
THE PUBLIC
ABOUT THE
IMPORTANCE OF
SUSTAINABLE WASTE
MANAGEMENT
It is suggested that part of the extra finance to help authorities
meet the recycling targets announced in the Government's comprehensive
spending review should be used to fund a national education campaign
aimed at raising public awareness of the issues and obtaining
support in providing the solutions. This is likely to be a long-term
process and so an essential starting point would be repeated reinforcement
at schools.
CONCLUSIONS AND
RECOMMENDATIONS
The Waste Strategy sets clear targets for waste recycling
and composting, recovery and reductions of the amounts going to
landfill. However, these are not supported by legislative, or
perhaps more importantly, financial incentives.
By comparison with the German experience where recycling
is much more advanced, these targets may prove to be very ambitious
without financial incentives and significant regulatory support.
There is insufficient attention paid to the avoidance of
waste generation and the provision of a motivating influence.
Even after the achievement of all the targets, alternative
methods of disposal will still be required.
Energy from waste (including incineration) will form part
of an integrated approach to waste management with landfill as
a necessary but flexible adjunct.
The provision of facilities to replace landfill is progressing
very slowly partly because of the initial high capital outlay
and long lead in times.
The landfill tax is proving to be a rather blunt instrument
in this diversion process and the more direct use of the tax collected
to encourage change would appear to be necessary.
Both central and local Government need to recognise the important
roles they can play in accelerating the planning process to ensure
that all the necessary new waste management facilities can be
put in place.
Even greater difficulties may be encountered in providing
new facilities to treat hazardous waste in order to comply with
the Landfill Directive. Progress has been slow and no guidance
has yet been given to industry from which they may plan the necessary
facilities and obtain the necessary finances.
If the aims of the strategy are to be fulfilled, the full
support of the general public will be required. A major long term
education campaign for all groups will be needed, probably starting
at a young age in schools.
September 2000
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