MEMORANDUM BY MR BRIAN MAYNE (DSW 81)
It should be welcomed by the committee that
there is a move towards sustainable waste management through the
publication of a statutory framework as outlined by the Waste
Strategy 2000. However, whilst the document should be seen as
an important move in the right direction, there are a number of
concerns which need to be raised and recognised by the committee.
The overriding concern is that through lack
of local authority funding the goals set out in the waste strategy
will not be achieved. The whole area of how local authorities
will receive funding to achieve the aims of the strategy needs
to be considered. It is hoped that the Welsh Assembly will conduct
a thorough financial assessment of the proposals they intend to
introduce in Wales and allocate funding to deliver them, which
is likely to mean ring fencing any new resources. In the highly
pressurised financial environments that local authorities have
become, strategies will not survive without such accompanying
funding as alternative pressures can always take precedence.
A further concern is that in order to meet the
targets there will be a need for a range of waste management facilities.
Unless radical changes are made to the planning process then it
is unlikely that progress will be made, not only in granting permission
for Energy from Waste facilities which may be required, but equally
for Materials Recycling Facilities or commercial composting plans.
Therefore, the publication of the Planning Guidance note PPG10
or equivalent for Wales is even more imperative than before.
As regards the other specific issues the environment
sub-committee has resolved to inquire into the following issues
need to be considered.
More efficient use of resources and a consequent
reduction in the amount of material entering the waste stream
It should be recognised that at the heart of
sustainable waste management is resource optimisation. Minimising
the amount of waste an householder or a business produces goes
hand in hand with optimising their use of resources.
There is also a need to consider the issue of
waste in broader terms than the solid product left over at the
end of a process or action, and recognise that waste is a much
broader issue than that. We should not concentrate on reducing
the amount of solid waste we produce at the exclusion of considerations
about, among other things, wastage of energy or water.
Whilst waste minimisation is at the top of the
waste management hierarchy. Most attention is focused, apart form
a few schemes conducted within particular companies and industries,
on finding ways to deal with wastes once they have been produced.
This is due to the fact that minimising the wastes actually produced
during a particular process requires very specific knowledge of
that process, unlike techniques used once the waste has been created
such as re-use, recycling or composting. In order to successfully
reduce waste volumes it is necessary not only to establish the
composition of the waste but the reasons why it was created.
A way of introducing waste re-use could be gained
from considering new developments in the area of waste reduction
in Germany for example. The Kreislaufwirtschaftsund Abfallgesetz
(Cycle Economy Law Oct 1996). Instead of supporting the commonly
held view that refuse is for disposal, this law encourages the
avoidance of waste and makes reduction and re-use mandatory. A
distinction is made between waste for recycling and for disposal,
removing the gap between secondary raw materials (glass, paper,
metals) and refuse.
Many German firms are designing novel concepts
to help come to terms with the new law. One such concept is ShaRe
Centres, a Second Hand Department Store and Recycling Centre.
ShaRe Centres are a combination of a depot for second hand goods,
for both re-use and recycling. It functions as a conventional
department store offering the same selection and convenience but
with used products only. Ideally situated centrally to populations
of 10,000 inhabitants and close to supermarkets. By combining
their grocery shopping with a trip to the ShaRe Centre, customers
can minimise travel.
The ShaRe Centre is a service provider offering
collection, storage, repair, distribution, rental and recycling.
ShaRe Centres could offer expensive equipment to rent, a local
laundry service including a nappy washing provision, an on-line
computer service with up to date databases of goods along with
a range of products and materials for sale, to rent or share.
This concept could be developed in the UK.
An increase in recycling of waste, particularly
by greater development of markets for recycled material (including
compost) and the use of producer responsibility measures
There is a lack, however, of meaningful producer
responsibility measures in the strategy which means that the public
continue to pay the full costs of waste disposal and not the producers
of products that eventually becomes waste. The result therefore
is that the responsibility of dealing with waste falls upon local
authorities who have to bear the brunt of the costs. Concerted
action across Europe and indeed other developed nations will be
the only way that ultimately, producer responsibility measures
can be deployed to adequately account for and make manufacturers
of wasteful products pay the true costs of their activity.
It is unlikely that there will be a significant
demand for secondary materials unless some form of financial incentives
to manufacturers are introduced. These could include, reduced
or zero rated VAT on recycled products used in manufacturing,
or tax benefits with targets for consumption of secondary materials
to match those for reduction.
Increased use of incineration as a waste disposal/recovery
option
Government should take account, however, that
energy recovery may be the BPEO at present simply because markets
for recyclate are uncertain. As the EU landfill directive is implemented,
waste may be diverted from landfill at a rate faster than the
market for recycled goods can sustain, creating a need to expand
incinerator capacity. The measures proposed by WRAP therefore
to increase markets are extremely important. Energy from waste
in the light of this should only be supported when recycling has
been given time to develop. This would create a level playing
field.
There is also concern that as a result of the
lack of definitive guidance on how waste planning authorities
are to prove that they have fully examined different recycling
and composting options before moving lower down the waste hierarchy
and expanding energy from waste initiatives, EfW projects will
benefit. It is recognised that the strategy outlines that various
recycling and composting avenues should be fully explored before
energy from waste, but his scarcity of guidance will leave waste
planners open to concern of the public that EfW options are being
given a clearer run than public opinion is likely to desire.
A reduction in the amount of waste sent to landfill
The issue of tradable permits requires a great
deal of consideration. A major concern is that there is a possibility
that a permit system could well lead certain areas of the country
being encouraged to concentrate on landfill, which would limit
them to developing other waste management options. This could
also result in transporting waste over long distances to landfill
in order to reach permitted areas. This would be environmentally
unfriendly. The further consultation on the implementation of
landfill permits proposed should take these issues into consideration.
The landfill tax has had a pronounced impact
on local government finances and a limited impact on sustainable
waste management. It has directly led to higher disposal costs
for local authorities which has meant less money available to
invest in sustainable waste management activities. This means
that what were originally limited funds available for community
recycling projects from local councils is stretched even further.
A WLGA survey of authorities in Wales indicated that over half
of the Authorities reported an increase in disposal costs of between
25 per cent and 75 per cent.
It has also led to increased flytipping around
the country which means even more unnecessary expenditure by local
authorities to clean up the mess left by environmental vandals.
In addition, misuse of Civic Amenity Sites by unscrupulous traders
using the waste disposal facilities has also added to the financial
burden. To add insult to injury, not only do authorities have
to bear the additional costs of collection or removal they then
have to pay the tax on the waste which has illegally been deposited
in the first place.
It is worth raising the point that local authorities
have no control over the amount of waste they are obliged to collect
by law, but have to pay for the consequences of carrying out their
duties. Authorities collect the waste but do not produce it, so
much for the producer pays principle. This however leads to another
debate on the environmental and social aspects of charging for
public waste collection.
The answer to the continuing spiralling costs
of landfill is obvious, cut down the amount we produce and recycle
more, but the tax has had an adverse effect on the latter. Reprocessors
whose authorities provide materials collected from recycling have
reduced their payments or in most cases introduced charges by
the level of the landfill tax, thereby nullifying any financial
benefits that would have been achieved.
Another negative result of the tax has been
described by the WLGA who have shown that there has been a net
flow of resources out of Wales with little coming back into the
system. In 1997-98 £4.7 million was paid in landfill tax
and yet only 4 per cent (£185,000) was apparently made available
in landfill tax credits. Money leaving Wales which could have
been spent on waste management projects in the country.
A further drawback to the scheme is the requirement
for landfill operators to contribute or find a contribution of
10 per cent towards initiatives using the tax. If this was removed
then it would result in a greater number of small operators participating
who would be more likely to support community based projects.
Apart from the negative financial impacts of
the tax, the block on local authorities directly benefiting from
the scheme has led to bitter recriminations from the community
sector when Authorities have been able to obtain funding to support
trial or research waste prevention/recycling projects. The overly
complex application system which has resulted in fewer applications
by community projects has not helped either. A drawback for voluntary
groups is the £100 required to register as an Environmental
Body. What is needed is a fund made available to help small voluntary
groups register as environmental bodies. There is also a need
for advice to be provided to groups to explain how they become
Environmental Bodies and the type of projects the Landfill Credits
are able to support. There is a great deal of confusion around
who to apply to and how.
One way to ensure that recycling received a
major boost in Wales would be to allow local authorities to submit
schemes directly to ENTRUST for approval.
Apart from the financial problems caused by
the tax there is the limited impact that the present funding from
the tax has on sustainable waste management, for example, repairs
to historic buildings and landscaping of parks. There is little
enough money now for recycling and re-use, without money which
has been directly raised through landfill being used on repairing
the church roof. There is a way that could resolve this and that
would be to increase money for recycling and re-use without interfering
with the present expenditure on "worthy" projects. The
WLGA have stated that a greater proportion of the tax collected
could be made available for re-use as the tax increases. In their
response to the government document "Less waste more value"
they state that the proportion of tax for re-use could increase
from 20 per cent to 40 per cent without any detriment to Customs
and Excise Revenue. By 1 April 2000 this could have increased
to 49 per cent and by 2004, when the tax is projected to be at
a level of £15 per tonne, 63 per cent of the tax could be
made available to re-use without detriment to Customs and Excise
income.
The way forward for the landfill tax would be
to ensure that:
— more use is made of the Tax to promote
sustainable waste management;
— explore methods of transferring the
tax to producers of waste;
— investigate a system that addresses
the flow of landfill tax from Wales;
— remove the requirement for landfill
operators to contribute towards initiatives using the tax;
— establish a fund and advice scheme
to help convert voluntary groups into Environmental Bodies;
— allow local authorities direct access
to submit schemes;
— increase the proportion of tax for
re-use.
A reduction in, and better management of hazardous
waste
The burden of the collection and separation
of hazardous household waste cannot fall on Authorities alone,
restricted resources could mean the cheapest rather than the best
option for an area is considered. Most Authorities deal with HHW
through their CA Sites where members of public bring their waste.
These sites are generally not available to traders and anything
that is likely to compound existing control problems should be
avoided. In addition as the initiative is expected to be highly
publicised Authorities may not have the infrastructure to cope.
The way forward should be to develop a partnership
approach between the manufacturing industries, retail outlets,
local authorities and waste management companies.
Manufacturers/Retailers need to consider labelling,
return packaging options and waste disposal options. Whilst LA's
need to think about waste collection from both bring and doorstep
schemes to cover hazardous household waste material in larger
volumes. The expense of operating collections in sparsely populated
rural areas found in Wales and their subsequent disposal will
no doubt be costly. In addition there are likely to be significant
costs in publicising schemes.
It is important that the public are educated
and informed of what is and is not considered to be hazardous
waste and how it should be dealt with.
Consideration should be given to product labelling,
a crossed out wheeled bin is totally inappropriate as a number
of Authorities use refuse sacks and more importantly it does not
indicate what should be the correct method of disposal. There
needs to be careful consideration of the symbol used and liaison
with all sectors involved should be undertaken to ensure an appropriate
symbol is promoted.
Significant action to improve the example set
by Government in exercising "green" procurement policies
The Waste strategy commits DETR and the Office
of Government Commerce to developing a list of products with high
levels of recycled content which should be purchased. This should
be welcomed as the potential is vast; EU figures on public spending
at around 18 per cent of total spend indicate the enormous potential
a public sector procurement programme could have.
Much of the programmes development will borrow
from the US Governments Comprehensive Procurement Guidelines (CPG)
programme which was developed as a result of the Resource Conservation
and Recovery Act. The US approach encourages the purchase of recycled
products by introducing legislation which requires government
agencies to buy recycled products. The first CPG designated 19
products which procuring agencies are required to purchase. A
procuring agency is any federal state, or local agency or government
contractor that uses appropriate federal funds to purchase products.
The range of products continues to be expanded under these guidelines.
It is disappointing therefore that WS2000 starts solely with paper
purchasing. A pilot scheme focused on recycled paper is simply
not enough. Good quality recycled paper has been on the market
for many years.
Work has already been undertaken by the Environment
Industries Commission with the Treasury on using Whole Life Costing
to bring environmental issues into public procurement. The EIC
have said that their work "has highlighted that the need
is not for tinkering with pilot schemes on recycled paper but
for a full scale effort to reduce the impact of all public sector
purchasing".
The waste strategy has therefore in my opinion
wasted an opportunity and this is an area that needs to be addressed
as there is an urgent need for effort to be applied to the reduction
of the impact of all public sector purchasing.
Sufficient action to educate the public about
the importance of sustainable waste management
No guaranteed support for the National Waste
Awareness Initiative is extremely disappointing, if the public
are to be made aware then the type of activity this organisation
can promote needs appropriate funding. A concern about the structure
of the NWAI is that it does not have a representative from Wales,
although it does have representatives who represent Welsh organisations
(Cylch and some local authorities who are members of LARAC). There
is a need that if they intend to campaign in Wales this omission
is addressed.
September 2000
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