MEMORANDUM BY THE NATIONAL FARMERS' UNION
(DSW 85)
INTRODUCTION
The National Farmers' Union welcomes the opportunity
to submit comments to the Environment Sub-committee of the House
of Commons Select Committee on the Environment, Transport and
the Regional Affairs inquiry into Delivering Sustainable Waste
Management. Waste Management is a matter of increasing relevance
and concern to agricultural and horticultural businesses not only
because of waste arisings from farms themselves but also because
farms are often the targets of illegally dumped wastes through
fly-tipping. Our interest in the Sub-committee's inquiry therefore
needs little amplification.
The range and nature of questions outlined in
the invitation are not all directly relevant to agriculture so
our response addresses only those matters of most relevance. For
ease of reference, we have addressed the issues in the sequence
outlined in the invitation.
AN INTRODUCTION
TO AGRICULTURAL
WASTE ARISINGS
Because of the diverse nature of operations
and processes carried out on agricultural and horticultural businesses,
the types of wastes produced on farms are very varied.
A PROFILE OF
AGRICULTURAL WASTE
ARISINGS
| Estimated quantity arising in the UK (tonnes/yr)
|
| Sheep dip | 116,000 |
| Pesticide washings | *105,000
|
| Waste oil | *27,000 |
| Vet products | 800 |
| Non-packaging plastics—silage wrap, crop cover, bale twine, net wrap, etc
| 48,000 |
| Packaging—plastic | 33,000
|
| Packaging—paper and cardboard | 11,000
|
| Animal by-products—animal tissue, fallen stock
| 344,000 |
| Machinery waste—scrap, tyres, batteries
| *52,000 |
| Manure and slurry | 81,477,000
|
| Silage effluent, crop residues, straw and waste milk
| *13,756,000 |
Source: Marcus Hodge Environment Limited.
No figures are available for waste asbestos.
*Low-medium accuracy.
As the table indicates, organic by-products account for 99
per cent of the total of approximately 96 million tonnes of agricultural
waste produced on UK farms in any one year. These organic wastes
have a value in that they can be and usually are recycled to land
as a fertilizer or re-used as an energy source.
Agriculture is, however, also burdened with non-natural wastes
such as plastic and paper packaging, which arise mainly because
products are provided to the farmer pre-packaged. As a result,
farmers and growers have to deal with tens of thousands of tonnes
of waste packaging. For example, approximately 44,000 tonnes of
plastic and paper packaging arise on agricultural or horticultural
holdings each year.
Agricultural waste arisings tend to be regional in nature
and vary with the season. For example, accumulation of wastes
associated with arable farm businesses arise predominantly in
the lowland areas of the country and mainly over the spring and
autumn periods. By contrast, accumulation of other wastes, such
as special waste on farms, may be small in quantity and infrequent.
Their geographical location and remoteness make farm businesses
very different from most other businesses. The logistics of the
collection and transport of waste can be very difficult, and potentially
quite costly for farmers and growers. Many agricultural wastes
such as plastic film and wrap can also be bulky and difficult
to handle.
General principles
The NFU supports the principle of the waste hierarchy; we
believe that there is great merit in the re-use, recycling and
recovery of waste, use before disposal, the proximity principle
and the Best Practicable Environmental Option (BPEO). To date
however, it seems that measures for addressing waste on farms
have been mainly regulatory in nature. We believe that more emphasis
needs to be given to other measures such as information, advice
and incentives in order to ensure that the principles of the waste
hierarchy can become practical instruments on the ground.
The Regulatory Route
At present, waste issues are dealt with by the Environment
Agency through the Waste Management Licensing Regulations and
the Special Waste Regulations and it is legally required to recover
the costs of regulating and monitoring these regulations. However,
that does not mean that the Agency should apply the same cost
structures for farm businesses as might be justified in the case
of large industries.
Most agricultural and horticultural businesses are small-scale
often one-person units many of which are currently operating at
the margins of economic viability. Moreover, unlike many other
industries, they are "price-takers" not "price-makers"
and as such, cannot pass on the cost of regulatory controls to
the consumer.
With the imminent extension of Waste Management Licensing
to agricultural waste this will inevitably lead to the quantities
of controlled waste in the UK waste stream increasing. As farmers
and growers have not had to formally address the issue of waste
management controls before, a plan to deal with agricultural wastes
or market development for waste arisings has not been undertaken.
Unless positive efforts are made in the implementation of
measures such as recycling and recovery and the development of
the infrastructure to deal with these wastes, many agricultural
wastes may go to landfill with little net improvement in the position.
Dealing with wastes that arise on farms should not be seen
as only a problem for farmers and growers to solve. All stages
in the supply chain all have roles to play in reducing, recycling
and recovery of wastes.
1. MORE EFFICIENT
USE OF
RESOURCES AND
A CONSEQUENT
REDUCTION IN
THE AMOUNT
OF MATERIAL
ENTERING THE
WASTE STREAM
The introduction of Waste Management Licensing controls on
agricultural businesses will undoubtedly affect the attitude of
farmers and growers to the volumes of wastes that are produced.
Waste audits and education measures
Some assurance programmes, such as Assured Produce, already
place an obligation on growers to carry out an audit of wastes
arising on-farm or on the holding.
The Ministry of Agriculture, Fisheries and Food (MAFF), together
with the BOC (British Oxygen Company) Foundation, have produced
a waste minimisation manual which can help farmers assess how
much waste they produce. It gives advice and guidance on re-use,
recycling or disposal of the waste and makes estimates of the
potential cost savings to be made.
We see some merit in a self-audit approach as a way of helping
farmers and growers to assess the waste produced by their businesses.
However, there are currently few incentives for farmers to address
the quantity of non-natural wastes they produce.
Incentives, advice and information measures are needed to
promote and encourage the reduction of waste production and the
re-use and recycling (where possible), of waste.
We believe that the Government should introduce or promote
education measures such as those currently adopted by the British
Agrochemical Association, encouraging farmers to rinse their pesticide
containers to reduce the amounts of pesticide wastes arising on
farm.
Product stewardship
The onus to find solutions to the proper disposal of those
wastes arising on farms should not just fall to farmers and growers.
Suppliers and manufacturers also have a role to play. Product
stewardship schemes have encouraged agrochemical manufacturers
and suppliers to develop packaging that can be re-used or recycled.
In addition, advances in container design, such as the use of
larger or refillable containers and the use of soluble packs should
be encouraged to reduce the quantity of packaging requiring disposal.
2. AN INCREASE
IN RECYCLING
OF WASTE,
PARTICULARLY BY
GREATER DEVELOPMENT
OF MARKETS
FOR RECYCLED
MATERIAL (INCLUDING
COMPOST) AND
THE USE
OF PRODUCER
RESPONSIBILITY MEASURES
Re-cycling of livestock manures
As indicated earlier, the majority of wastes produced on-farm
is slurry and manure. These organic wastes have a value in that
they can be recycled to land as a fertilizer, or re-used as an
energy source.
Information on the value of recycling these livestock manures
has been disseminated through the codes of practice, guidance
and advice issued by Government and is recognised by most farmers
and growers. Unfortunately, the recognition of that value is often
not shared by farming's new neighbours in the countryside.
Organic waste treatment
The Royal Commission on Environmental Pollution report on
Sustainable Use of Soil published in 1996 recommended that Agriculture
Departments and rural development agencies "promote further
feasibility studies on the use of centralised farm waste digesters'
in selected areas with a concentration of intensive pig units
or large numbers of other livestock".
In the response made by Government in 1997 to this recommendation,
problems with anaerobic digestion of farm wastes were highlighted.
MAFF research had acknowledged that anaerobic digestion has a
role in farm waste management, but its potential is limited by
high capital costs and difficulties in marketing by-products.
The NFU agrees that the technology must be cost-effective
but believes that there is still potential for the use of alternative
treatment methods for livestock wastes. For instance, aerobic
digestion of slurry has the potential to reduce the quantities
of material to be applied to land and the gas generated from anaerobic
digestion can be used to generate electricity.
Plastic waste recycling
As farmers and growers and their suppliers have not had to
formally address the issues raised by waste management controls
on-farm, the development of markets and the infrastructure for
dealing with many of these wastes does not exist.
The accumulation of plastic wastes on farms, such as silage
wrap, crop cover, polytunnel, fertilizer bags, plastic twine and
pesticide containers has been identified as a major waste stream
in agriculture. Approximately 81,000 tonnes of plastics (packaging
and non-packaging) are generated by farmers and growers each year.
These wastes are difficult to handle because they are bulky, there
are often large quantities to be dealt with, they can be dirty
and disposal routes are limited. However, these plastics can be
recycled.
In 1988, British Plastics Industries set up a scheme to collect
and recycle plastics such as silage wrap and crop cover under
the title of Second Life Plastics. By 1992 the scheme was collecting
more than 4,000 tonnes per annum, but due to the slump in the
plastics market the scheme collapsed in 1993. In 1994 the scheme
was re-launched, with a voluntary levy of £100 per tonne
placed on sold film. As imported plastic did not carry the levy
the scheme collapsed again in 1997.
At present a plant in Dumfries recycles silage plastic into
pellets that can be remoulded into plastic products. This plant
is supplied with silage plastic collection from Wales and Ireland.
However, we acknowledge that this raises legitimate questions
about the sustainability of a process that requires long distance
haulage of low value bulk products.
With the application of Waste Management Licensing Regulations
to agricultural wastes and in the absence of an organised collection
and recovery scheme for these plastics, these wastes may go to
landfill.
Many farmers and growers who generate these plastic wastes
would prefer to recycle them instead of disposing of them. In
principle the NFU would support a collection and recovery scheme
to be organised for plastics. However, before launching another
scheme the difficulties encountered by earlier schemes need to
be addressed including the organisation of the collection scheme,
the cleanliness of the plastic that can be collected and tackling
the free-loaders. The degree of involvement and backing from farmers
and growers will also depend on the costs of participation.
For other agricultural waste arisings such as veterinary
medicines and clinical wastes, tyres, and batteries we believe
that there is further scope for the development of take-back schemes
or services with suppliers.
We are encouraged by the success of collection and recovery
schemes for plastic film in Wales, Ireland, France and the Netherlands
and existing container recovery schemes for packaging plastics
in the Netherlands and Germany.
Bio-degradable plastic is available on the market but it
is expensive and, from our experience, can be an unreliable alternative
for farm use. Plastic wrap or bags needs to provide a secure seal
from the elements. Bio-degradable plastic has been shown to degrade
quite quickly when exposed to sunlight.
Composting of green wastes
On-farm composting units, approved under a waste management
licence or under exemption, could make a contribution to the waste
strategy by taking biodegradable wastes that would otherwise go
to landfill.
There is some evidence of a growing interest amongst farmers
who wish to diversify their farm business and run part of their
farm as a composting site, or as a small site under a licensing
exemption. However, major barriers to the development of this
type of diversification are the lack of guidance on on-farm composting,
a lack of co-ordination of the research and development work that
is being carried out and a lack of confidence in the final product
in terms of content and consistency.
The Environment Agency has been consulting composting industry
representatives with a view to developing guidance for sites that
are licensed by the Agency for composting. At the very least,
a similar document is also required for exempt sites.
Farmers and potential compost producers are also reluctant
to develop on-farm composting businesses until they know the nature
of any amendments to the current exemptions from Waste Management
Licensing. Any changes to the current exemption conditions, such
as additional environmental controls or a reduction in the quantity
of waste that can be processed at any one time could affect the
viability of any diversification venture. If farmers and growers
are to play a role in composting they need to be positively encouraged.
Packaging waste
The Producer Responsibility Obligations (Packaging Waste)
Regulations have had little effect on the quantities of packaging
waste that farmers and growers handle. Many suppliers, who have
legal responsibilities under the Regulations, have joined compliance
schemes that deal with their recycling and recovery obligations
on their behalf.
Product stewardship schemes (see section 1) seem to have
had a greater impact on packaging design and the development of
reusable or recyclable packs.
Some responsibility for the reduction in the volumes of domestic
waste (including packaging waste) must also lie with the retailers.
For example, fresh produce suppliers must package goods according
to the retailer specifications. Bulky and unnecessary packaging
only adds to the problem of waste quantities for the end-user.
3. INCREASED USE
OF INCINERATION
AS A
WASTE DISPOSAL/RECOVERY
OPTION—THE
SUB-COMMITTEE
WOULD ALSO
WISH TO
EXAMINE WHAT
THE IMPLICATIONS
OF SUCH
AN INCREASE
WOULD BE
Although the recycling of wastes may be very worthwhile and
fulfil the Government waste hierarchy objectives, we believe that
this should not necessarily always be the preferred option. Regard
should also be paid to the BPEO and the proximity principle for
certain waste types.
A very good example of this is the incineration method used
on some farms for the disposal of fallen stock. The incineration
process is quick and efficient. The alternatives to on-farm incineration
are limited. Burial of fallen stock, particularly on large intensive
livestock units, is sometimes not the BPEO and collection for
rendering can be very costly and may spread disease.
Although large waste incinerators are now subject to very
strict controls, there remains a public perception that emissions
from these plants may be harmful. Recent or well-publicised cases
involving dioxin contamination of food from incinerator emissions
or ash reinforces this belief.
At a time when food safety is a key priority for producers
and consumers alike such perceptions cannot be overlooked.
4. A REDUCTION IN
THE AMOUNT
OF WASTE
SENT TO
LANDFILL—IN
THIS CONTEXT,
THE SUB-COMMITTEE
WOULD WELCOME
VIEWS ON
THE EFFECTS
OF THE
LANDFILL TAX
AND ITS
ASSOCIATED CREDIT
SCHEME
The fly-tipping of waste material on land has increased since
the introduction of more controls on waste. The introduction of
the Special Waste Regulations, the Landfill Tax, the increases
in the tax rate and more stringent waste management controls have
all contributed to the illegal dumping of wastes on land.
As part of the Tidy Britain Group survey in 1998 on the impacts
of the Landfill Tax, the NFU carried out a detailed survey amongst
farmers and growers. The survey found that 80 per cent of all
fly-tipping incidents took place in rural areas. Almost two thirds
of the respondents considered fly-tipping had increased in the
previous year. Well over half the respondents thought that the
increase in fly-tipping was due to the increase in landfill tax.
In the Tidy Britain Group survey, most of the fly-tipped
material was of local origin and was household or garden waste
(57 per cent), but a considerable portion of it (21 per cent)
could also have been attributed to the building trade or to the
dumping of cars (and tyres) (9 per cent). These were quite often
deposited on the verges of country lanes (28 per cent) but frequently
also on private land (28 per cent) or in rivers (12 per cent).
In mid-August 2000 the NFU carried out a further survey of
300 farmers and growers which revealed that more than half the
respondents said fly-tipping is a major on-going problem with
more than a quarter having seen a significant increase in fly-tipping
over the past year.
In some cases, the volume of material tipped is substantial
(several tonnes of tyres, or builders rubble) and once wastes
have been dumped at one site, the offenders often return.
The level of evidence needed for a successful prosecution
of fly-tippers is substantial and few are prosecuted for their
actions. We have also found that although local authorities may
have a statutory duty to remove some fly-tipped wastes (such as
abandoned vehicles), in many cases the authority cannot recover
the costs of removal of the material as the responsible person
cannot be found. In circumstances where the local authority and
other bodies such as the Environment Agency have a power to remove
waste, as opposed to a duty, they are often reluctant to use that
power.
In the absence of the person responsible for the illegal
dumping of waste, the authority can take action against the landowner
requiring him/her to remove the material (as the person who deposited/knowingly
permitted a deposit of waste material). This is often cheaper
for the authority than using its own power of removal.
In effect, landowners can be held responsible because the
land is accessible (ie not fenced off or a gate is left open).
Farmers have been advised to ensure that their land is secured
against entry for the purposes of abandoning a vehicle, or tipping
wastes.
In these circumstances, the farmer often may find that he
not only has to pay for the removal of material from his land
but also the costs of disposal at a licensed landfill site.
Solutions to the fly-tipping problems
We have argued in the past that more money should be made
available through local authorities or from Landfill Tax Credits
to help farmers and growers remove fly-tipped material from their
land, or to enable authorities to extend their duties to the collection
of fly-tipped material.
We reiterated those views last year in our evidence to the
House of Commons Environment, Transport and Regional Affairs Committee
inquiry into The Operation of the Landfill Tax outlining the problems
for landowners.
In their report, the Committee said:
"Revenues arising from the tax . . . should be used both
to mitigate some of the undesirable effects of the tax, notably
the increase in fly-tipping and the added burden on local authorities."
"We recommend that the Environment Agency and Customs
and Excise jointly publish an Enforcement Statement to address
fly-tipping. We recommend that the Environment Agency give a higher
priority to preventing fly-tipping and that the grant to the Agency
be increased correspondingly. The Government should review the
penalties imposed by the courts for environmental crimes and ensure
that magistrates receive training which indicates the seriousness
of such crimes and the need for appropriate sanctions."
The Government response indicated they were unconvinced of
the need to channel funds to mitigate fly-tipping. It also welcomed
the Fly-tipping Guidance produced by the Environment Agency and
Local Government Association, with input from a number of associations,
including the NFU.
As the Courts are independent of Government so Government
cannot review the penalties imposed. However, the Magistrates'
Association and the Environment Agency have produced a training
pack for magistrates and plan to provide training sessions for
them.
In addition, in the recent report of the House of Commons
Environment, Transport and Regional Affairs Committee on the Environment
Agency, the committee recommended that "urgent action"
be taken by the Agency and the Government to prevent fly-tipping
of waste. In response the Agency mentioned the work of the Fly-tipping
Stakeholders Forum that had been carried out in 1998.
The Environment Agency set up a Fly-tipping Stakeholders
Forum in 1998 to discuss the issues affecting landowners. This
group included stake holders such as the NFU, Railtrack, the National
Trust and the Country Landowners Association. A Fly-tipping Guidance
document was also produced.
This document outlines a brief guide to the law surrounding
fly-tipping, a Fly-tipping Matrix showing which organisation needs
to be informed of the various types of fly-tipped material (the
local authority, the Environment Agency or the Police) and gives
advice on how to avoid your land being used for illegal tipping.
The Fly-tipping Stakeholders Forum is to be re-formed in
the autumn to re-assess the scale of the problem and to review
the Guidance document.
The NFU applauds the Agency recognition of the extent of
the problem. However, we would also like this group to focus their
attention on finding solutions to the problems. In that context
we want:
(i) local authority funding or landfill tax scheme credits
to be made available to assist landowners with the costs of removing
fly-tipped material;
(ii) landfill tax credits to be used to waive fees for
those landowners that have to pay the landfill tax for fly-tipped
material at a properly licensed landfill sites;
(iii) communication and education measures to encourage
waste producers to employ properly licensed waste carriers to
dispose of wastes;
(iv) more information on proper disposal options for various
wastes should also be made available to waste producers; and
(v) clear guidance to authorities on when it is appropriate
for them to remove fly-tipped material rather than compel the
landowner to do so.
With further increases in Landfill Tax year on year and the
introduction of the Landfill Directive requirements, these pressures
will inevitably lead to further increase in fly-tipping.
The NFU believes that there is a strong case for the use
of Landfill Tax Credits to assist landowners in the removal and
proper disposal of tonnes of fly-tipped waste material that is
clearly not agricultural waste.
Moreover, as the waste regulations are soon to be amended
and agricultural wastes will become controlled wastes, more scheme
credits need to be made available for research and development
of sustainable waste management in order to fulfil the Government's
objectives for more wastes to be reduced, reused, recycled or
recovered.
5. A REDUCTION IN,
AND BETTER
MANAGEMENT OF
HAZARDOUS WASTE
The Groundwater Regulations allow the disposal of pesticide
washing waste or used sheep dip on-farm, in a safe manner with
full approval from the Environment Agency.
Special or hazardous waste, such as used oil and batteries,
arising on-farm has not been subject to any formal control. Take-back
systems are already in place for batteries, however, as an industry
that will soon be subject to these controls, there would also
be great benefit from the development of a scheme for other special
wastes, such as used oil.
Reliable data on the actual amounts of waste oil produced
by the agricultural industry is hard to find. Current estimates
put the figure at 27,000 tonnes per annum. In order to fulfil
the Government waste hierarchy, recovery instead of disposal of
this oil should be encouraged.
6. SIGNIFICANT ACTION
TO IMPROVE
THE EXAMPLE
SET BY
GOVERNMENT IN
EXERCISING "GREEN"
PROCUREMENT POLICIES
Greater investment is also needed in the development of infrastructure
for the collection and recycling of agricultural wastes. Without
this, the market for recyclables will remain static and progress
in achieving the objectives of the Waste Strategy will be slow.
Difficulties also arise in handling farm wastes that may
be bulky and soiled and there is no incentive to recycle waste
when there is a lack of markets for secondary materials.
Suppliers and manufacturers of products for the farming industry
also have a role in the development of the infrastructure for
a collection and recovery scheme. However, for those companies
who are already complying with their responsibilities under the
Producer Responsibility Obligations Regulations, there is little
incentive to play a part in the development of schemes.
A major barrier to the participation of farmers and growers
in waste management schemes is the difficulty of passing on the
costs to customers and consumers. Farmers and growers are "price-takers",
not "price-makers", and as such cannot pass on the cost
of regulatory controls to another end-user.
7. SUFFICIENT ACTION
TO EDUCATE
THE PUBLIC
ABOUT THE
IMPORTANCE OF
SUSTAINABLE WASTE
MANAGEMENT
Although there may be great enthusiasm amongst the general
public to recycle bottles, plastic and paper packaging, they also
demand that products they purchase be packaged heavily. The general
public also needs to be educated and encouraged to change their
habits. Local authorities have a major role to play in the co-ordination
of awareness campaigns.
September 2000
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