SUPPLEMENTARY MEMORANDUM BY FRIENDS OF
THE EARTH (DSW 15 (A))
From our experience of local communities there
is much anger at plans for incinerators and the lack of adequate
recycling services. Many local anti-incineration action groups
have been established.
Eg GAIN (The Guildford Anti Incineration Network),
SKI (Stop the Kidderminster Incinerator), Capel Action Group and
groups in Redhill, Hull, Lancashire, Essex, Sussex, Kent and Medway
etc . . .
A Wastewatch NOP survey in 1999 showed that
89 per cent of people support recycling. (90 per cent say they
A DASH TO
Despite Meachers' desires, as a consequence
of Waste Strategy 2000 most waste disposal authorities are planning
a main role for incineration in management of their municipal
waste. Many of these are totally out of proportion with local
eg Planning permission has been given by Slough
Council for S.Grundon to build a 440,000tpa incinerator. The municipal
waste arisings for Slough are 57,306tpa (1999-2000). Recycling
rate 11.06 per cent 6,340tpa. This is a huge incinerator, way
out of proportion with local arisings, but was not called in by
the DETR even though WS2000 says it does not expect "incineration
with energy recovery to be considered before the opportunities
for recycling and composting have been explored", and that
"energy from waste plants should be appropriately sized".
They will be taking waste from many of the surrounding disposal
authorities, and have approached Oxfordshire, Bucks, Surrey, all
the West London waste authorities, Surrey, Reading, Berkshire
etc . . . Blatently in opposition to the proximity principle,
which should be a key determinant of the BPEO.
In Kent, the county council have already given
planning permission for an 500,000tpa capacity incinerator at
Maidstone (225,000 for Kent's MSW and rest for C&I). There
are also proposals for two more incinerators in Sittingbourne
(SITA 265,000tpa) and Richborough (400,000tpa). The municipal
waste arisings for Maidstone are only 46,203tpa, with a recycling
rate of just 8 per cent. MSW arisings in Kent are 800,000 tonnes.
If the other two proposals take only MSW, then the total MSW incin
capacity from Maidstone and the other two would be nearly 900,000tpa!
What should the Government's short and long term
targets for recycling and composting be?
Any specific targets must be based on the ultimate
aim of reducing primary resource use to sustainable levels. FoE's
publication "Tomorrow's World" calculates the
levels we can sustain and the cuts we need to make.
eg For wood we calculate the need for between
a 67 per cent and 89 per cent reduction by 2050 (depending on
population and production estimates).
eg Metalsneed an 88 per cent reduction
in the use of primary aluminium by 2050, principally through increasing
recycling and durability.
FoE is aware of current high levels of primary
resource use, and the pressures to increase consumption, therefore
targets must be set progressively. Short and long term targets
will send a signal to industry that the Government is serious
about achieving sustainability and drastic reduction in resource
use, and that they do not consider there to be a ceiling on recycling
FoE suggests that of 50 per cent recycling and
composting by 2010 would bring us into line with international
best practice cf other countries (see below) and allow us to meet
our European Landfill Directive Requirements without incineration.
An analysis of the composition is household waste shows this could
even by achieved by composting alone.
In the longer term most of the levels of recycling
of specific material required to meet our Tomorrow's World targets
are between 75-90 per cent. Research shows that 80 per cent of
the household waste stream can already be recycled or composted,
and it is only beyond these levels that issues of technical ability
and energy use mitigate against efforts. Given that we are so
far from these levels, FoE believes that in the long term the
Government should first aim to maximise recycling as much as possible,
focusing on the cultural changes to markets necessary, and beyond
that work with industry to improve the recyclability of the remaining
20 per cent or so of household waste.
Are these targets achievable? How and why? What
more needs to be done?
We need to look at the composition of the waste
stream: Research shows that approximately 80 per cent is already
recyclable. One third kitchen and garden organics which can be
managed through open, closed and in-vessel composting and anaerobic
digestion (AD). Approx another third is paper and card, which
can be managed by recycling, composting or AD. Approx 8 per cent
is glass which can be recycled, approx 3 per cent is metals which
can be recycled, 2-3 per cent textiles which can be recycled.
Plastics can also be recycled, although there is lack of reprocessing
capacity in this country.
1. Kerbside Collections for every household.
Source separation is the best way to obtain high quality materials
and the best way to drive home the importance of resource efficiency.
Eg a trial scheme in Daventry increased the recycling rate from
12 to over 50 per cent in one year.
2. Research into use of variable charging.
FoE believes this should be applied only after an effective and
convenient recycling system is in place, and only if it does not
disproportionately impact on low income households.
3. Sufficient Funding of local authority
recycling. Research shows approximately £10 per household
per year is needed to fund collections. (Though in Daventry council
tax only went up by £6.50) FoE suggests that this should
come from landfill tax revenue, through a refund system to local
authorities. Costs are likely to decrease in the long term.
4. A higher Landfill Tax to make it bite.
The Treasury take would then not decrease with a refund to Local
5. A tax on Incineration.
6. Producer Responsibility regulations,
to ensure products are easier to recycle, with better design and
7. Minimisationthe Government should
aim to cap on waste arisings. They should set a national and local
minimisation target to do this, and provide advice to Local Authorities
and householders on eg Home composting and nappy washing services.
8. Phase out of hazardous materials/materials
which cannot be recycled.
How important is source separation, and how can
it be encouraged?
Source separation is fundamental to obtaining
high quality, uncontaminated recovered materials for recycling
and reuse. It is also the best way to drive home the importance
of reducing resource consumption to householders, and the best
way for everyone to "do their bit".
Source separation in the home can be encouraged
by a mixture of sticks and carrots.
Carrots: Intensive education programmes, with
telephone/personal support have proved very successful and popular
in places, eg In Daventry 30,000 households have a weekly collection
of dry recyclables, while organic materials and residual waste
are collected on alternate fortnights. Participation is around
90 per cent.
Education is fundamental. People must understand
why they should recycle, and exactly howit must be absolutely
clear to the householder what can and cannot be separated for
recycling and composting. Recycling must be as easy as putting
the rubbish out.
Sticks: In addition, evidence from abroad indicates
that higher levels of recycling are achieved by including a financial
incentive/penalty for non-compliance. Eg the Blue Box 2000 scheme
in Canada introduced regulatory measures after the diversion options
had been established, which resulted in a significant increase
in all diversion activities. FoE believes that local authorities
should explore the use of variable charging for waste collection,
although FoE believes this should only be introduced if it can
be shown not to disproportionately burden lower income households,
and only after householders have been provided with a high quality
recycling and composting service.
Should PFI be used at all for waste management?
FoE does not have a problem in principle with
PFI being used for waste management, and to ensure that investments
are made in recycling and composting. We do have concerns over
how it is done. It is important that communities and Local Authorities
retain an element of control. Some local authorities have in the
past been locked into contracts for incineration and landfill.
Waste management in this country requires rapid and considerable
reform and PFI must not be a barrier to that. (FoE thinks this
would be much less likely to happen if PFI investment is in recycling
Is the funding allocated adequate?
NoThe overall amount committed is inadequate,
and the means of provision is not steady or predictable enough
for local authority fiscal calculations:
The DETR £140 million Challenge Fund will
leave winners and loserswill not improve recycling services
across the board. There may be a significant bias in the distribution.
The Institute of Waste Managers calculates that £140 million
is equal to £1 per person per year for next three years.
SSA increases are not ring fenced and there
are other pressing claims on the cash. (The EPC block includes
sports, leisure and library facilities, council tax administration,
parking and magistrates courts. Environmental services such as
waste management and environmental health are only a quarter of
EPC spending). In addition, the increase is only of 4.4 per cent
per yearmuch of this will be needed to cover inflation.
If MSW arisings are allowed to increase at 2-3
per cent each year, then management costs will also increase,
including the costs of a higher landfill tax of £14 by 2003-04.
ENDS suggests that if MSW growth is allowed to continue, it could
increase costs by more than £100 million per year by 2003-04
while the increase in landfill tax could add a further £70
Blair's £50 million commitment to Community
Recycling through the New Opportunities Fund is welcome, but will
not reach local authorities.
The CRN, LARAC, the LGA, the ESA and the IWM
have all expressed the view that funding for recycling is inadequate.
Landfill is still very cheapFor example
AEA Technology, in their report on waste management and climate
change for the European Union, estimate the average UK landfill
gate fee to be 43 euros (including tax), while in Austria the
average cost if 117 euros, in Germany 90 euros, in the Netherlands
113 euros, in Sweden 86 euros and in Luxembourg 162 euros. While
landfill remains cheap and does not reflect the true costs of
resource use and pollution, it will be hard for recycling to compete.
The Landfill Tax is not working in encouraging
a drive to more recycling of household waste, as shown by the
fact that the UK's municipal solid waste recycling rate has hardly
risen at all during the last four years when it has been in operation.
A survey in Materials Recycling Weekly showed that 81.8 per cent
of the waste management industry thought the tax should be increased,
the majority of which believed it should be £25 per tonne
or more. At the same time as local authorities are expected to
fund recycling systems, the proportionate burden of the landfill
tax on them is increasing. In 1998 LAs contributed 35 per cent
of gross tax yield (£140 million out of total £450),
and today they contribute 60 per cent (£308 million out of
By contrast Incineration is subsidised from
a variety of sources:
PFIseven packages awarded
so far, all intended for incineration.
NFFO£233 million so far,
and another £187 million agreed in future.
Climate Levy Exemptionexempt
through its definition as a renewable energy.
Netherlands60 per cent by 2000.
USA35 per cent by 2005.
Switzerland53 per cent in 1998.
Austria48 per cent 1996.
Norway38 per cent in 1999.
Sweden34 per cent in 1997. A ban on the
landfilling of organics by 2005.
Denmark40-50 per cent by 2000.
Finland30 per cent in 1997, 75 per cent
of biowaste to be treated by composting and anaerobic digestion
(ie no incineration).
Spain20 per cent in 1997.
Greece25 per cent of biodegradable waste
to be composted by 2005.
Italy 35 per cent source sep by 2003.
What should have been done in the strategy about
Again the ultimate aim is reduction in primary
resource use, and minimisation is a key part of any package to
Resource use must be decoupled from economic
growth. The potential for resource efficiency is huge. The book
"Natural Capitalism" suggests that in the US, just 1
per cent of the materials used in product production are still
in the economy in six months' time.
There are many ways industry could minimise
waste, such as improving durability and recyclability in consumer
products. Producer responsibility provides and incentive for them
to do this. Shifting to a repair culture would also be good for
local economies and provide more jobs.
Policy measures the Government could practically
Set a short term target to cap waste
arisings, and a longer term target to reduce them. (Nationally
and for local authorities).
Give guidance to local authorities
and households on waste minimisation. Eg nappy washing service,
home composting. However while there is much local authorities
could do, their impact is limited.
Producer responsibility and taxes
on virgin materials will give industry the necessary incentive
to improve design and increase uptake of secondary materials.
Many industries could move from providing
products to providing services, as the photocopying service Xerox,
and the carpet provider Interface have done. Government is supposedly
committed to this shift, and should use economic instruments to
reduce the use of raw materials and increase the use of labour.
Product information should be given to inform consumers about
appliances and about the benefits of product service options compared
to the waste-fullness of existing patterns.
How can markets for recyclate be developed?
FoE welcomes the establishment of WRAP, and
is sure it will have a very positive impact on the development
of markets for recycling. We also welcome the presentation of
recycling as a business opportunity. However, we feel that ultimately
this approach is limited, and it is unlikely that our goal of
drastic cuts in resource use will be achieved by the market alone,
which still does not reflect environmental externalities. We believe
economic instruments are vital to internalise these environmental
costs, such as:
Resource Taxes on virgin raw materials
like plastics and paper to further incentivise the uptake from
Waste taxes like a higher landfill
tax and a tax on incineration.
Producer responsibility legislation
to improve design and durability.
Minimum recycled content.