Select Committee on Environment, Transport and Regional Affairs Fifth Report



  The Environmental Services Association ("ESA") is the trade association for the waste management and secondary resource industry, a sector that contributes more than £4 billion to the United Kingdom economy, about 0.5 per cent of GDP. Our members provide integrated solutions to waste across the full spectrum of biological, thermal and mechanical treatment options and are consistently achieving more sustainable waste management practices.

  ESA welcomes the opportunity to submit comments on the Select Committee's inquiry into sustainable waste management. Sustainability is an opportunity for our industry. The development and growth of the waste management industry resides in higher added value and continuing evolution of a dynamic and vibrant resource management industry.

  Consequently, there is much for our Members to welcome in the aspirations of the Government's Waste Strategy for England and Wales ("Waste Strategy 2000"). However, whilst being stronger on the vision, Waste Strategy 2000 is less effective in supplying the mechanisms to initiate the necessary behavioural, environmental and economic changes that will facilitate the growth of secondary resource industry.

  The direction of Waste Strategy 2000 is clear. What remains uncertain is the pace of the change and how the Government's' vision will be delivered. Only by working in partnership with ESA's Members can the Government lead the Country to sustainability.

Q1.   More efficient use of resources and a consequent reduction in the amount of material entering the waste stream:

  ESA Members do not see perpetual growth in waste arisings as the future of the waste management industry. Growth lies in higher added value and the evolution of a dynamic and vibrant secondary resource industry. Growth therefore lies with what industry is enabled to do with waste through sophisticated management techniques rather than with unit volumes.

  The Landfill Directive and Waste Strategy 2000 are helping to drive this trend. However, it is only if the Government creates a framework where sustainability is profitable that industry can help the Government, through sustainability, to demonstrate a decoupling of waste production from economic growth.

  Again, the Government's only chance of enabling the UK to comply with the Landfill Directive is to treat the waste management industry as a responsible partner and to create the conditions to enable the industry to provide what is needed.

  Waste minimisation can be compatible with the growth and development of the industry, arising from increasingly treating waste as a resource to which value is added. However, ESA Members deliver solutions to the problems of waste and both regulation and public attitudes to production of waste will significantly determine the shape of the industry. We agree with the observation at ESA's 1999 Annual Conference of Mr Chris Mullen MP that the public consciousness of waste as a problem is broadly analogous to that of smoking in the 1960s.

  Reducing primary resource consumption by changing the behaviour of waste producers is crucial to delivering real change and we welcome new initiatives outlined in the Strategy. The implementation of the Pollution Prevention and Control Regulations will assist this by bringing a more holistic approach to the regulation of industry. However, ESA is unconvinced that the Strategy is sufficiently potent to drive the necessary change.

  If the primary intention of Waste Strategy 2000 was to reduce the amount of waste society produces, a system of waste minimisation credits could have been introduced. This goes further than the indicator A1 of the Government's sustainable development strategy. The scheme could resemble the recycling credits system with credits awarded to local authorities where the quantities of total waste within their areas decline from the previous year. Reducing the amount of waste produced by local authorities would allow more to be spent on the development and growth of the secondary resource industry.

  If the Government were willing to trust a combination of market and regulatory mechanisms, there could be a positive role for direct charging. For example, each household could be issued with a notional voucher entitling it to free disposal of a certain weight of waste per year. Excess waste would then be liable for direct charging. Such a mechanism could avoid regression and, if designed in the right way, could help in generating the motivation that is essential to changing behaviour. ESA supports a controlled test to see whether a household charging scheme could be successfully applied to UK households.

  ESA's Members already deliver expert advice to a range of industries on issues such as waste minimisation, higher resource use and selection of the waste-specific Best Practicable Environmental Option ("BPEO"). The decision making process can be assisted by such environmental management tools as Life-Cycle Assessment and we hope businesses will increasingly seek the help of our Members.

  New technology will have an important role to play, not only in facilitating more sustainable and environmentally friendly design and increasing extract value from the product but also in monitoring resource wastage and changes in behaviour of waste producers. Government can use regulation to promote new technologies that will offer exciting opportunities to indigenous capital equipment manufacturers able to compete in the market.

Q2.   An increase in recycling of waste, particularly by greater development of markets for recycled material (including) compost and the use of producer responsibility measures

  ESA supports an expansion in recycling and composting as well as the introduction of statutory targets.

  However, statutory targets by themselves do not deliver an increase in recycling. An economy that effectively recovers resource from wastes needs a process from waste producer, to reprocessor and on to the end market with adequate transport throughout. For long-term viability, recycling must be seen as a sophisticated industrial process, provided by a profitable and well-regulated industry.

  ESA's Members are investing heavily in recycling infrastructure and it is for Government to create the conditions for this sector to grow without destabilising existing infrastructure in which the industry has invested.

  Large amounts of commercial waste are recycled because it is economically viable. Provided it works with the grain of the market, the Waste and Resources Action Programme ("WRAP") in overcoming market barriers to promote, re-use and recycling could make a positive contribution and ESA is willing to help. The Government has wisely chosen to work with representatives from the waste management industry and ESA hopes that this partnership will deliver real solutions. ESA asked the Government to include market development as a criterion under the Landfill Tax Credit Scheme and our Members have contributed substantial funds to initiatives such as ReMaDe.

  However, markets in recyclates are often global and ESA would have welcomed complementary new policy and market instruments. For example, Waste Strategy 2000 could have built on the voluntary minimum recycled content established by the Newspapers Association of 70 per cent by 2006 and introduced similar initiatives across other industries to significantly stimulate demand for secondary materials and products.

  Ultimately, increasing household recycling—the visibility of which exceeds its proportionate share—will largely depend on the behaviour of consumers: their participation in recycling schemes, inclination to purchase recycle products and willingness to pay higher costs. Changing the perceptions of householders will significantly impact on developing markets and increase certainty to invest in recycling facilities.

  The greater the confidence that financial institutions have in the growth of recycling, the lower the cost of raising capital and the more cost-effectively our Members can deliver innovative recycling and composting solutions. However, the failure to meet the recycling targets of "Making Waste Works" demonstrates the cultural change needed to deliver the Waste Strategy. We hope the pilot schemes announced in paragraph 5.7 Part 2 will prove to be effective.

  ESA supports the duty which producer responsibility places on producers to accept responsibility for their management of waste and the generation of an economic incentive to maximise the life of a product.

  For example, with our Members, we are already working in partnership with the Lighting Industry to develop a recycling scheme for end of life fluorescent lamps to meet the requirements of the prospective Waste Electrical and Electronic Directive even before that Directive has been implemented.

  However, as the Committee noted in their previous report into sustainable waste management, producer responsibility initiatives only cover specific waste streams and cannot alone reduce excessive consumption. Producer responsibility is part of the solution and may need to be accompanied by economic incentives at the end of consumption.

  However, sustainability is not the inherent property of any one particular waste management option and it is very important to be aware that recycling will not always represent BPEO. It is therefore important that the industry is able to offer a spectrum of sustainable waste management options to complement materials recovery and dispose of the residue created by reprocessing and recycling. This will eventually include the product: there is a limit to how many times a recyclate can be re-used.

Q3.   Increased use of incineration as a waste disposal/recovery option.

  The experiences of countries such as Sweden and Switzerland demonstrate that recycling and composting will not deliver in isolation and ESA therefore supports the integrated approach and Waste Strategy 2000.

  Energy from waste is complementary to management options such as recycling and an environmentally and economically sustainable waste strategy involves a portfolio of waste management solutions.

  We expect more energy from waste facilities to reduce the Country's reliance on landfill, but incineration is not the answer to the Country's problem: it is part of a co-ordinated solution. For this reason, and because we expect recycling to grow so rapidly, ESA does not agree with the introduction of an incineration tax.

  In contrast to past reliance on landfill we do not expect any option to account for more than 50 per cent of municipal waste management activity. If, as a matter of public policy, there was a move to limit the capacity size of an energy from waste facility to encourage the growth of smaller scale plants, the public would also need to appreciate the implications for cost.

  Energy from waste offer one route to sustainability: not only do facilities provide solutions to the waste created by society but they also prevent the release of hundreds of thousands of tonnes of non-renewable carbon dioxide through using municipal waste rather than fossil fuels to generate energy. Residues from energy from waste can also be re-used in construction, preventing the use of virgin materials. Ultimately, the contribution of EfW will be dictated by whether waste management or renewable energy policy represents the primary driver.

  ESA Members' energy from waste facilities are operated to the highest standards and are tightly regulated by the competent authorities. The operational standards for energy from waste plants have been agreed democratically in Europe, a process in which all parties have been able to add value. To protect the environment, ESA has supported a level playing field to bring environmental standards up to that expected of ESA's Members.

  All waste management options have an impact on the environment. A waste specific BPEO seeks to optimise the balance between environmental performance and economic cost: energy from waste should be considered within this context. What is best for the environment might not always be necessarily the option which seeks to maximise the resource. As the Committee noted in its report in 1998 on sustainable waste management, there is no point in durability for durability's sake: re-use must be consistent with BPEO. Similarly the Committee noted the sustainable role of high temperature incineration in destroying those wastes where value is unable to be added and where the primary requirement is for the destruction of harmful substances.

Q4.   A reduction in the amount of waste that is sent to Landfill

  The Landfill Directive is the primary driver for the diversion of biodegradable municipal waste from landfill. However, well-engineered and maintained landfill sites will continue to play an important, albeit reducing role within an integrated framework of solutions to waste. Notwithstanding some media coverage, there will continue to be added value in ongoing improvement of landfill techniques.

  The setting of statutory recycling targets will spearhead the diversion of waste from landfill sites and is welcomed by ESA. However, there must be widespread political acceptance of the need for new facilities if the resource management industry is to grow. Sustainable waste management will not be possible without an efficient and responsive planning system. ESA is therefore disappointed that Waste Strategy 2000 contains no new initiatives to improve the speed of the planning system and is concerned that this might cause failure to meet the targets of the Landfill Directive.


  The voluntary contributions of hundreds of millions of pounds by ESA Members through the Landfill Tax Credit Scheme have contributed significantly to research into sustainable waste management and added considerable value to local communities, the environment and in helping to develop a more sustainable society.

  An advantage of the scheme to the Government is that the scheme does not fall within total public spending. This facilitates macro-economic management by the Treasury and probably increases total funding of environmental enhancement initiatives.

  ESA itself established two independent object "C" EBs to promote knowledge and awareness of sustainable waste management: the Environment Services Association Research Trust ("ESART") and the Environmental Services Training and Education Trust ("ESTET"). ESA hopes both will develop strong synergies with WRAP.

  ESA offered some time ago to work with the Government in setting indicative targets for the distribution of Landfill Tax Credits.

  The Government and others must be realistic as to what the Scheme can deliver: the Landfill Tax Credit Scheme makes a positive contribution but will never be large enough to pay for the UK's Landfill Directive obligations or to achieve "sustainability".

  ESA believes that there is now sufficient practical experience of the Landfill Tax Credit Scheme to justify an industry code of conduct to supplement and support the role and duties of the regulator. ESA's code will:

    —  draw on existing best practice and improve the rigour and professionalism between landfill operators and EBs;

    —  reinforce integrity in the relationship between local authorities and Landfill Operators; and

    —  apply the proven General Principles of financial regulation of the Financial Services Authority.

  The integrity of the Landfill Tax Credit Scheme is critical: the Scheme must be and must be seen to be clean.

  The industry supports consistent and reliable regulation and expects the regulator to draw on the expertise of those best qualified as regards its core task.

  As at the date of submission of this evidence, ESA is awaiting—together with the Institute of Wastes Management—a meeting with ENTRUST to discuss matters including its corporate governance. Pending the outcome of that meeting it is not appropriate for ESA to offer further comment.

Q5.   A reduction in and the better management of hazardous waste

  The Waste Strategy 2000 rightly acknowledges that BPEO should underpin the management of all types of waste and we welcome the commitment within Waste Strategy 2000 to determine BPEO for the management of key hazardous wastes.

  Landfill will remain an important management solution for hazardous waste and ESA Members are working in partnership with the Government and the Environment Agency to implement the requirements of the Landfill Directive. The work of this partnership will have important implications for the landfilling of hazardous waste.

  High temperature incinerators also offer a highly effective management solution for many hazardous wastes: simply, they destroy them. A drive to higher environmental standards is profoundly influencing the nature of this sector of the industry, leading to a limited number of large, more centralised and highly capital intensive facilities. As the Landfill Directive takes effect, this infrastructure will probably need to be viewed as a "UK resource" to which prohibited waste streams are re-directed. This will require a sufficiently flexible approach to proximity as the capital intensive nature of the plants will mean that it is extremely expensive to develop a large number of smaller and more regionalised high temperature incineration plants and other hazardous waste plants. Standards rather than geography should be the over-riding factor.

  The Landfill Directive imposes a requirement for pre-treatment for the landfilling of most hazardous wastes and we agree with the view of the Waste Strategy that implementing the Directive will develop new waste management options for pre-treatment. It is important that the Government ensures that regulation encourages market conditions to permit a range of alternatives to develop. Without this, innovative treatment methods will not emerge.

  Effective and transparent regulation of hazardous waste is vital. The Landfill Directive and IPPC will be huge undertakings for the Environment Agency and we are concerned that sufficient resources are made available to allow them to regulate effectively.

Q6.   Significant action to improve the example set by Government in exercising "green" procurement policies.

  Environmental policy needs to be a key consideration of public procurement decisions and we are pleased that the Government wants to go further than current public procurement policies in purchasing recycled products.

  Adding environmental consideration as a more significant component of economic decisions is a central tenet of sustainable development and the Government must be seen to drive movement in this direction.

  Leading by example, the Government will demonstrate its confidence in recycled products and help to create stable markets for recycled product by, for example, sending a reassuring signal to other consumers. ESA suggests that to further strengthen the markets for recycled products, the Government consider awarding medium to long term contracts to facilitate greater investment in new technologies, innovation and research and development.

  A problem in "green" procurement has traditionally been the cost and quality of recycled product and, again, the Government should act to change this perception. There are many high quality recycled products and if the Government wants to develop a strong secondary resource industry it must, as the of the largest purchasing organisations, be ready to pay higher costs. It is also important that the Government's procurement policy is not confined to a limited number of easily recyclable, visible and high profile products.

  We would encourage the Government to consider "green" procurement as a grant or tax credit to develop a more sustainable part of the economy. The Government should show the same willingness to develop this market as it does in trying to stimulate e-commerce. The Government has made a commitment in Waste Strategy 2000 to introduce more sustainable procurement policies and we hope that these will have positive impact.

  It is important for businesses to follow the lead of the Government in their procurement choices and we hope that the initiatives listed in Waste Strategy 2000 will prove to be successful in encouraging businesses to adopt more sustainable procurement policies. As waste producers, they have a role in helping to support the growing evolution of a resource management industry. However, the Government must monitor this activity of business closely and, if necessary, consider mandatory procurement policies.

Q7.   Significant action to educate the public about the importance of sustainable waste management.

  The public is a key partner in the evolution of a secondary resource industry. Public commitment and support is critical in delivering the aspirations of Waste Strategy 2000. Increasing household recycling needs consumers to recognise their role and responsibilities as waste producers and in regarding landfill as a valuable and finite resource. Sustainability is part of the quality of life and the public will need to pay for the Country's future resource management industry which ESA's Members are ready, willing and able to develop.

  Success will largely depend on ceasing to think about waste as the end product of consumption and more as a resource. As suggested above, this is a huge cultural shift and comparisons are often made with the early stages of the drink drive campaign in trying to change attitudes.

  Effective, honest and influential initiatives to educate and energise the public are therefore vital and ESA's Members have already contributed millions of pounds through the Landfill Tax Credit Scheme to raise awareness and increase knowledge of sustainable waste management. ESA's Research Trust ("ESART") has this year contributed £50,000 to the National Waste Awareness Initiative. Waste Strategy 2000 rightly acknowledges the important role and strong contribution of education programmes and our Members remain committed to working with partners in demonstrating the environmental impact of waste producers. It is crucial that the public is aware of the need for sustainable waste management and able to express their choice. This will only happen if the public feeds connected to the vision of the Waste Strategy 2000.

  However, it is crucial that educating the public on the importance of sustainable waste management is done in a mature and honest manner, based not on flimsy and anecdotal evidence but on rational and scientific grounds with a clear understanding of the real choices to be made. Again we emphasise that only in partnership can the United Kingdom develop sustainability.

  Based on the experiences of our Members and the failure of the recycling targets of Making Waste Work, ESA is unsure whether the mechanisms contained in Waste Strategy 2000 will be sufficiently strong to change behaviour. We would have also liked to have seen a commitment to introduce fiscal instruments where sufficient progress was not being made, in order to add some bite to the commendable initiatives outlined in the strategy.

  ESA offers further views on matters fundamental to the delivery of a sustainable society:

Whether Waste Strategy 2000 will lead to a more efficient and responsive Planning System

  ESA believes that Waste Strategy 2000 does not provide real solutions to increase the efficiency and responsive of the planning system in implementing the vision of Waste Strategy 2000. Part 2 of the Waste Strategy shows that new facilities will be needed to meet the targets of the Strategy and the Landfill Directive. This is of particular concern as our Members' experience of the planning system in processing applications for a range of facilities, including Material Recycling facilities and composting stations, is dilatory, expensive and unpredictable. We are unpersuaded that the Strategy creates the planning system that is urgently needed and there is a real danger that new facilities will not be provided or that they will not be placed in the most suitable locations.

  Particular problems include the failure of the plan led system to produce plans and the failure of local authorities to accept ownership of a problem they themselves create. Whilst the need for new facilities is often agreed at regional level, delivery at a local level is far more difficult, with political considerations often obstructing delivery. The motivation for local authorities to deliver must be stronger and ESA believes it is vital for the recycling performance indicator to be underpinned by a tough sanction where compliance is not reached.

  ESA would have liked to see statutory recycling targets supplemented with other mechanisms. To improve the speed of the plan led system, ESA would have warmly welcomed a deadline for the production of plans supported by placing the stage of development of each plan in the UK on DETR's website to facilitate transparency and monitoring. A strong sanction would need to underpin this deadline to ensure that there is the necessary motivation to complete the plan within the permitted time. The Government may have missed an opportunity to improve the certainty of the planning system.

  Raising awareness of sustainable waste management and increasing knowledge of the responsibilities partners have in delivering the vision of Waste Strategy 2000 may help to improve efficiency but there is growing concern that decisions are being made in favour of public perceptions even when they are profoundly mis-informed. Ultimately it is not in the interest of society to erect barriers against the development of new facilities as by doing so, industry is prevented from adding higher added value and the evolution of a sustainable society is decelerated.


  ESA's Members need to work in partnership with the Environment Agency to meet the challenges ahead: only a broadly consensual approach can deliver a more sustainable society within a reasonable period of time. The challenges associated with delivering the National Waste Strategies within the framework of sustainable development are significant as regards both their nature and the timescale for delivery. There has never been a more pressing time for an effective and clearly focused regulator to underpin the delivery of the Waste Strategy 2000. ESA looks forward to working closely with the Environment Agency in negotiating the many challenges ahead.


  Waste criminals prevent waste from being managed to the high environmental and regulated standards under which ESA's Members operate. ESA is working in partnership with agencies including Interpol, the police and the Environment Agency to try to eradicate criminals which unfairly tarnish a highly regulated industry. The public must have confidence in the waste management industry and when waste criminals have the highest profile, this reflects negatively and unfairly on ESA's Members who operate to the highest technical standards. ESA is therefore disappointed that Waste Strategy 2000 did not allocate extra resources to combat waste criminals whose activities will otherwise rise as the Government, regulators and membership of ESA seek to achieve sustainability.

September 2000

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