Memorandum from the Environment Agency
1. INTRODUCTION
1.1 The Environment Agency welcomes the
opportunity to submit evidence to this inquiry into Government's
Waste Strategy 2000. The report commissioned from the Cabinet
Office Strategy Unit is both important and timely if changes are
to be made to improve waste management in England and Wales.
1.2 The improvements are driven in part
by a growing recognition of the importance of resource efficiency
and of the need to protect people and the environment from the
potential impacts of wastes. Many of the changes also stem from
European regulatory drivers. Examples include the Landfill Directive
and Producer Responsibilities for packaging and packaging waste,
and these will need to be met regardless of other pressures. The
Agency therefore looks forward to the Strategy Unit report and
hopes that its recommendations will be acted upon by Government
and will make a real difference to the way that wastes are perceived
and managed.
1.3 The Committee will be aware that at
this stage the Strategy Unit has yet to publish its report. In
preparing this evidence we have therefore identified key issues
in waste management that we would especially like to see reflected
in the report. Many of these have been presented elsewhere, and
in particular to recent Select Committee inquiries including:
Packaging and Packaging Waste: Revised
Recovery and Recycling Targets, July 2002, House of Lords Select
Committee on the European Union, Sub-Committee D
Hazardous Waste, May 2002, House
of Commons Environment, Food and Rural Affairs Committee
Delivering Sustainable Waste Management,
Sept 2000, House of Commons Environment, Transport and the Regions
Committee
Waste Incineration, June 1999, House
of Lords Select Committee on the European Communities, Sub-Committee
C.
1.4 Although the final report of the Strategy
Unit is still awaited, the Agency hopes that it addresses the
following three important issues:
The need to plan for industrial and
commercial wastesespecially hazardous wastesas well
as household/municipal wastes
The need for shared responsibility
for our waste, how it is managed and who paysincluding
greater involvement of communities in planning and clearer targets
for local authorities with regard to household waste
The need for a mix of regulatory
and non-regulatory approachesincluding enhanced green purchasing
by public sector organisations to promote the use of goods made
from recycled materials and the purchasing of goods with a low
environmental impact.
2. THE NEED
TO PLAN
FOR INDUSTRIAL
AND COMMERCIAL
WASTES AS
WELL AS
HOUSEHOLD WASTES
2.1 We need to plan for the management of
industrial and commercial wastes with the same vigour as is applied
to household wastes. Wastes from businesses constitute seven or
eight times the tonnage (27 million tonnes) of municipal solid
waste[1]
in England and Wales, and, as a result of legislative changes,
an increasing proportion of it is classed as "hazardous".
The Waste Strategy 2000 and local and regional waste plans do
take account of these wastes but in nowhere near the same detail
as is applied to municipal wastes. Important changes to the UK's
waste "market" will be driven by a series of European
Directives in the next 2 to 5 years especially the Landfill Directive,
Hazardous Waste controls and new "Producer Responsibilities".
The Agency is therefore pleased to note Government's intention
to convene a Hazardous, or industrial, Waste Forum. The Forum
needs to start work soonand its task should be to assess
current and likely future hazardous waste production and waste
management capacity, and to assess any shortfalls in how Waste
Strategy 2000 considers/addresses these wastes.
2.2 Restrictions on which wastes can continue
to go to landfill under the Landfill Directive will bite much
earlier for hazardous wastes than for household wastes, and we
need to plan and provide for their future (non-landfill) management,
as soon as possible. The Agency is about to publish hazardous
waste data for the year 2000, with 2001 data to follow shortly,
and has commissioned work to assess hazardous waste markets as
valuable inputs to the forum.
2.3 The strategy needs to drive waste minimisation
and in particular a reduction in hazardous waste productionboth
in terms of quantity and hazard. Industrial and commercial waste
quantities are reducing with the move away from heavy industries
to lighter, hi-tech and service industries, and there are examples
of excellent waste minimisation. However, absence of any waste
reduction or recycling targets for industry and commerce does
little to raise awareness or to encourage action. Targets also
need to be backed with proper planning and funding, especially
if best practise guidance is to reach SMEs. The Agency has, through
its "Netregs" website, sought to promote understanding
of environmental protection and legislative compliance with SMEs.
Government will also need to continue its support to businesses
through Envirowise. The Agency also looks forward to the forthcoming
review of hazardous waste controls in England and Wales. This
will give the Agency much better contact with hazardous waste
producers and allow an opportunity, provided that adequate resources
are provided, to spread best waste management awareness.
2.4 We need early clarification of the European
Waste Acceptance Criteria and maximum notice of how they will
be applied and when. The future of the treatment and disposal
of many industrial and commercial wastes that are now classified
as hazardous will hinge on the standards to be applied to landfilling
them. Current management is often through "co-disposal"
which must stop in 2004. Waste planners, regulators, producers
and managers need time to plan for and provide the alternative
facilities that will be needed to reduce our reliance on landfill
in the UK.
2.5 The planning system in general needs
to be reviewed. It will have to cope with a dramatic increase
in the number and range of facilities needing planning permission
over the next decade. This would be helped if a deadline were
set for completion of all regional and local waste strategies,
and with clear links to the planning development control system.
Individual planning permission applications should preferably
be strategy lead rather than speculative, and will increasingly
benefit from "twin tracking" of both planning and permit
applications allowing the detailed technical information to be
considered together with more general planning issues. The links
between BPEO identified in planning strategies with individual
planning permission or permit applications must also be made clear
through the Office of the Deputy Prime Minister.
2.6 The Agency would therefore like to see
the Strategy Unit report recommend:
Early assessment of current and likely
future hazardous waste production and management capacities through
the Forum
Reassessment of the Waste Strategy
2000 in the light of the forum's findings
Reduction/recycling targets for industrial
and commercial wastes.
Early clarification of regulatory
controls for hazardous waste disposal by landfill to encourage
investment in new non-landfill treatment and disposal facilities
Planning for all wastes through early
completion of regional and local waste strategies
Clarification of the links between
strategies and individual applications
Clear commitments to how the Strategy
Unit report will be taken forward
Better data and information on waste
production and waste management produced and updated on a regular
basis
3. THE NEED
FOR A
SHARED RESPONSIBILITY
FOR OUR
WASTE
3.1 Greater community involvement in making
decisions on how waste should be managed is essential. We all
have a shared responsibility for wastethe waste we produce
in our homes and the waste produced on our behalf by industry
and commerce. For every tonne of household waste produced by the
average household, another tonne is produced from the shops, banks
and insurance companies we use; a further two tonnes comes from
the industries which make the goods we buy; and three tonnes is
produced by the construction industry.[2]
In other words, on average, every week of every year we each produce
our own body weight in waste.
3.2 If we are to reduce our reliance on
landfilling we are likely to need more (and more diverse) waste
treatmentsoften closer to where people live or work. This
will bring new opportunities for the waste/materials management
industries, but will not necessarily be popular. This will be
accepted only if there is greater involvement in decision making,
particularly in terms of the types and locations of facilities
we want to manage our wastes. Local and regional waste management
strategies must therefore be based not only on environmental and
technical merit but also on planning realities.
3.3 Community involvement in strategy development
is time consuming and costly, but there are good examples to draw
on. Often real and perceived risks to health and the environment
become sticking points to gaining general acceptance for waste
management proposals. Science can help quantify and reduce the
risks associated with waste management but cannot, despite some
expectations to the contrary, make them zero.
3.4 Increased demand will be placed on the
land-use planning system as we see a shift to smaller capacity,
more numerous waste management facilities. This planning capacity
will take time to develop and must be adequately resourced, and
the provision of the diverse range of facilities required will
take time.
3.5 Clear timetables should be set for the
completion of regional and local waste strategies. Most local
authorities' waste strategies were completed preWS2000,
and up to a quarter of Waste Local Plans were not completed. The
Welsh Assembly Government is setting a November 2003 deadline
for Municipal Waste Management Strategies and the three Regional
Waste Plans in Wales. The Agency would like to see clear deadlines
for the completion of all English regional strategies, local waste
development frameworks and Municipal Waste Management Strategies
The plans should be site or locationspecific wherever possible
to encourage appropriate applications.
3.6 We should aim to reduce the wastes we
produce. There is a linkage between GDP and waste productionas
GDP rises so does the amount of waste produced. The Agency would
like to see this link broken. It could be argued that more wealthy
countries should have lower waste production as wealth can be
used to achieve greater minimisation of waste than is possible
in less well off countries. However, local and regional waste
strategies must also be realisticzero waste is an admirable
objective, but we can't just wish waste away. We should plan to
reduce, recycle or recover value from ever greater proportions
of our waste, but also plan for the environmentally sound, socially
acceptable management of the inevitable residues.
3.7 Local authorities need clearer targets
and better guidance on waste management options and how to achieve
the targets. These must come from central government and must
be more challenging than at present if we are to get anywhere
near the 48% recycling figure achieved in Germany for example.
The penalties for individual authorities' failure to meet waste
recycling or landfill diversion targets or any deadline for strategy
development should be made clear at an early stage.
3.8 We need properly monitored and reported
trials by a range of local authorities to assess different methods
of making householders more aware of their waste production and
incentivising reduction and recycling. The Agency recognises that
there are difficulties associated with charging householders directly
for waste collection, but our research shows 70% of householders
say they would sort their rubbish, to allow something better to
be done with it, if it was made easy for them. More than half
of respondents in the same survey said they would accept extra
volumerelated charges for taking away unsorted waste.
3.9 National, regional and local authorities
will need help in preparing waste management strategies and determining
planning applications for waste management facilities. It is unreasonable
to expect individual authorities to have all the in-house expertise,
information or tools required. It is reasonable to expect them
to have access to these things, and many have suggested the need
for some sort of "Strategic Waste Authority" to satisfy
this need. This could be a single body or the provision for enhanced
roles for one or more existing organisations. The exact roles
and inter-dependencies of this body or bodies, and how the work
should be funded, should be a primary recommendation of the Strategy
Unit's report.
3.10 The Agency would therefore like to
see the report recommending:
Greater community involvement in
developing regional and local waste strategies
Proper provision of resources for
strategic and land use planning systems
Better guidance to local authorities
and clearer targets including more ambitious recycling targets
Clear deadlines for waste strategy
completion at all levels
Early clarification of penalties
for poorly performing authorities, coupled with recognition of
the resources needed to meet tough targets and deadlines
Encouragement of waste reduction
as well as recycling or recovery
Trials of options to make householders
more aware of the costs of managing their wastes and to encourage
greater public participation in waste reduction and recycling.
4. THE NEED
FOR A
MIX OF
REGULATORY AND
NON-REGULATORY
APPROACHES
4.1 A significant increase in the Landfill
Tax is needed. Landfill in the UK is amongst the cheapest in Europe.
It deters companies from introducing more sustainable waste management
technologiesincluding waste reduction and recyclingalready
in use in other countries. The revenue from an increased Landfill
Tax should be used to fund:
better data and information on waste
arisings, waste management options and support to more sustainable
waste strategy development (a "Strategic Waste Authority"
service)
provision of infrastructure necessary
for better waste management options for municipal waste.
4.2 The Strategy Unit should recommend early
announcement of any increase proposed to the Landfill Tax. Anticipation
of the increase will begin to affect waste producer behaviours
almost immediately. The Tax could be increased through a steeper
"escalator", but this would generate comparatively little
extra revenue for use (as above) in its early days. The Agency
would therefore prefer to see at least an initial significant
increase in the Tax.
4.3 The Strategy Unit should also recommend
a more general waste disposal tax to include waste incineration
and other disposal options. Raw materials taxes should also be
explored by Government to encourage resource efficiency and recycling/re-use
by both public and private sectors. The work of the Waste and
Resources Action Programme should be encouraged and extended to
stimulate secondary materials markets, funded through the increased
Landfill Tax.
4.4 New "producer responsibilities"
will help focus resource efficiency and waste recovery/recycling
responsibilities onto product manufacturers or suppliers. The
Agency supports these developments and would encourage Government
to identify where additional producer responsibilitiesbeyond
those being required through EU Directivescould be effective.
We must, however, avoid interim "last user" responsibilities
as chosen for end of life vehicles in the UK, as this will only
encourage abandonment.
4.5 The Strategy Unit report should also
promote "green purchasing" policies, especially in the
public sector where ambitious targets should be set. The Agency
will continue to promote green purchasing through its own policy
and through working with Agency-regulated and non-regulated industrial
and commercial sectors.
4.6 The Agency is committed to risk-based
regulation, supported by sound science. This may allow the Agency
to streamline or reduce regulation for some facilities or activities
without increasing risk to people or the environment. However,
it is clear that a larger number and range of waste management
sites will be needed to meet the demands of Waste Strategy 2000
and waste-related EU Directives. We estimate that 2000 new facilities
will be needed in the next few years, and that many existing sites
will need to be re-permitted under the new Pollution Prevention
and Control regimeincluding up to 1,000 landfills. The
Agency would therefore like to see the Strategy Unit report recognise
the increased regulatory costs to the Agency, and the resource
needs of DEFRA itself in providing appropriate and timely policy
and regulatory systems.
4.7 Penalties for illegal waste management
are still too low. Fines should at least reflect the savings or
profits made through non-compliance with the law. Until they do,
penalties will not deter waste crime. As the cost of responsible
waste management inevitably increases under the Landfill Directive,
producer responsibilities etc, the profits to be made through
illegal management will also increase. The Agency, local authorities
and others must therefore be fully resourced to prevent fly-tipping
and when it does occur, to identify, clear up and tackle illegal
waste management. Early increases in fly tipping could well involve
hazardous wastes. These will quickly be excluded from many landfills
over the next two years, whilst at the same time more wastes will
be classed as hazardous or separated from previously non-hazardous
wasteslike scrap cars. Well resourced response to fly tipping,
coupled with prevention campaigns, provision of an adequate network
of non-landfill facilities and tough penalties for offenders will
be needed to protect people and the environment.
4.8 The Agency would like to see the Strategy
Unit report recommend:
Early confirmation of an increased
Landfill Tax, preferably not through an increased "escalator"
Development of a broader waste disposal
tax or taxes
Use of the greater tax revenue to
support more sustainable waste solutions and support development
of a Strategic Waste Authority service
Development of other financial incentives/disincentives,
including raw materials taxes and support for secondary materials
markets
New "Producer Responsibilities"
either EU or UKdriven
Green procurement targets for the
public sector
Increased funding for waste regulation
and illegal waste management response.
4.9 The Strategy Unit's report is eagerly
awaited, and is certain to include important recommendations for
the Agency as well as most other organisations or concerns involved
in more sustainable waste and materials management. The biggest
outstanding questions will be the status of the report and its
recommendations and whether, how or when they will be acted upon
by Government. The above evidence is offered in anticipation of
the report and the Agency would be pleased to offer oral evidence
to the Committee or further written or verbal input to its deliberations
if this would be helpful.
October 2002
1 The term "municipal solid waste" is used
to denote household and other wastes collected by a waste collection
authority or its contractors, such as municipal parks and garden
waste, beach cleansing waste and any commercial and industrial
waste for which the collection authority takes responsibility.
This term is sometimes abbreviated to "municipal waste". Back
2
Source: Defra for household waste arisings data (¸25
million t.p.a.), Agency surveys for commercial (¸25 million
t.p.a.) industrial arisings (¸50 million t.p.a.) and construction
and demolition waste arisings (¸72.5 million t.p.a.). All
for 1998-99. Back
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