Select Committee on Environmental Audit Minutes of Evidence


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 wastes—especially hazardous wastes—as well as household/municipal wastes

    —  The need for shared responsibility for our waste, how it is managed and who pays—including 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 approaches—including 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 soon—and 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 production—both 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 waste—the 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 treatments—often 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 pre—WS2000, 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 location—specific 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 production—as 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 realistic—zero 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 volume—related 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 technologies—including waste reduction and recycling—already 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 responsibilities—beyond those being required through EU Directives—could 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 regime—including 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 wastes—like 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 UK—driven

    —  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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