APPENDIX 6
Memorandum from Cleanaway
A memorandum in response to the strategy
unit report ("Waste Not Want Not") and the Chancellor's
Pre-Budget Report, by Cleanaway
1. Cleanaway is a global waste management
and recycling organisation employing 15,500 people, with operations
spanning 14 countries on three continents. It is a wholly owned
subsidiary of Brambles, a global industrial services company listed
on the London and Sydney stock exchanges.
2. In the UK, the company operates one if
the largest collection services for commercial, industrial and
hazardous wastes through a specialist fleet of over 1,700 vehicles.
The wide range of services offered to local authorities and industrial
and commercial clients cover a broad spectrum including waste
recovery, recycling, collection, disposal, high temperature incineration
and advice on Best Practice.
"Waste Not Want Not"
3. Whilst the production of this detailed
report by the Strategy Unit into waste management in England is
to be commended, especially as it appears to build on the Government's
Waste Strategy 2000 and a number of DEFRA consultations, it would
have been most useful if the status of the report had been explained.
It is not clear whether this forms part of the Government's policy
on waste management and if so, what the role of DEFRA is now in
such policy development.
4. The report is concerned with municipal
solid waste but this constitutes a small proportion of the total
volume of waste generated in England. Waste Strategy 2000 does
not place a great emphasis on dealing with commercial and industrial
waste and provides very little incentive for achieving the required
diversion from landfill. As it becomes increasingly difficult
to obtain planning permissions for landfill, the potential problems
in making provision for the wider range of wastes do not seem
to be recognised.
5. The report seems ambiguous as to whether
financial incentives should be or could be used to persuade businesses
to employ more environmentally friendly methods of waste management.
At page 11, it suggests that a rise in the landfill tax to £35
per tonne is required to change behaviour. Yet, it states that
waste costs would still be a small part of most business sectors'
turnovers and implies that this would be an insufficient incentive,
compounded by explaining that proceeds are redirected back into
business to minimise upward pressure on business costs. If the
recycling of this revenue is via subsidies to national insurance
contributions, the benefits will not focus on those industries
paying the tax. We suggest that the tax will make distinct changes
to behaviour. Therefore, much further consideration will be needed
to address the provision of facilities for the management of industrial
and commercial waste. Simply to opine that producers and retailers
reduce the amount of waste they produce, as on page 14, will have
little effect.
6. It is suggested at page eight that on
the basis of current best practice, over 50% of household waste
landfilled or incinerated could be diverted through home composting
and recycling. This may well be true, and whilst for some, home
composting is perfectly acceptable and feasible, for a large number
of households it is simply not possible and many other householders
would not be prepared to co-operate. As Government urges the population
to adopt healthier lifestyles and diets with a need to eat five
portions of fruit or vegetables per day, there is the potential
for the separation of a significant mass of putrescible wastes
from the household waste stream. It would appear to be a far more
realistic strategy to ensure that there is separate collection
of the different fractions of household waste for recycling or
composting on a large scale. With forthcoming changes to the Animal
By-Products Order, the composting of separately collected kitchen
waste ("catering waste") will be possible, provided
the facilities can be made available.
7. The Waste Strategy 2000 appeared to promulgate
a concept, that provided waste is recycled, it is acceptable.
This is a concept perpetuated in the Strategy Unit Report, despite
looking for measures to curb the growth in waste volumes. For
example, at page 35, it cites the Producer Responsibility measures
for packaging waste as a measure that curbs the growth in waste
volumes. These measures are mainly an incentive to recycle waste
once it has been generated and do little to reduce the volumes
generated at source.
8. We strongly agree with the suggestion
at page 36 that the Environment Agency builds and improves upon
their work on Life Cycle Assessment so that, for example, the
overall quantity of packaging waste can be reduced and that which
has to be produced is most economical in use of initial resources
and can most easily be recycled. A large proportion of the household
waste stream is packaging. "Bring" and "kerbside
collection" systems are increasingly allowing the recycling
of some of the packaging materials. However, why should there
be such a proliferation of different materials used in containers
for packaging? Should there not be much more careful consideration
of the optimum materials to be used for each packaging requirement.
For example, soft drinks can be supplied in glass bottles, plastic
bottles, cartons or cans and within each of those container types,
there will be significant variations in materials. There must
be an optimum material taking into account the initial use of
resources, the ease of use and the ease of recycling. If the correct
material were properly assessed, fiscal measures (possibly including
taxes) could be taken to encourage the use of single, rather than
multiple, material packaging and to incorporate recycled materials.
This could be enforced by charging deposits on containers.
9. Industry's criteria for investing in
waste management appear not to be understood. It is suggested
at page 50 that the waste industry has a role and a responsibility
to provide an appropriate range of facilities to handle waste
in line with the Government policy and regulatory requirements.
Industry will only invest in such facilities if they are financially
viable and if the necessary permissions can be obtained. This
may require new legislation or fiscal incentives to ensure that
the facilities are provided and/or used.
10. In order for the materials to be processed
and recycled, it is recognised that large numbers of processing
facilities will be required. Compliance with the Waste Strategy
targets will not be achieved unless changes are made to the planning
system that will allow these facilities to be provided. Most industries
can move straight into premises that have permission for general
industrial use. Light industrial use would cover a wide variety
of food processing industries, yet waste management and composting
are regarded as "suigeneris", so requiring specific
planning permission for the change of use. Existing warehouses,
which are allowed to accommodate some light industrial use without
requiring a new planning permission would be ideal for MRFs and
for in-vessel composting plants. Currently, only storage of matured
compost can be carried out in such buildings (since matured compost
would be equivalent to goods and the storage of goods would be
covered by light industrial usage). Maturation of the compost
and composting itself cannot be carried out. If this restriction
were removed by giving permitted development rights for change
of use from industrial or warehouse uses to waste recovery operations,
not only would the provision of the facilities be accelerated,
the costs involved would be reduced by avoiding the expense of
specific planning applications, inquiries and the construction
of specific buildings.
11. This limitation on permitted development
rights for change of use of industrial/warehouse premises for
waste management generates some absurd situations, stifling development
and waste recovery. For example, premises that have permission
for the production and distribution of electronic equipment could
not be used to receive and reprocess the very same equipment if
it became obsolete and was discarded, because it would be regarded
as waste.
12. The problems encountered by the industry
in providing facilities are particularly pertinent with regard
to hazardous waste. Until very recently, there have remained significant
doubts about the preparatory requirements for landfills for hazardous
wastes and the nature of hazardous waste that can be accepted
in them after treatment. The corollary to this problem is that
the design of treatment plants and their capacities for hazardous
wastes has also been unknown. We are now in a position where in
18 months time, there will be very few hazardous waste landfills
remaining and in two and a half years time, there will be a need
for a great increase in the capacity to treat hazardous wastes
prior to recovery or disposal. It is doubtful that there is sufficient
time remaining to design such treatment plants, to obtain planning
permissions and to commission them, even if industry were prepared
to risk their capital. Similar risks apply to the provision of
facilities to treat household waste streams: for instance, the
long-standing uncertainties associated with composting requirements
for kitchen waste.
13. Other misconceptions have been held
about funding sustainable waste management through the landfill
tax credit scheme. The use of the scheme by the industry has been
criticised, as stated at page 38, for failing adequately to focus
on funding projects to reduce, re-use and recycle waste. It has
been extremely frustrating for the industry to hear this criticism
when the limitations in the Landfill Tax Regulations prevented
the use of funds for these purposes.
14. On page 53, expert analysis has revealed
that the reduction of waste output, together with recycling, is
ranked as the best strategic approach. This includes 30% to be
disposed of by incineration or other methods. After removing recyclables
and putrescibles, the residuals would be comprised of paper, card
and plastics contaminated by foodstuffs with inherent health risks.
The environmental benefit of reprocessing would be questionable
because of the significant further use of resources to produce
a low-grade material with little scope for reuse. The only proven
reliable method for minimising the use of landfill for disposing
of these materials is the energy from waste process. The paranoia
in this country about energy from waste means that the UK is significantly
out of step with most of the rest of Europe where incineration
with energy recovery co-exists with landfill.
15. Cleanaway has useful experience in considering
environmental benefits of reprocessing waste materials. We operate
two plants taking post consumer PET drinks bottles and reprocessing
them into food grade PET chips for further bottle manufacture.
This process is only viable because the reprocessing returns the
materials to the original high value use. Capturing these materials
for low-grade use would not justify the further consumption of
energy, water and chemicals in the regeneration process (or the
cost). However, this is using large quantities (for economies
of scale) of source-segregated materials that are not heavily
contaminated. The reprocessing of mixed contaminated materials
would be much more difficult and an inefficient in use of further
resources.
16. Energy from waste through incineration
is the second use of raw materials. Indeed, for the materials
based on wood fibres, the use of a renewable resource in this
way would be virtually neutral in terms of CO2 emissions and so
can be considered environmentally sustainable, displacing the
consumption of fossil fuels. With the latest European Waste Incineration
Directive, there can be no argument against incineration on the
basis of emissions but this is an argument that the Government
and the Environment Agency must project strongly to the public.
17. The target of a 1% reduction in the
growth rate of waste by 2006 still allows a very significant increase
in waste production. The Report appears to confuse waste reduction
with recycling. Calculations of waste production and growth do
not show any reductions as a result of recycling or composting.
Waste reduction, or avoidance, requires careful consideration
of the reasons for the generation of waste in the first place—this
leads back to the life cycle assessment of materials and products
to determine which best avoids waste and waste of resources as
well as damage to the environment.
18. At page 60, the effects of initiating
improvements in waste management procedures today are predicted
for the year 2015. It mentions that the market for recycled and
environmentally friendly goods would be well established since
people would be willing to pay a little extra for these goods.
If there are such great concerns for the environment and the generation
of waste is considered so problematic, then there is no conceivable
reasons why legal measures should not be implemented requiring
the recycling of waste, of waste reduction and the production
of goods that are less damaging to the environment. The summary
at page 61 assumes that measures to encourage reuse are environmentally
friendly. An assessment would have to be made to determine whether
the processes needed to facilitate re-use are indeed environmentally
beneficial.
19. To reduce the rate of growth in waste
volumes, it is suggested at page 62 that there are three main
options. The first is for households to reduce the volume of waste
they produce in response to incentives and rewards but immediately,
the concept of reduction is confused with recycling. In reality,
there is no realistic possibility of such reductions by households
unless the general population reverts to an age of pre-consumerism,
avoiding processed foods and packaged goods generally. A way to
influence this volume is by manufacturing being more economical
with the materials used. This is, in effect, the third option,
ie stimulating eco-friendly design. This is an option supported
by Cleanaway, together with a fourth option mentioned below.
20. The second option, ie strengthening
producer responsibility obligations, also does little to reduce
waste production. It is a system for increasing recycling. This
is a further illustration of the confusion over the potential
to reduce waste volumes and the potential to increase the amount
of recycling. Recycling does not reduce the volume of waste produced.
A fourth simple option would be to discourage, through fiscal
means, certain items or types of materials that produce waste.
One waste often criticised is supermarket carrier bags, though
such use is condoned in this report as it is considered to be
a small proportion of the total waste stream. Dense, multi-material,
non-ecofriendly packaging should be discouraged. Returnable reusable
containers should be encouraged through deposit schemes.
21. Options for increasing recycling are
considered at page 70. It should not be automatically assumed
that recycling is the most environmentally beneficial option since,
for example, incineration may be the best use of resources overall.
Before pursuing recycling, the nature of the wastes being produced
should be critically examined to make them more appropriate for
recycling, eg of a lower mass or lower energy consumption in production
or easier to recycle. Materials to be recycled should be more
clearly labelled to encourage and enable the public to facilitate
recycling.
The Chancellor's Pre Budget Report 2002
22. The report emphasises that effective
waste management is an essential component of an environmentally
sustainable economy and that reliance should not be placed on
cheap landfill simply for the disposal of waste. It refers to
the Waste Strategy and that the pre-budget report sets out the
first step in the Government's response and how the tax system
will be used to help achieve the changes in behaviour that are
required.
23. Given that the status of the Strategy
Unit report is not explained and that it concentrates on municipal
solid waste disposal in England, it is difficult to see why the
Chancellor relies so heavily on it when the Government has its
own departments, ie DEFRA, DTI and The Treasury, to consider environmental
and taxation measures that can be taken.
24. It wrongly states that the Strategy
Unit Report sets out the case for reducing volumes of waste when
it merely urges reducing the rate of increase in waste production.
25. Given the emphasis on municipal waste,
it is not clear what the Government's intentions are with regard
to industrial waste by the imposition of landfill tax escalator
when it is suggested that this is a revenue neutral proposal to
business as a whole. Indeed, it implies that even at £35
per tonne, the tax on waste disposal charges would be a small
proportion of most business sectors' turnovers which suggests
it would not be sufficient to have a large impact on the matters
of disposal of industrial and commercial waste. We consider that
at this level, the tax will cause a considerable diversion and
provision must be made to deal with the diverted waste.
26. Regarding the landfill tax credit scheme,
it is unfortunate to note that the limitations on delivering more
sustainable waste management in the Landfill Tax Regulations have
not been recognised and instead the waste industry has been criticised.
27. It is accepted that the landfill tax
escalator will provide the incentive for local authorities to
try to recycle and recover increasing proportions of municipal
waste. However, to tax the local authorities in this way and then
return only a small proportion of the tax to public spending to
encourage sustainable waste management is difficult to comprehend.
Even if all of the tax collected were hypothecated, it would still
not provide funding adequate to achieve the aims of the Waste
Strategy.
28. If it is accepted that the reforms to
the LTCS are to take place, and that the Chancellor is serious
about ensuring that projects which have been allocated tax credit
funding will continue to benefit until such time as they are completed,
then an extension beyond 1 April 2003 deadline should be allowed
to provide additional credits, sufficient for the approved projects.
29. In recognising that there is a need
to minimise the volume of waste produced, the Chancellor states
that significant changes in household behaviour as well as action
by manufacturing and service sectors and by waste disposal authorities
will be required. National taxes on household waste have been
ruled out so it is not readily apparent how the Chancellor is
proposing to change such household behaviour.
30. Finally, the proposal to commission
a review of the environmental and health effects of all waste
management and disposal options is strongly commended and further
information on this proposal will be most welcome. It is essential
that the Government ensures the review uses modern data from state
of the art facilities (rather than from earlier plants in operation
prior to the implementation of current emission standards) and
positive messages about waste management systems are given prominence
and not allow them to be overwhelmed by negative propaganda.
September 2002
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