APPENDIX 12
Memorandum from English Nature
Submission by English Nature in response
to Strategy Unit report "Waste Not, Want Not" and the
Chancellor's Pre-Budget Report
English Nature consultation reference
number 02/03—240
1. BACKGROUND
TO ENGLISH
NATURE
1.1 English Nature is the statutory body
that champions the conservation and enhancement of the wildlife
and natural features of England. We do this by:
— Advising—Government, other
agencies, local authorities, interest groups, business, communities,
individuals
— Regulating—activities affecting
the special nature conservation sites in England
— Enabling—helping others to
manage land for nature conservation through grants, projects and
information
— Enthusing—advocating nature
conservation for all and biodiversity as a key test of sustainable
development
1.2 In fulfilling our statutory duties,
we
— Establish and manage National Nature
Reserves (NNRs);
— Notify and safeguard Sites of Special
Scientific Interest (SSSIs);
— Advocate to government departments
and others effective policies for nature conservation;
— Disseminate guidance and advice about
nature conservation;
— Promote research relevant to nature
conservation
1.3 Through the Joint Nature Conservation
Committee, English Nature works with sister organisations in Scotland,
Wales and Northern Ireland to advise Government on UK and international
nature conservation issues
2. EXECUTIVE
SUMMARY
2.1 We welcome the emphasis being placed
on waste issues in the Strategy Unit report and the Chancellor's
Pre-Budget Report, including the recent proposals for environmental
taxation.
2.2 We support in principle the proposals
made by the Strategy Unit in their report "Waste Not, Want
Not", and the response made to it in the Chancellor's Pre-Budget
Report.
2.3 In particular we support the proposals
to move the UK up the waste hierarchy through greater re-cycling,
composting and re-use of waste materials, combined with increased
emphasis on waste reduction.
2.4 In principle, recycling, composting
and re-use of waste materials should have positive environmental
and resource implications. However other factors have to be taken
into account when assessing their actual environmental impact.
2.5 While we believe the Landfill Tax, and
the recently announced accelerator, is appropriate, it is not
in itself a sufficiently comprehensive mechanism to encourage
a transformation of the waste hierarchy.
2.6 We recommend a long term approach which
develops further incentives for waste collectors, disposers and
ultimately the domestic sector to develop waste reduction alternatives.
2.7 There will be a need for strong Government
support and lead, particularly for setting in place the infrastructure
required and for emphasising the importance of waste as an environmental
and nature conservation issue.
2.8 English Nature therefore suggests that
further consideration is given to the following:
— The environmental impacts of the
various waste options, including impacts on nature
— Providing clear guidance about the
targets to be achieved, the impacts of not achieving them (including
financial), and greater support for methods for reaching the targets,
such as providing support for the recycling and recycled markets
— Ensuring that wider, non-municipal
waste issues are not forgotten
3. ENVIRONMENTAL
IMPACTS OF
WASTE MANAGEMENT
3.1 As a statutory body English Nature advises
central, regional and local government on the environmental implications
of delivering the Waste Strategy 2000. This includes, for example,
responding to consultations on regional and national waste strategies
and on individual planning applications for waste facilities.
3.2 Waste management is a key measure of
progress towards sustainable development, having potential impacts
on the wise use of resources, environmental quality and nature
conservation concerns. While, in principle, recycling, composting
and re-use of waste materials should have positive environmental
and resource implications, other factors have to be taken into
account when assessing their actual environmental impact.
3.3 The risks to wildlife and nature conservation
from waste disposal include
— the loss of wildlife habitat and
damage to geological features in providing sites for disposal
of waste
— impacts of transport and its infrastructure
— attraction of scavenging animals
and birds
— and water, soil and air pollution
impacts, both locally and more widely.
3.4 Due to the limited market for recycled
materials at present, glass, paper, plastics etc are often transported
hundreds of miles or even abroad for processing. As part of the
waste hierarchy the proximity principle is a key factor in reducing
some of these environmental effects, ensuring that waste is dealt
with as close to its source as is practical.
3.5 There is also major public concern about
the environmental impacts of various waste options, particularly
for incineration. While English Nature recognises that incineration
plants are generally well regulated, we suggest that further studies
are carried out on possible effects from all waste management
options. This will be important to reassure both environmental
organisations and the general public, and should thus assist with
the processing of individual planning applications. It will also
give greater clarity on the best environmental options available.
3.6 A positive outcome from increases in
composting will be to reduce the need for peat. Extraction of
peat for growing media is a major nature conservation issue in
the UK and internationally. Demand for peat has grown significantly
in the past decade. The joint English Nature and RSPB report "Peatering
Out—towards a sustainable UK growing media industry"
(available on English Nature's website www.english-nature.org.uk
under publications) demonstrates that viable alternatives are
now becoming available. Implementing the objectives for composting
provides a clear opportunity to reduce waste and also reduce damage
to an important and irreplaceable wildlife asset.
4. REACHING THE
TARGETS
4.1 Reaching the targets given in the Waste
Strategy 2000 and the actions required by the EU Landfill Directive
will involve all sectors of society and demand clearer direction
and financial support from Government. We welcome the emphasis
being placed on waste issues in the Strategy Unit report and the
Chancellor's Pre-Budget Report, including the recent proposals
for environmental taxation.
4.2 Previously, the approach to waste reduction
incentives has been driven entirely by the Landfill Directive
targets. While we believe the Landfill Tax, and the recently announced
accelerator, is appropriate, it is not in itself a sufficiently
comprehensive mechanism to encourage a transformation of the waste
hierarchy. We therefore welcome the report's suggestion to look
at wider options, such as incentives.
4.3 We recommend a long term approach which
develops further incentives for waste collectors, disposers and
ultimately the domestic sector to develop waste reduction alternatives.
This could be achieved through targeting of money raised through
the Landfill Tax back into developing waste management options
or through the development of local incentives.
4.4 Within all of this it is important that
environmental issues and concerns are taken into account and consideration
given to whether the options being looked at are sustainable in
the long term. It is also important that support is given to local
authorities and the Environment Agency to deal with the associated
likely increases in fly-tipping.
4.5 Transportation of waste over long distances
has negative environmental impacts. It can also make the cost
of options requiring such transportation prohibitive. It will
therefore be necessary that the markets for recyclable and recycled
materials are developed, to provide the infrastructure to enable
this waste management option to work effectively and with minimal
environmental impact.
5. NON-MUNICIPAL
WASTE ISSUES
5.1 The Strategy Unit report looks only
at municipal waste. We acknowledge that this was the remit given
for the report. In addition, current changes in legislation, such
as under the Landfill Directive and the Waste Electrical and Electronic
Equipment Directive, will have implications for dealing with industrial
and certain other wastes. In English Nature's opinion it is important,
however, to ensure that all aspects of waste management are kept
under review.
5.2 We have particular concerns about aspects
of the waste regulations which exempt certain activities, for
example the disposal of materials such as paper pulp or sewage
sludge to land. These activities can have significant negative
impacts on the environment, including direct impacts on Sites
of Special Scientific Interest (SSSIs) and are not adequately
regulated. The matter of paper pulp in particular has been a matter
for discussion between English Nature, the Environment Agency
and Defra, and we hope that this issue will be resolved during
the coming year. However, this is an example where an agricultural
use provides a loophole in the current legislation. We would therefore
urge that waste management as a whole is considered and not lost
within this enquiry into the municipal waste stream. Municipal
waste accounts for only around 8% of total waste produced in England
each year.
5.3 English Nature's position statement
on waste management is attached and can also be found on our web-site
www.english-nature.org.uk.
January 2003
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