APPENDIX 15
Memorandum from Friends of the Earth
1. Friends of the Earth is pleased to respond
to the Environmental Audit Committee's call for evidence on the
topic of waste management.
2. Friends of the Earth in England, Wales
and Northern Ireland has campaigned on waste issues for over 30
years. We have over 200 local voluntary groups, the majority of
which campaign for better recycling in their areas. We are also
part of Friends of the Earth International, which has 70 member
groups across the World, the majority of which are in developing
countries. Many of these groups are involved in campaigns to prevent
the serious environmental and social impacts caused by resource
extraction. Our work on waste is informed by all these different
perspectives.
3. Our experience is that the UK Government
is far too timed in driving forwards better resource use and waste
management. It also fails to adequately consider the global impacts
of our throw-away society. Instead, it grudgingly responds to
European directives. We elaborate on these points during our evidence.
Our evidence is restricted to the municipal waste stream.
WASTE STRATEGY
2000
4. Friends of the Earth applauded Waste
Strategy 2000 for setting statutory waste recycling targets on
local authorities for the first time. Our experience of voluntary
targets is that they are generally not met. For example the voluntary
target set in the early 1990s to recycle 25% of waste by 2000
was missed by a mile. However, we also raised concerns that the
failure to set more ambitious longer-term recycling targets would
result in many local authorities aiming to recycle to the minimum
and instead aim to build large-scale incinerators to deal with
the majority of waste. This has indeed been the case, with the
result that numerous campaign groups have sprung-up around the
country. These groups have not only been motivated by the prospect
of having a large incinerator built on their door-step but have
also been motivated by evidence on how little the UK recycles
compared to our European neighbours.
5. Friends of the Earth surveyed these groups,
together with groups living next door to landfill sites or with
quality recycling schemes, to elicit their views on what the Government
should do on waste. They were strongly in favour of more ambition
in recycling and less dependence on disposal [1].
6. Waste Strategy 2000 was largely driven
by the Landfill Directive but this directive is only one of a
number of directives which, rightly or wrongly, will influence
how we deal with waste in the UK. Unfortunately the strategy failed
to anticipate future directives, even though these were already
in the pipe-line. Because of this, and the Government's failure
to drive forwards its own agenda on improving resource use and
reducing waste, the strategy needs to be significantly rewritten
to ensure that the meets the requirements of future directives
or revised directives. Future challenges include:
— The Biowaste Directive—the
European Commission has pledged to table by 2004 a proposal for
a directive to require source-separated collection and composting
or anaerobic digestion of household biodegradable waste. It has
recently published a report suggesting that is a better environmental
option for this waste than incineration with energy recovery or
landfill [2].
— The revision of the targets in the
Packaging Directive will result in the need to recycle around
55-65% of packaging by 2006/8 [3]. This will be more of a challenge
for the UK, which set the lowest recycling targets allowed in
the original directive, than for other countries which set higher
recycling targets.
7. These directives would have been less
of a problem to the UK had local authorities been instructed to
ensure that any long-term arrangements they had for dealing with
their waste were flexible enough to enable compliance with future
directives. However, Waste Strategy 2000 failed to do this, with
the result that a number of local authorities have entered into
25-30 year contracts with incineration companies which, as far
as we can ascertain given the secrecy surrounding these contracts,
will require the vast bulk of waste to go to incineration rather
than composting or recycling. The greater the number of local
authorities sign these contracts the greater the difficult for
the UK in meeting its future legal obligations.
8. The disappointing aspect of this situation
is that had the UK adopting the approach of the more forward thinking
countries in Europe it would not find these directives difficult
to implement. For example, the study for the Biowaste Directive
points out that mandating source separation at EU level would
hardly affect countries such as Austria, Germany, the Netherlands
and Denmark, because they already have similar national requirements
in place because it is environmentally the right thing to do.
If the UK were amongst the leaders in Europe on environmental
matters then these directives would hardly impact upon us.
THE SCOPE
OF NATIONAL
WASTE TARGETS
9. As mentioned previously, Friends of the
Earth believes that the recycling targets in the UK are too low
to meet future legal obligations. However, we also believe that
targets are far too low to drive the UK towards sustainable development.
To help inform the Cabinet Office Strategy Unit review of Waste
Strategy 2000, Friends of the Earth helped fund research into
recycling and the treatment of residual waste. The research has
just been published and is entitled Maximising Recycling Rates,
Tackling Residuals [4]. This report uses evidence from recycling
schemes and disposal options in the UK and Europe to ascertain
what levels of recycling are feasible in the near future and what
is the least worst option for dealing with the residuals.
10. In considering recycling rates it took
into account evidence that social deprivation had a significant
impact on participation in recycling. The research concluded that
England could recycle and compost 62% of waste within the next
ten years. It also suggested that this rate should not be viewed
as a maximum because higher rates could be achieved through greater
participation in recycling schemes and through increasing the
recyclability of the waste stream.
11. Of course a fair question to ask is
whether a recycling rate of 60% plus is environmentally desirable
or not. Friends of the Earth's view is that it is environmentally
right to increase recycling to these levels and beyond for the
following reasons. The UK consumes far more than its fair share
of resources, the gathering of which can have significant environment
and social impacts in countries where they are extracted [5].
The World Summit on Sustainable Development clearly showed the
desperate need to help poorer countries develop, which will invariable
mean increasing their resource use. If the UK is to consume no
more than its fair share of resources, and if global limits to
resource extraction and pollution absorption are not to be breached,
then work by Friends of the Earth suggests that the UK needs to
cut resource use by 80-90% [6].
12. Unfortunately, local authorities and
regional bodies have been guided in their decision making by the
Environment Agency's life cycle analysis tool Wisard. Wisard fails
to account for the environmental impact of resource extraction
or the global equity dimension of resource use. Instead it arrives
at "optimum recycling levels" based on some very dubious
assumptions which tend to favour incineration rather than recycling
(such as energy recovery from incinerators replacing coal fired
energy rather than gas fired energy).
13. With regards disposal of residual waste—which
in Friends of the Earth's view should be an ever decreasing quantity
as society aims to zero waste—the waste strategy does not
prescribe which disposal options may be the least worst option,
although it does suggest that new technologies are developing
which local authorities should take into consideration, such as
gasification. This lack of Government guidance has resulted in
many local authorities to be again by the Environment Agency's
Wisard life cycle analysis tool. Yet again the inadequacies of
this tool has steered local authorities down the wrong path. Wisard
only considers landfill and incineration as options for disposal,
it does not consider other options such as gasification, pyrolysis,
mechanical and biological treatment, cement kilns, power plants
or treated residual waste going to landfill.
14. The study leading to the report Maximising
Recycling Rates, Tackling Residuals did investigated these options
and found that incineration and untreated residual waste to landfill
are the worst of all options studied. Friends of the Earth's analysis
of the data in Maximising Recycling Rates, Tackling Residuals
suggests that the least worst option for residual waste is small-scale
mechanical biological treatment to remove recyclable metals, plastics
and paper, followed by composting or anaerobic digestion of the
remaining waste with any unusable residuals going to landfill.
15. Friends of the Earth would welcome a
parliamentary inquiry into the cost, production and use of Wisard.
ECONOMIC AND
REGULATORY INSTRUMENTS
16. Doing the best thing environmentally
with waste is currently the most expensive option. Friends of
the Earth has some sympathy with local authorities who want to
substantially increase recycling but do not have the finances
to do so. Previous work for Friends of the Earth and others on
the economics of waste management, entitled Beyond the Bin, together
with subsequent work, suggests that the average net cost of provided
a doorstep recycling and composting service is on average £17
per household, or £375 million a year in England and Wales
[7, 8]. Although there is little transparency provided on funds
provided to local authorities from Government is does appear that
around a further £200 million per year is needed.
17. Friends of the Earth suggests that the
Government should use a range of economic incentives to reduce
resource use and waste and encourage waste minimisation. The landfill
tax should become a waste disposal tax (to cover incineration
and other disposal methods) and should be structured to reflect
the waste hierarchy, significantly increasing the cost of waste
disposal. The proceeds of this tax should be hypothecated to fund
local authority recycling and composting. The Government should
also introduce resource taxes (for example on virgin paper or
aluminum) to reflect the environmental damage caused by their
extraction. It should introduce taxes to encourage reuse (eg deposits
on beverage containers) and waste minimisation (eg plastic bag
tax). Where funds do not need to be hypothecated they should be
used to reduce taxes on employment.
18. With regards financial incentives for
households to participate in doorstep recycling schemes, such
as variable charging, Friends of the Earth suggests that these
should only be introduced once a quality local authority wide
doorstep separated recycling and composting scheme has been in
place for at least two years and supportive educational initiatives
undertaken. The introduction of any financial incentives should
be designed so that they do not have an unfair or disproportionate
impact on any particular sectors in society (eg the socially disadvantaged,
the elderly or those with large families).
CONCLUSIONS
19. The UK Government should be far less
timed in addressing the issue of resource use and waste. It needs
to devise a strategy that sets longer term ambitions for reducing
waste and resource use, put these in the context of reducing the
UK's global footprint, and put in place the economic and regulatory
mechanisms to deliver the strategy. It should aim to be a leading
force in Europe for delivering improvements in resource use and
reductions in waste. It could start this process by developing
and adopting a policy and programme to move towards zero waste.
20. The Government should also instruct
the Environment Agency to withdraw its life cycle analysis tool
Wisard until it significant failings can be addressed.
21. Local authorities should be prevented
from entering into contracts which reduce the chances of the UK
meeting its aspirations or meeting targets within existing or
expected European laws. They should be encouraged to set ambitious
targets for recycling and composting, ideally aspiring to zero
waste. Friends of the Earth believes that by 2006 all households
should be provided with a weekly doorstep collection for separated
food waste. They should also be offered a subsidised or free composting
bin, or if they prefer a regular and free separate collection
for garden waste by the same date. All households should also
be provided with a quality doorstep separated recycling service
for dry recyclables (paper, cans, plastic, glass, etc) by 2010
at the latest The Government should fund them accordingly.
22. The Government should also support the
Doorstep Recycling Bill.
End Notes
1. Friends of the Earth, 2002, Communities
speak out on waste, available at: http://www.foe.co.uk/resource/reports/communities—speak—waste.pdf
2. See the Commission working document on
this Directive at: http://europa.eu.int/comm/environment/waste/biodegradable2—en.pdf
The Commission has also recently published a report they commissioned
on this issue. The report is available at: http://europa.eu.int/comm/environment/waste/compost/economicanalysis—finalreport.pdf
3. Discussions on precise targets and dates
are still on-going, see: http://www.letsrecycle.com/news/news.jsp?story=1518
4. A summary 10 page briefing on Friends
of the Earth's conclusions from the research can be found here:
http://www.foe.co.uk/campaigns/waste/resource/experts.html The
150 page report plus shorter 40 page summary can be found here:
http://www.crn.org.uk/publications/research/main.html
5. For example, see evidence of damage from
logging of old growth forest in the report Paper Tigers, Hidden
Dragons at: http://www.foe.co.uk/resource/reports/paper—tiger—hidden—dragons.pdf
6. Friends of the Earth, 1997, Tomorrow's
World: Britain's share in a sustainable future, Earthscan.
7. Ecotec Reearch and consulting for Friends
of the Earth, Waste Watch and UK Waste, 2000, Beyond the bin:
the economics of waste management, available here: http://www.foe.co.uk/resource/reports/economics—waste—options.pdf
8. Friends of the Earth, 2002, Recycling:
can local authorities afford it? Available here: http://www.foe.co.uk/resource/factsheets/recycling—local—authority.pdf
October 2002
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