Memorandum submitted by Waste Watch
I am pleased to submit Waste Watch's response
to the above inquiry, along with my apologies for the delay in
its submission. As you can appreciate, the delay has been due
to a mixture of workload pressure from Government activity following
the Strategy Unit report publication, and intermittent electricity
supply at the office. I am very grateful for the extension you
agreed to allow us to submit our response, and apologise for providing
it after the agreed deadline.
Also attached is our response to the April 2002
House of Lords inquiry into the costs to industry of implementing
the Packaging and Packaging Waste Directive. Mention is made of
that response in this response. I am afraid that I cannot attach
an electronic version of a Waste Watch report which also is mentioned
in this response. However, a hard copy will be forwarded to you
as soon as possible.
We are pleased to have been invited to submit
oral evidence to the Committee, to which we look forward. In the
meantime, please do not hesitate to contact me if you need any
further information.
INTRODUCTION
1. Waste Watch is a leading UK NGO promoting
sustainable resource use with a focus on the "3Rs"—waste
reduction, reuse and recycling. Waste Watch has over 400 members
from a wide cross-section of local authorities, the community
and social economy sector, business, other agencies and individuals.
Waste Watch is supported nationally by funding from the Department
of the Environment, Food and Rural Affairs' Environmental Action
Fund, together with project funding from a number of waste management
companies through the Landfill Tax Credits Scheme, a range of
corporate supporters and our membership.
2. Waste Watch's expertise historically
lies in communication, education and information-provision relating
to waste and resource issues. A restructuring of activities has
resulted in the embryonic development of a Policy, Research and
Information team. The team represents a stronger link between
information collection, provision, research and policy activities.
It is Waste Watch's intention, through the team, to more effectively
and efficiently provide analysis to advance debate on issues relating
to waste management and sustainable resource use.
BACKGROUND
3. The Committee's inquiry focus is on the
future of waste management strategy, and particularly what steps
need to be taken to move further up the waste hierarchy as set
out in the Waste Framework Directive. Although the Committee's
press release states that it is looking for innovative solutions
to waste management problems, it also states that the Committee
will be looking at best practice in recycling, energy recovery
during incineration, producer responsibility, and waste minimisation.
It could be argued that there are some potential activities in
these particular areas that would provide innovative solutions
to the current state of waste strategy in the UK, however this
is a sad indictment of waste strategy in the UK and not a reflection
of the innovative solutions that could be incorporated into future
waste strategy. Therefore, it is our intention to provide the
Committee with views on activities beyond these areas.
4. It is Waste Watch's view that the Government's
waste management strategy needs to develop as part of a wider
resource productivity strategy, since waste is one element of
the resource production and consumption chain. Continuing to look
at waste management in isolation of resource use helps to ensure
that the disconnect between resource use and waste disposal continues.
5. In order to develop a waste management
strategy with a focus higher up the waste hierarchy, waste management
needs to be seen as the final solution to resource use in our
economy. This still does not appear to be the case in current
Government activity and communication. Even the recent Strategy
Unit waste study report[1]
makes very weak links between resource use and waste management.
It also continues the Government focus on household waste, implying
that the main driver for Government waste policy is meeting the
Landfill Directive targets, despite this source of waste representing
approximately one-quarter of that produced by the UK.
6. A shift of focus further up the waste
hierarchy implies the valuing of resources earlier in the production-use-disposal
chain. For this to happen, there needs to be an attitudinal shift
by Government of viewing waste as a "resource in the wrong
place".
FROM WASTE
TO RESOURCES
7. The UK Waste strategy to date has slowly
pushed activities further up the waste hierarchy as a means of
meeting the Landfill Directive targets. This compliance approach
is played out in other areas of waste activity, such as the implementation
of the Packaging Directive and the recycling of refrigerators.
Our response aims to identify other potential Government activities
that would serve to pull, as well as push, activities further
up the waste hierarchy.
8. The then Performance and Innovation Unit's
report on resource productivity[2]
identified that improving how resources were used in the economy
was a "key to change" in achieving sustainable development.
Waste management, as a means of retaining value from materials
considered a "waste", is an important element of resource
productivity. Indeed, at the top of the waste hierarchy is waste
prevention and minimisation—activities which link directly
to resource productivity.
9. Similarly, a recent report[3]
by the DTI's Innovation and Growth Team (IGT) has identified that
"a strong domestic market that demands new process technologies
and methods of waste minimisation" does not exist in the
UK. It also acknowledged that action was required to develop fiscal
incentives and other measures to help meet regulatory targets.
Although the IGT stated that it looked forward to the Strategy
Unit report on the waste sector as a source of
GOVERNMENT LEADERSHIP
10. It is widely recognised that Government
leadership has been distinctly lacking in the waste strategy area
for some time. This was highlighted at the Waste Summit held in
November 2001, which Waste Watch attended, and where representatives
of local authorities, the waste industry, regulatory bodies and
environmental NGOs called for Government leadership. It is increasingly
palpable that the Government's view on strategy around resource
use and, particularly, waste strategy will continue to remain
one of compliance with EU Directives. Highlights from the resource
productivity report mentioned in paragraph 8 include the following:
"Business and households should play lead roles in making
more productive use of natural resources. However, there is also
an important role for Government in setting the right incentives,
providing an example and overcoming barriers—such as information
deficiencies, limited access to finance, skills shortfalls and
other factors." It is unrealistic for the Government to make
such statements, in particular suggesting that businesses and
households should lead in resource productivity, particularly
when the report goes on to state that the price signals are not
there to encourage better use of resources. This is where Government
leadership is needed, and the examples given in the quote from
the report do not address this at all.
11. Relating more directly to waste strategy,
the lack of Government leadership continues to be played out here
as well. We will go into greater detail about what mechanisms
the Government could use to support better resource use and to
develop a more innovative waste strategy.
12. In the light of the continuing prevarication
on resource and waste strategies, and to help harmonise Government
Department approaches to these issues, we recommend the setting
up of a strategic resource authority. This would operate under
the directions and guidance of DEFRA or ODPM, and would set out
the strategic priorities for resource use and waste management.
Such a body would help to eliminate the current fragmented approach
to waste management strategy, which has been highlighted in the
Strategy Unit's waste report mentioned in paragraph 5—that
policy is divided between DEFRA and DTI, and funding between HMT,
ODPM and DEFRA. It would also help to focus much-needed attention
on what are still decoupled issues—resource use and waste
strategy.
13. Notwithstanding the creation of a strategic
resource authority, the Government needs to show leadership and
a change in approach to help guide the cultural change which needs
to occur in the UK towards waste management. The general compliance
approach taken by the Government has led to this approach permeating
many other sectors with responsibility and influence in the delivery
of waste strategy objectives. The remainder of this response will
focus on some potential mechanisms for encouraging a "beyond-compliance"
approach to resource use and waste strategy.
GOVERNMENT MECHANISMS
14. Although we stated early in this response
that we would not limit our considerations to those activities
highlighted in the Committee's press release in relation to suggesting
innovative solutions to the current waste strategy, we will consider
this briefly.
BEST PRACTICE
IN RECYCLING
15. The Strategy Unit report suggested that
WRAP implement a kerbside taskforce programme, to help identify
and replicate good practice in recycling. This is a welcome development
in the implementation of the current UK waste strategy, particularly
as we are very short of the national recycling targets that exist.
The current national rate is 12% and the Government's recycling/composting
targets are 25% by 2005, 30% by 2010 and 33% by 2015. What belies
this national rate is a range of individual local authority recycling
rates ranging from over 50% to under 2%. Waste Watch hopes that
a kerbside taskforce would serve to convince local authorities
that kerbside services are required to achieve higher rates of
recycling, and that multi-material schemes would be encouraged
more widely. At present, local authorities are developing recycling
schemes that will help them meet tonnage-based targets, therefore
focusing on materials such as paper and card and glass. This utilitarian
approach to recycling is not shared by the public, who are increasingly
contacting Waste Watch's national Wasteline advice service to
question why other materials are not recycled by their local authorities.
It is Waste Watch's view that a less Landfill Directive targets-based
approach to recycling can be developed by WRAP.
ENERGY RECOVERY
DURING INCINERATION
16. The Government has continued to avoid
making clear statements about its views on the development of
more incinerators in place of landfills as traditional disposal
method options. With the landfill tax remaining at too low a rate
to have encouraged any substantial waste prevention or a swifter
shift to other methods of disposal, the only other alternative
that has, until as recently as 2002, received attention has been
incineration. This landfill-or-incineration approach has been
allowed to develop, as the Government has not sought to encourage
the exploration of other types of disposal. Waste Watch welcomes
the recognition of the need for other technologies to be considered,
as was recommended in the Strategy Unit report.
17. As a means of encouraging activities
further up the waste hierarchy, Waste Watch recommends that the
Government begin to develop a fiscal system that redresses the
balance in favour of those activities higher up the hierarchy.
It can do this by speeding up the increase in the Landfill Tax
level beyond that which was announced by the Chancellor for the
Exchequer in the November 2002 Pre-Budget Report. An increase
of the annual escalator from £1 to £3, although a step
in the right direction, is too small a step to achieve the results
needed. We suggest a more speedy and marked increase to the £35
per tonne level identified by the Government.
18. However, the focus on a particular method
of waste disposal risks encouraging, and even worse, subsidising,
other methods. In particular, without clear objectives on the
introduction of new technologies, there is the threat that the
alternative to receive the most attention will be incineration.
If one objective of a future waste strategy is to reduce waste
arisings levels, then waste disposal of any sort needs to be discouraged.
Therefore, we recommend the broadening of the Landfill Tax to
a Waste Disposal Tax, thereby taxing the act of disposing of waste
not just of landfilling it.
PRODUCER RESPONSIBILITY
19. Producer responsibility has developed
in the UK as a means of implementing the Packaging and Packaging
Waste Directive. Waste Watch, in response to the 2002 House of
Lords inquiry into the costs to industry of the Directive, provided
a brief analysis of implementation of the Directive by a number
of member states. It is Waste Watch's view that the flaws in the
UK's implementation centre around: spreading of responsibility
among too many players in the packaging chain, having a number
of compliance companies rather than one national one, not incorporating
the costs of collection of the materials into the cost of a packaging
recovery note (PRN), and the regulations being the only mechanism
for meeting the Directive targets. We attach our response to that
inquiry, as added detail under this point.
20. It is worth noting, in particular relation
to the Packaging Directive, that the UK is one of two member states
to have fully implemented the Directive. Waste Watch is pleased
to commend the Government on this point. However, this accolade
is not shared by the surpassing, or even the meeting, of recycling
targets set within the Directives. In 2001, the UK was one of
two member states to not achieve the recycling levels. It is Waste
Watch's view that this result is due to the compliance approach
adopted by the UK Government, rather than simply because one compliance
scheme was not able to meet the levels of recycling it needed
to. The PRN system is designed to achieve the recycling targets
set at the EU level, at the cheapest cost possible. What this
has helped to create is a market for industry-sourced materials
recycling, increased plastic packaging in shops (since recycling
levels are tonnage-based), a frustrated public who cannot recycle
their plastic packaging even though this type of packaging is
increasingly being used in shops, and local authorities who will
not recycle plastic because it is considered too expensive (since
recycling levels are tonnage-based). Hence, a series of negative
feedback loops continue to hamper the system.
21. Further producer responsibility legislation
is impending as a means of implementing the End-of-Life-Vehicles
Directive and the Waste Electrical and Electronic Equipment Directive.
However, the negotiation process on these to Directives has shown
that the Government has not taken into consideration design flaws
in the implementation of the Packaging Directive. Waste Watch
strongly believes that further analysis of producer responsibility,
as has been implemented in the UK, needs to be undertaken as soon
as possible, to avoid further negative feedback loops being designed
into systems relating to more substantial and hazardous types
of "waste" (ie vehicles and electronics equipment).
22. The Strategy Unit report reiterated
the Government's intention to use voluntary agreements in encouraging
industry sectors to improve their waste management practices.
Although voluntary agreements can be used as a means of developing
or enhancing the concept of producer responsibility in industry,
used on their own they are not very effective. It is Waste Watch's
view that mandatory producer responsibility is needed more immediately
to ensure that relevant companies meet the regulation objectives.
Voluntary measures are less likely to succeed in a culture where
the compliance approach has dominated. This is not to say that
voluntary measures can never be used, rather that their use needs
to be assessed in more depth before these measures are considered
the more appropriate way to meet Government objectives. In the
meantime, Waste Watch suggests that mandatory producer responsibility
mechanisms be used in place of voluntary ones.
WASTE MINIMISATION
23. There has been much recent attention
to the need to minimise municipal waste, particularly as the general
view is that this is increasing at a rate of 3% per year. A barrier
to implementing waste minimisation activities targeted at householders
is that it is difficult to measure minimisation. Waste Watch has
been involved in a number of projects and programmes that have
provided targeted households with information on waste minimisation,
and recorded some substantial reductions in waste. One family
recorded a 90% reduction in the waste they set out for collection,
although this was due to a combination of recycling and composting,
as well as "smart shopping" (altering their purchasing
decisions).
24. Waste minimisation in households, apart
from through recycling and composting, can be encouraged through
messages around reuse (either finding new uses for some products
or materials, or giving them to charity shops, etc.), repair,
refusing (for example, shopping bags) and smart shopping. However,
returning to the situation described in paragraph 20, waste minimisation
is not encouraged when there are mostly plastic-packaged products
on shop shelves, and plastic recycling is not provided by local
authorities. The Government needs to consider how to undo the
negative feedback loops in the system, and the gaps that prevent
the waste minimisation chain from being formed.
25. For industry, waste minimisation, apart
from through weak measures such as the low-level Landfill Tax
or through sector-specific legislation such as Integrated Pollution
Prevention and Control, features generally as a voluntary measure.
The Strategy Unit report recommended that Envirowise, the Government's
environmental best practice programme, be expanded so that it
covers more companies. It is Waste Watch's view that this focus
on industry is to be encouraged, and needs to be increased, since
it is here that solutions "further up the resource use pipeline"
can be implemented. If industry is using fewer resources to manufacture
its products, then there are theoretically fewer resources for
consumers to dispose of (unless they are buying more products).
Also, and very importantly, it is a focus on industry activities
that will encourage innovation in product design, packaging design,
resource use, etc.
FURTHER INNOVATIVE
SOLUTIONS
26. The following are a series of solutions
that we suggest the Government needs to consider in developing
a strategy that shifts the focus further up the waste hierarchy,
some of which feature in the Strategy Unit report:
(i) Zero-rated VAT, and other cost incentives,
on recycled materials and on their recyclability.
(ii) Minimum recycled content legislation
requiring the use of recycled materials in some uses. For example,
recyclates in road construction.
(iii) Leading by example—central and
local Government establishing more robust requirements to purchase
recycled. Central Government Departments have the Framework for
Sustainable Development in Government (building upon the Greening
Government Initiative) which features an as-yet incomplete section
on green procurement. There is no equivalent framework for Local
Authorities, although Waste Watch has been undertaking some preliminary
research into such a mechanism. (A recent Waste Watch report[4]
provides the first analysis of public sector resource use.)
(iv) Encouraging the inclusion of non-packaging
or non-Landfill Directive-specific materials in kerbside recycling.
For example, some local authorities recycle batteries, hazardous
household waste, motor oil, fluorescent tubes, textiles, etc.
(v) The increased funding of Rethink Rubbish,
the national public awareness campaign. Although this does not
require a multi-million pound television campaign, there is great
need for messages that counter advertising that encourages the
public to consume.
(vi) The incorporation of the Zero Waste
objective as an underpinning aim of Government resource use and
waste management strategy. The UK can learn from regional and
national governments in countries such as New Zealand, Canada
and the United States, in developing policy mechanisms within
the main objective of reducing waste to as near to zero as possible.
Although currently broadly aspirational, the intended aim is to
maximise resource productivity and to minimise waste production.
Waste Watch
17 January 2003
1 "Waste not Want not: A strategy for tackling
the waste problem in England", Strategy Unit, December 2002. Back
2
"Resource productivity: making more with less", Performance
and Innovation Unit, November 2001. Back
3
"enabling business in resources management", DTI, November
2002. Back
4
"Adding value to the public sector: an analysis of public
sector resource use"; Waste Watch, November 2002. Back
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