Memorandum submitted by Cambridge and
District Chamber of Commerce and Industry
EXECUTIVE SUMMARY
The Hierarchy must be flexible to take account
of local circumstances and efforts must be made to promote an
active transparent flow of information to businesses and households
on the waste problem.
COMMENT ON
WASTE FRAMEWORK
DIRECTIVE HIERARCHY
The Hierarchy is currently accepted in descending
order of desirability as:
Waste prevention/minimisation
Whilst this is acceptable as an overall blue
print, there must be transparent and open provision for consideration
of the hierarchy in each instance. The only rankings that are
set are the first and the last. All the other rankings can and
should be able to move up or down depending on the circumstances.
There must not be a blind acceptance that under all circumstances
recycling is "better" than Energy from Waste. It must
be acknowledged that in certain circumstances EfW can be less
of an environmental burden than recycling. The scientific evidence
must not be ignored in favour of emotive arguments put forward
by green groups that have a policy objection to EfW. The Hierarchy
must contain a requirement that involves the reasoned consideration
of scientific information concerning EfW as an alternative, balanced
against the actual (not perceived) environmental burden of recycling.
This must be transparent and open to ensure that all levels of
the Hierarchy are given consideration and not swept under the
carpet or passed over by hidden agendas.
A topical example of this is the move within
the newspaper industry to water based flexographic printing. This
process is less environmentally damaging than the current letterpress
or lithographic processes but is being held back by protestations
that the resulting newsprint cannot be recycled. Whilst this may
be true for the current recycling routes (the de-inking process
will not work), this may be developed in time. However, there
is good evidence to show that burning of used newsprint (however
printed) is an option-each tonne of used newsprint can generate
the same energy as a tonne of good quality coal and with the advantage
that it is from renewable resources. In this case Energy from
waste should move up the Hierarchy above recycling.
Another example of repositioning in the hierarchy
is the use or otherwise of refillable beverage containers such
as beer bottles. It is generally promoted by some green groups
that refilling beer bottles is less environmentally damaging than
recycling of one trip bottles. This is a classic example of individual
circumstances tipping the balance in favour one way or another.
In Germany most towns have their own brewery
and there are only two sizes of bottle and only one shape for
each of these. Breweries sell mainly locally and "brand"
their product by the cap, the label and the crate. Sales at supermarkets
are individually or by the crate and are returned as such (retail
outlets have to provide for only one/two spaces in the warehouse
for returned bottles). Breweries collect from local supermarkets,
bars etc and do not have to transport bottles any significant
distance. The bottles are cleaned, filled and new labels/caps
applied. If a bottle ends up in another town at a different brewery,
the bottle is not unacceptable because once the label has been
removed in the cleaning process; it is the same size and shape
as "local" bottles. Thus in Germany refilling beer bottles
is both economically and environmentally beneficial over recycling
of one trip bottles. In this case the Hierarchy is appropriate.
However, in the UK the situation is quite different.
Breweries are much larger and very much less in number, thus any
return of empty bottles for refilling would involve longer transport
journey with the accompanying increased use of fossil fuels: there
are several sizes of beer bottle and multiple variations in style
of bottle within each size as "branding" is by shape
(and colour of glass) as well as label and cap, thus supermarkets
and pubs would have to provide multiple locations for sortation
of returned bottles, added to this is the power of the UK supermarkets
(compared with Germany) who refuse to consider return and sortation.
The considerations of a much heavier bottle (to be able to stand
up to return and multiple washing and filling) and the capital
cost of washing equipment and the considerable energy requirements
and effluent concerned with washing, tip the balance very much
both environmentally and economically in favour of recycling of
beer bottles in the UK. Thus in this case recycling should move
up the Hierarchy above re-use.
HOW TO
GET ACTION
Whilst the principal objective must be to minimise
waste, there is little hope of achieving this without massive
publicity regarding the other benefits to waste minimisation.
Companies are in business to make money and most environmental
advances are made to comply with legislation (and there is no
plan to make waste minimisation a legislative requirement?) or
in parallel as a result of cost saving measures. It must be made
clear to business what is in it for them-an indication of the
financial benefits to companies in minimising waste. It is generally
accepted that savings of 2-4% of turnover can be achieved.
Whilst the Envirowise and Action Energy programmes
are helpful for spreading the word of waste minimisation, many
of the publications are extremely complex. More attention should
also be paid to informing businesses what help is available for
them.
We should not neglect informing the next generation
of citizens, as a programme of education for schools on waste
minimisation will pay dividends for the next generations.
SMALL BUSINESSES
The comments above concerning action are especially
relevant to SMEs. Larger companies have resources and time that
smaller companies do not have and they will need help and guidance.
As the majority of businesses are SMEs, specific targeted help
is necessary, such as further assistance for organisations such
as Chambers of Commerce and Business Link to reach more small
businesses
LOCAL AUTHORITIES
LAs are pivotal to any waste management programme,
but there appears to be little incentive from central government
to encourage local authorities to work with businesses in the
areas of waste management or waste minimisation. Indeed the recent
Regional Waste Management Strategy documents across the country
were produced by Regional Waste Technical Advisory Bodies with
membership set up under the guidelines laid down by central government
that does not make the membership structure balanced or correct.
It would have been beneficial if such an important document had
been produced with the formal input of the waste producers.
Household waste comprises a significant proportion
of the waste stream and much more could be done to inform householders
of the problems of the growing waste mountain. Many local authority
schemes whilst well meaning, concentrate on the results not the
reasons. Householders are simply not aware of the consequences
of the throw away society that has built up over the last few
years and efforts should be made to inform intelligent householders
of the full repercussions so that perhaps less frequent replacement
becomes the fashion and more use is made of repairing.
INNOVATIVE SOLUTIONS
Whilst there will be some very good ideas coming
forward, we should not dismiss current thoughts. Many solutions
already exist but are not exploited to the full. For example,
despite current publicity most SMEs are unaware of the assistance
that is available on Waste Minimisation from Envirowise
RECOMMENDATIONS FOR
GOVERNMENT
— Tackle areas of waste that have the
largest environmental impact.
— Allow flexibility in the Waste Hierarchy.
— Provide the means for bodies such
as Envirowise/Action Energy to publicise their services more widely
and simplify their information.
— Actively publicise the cost saving
benefits of waste minimisation.
— Encourage local authorities to improve
dialogue with businesses and householders.
— Promote repair rather than replacement.
— Provide the means for organisations
such as Chambers of Commerce and Business Link to reach more small
businesses
Cambridge and District Chamber of Commerce and Industry.
28 November 2002
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