Memorandum submitted by the Chartered
Institution of Wastes Management
1. INTRODUCTION
1.1 The Chartered Institution of Wastes
Management (CIWM) is pleased to provide the following comments
to the Select Committee in their enquiry into the future of waste
management
1.2 CIWM is the pre-eminent body for waste
managers in the UK, with a membership base of over 5,000 individuals
from all areas of the waste industry including organisations that
produce or manage waste, educational and research establishments,
environmental consultancies, Local Authorities, waste equipment
manufacturers/suppliers, waste collection or disposal companies,
and waste regulators. CIWM sets professional standards for individuals
working in the waste management industry and its objectives are
to: Advance the scientific, technical and practical aspects of
wastes management for the safeguarding of the environment; Promote
education, training, research and the dissemination of knowledge
in all matters of wastes management; Strive to achieve and maintain
the highest standards of practice, competence and conduct by all
its members. CIWM provides professional impartial representation
on all waste matters.
1.3 CIWM has a unique position in the industry
having an extensive membership and representation across all sectors,
which enables CIWM to draw on that expertise. In our response
to this consultation exercise, as a result of time and word constraints,
we have chosen to focus on a number of more pertinent issues.
We would however be happy to provide further information on request
and would be prepared to provide verbal evidence.
2. WASTE PREVENTION
AND MINIMISATION
2.1 CIWM believes that waste minimisation
is ultimately concerned with resource availability and consumption.
However achieving this in practice poses a challenge to all stakeholders.
Commercial and industrial waste minimisation generally occurs
as a result of good in-house practices and is driven by market
forces (the bigger the company the greater the economies of scale
and the easier it is to undertake these practices). Many good
examples exist of specific industry sectors and organisations
implementing waste minimisation procedures, which have provided
an economic and environmental gain. However, there is still considerable
scope for improvement. More effective and wider dissemination
of examples of good practice and guidelines for achieving practical
waste minimisation should be a priority, and the work of Envirowise
or similar organisations should be supported further.
2.2 The use of benchmarking for waste minimisation
in the commercial and industrial waste sector should be promoted.
This could be through the further development of self-regulatory
tools such as Environmental Reporting. It has been found in a
review of priorities for companies publishing environmental reports
and setting policy that waste management scored the highest in
terms of topics covered in future plans and targets. Environmental
reporting makes organisations more aware of the waste they produce
and also provides the opportunity to benchmark their waste management
practices each year. Environmental reporting is considered as
a useful tool in changing practices and increasing reuse and recycling,
so much so that a number of countries have now implemented mandatory
environmental reporting, either targeted at specific sectors or
sizes of organisations. The government has challenged industry
to provide more comprehensive environmental reporting, but it
remains a voluntary activity to date, generally taken up by specific
sectors keen to prove their environmental credentials. We therefore
support the recommendation to consider the value of mandatory
environmental reporting. In addition, a higher profile of environmental
management systems, through ISO/EMAS certification is supported.
2.3 A major issue is that the vast majority
of businesses are SME's, who do not have the same knowledge of
their waste generation and management and have little or no incentive
to change behaviour. As individual organisations they will be
producing relatively small quantities of waste, but collectively
they will be contributing a significant quantity to landfill disposal.
We therefore support the Strategy Unit recommendation to increase
the role of waste minimisation clubs, as they have an essential
role to play in changing behaviour particularly within this sector.
In addition it is paramount that training and education for waste
producers is paramount if change is to be achieved in the medium
term. Nowhere is this need for training and education more obvious
than the hazardous waste sector. Recent and forthcoming changes
in legislation have imposed restrictions on the options available
for hazardous waste producers and therefore clearer guidance is
essential. We look forward to contributing to the DEFRA Hazardous
Waste Forum, and receiving clarification on the Environment Agency's
position on a potential Hazardous Waste Strategy.
2.4 Little or no incentives currently exist
at the household level for waste minimisation. "Shop smart"
is one of only a few opportunities for consumers to minimise their
waste. There have been a number of local level initiatives but
their success has been limited to date. It is therefore imperative
that measures are taken to increase responsibility at the household
level. Rather than consumers refusing to purchase certain goods
with excess packaging we should be looking to encourage lifestyle
changes, which minimise the potential and actual generation of
waste. CIWM supports the need for a nationally coordinated campaign
and it is imperative that organisations such as the National Waste
Awareness Initiative are resourced sufficiently to meet their
aims and objectives. Whilst the Government has ruled out the introduction
of a national tax on household waste CIWM supports Local Government
having the power to develop innovative waste minimisation solutions,
thereby removing restrictions on local authorities to directly
charge for municipal waste collected. Variable and direct charging
at the household level are widely used across Europe and are accepted
as one of the best tools to induce positive behaviour amongst
householders and increase recycling rates. CIWM advocates the
implementation of direct charging, specifically identifying a
charge for the collection and disposal of MSW to each household,
as opposed to its inclusion within the Council Tax. Once this
approach is in place this can be followed by the introduction
of variable charging, whereby the household pays a fee related
to the quantity of waste generated. CIWM is fully supportive of
the use of this type of instrument as long as the necessary support
structures are in place, specifically appropriate information
provision in addition to a well-developed recycling infrastructure.
2.5 Despite the implementation of the EC
Packaging Waste Directive, producer responsibility has achieved
limited success in the UK; this is set to increase in the near
future with the implementation of a number of policy initiatives
and Directives. The deliverability, for example, of the End of
Life Vehicles Directive, and the Waste from Electrical and Electronic
Equipment Directive, may well hinge on effective producer responsibility
regulations at national level. In addition, in an effort to attain
higher levels of waste recycling, there may be a move towards
implementing producer responsibility at the household level, through
variable charging.
3. REUSE AND
RECYCLING
3.1 Many factors contribute to the disappointing
level of recycling currently being achieved in the UK. We supported
the move from voluntary to statutory recycling targets and think
they should be challenging but achievable. We have some concerns
that the high achieving local authorities will face difficulties
in further increasing their recycling rates. It is considered
easier in both practical and economic terms to put a new scheme
in place and improve upon a low baseline recycling rate, compared
to improving systems already in place. It is essential that support
is offered to the high achievers and that they do not face the
same type of penalties as the low achievers in terms of satisfying
interim targets.
3.2 Whilst we support the higher recycling
and composting targets proposed in the SU report, which are not
unrealistic given the intended changes to the regulatory and economic
framework, however they are only achievable if the necessary infrastructure
is in place in a timely fashion.
3.3 As the pressure is increasing on Local
Authorities to boost their recycling performance, meet best value
targets, and divert material away from landfill, kerbside collection
schemes have been seen to be a more efficient way of capturing
recyclables from the household waste stream, rather than relying
on bring or drop off systems. Cost and local circumstances are
usually limiting factors in terms of the type of kerbside scheme
adopted, however there is a plethora of material available on
best practice throughout the UK and overseas and it is now possible
to develop a kerbside collection scheme to suit a range of different
local conditions. Experience has shown that prior to and following
implementation of a kerbside scheme, regular information and education
provision is paramount to its success. However the convenience
of well operated kerbside schemes does ensure that it is an effective
approach to maximising collection of recyclables and boosting
local recycling rates. We therefore fully support the recommendation
in the SU report for a roll out of kerbside recycling schemes.
3.4 Adequate funding to local authorities
for infrastructure development is essential—the gap between
the funding available to Local Authorities and the need for expenditure
to meet sustainable waste objectives, is widening. The £140
million Challenge Fund was a start, however the value of the fund
was insufficient to meet the needs of all local authorities. There
is concern that the current funding mechanisms, through the EPCS
block, may not be the most appropriate and whether ring fenced
funds would be more suitable to ensure that waste management receives
the resources needed.
3.5 As an Institution we have long advocated
greater producer responsibility and we therefore support the increase
of incentives for reuse and the promotion of the use of secondary
resources and environmentally friendly products, in addition to
the development of green procurement initiatives
3.6 Waste exchanges are an option for diverting
hazardous, industrial, or commercial waste from final disposal
and promoting reuse or recycling. Exchanges have achieved varying
degrees of success in Europe and beyond but in the UK they are
currently underused and can essentially be described as a waste
"dating service". Waste exchanges generally operate
on a low key basis in the UK and deal in very small quantities
of waste and as such awareness of their operations is limited.
The Environment Agency has set itself a policy to encourage waste
exchanges and facilitate networks however there has been no real
evidence of this to date. There are a number of waste exchanges
currently operational in the UK and we support the recommendation
to explore the potential for supporting the wider development
of waste exchanges.
4. INTEGRATED
SYSTEMS
4.1 Whilst CIWM supports the ethos of the
waste hierarchy in terms of moving towards more sustainable management
of waste, this should not been seen as a prescriptive process.
Selecting the best environmental option, taking into account life
cycle assessment, should always be the preferred approach.
4.2 National strategies should be cognisant
of the potential role of all elements of the hierarchy. There
are numerous examples of good practice from overseas where high
levels recycling have been accompanied by high levels of energy
recovery from waste. However, options needed to deal with residual
waste have tended to have been perceived rather negatively, making
planning and investment more difficult. Clear government support
needs to be given for all options on the waste hierarchy, promoting
those at the top, but with acceptance for an integrated approach
to allow residual waste to be managed in an environmental manner.
4.3 CIWM is fully supportive of utilising
energy from waste as a viable waste management option and has
an active Thermal Treatment Special Interest Group, and Energy
from Waste Technical Working Group focusing on these issues.
4.4 Health studies to date have shown that
incineration does not pose a significant risk and that causal
links cannot be identified for landfill sites and health incidents.
It is essential that further health studies continue to be undertaken
to address perceived fears and enable scientific judgements to
be made. However, when data and information is presented it is
paramount that it is done so in a contextual manner, and that
all options for managing waste are investigated, not just traditional
disposal routes.
5. FUNDING
5.1 Funding as ever remains a priority for
waste management and is fundamental to the delivery of more sustainable
waste management. It is generally accepted that householders have
little understanding of the costs associated with MSW management
and charges are currently insufficient to meet the needs for infrastructure
development. The SU report has identified costs associated with
the implementation of priority areas, however, aside from the
existing routes of funding currently available and the changes
to landfill tax and the landfill tax credit scheme, no additional
funds have so far been agreed. All stakeholders in waste management
are united on the issue that funding is a priority if we are to
move towards a more sustainable way of managing waste. CIWM recommends
a need for ring fencing and implementation of direct charging
as a first step towards variable charging at the household level
in order to meet the funding requirements for waste management.
6. LANDFILL TAX
AND THE
LANDFILL TAX
CREDIT SCHEME
6.1 The Pre-budget report raised the landfill
tax by just £3.00 per tonne, per year from 2005-06. Prior
to the Pre Budget Report expectation amongst the industry was
high as it was anticipated that there would be a significant increase
in the level of tax to bring the UK more in line with its European
neighbours. CIWM has been key amongst a wide range of stakeholders,
who, whilst supporting the landfill tax in principle, have called
for much higher levels if its aim of diverting material away from
landfill is to be realised. Currently set at £13.00 per tonne,
on an escalator over the next two years to £15.00 per tonne,
it was anticipated that a doubling of the level of tax would be
needed to put the cost of landfill disposal on par with, or higher
than, alterative waste management options, thereby presenting
a more level playing field. More importantly, a higher tax would
present more opportunities for hypothecation of the taxes into
sustainable waste management initiatives. The Chancellor announced
that a taxation level of £35.00 per tonne would be a long-term
aim. However, the problem with long-term fiscal instruments is
that they are not in tune with short-term targets in the landfill
directive and statutory recycling targets. Whilst any increase
in the landfill tax could be viewed as demonstrating positive
support from the government, the reality is that a £3.00
per tonne escalator will do little to promote further diversion
from landfill or provide sufficient funds for infrastructure development
through the landfill tax credit scheme. We are disappointed and
will proactively urge Government on behalf of our members to review
the level of escalator set, and promote the figure of £35.00
per tonne to be a short-medium rather than long term target.
6.2 The pre-budget report also confirmed
reform of the Landfill Tax Credit Scheme with a third of the funding
continuing to be available for spending on community environment
projects and two thirds to be allocated to public spending to
encourage sustainable waste management. Whilst the advantages
of allocating a proportion of the funds to the public sector can
be appreciated, there are concerns relating to the uncertain future
for other areas currently funded by the credit scheme, such as
research, and information and dissemination, which have been hugely
beneficial to waste management. There are also concerns relating
to the knock-on effect a lack of funding for specific projects
will have on employment and accessing external funds (refer to
the discussion held at the December meeting of the Associate Parliamentary
Sustainable Waste Group).
7. DATA
7.1 The need for accurate and reliable data
has long been identified by the industry as a major barrier to
progress and is an issue highlighted at various times throughout
the SU report. All the stakeholders will therefore be supportive
of the recommendation for the Environment Agency and DEFRA to
draw up a data and research strategy for the next three years.
This needs to take into account existing projects, for example,
Dataflow which demonstrates both a good use of landfill tax credits
and is also an example of industry, and government departments,
working together and actively redressing the deficiency in MSW
data.
8. PARTNERSHIPS
8.1 With regard to the role of Local Government,
whilst there are a number of good examples of joint municipal
waste strategies, this is by no means universal. Therefore CIWM
support the continual incentivising of local authorities to work
together. The possible medium term option of developing unitary
resource management authorities, combining the role of waste collection
and disposal authorities, as proposed by the SU report, builds
on the previous implementation of unitary authorities. CIWM will
continue to debate this issue both internally with members from
all sectors and externally with key stakeholders, including the
Local Government Association.
9. TRAINING
9.1 The level of training in the waste management
industry has been criticised in previous reports. CIWM now provides
118 days of training per year, covering all practical and legislative
aspects of waste management. However, in terms of moving up the
hierarchy and developing more sustainable waste management practices,
there is an urgent requirement for training at all levels. Whilst
a number of strategies are already in place for training those
in the waste industry itself (NVQ's at all levels etc.), there
is also a need to extend the focus to waste producers.
10. PLANNING
10.1 CIWM supports the need for an overhaul
of the planning system and related policies. Currently the planning
process poses a significant barrier to the development of essential
facilities to treat waste and therefore this has significant implications
on movement up the hierarchy. This is particularly the case for
re-use/recycling facilities. There is an urgent need for the development
of generic responses identifying the government position, and
including objective data and information.
11. CONCLUDING
COMMENTS
11.1 There is a need for a strengthened
role, and higher profile, of waste in government. In addition
there needs to be full utilisation of existing policy and legislation,
and improved enforcement by the Environment Agency.
11.2 CIWM welcomed the first step towards
recognising the very real barriers to meeting statutory requirements
when the Secretary of State held the Waste Summit last year. As
the second step, the Strategy Unit Report takes the debate further
and identifies solutions to overcome the barriers. The Institution
now looks forward to the implementation of the recommendations
as the third step in the process and remains committed to playing
our role in their delivery and maintaining the momentum of interest
amongst the decision makers and key stakeholders.
Chartered Institution of Wastes Management
6 January 2003
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