Memorandum submitted by Eunomia
INTRODUCTION
1. This submission focuses primarily on
the management of municipal waste. It also adopts a view of the
waste management hierarchy consistent with the interpretation
of the Waste Framework Directive implied by a Commission Communication
arising from a waste management strategy review, endorsed by the
European Parliament in a resolution of 1997. This stated:
"Within the recovery principle, where environmentally
sound, preference should be given to the recovery of material
over energy recovery operations. This reflects the greater effect
on the prevention of waste produced by material recovery rather
than by energy recovery" (my emphasis).
2. The UK interpretation of the hierarchy
is slowly aligning itself with this view, as illustrated in the
strategy for England and Wales, A Way With Waste, and most
recently, in the Strategy Unit Report, Waste Not Want Not.
Indeed, we follow the SU report, and commend it, in making the
distinction between "high-in-hierarchy" options (materials
recovery, re-use and minimisation) and those generally related
to residual waste (energy recovery and disposal).
3. Much will probably be made in this inquiry,
as usual, of the lack of harmonisation of data across countries
being compared with the UK. Yet UK waste management remains, to
borrow the term used by an Italian professor recently, "prehistoric".
Whatever recycling rates may or may not be, or may or may not
include, it is sobering indeed to consider that whilst the average
inhabitant in the UK generates residual waste (ie waste remaining
after materials recovery) of around 400kg per capita. In leading
European situations, this figure is of the order 150kg (with individual
households, of course, producing much less). In other words, every
man, woman and child in the UK is "throwing away", on
average, almost three times as much material as people in, for
example Flanders and parts of Austria and Germany.
THE HIERARCHY
AND THE
BEST PRACTICABLE
ENVIRONMENTAL OPTION
4. Clarification of this point is intended
to orient subsequent thinking in this submission, but it is also
important to understand the eclectic role played by "the
waste management hierarchy" in orienting thinking about waste
management in the UK. It remains the case today that although
the hierarchy is intended to orient thinking about waste management,
it has an awkward relationship with the concept of "Best
Practicable Environmental Option" (BPEO).
5. In its twelfth report of 1988, the Royal
Commission on Environmental Pollution (RCEP) addressed the issue
of establishing the Best Practical Environmental Option (BPEO)
to deal with pollution and other environmental problems, and defined
it as:
"the outcome of a systematic consultative
and decision making procedure which emphasises the protection
and conservation of the environment across land, air and water.
The BPEO procedure establishes, for a given set of objectives,
the option that provides the most benefit or least damage to the
environment as a whole, at an acceptable cost, in the long term
as well as the short term".
This "definition" does not take us
very far as regards operationalising the concept. The fine words
mask all sorts of problems, including the weight given to serious
consultation as opposed to more technocractically based decision
making, the degree to which one can establish, on an objective
basis, the superiority of one or other approach, the issue of
what is "an acceptable cost", and the degree to which
any technocractic attempt to rank options is open to public scrutiny
and debate.
6. Considerable time and effort continues
to be devoted to technocractic efforts aimed at illustrating why
more or less anything and everything can be promoted as "the
best practicable environmental option", as long as one chooses
one's assumptions carefully. Indeed, we believe we could present
a case, with the assumptions suitably made, to support just about
anything as the "BPEO". This catch-all can frequently,
therefore, constitute a barrier to the movement of waste up the
hierarchy.
7. Hence our first recommendation is that,
in the absence of clear proof that the waste management hierarchy
does not give a guide as to what is the best option (and the burden
of proof should clearly rest with those who seek to "buck
the hierarchy"), the hierarchy, and not the concept of BPEO,
should guide waste management strategies in the UK. This is necessary
because of the frequent attempts made by waste management companies
and local authorities alike to posit anything and everything as
the BPEO in what amounts to "excuses" to engaging seriously
with materials reduction, re-use and recovery.
WASTE MINIMISATION/REDUCTION/AVOIDANCE
8. At the household level, the number of
actions which can be taken by individuals to reduce their generation
of waste is considerable. However, this requires sensitisation
of consumers to the issues concerned. There are good reasons to
believe that for this reason, minimisation will follow recycling,
much as it may desirable for the opposite to be the case.
9. For this reason, the influence on waste
generation of government-led initiatives, either in terms of taxation,
other market-based instruments such as deposit-refund schemes,
negotiated agreements, or (perhaps less desirably) regulation
should not be overlooked. A clear problem here has been that in
the domain of "producer responsibility", the fact that
the lead is being ceded by DEFRA to DTI implies that in the very
area where some action is required to "make measures stick",
the responsible government department is the one which seeks to
minimise any new burdens, regulatory and otherwise, on industry.
This has tended to weaken producer responsibility initiatives,
and in the case of Packaging, has tended to deflect the burden
of compliance on to local authorities. The net effect is that
instead of the burden being shouldered by producers and consumers
of specified products, part of the burden has fallen upon the
collective of tax payers. The chance of implementing the Polluter
Pays Principle is thereby lost, and the opportunity for "making
producers responsible" is foregone.
10. Our second recommendation is that deposit-refund
schemes should be introduced for beverage packaging.
11. Our third recommendation is that lead
responsibility for Producer Responsibility legislation should
be removed from DTI.
12. Our fourth recommendation is that a
wide ranging investigation of the feasibility of new producer
responsibility initiatives should be undertaken (including batteries,
tyres, waste electrical and electronic equipment, pharmaceuticals,
household hazardous wastes, etc). In each case, these should be
designed in such a way that where local authorities undertake
activities which support the initiatives, they should be remunerated
for this activity in line with an estimate, for example, of the
(incremental) costs to them of providing infrastructure for the
separate collection of the relevant materials. Only when such
considerations are made part of the design of such mechanisms
will producer responsibility begin to resemble a polluter/consumer
pays mechanism.
13. Furthermore, in public sector activities,
and other areas of communal activity, there is considerable potential
for waste minimisation through, for example:
— Use of re-usable equipment, such
as crockery and cutlery, in public places/at public events. This
can be achieved through lease/hire mechanisms. Some schemes in
market places benefit from support for use of dishwashers.
— Promotion (in public owned healthcare
facilities) of the use of re-usable nappies.
— Promotion (in schools, as part of
the curriculum—waste from schools is "municipal waste")
of waste minimization and recycling activities. This could include
establishment of on-site composting facilities, schemes to ensure
the use of paper on both sides, etc.
— At Christmas and other festival periods,
initiatives should be undertaken to encourage giving "experiences
not stuff". This type of approach, used in Washington State,
aims at both reducing waste and boosting the local economy through
encouraging citizens to buy presents in the form of vouchers usable
at arts and leisure events.
14. Our fifth recommendation is that central
government should consider establishing a mechanism to support,
financially, local efforts to minimise waste in schools, hospitals,
and other areas under local authority jurisdiction in appreciation
of the fact that these are likely to be investments which deliver
net benefits, environmental and financial, over the medium to
long term.
15. The other key influence on waste generation
is the nature of service provision for waste collection. In recent
work, we suggested that the impact of local authorities issuing
wheelie bins for the collection of garden waste was to increase
the overall quantity of waste collected by something of the order
100kg per household per annum, or around 7-8% of the municipal
waste collected per household per annum[48].
This tends to discourage home composting in favour of collection
in large bins. This imposes unnecessary costs upon the collection
system.
16. Our sixth recommendation is that the
services provided for the collection of waste have to take into
account their potential for "drawing out" of the household
more waste than is necessary (with implications for the cost of
service provision). Ideally, this implies that schemes for biowaste
collection should focus on the denser kitchen waste fractions
rather than the garden waste fraction, or the combination of kitchen
and garden waste. The inclusion of garden waste acts as a disincentive
to deal with garden waste in the garden (through "grass-cycling"
and/or home composting). It also constitutes (under current arrangements
for paying for waste—see below) a regressive element in
cost terms since the wealthiest people tend to be among those
with large gardens.
HOME COMPOSTING
17. Some local authorities underestimate
the role that home composting can play in dealing with garden
and some kitchen wastes, and the role that it may already be playing
in reducing the amount of waste set out for collection. In parts
of Europe, such as Austria, home composting accounts for half
of all biowaste management.
18. A seventh recommendation is that home
composting should be encouraged through demonstration activities
(at recycling centres), and the training of volunteers in areas
with gardens. Another way to ensure that home composting is not
discouraged is through the design of charging mechanisms for waste
collection (see next section).
DIFFERENTIAL AND
VARIABLE RATE
(DVR) CHARGING
19. DVR charging schemes, sometimes referred
to simply as "variable charging", or "direct charging",
or "unit pricing" or "pay-as-you-throw", are
schemes which charge householders on the basis of a defined measure
(weight, volume, frequency of emptying of bin, number of bags
etc) of use of one or more elements of the collection service.
In all schemes designed with an incentive effect in mind, the
scheme involves levying a higher charge for the use of the residual
waste collection service than for those elements of the collection
service designed to collect materials separately (for recycling
and composting/digestion).
20. The United Kingdom is one of few countries
where such activities are effectively outlawed in primary legislation,
though one scheme—in Blaby in Leicestershire—effectively
operates on this principle. The UK appears to be the only country
which has a landfill tax in place, but does not allow (not to
mention, encourage) the introduction of DVR charging schemes.
21. Where these schemes are in place, they
have been found to have two effects:
— a reduction in total waste generated/set
out (the output effect); and
— an increase in the use of separate
collection systems favoured by the price differential (the substitution
effect).
Both tend to lead to a reduction in residual
waste.
22. Skumatz, in the US, examined the impact
of DVR charging schemes on recycling and reduction. The results
are summarised below in Table 1 and indicate that variable charging
reduces waste generation by around 6% and produces further recycling
of around 11%.
Table 1
SEPARATE EFFECTS OF VARIABLE CHARGING ON
REDUCTION AND RECYCLING
| Community Comparison
| Time-Series Comparison |
| Source Reduction (%) | 5 to 7
| 5.8 |
| Dry Recyclables Effect (%) | 5 to 6
| 6.9 |
| Garden Waste Recycling (%) | 4 to 5
| 4.6 |
| Total Effect of PAYT/VR | 16
| 17.3 |
Source: Skumatz Economic Research Associates (SERA) in Resource Recycling August 2000.
|
| | |
23. We were pleased to see the Strategy Unit recommending
that "the Government should secure an early legislative opportunity
to grant local authorities powers to implement incentive and charging
schemes for waste if they want to do so." DVR charging systems
work best where convenient systems are available for citizens
to reduce their liability to charges through engaging in source
separation. In the absence of such convenient systems, the potential
for evasive behaviour, such as fly-tipping, increases. This makes
clear that one of the key measures used to support waste reduction
is a measure which, when intelligently applied, pre-supposes the
existence of convenient systems for source separation. DVR charging
systems should be deployed, and convenient systems for source
separation should be in place. Together, evidence suggests that
waste reduction can occur without increases in fly-tipping occurring.
The same cannot be said of systems where there is only one bin,
that for residual waste.
RE -USE
24. As regards re-use, we have discussed above the issue
of deposit-refunds for beverage containers. The distinction between
what is regarded as waste minimisation, or avoidance, and materials
re-use is often blurred (as some of the above examples illustrate).
Deposit refunds, and producer responsibility initiatives, can
encourage a reduction in waste arisings.
Recycling and Composting/Anaerobic Digestion (Materials Recovery)
25. Firstly, one must start this section by saying that
the definitions of recycling, and more especially, composting
are in urgent need of clear definition. The lamentable absence
of any statutory or quasi-statutory standard distinguishing between
a) those materials derived from waste which are suitable for unrestricted
application, and b) those materials which, because of their physical,
chemical and/or biological properties are suitable for application
to land only in certain cases, has been a major failing, not to
mention a significant loophole, in the existing regulatory framework
in respect of waste management, and specifically, the management
of biowastes. As long as "composting" remains poorly
defined, the obligation "to compost" will be open to
abuse by those who wish to take short cuts in respect of the law.
26. Linked to this, the categorisation of anaerobic digestion
as "energy recovery" rather than a material recovery
option is unfair where digestion is of source-separated materials
in such a way that the residues from the process are suitable
(possibly following a period of aerobic composting) for unrestricted
application to land. The digestion of source-separated kitchen
wastes ought to offer considerable potential for diversification
of on-farm incomes, with the prospect also of low-cost, locally
available energy through either electricity provision, or biofuels
for use in transport. This type of cross-cutting thinking is exactly
the type of imaginative approach which DEFRA ought to be encouraging.
27. The "quickest and easiest hit" in respect
of separate collection of materials is to be achieved at what
are still called "Civic Amenity sites". This is increasingly
recognised by local authorities. Relatively basic changes including
improved signage, improved layout, improved site supervision and
so forth can make rapid changes to the recycling rate achieved
at a given site. Allied to enhanced producer responsibility schemes
(see above), such a nationwide re-organisation of these sites
could deliver, on its own, a doubling of the UK's current recycling
rate at very little incremental cost. Indeed, at higher levels
of landfill tax, the changes will effectively become cost effective
to make (because of increased savings in respect of avoided disposal
costs).
28. We recommend that all local authorities are encouraged
to re-organise their "civic amenity sites", and that
the terminology is changed to reflect the new role of these facilities.
Consideration should be given to making these sites the responsibility
of waste collection authorities rather than waste disposal authorities,
once again reflecting the changed role envisaged for these "material
recovery parks".
29. More generally we recommend a review of the allocation
of responsibility for all services related to waste management
(specifically, in England, across the tiers of Government). Ideas
of potential interest might include: the creation of all WCAs
as "waste unitaries", with a duty to devise waste strategy
in partnership with neighbours (including consideration for letting
of contracts jointly); and the establishment of a financial relationship
between WCAs and WDAs under which WCAs received variable tonnage
based charges from WDAs related to the types of treatment/disposal
services purchased (WDAs would cease to receive notional EPCSSSA
allocations for waste disposal).
30. When taken together, kitchen waste and garden waste
constitute the largest fraction of the waste stream. Separately,
they are also significant fractions, but as suggested above, the
quantity of garden waste in the waste stream is amenable to influence
through the collection mechanism (and through appropriate charging
structures in DVR charging systems). Ideally, biowaste is approached
in the following manner:
— kitchen wastes, with high bulk density, are collected
separately in low-cost, flat-bottomed trucks;
— garden waste, of lower bulk density, is collected
separately at bring sites ("Civic Amenity sites") and/or
through using low frequency doorstep collections during peak months.
This type of system ensures that:
(a) waste arisings are not inflated by large, and seasonal
deliveries of garden waste into the collection system;
(b) home composting is not discouraged;
(c) the most putrescible and odorous fractions can be
targeted accurately, allowing for a reduction in the frequency
of residual waste collections and a reduction in cost; and
(d) because the denser kitchen waste fraction is targeted,
the lower costs of the vehicle stock can ensure that collection
costs are maintained at a low level AND that the frequency of
collection of kitchen wastes can (where necessary) be maintained
at a weekly level.
31. The problem in recent times has been that despite
the compelling logic of this type of approach, questions have
been raised about the suitability of kitchen wastes for composting.
These questions have arisen owing to a concern for the possibility
that the spreading on land of the products of composting of kitchen
wastes might give rise to the spread of animal pathogens such
as the virus responsible for the foot and mouth disease. It is
our view that these concerns have been exaggerated, and that the
biological treatment techniques for managing waste appear to be
being singled out for over-zealous regulation, especially when
one compares this with the comparatively lax approach to regulating
residual waste facilities such as incinerators (see below). The
application of the existing state of knowledge associated with
the respective plant types are clearly being treated from radically
different epistemological perspectives. It is a sobering thought
that a year's work of the Strategy Unit of the Cabinet Office
stands to be, potentially, dashed by the approach of DEFRA vets
to the issue of composting of kitchen wastes. The only mitigating
circumstance for the approach taken is the singular lack of clear
waste regulation in the area of biowaste treatment which, had
it been in place at the time of the outbreaks of foot and mouth
disease and swine fever, might have helped to deflect suspicion
from biological treatment approaches.
32. We recommend that the risk assessment carried out
for DEFRA be a) reviewed to display, transparently, the degree
to which the results obtained are based upon i) assumption and
ii) clear evidence, and b) supplemented by an empirical study
on the incidence of livestock diseases arising from composting
carried out through collaboration with those countries with most
experience with this treatment.
ENERGY RECOVERY
33. The terms of reference for the inquiry ask what is
"best practice" in terms of energy recovery. One can
say quite unequivocally that no such practice exists in the United
Kingdom at present. There are two reasons why one would remain
sceptical that such "best practice" could emerge in
the current context.
34. Firstly, the simple fact of the matter remains that
the legislative framework in the United Kingdom, such as it currently
exists, does not require best practice in the technologies available.
Several European countries—Switzerland, Germany, Austria,
Netherlands, Flanders (Belgium) among them—routinely apply
standards for emissions of key emissions that are tighter a) than
our own and b) than those under European Directives (even those
yet to be fully implemented in the UK). Hence, the question arises
as to whether the UK should not be applying similar standards
under the IPPC Directive, which it would be perfectly entitled
to do through specifying better abatement technologies as BAT
(Best Available Technology).
35. At present, it seems that the argument runs that
going beyond what is required in the latest revision of the Incineration
Directive is unnecessary because of the cost involved. On the
evidence available, we would strongly dispute this in the case
of, for example, NOx since under the IPPC Directive, the test
is a cost-benefit one, and it would appear that on the basis of
our own analysis, the benefit-cost ratio may be as high as 5:1.
[49]
36. On a much less thorough line of argument, one might
say "if it's not too expensive for the above countries, why's
it too expensive for us?" Switzerland is one of those countries
which is always mentioned as one where "incineration and
recycling (46%) co-exist". Most Swiss plants have installed
SCR (selective catalytic reduction) as standard for abatement
of NOx emissions.
37. The Environment Agency's own review of incinerators
indicated that as far as NOx abatement is concerned, of the 11
incinerators studied, three employ selective non-catalytic reduction
(SNCR), two have flue gas recirculation, one has both SNCR and
recirculation, and four have "no provision" for NOx
abatement (no info for Wolverhampton). No plant is equipped with
SCR to control NOx emissions. This is a lamentable state of affairs.
38. The Best Estimate from Enviros as regards NOx emissions
per tonne from UK incinerators is around 300mg/m3, about 15 times
higher than the level achieved in the best performing European
plants, and four times that achieved at "half decent plants"
in Europe.
39. One reason why incineration and recycling "co-exist"
in Switzerland is that the proper regulation of the facilities
and their outputs (not just air emissions—the ETH in Zurich
has been assessing issues of long-term effects of landfilling
ash etc) makes the cost of incineration higher, and makes source
separation for recycling/composting/digestion cost-effective from
the perspective of local authorities. The same is true in Flanders,
Austria, Germany, the Netherlands etc. In Austria, GUA Group (Vienna)
carried out analyses that suggested for every tonne of waste separately
collected for composting, the net financial saving was
50 per tonne.
40. The other reason why best practice is unlikely to
be achieved is that the strategic context for deploying energy
from waste facilities is frequently misunderstood. In a dynamic
strategy—and in the era of Best Value, it is incumbent upon
local authorities to challenge themselves rather than maintaining
stasis in their approach to waste management—the imperative
to "continuously improve" can be (it is not necessarily
the case) constrained by resort to investments in capital intense
plants which demand—for contractual or technological reasons—a
more or less constant throughput of waste materials.
41. An emerging approach for the deployment of energy
recovery techniques involves the use of energy recovery in the
context of what are known as mechanical biological (MBT) treatment
processes. In these processes, pre-treatment through "biological
drying", followed by mechanical separation, can reduce the
requirement for incineration capacity, and increase the flexibility
of waste management strategies. The approach is gaining acceptance
in Austria, Germany and Italy, and more recently, in the Netherlands
and Flanders. Some MBT plants resort to anaerobic digestion processes
for the delivery of energy from residual waste, and some make
resort to both anaerobic digestion and thermal recovery techniques.
42. In the UK, costs for energy recovery facilities are
increasing because of planning delays, protests, inappropriate
BPEO statements and so forth. The difficulties experienced in
"getting facilities in place" relate to poor proposals,
concern at the environmental and health impacts, and a lack of
transparent and open debate about the issues. These delays might
be reduced if the view were taken that these facilities ought
to be more tightly regulated, giving greater comfort to citizens
in respect of operating performance. Once regulators are trusted
in the public eye—and to be trusted, they must be seen to
be doing their job—and once facilities are operated to high
standards—for which, appropriate standards are required
to be in place—it seems likely that the public will at least
be more accepting of new facilities. At present, it would seem
that the costs of trying to have waste management "on the
cheap" is that nothing gets built at all!
43. We recommend that the proposals laid down in the
Environment Agency's Interim Sector Guidance for incineration
should be reviewed in the light of existing best practice in the
EU. This review should consider carefully the following issues:
— why it should be considered inappropriate for
incinerators to be equipped with current best practice abatement
technologies given existing practices in other EU Member States.
— what form of disposal of air pollution control
residues is acceptable in the context of a consideration of the
potential long-term effects of disposal in landfills?
We believe that tighter standards and regulation, with appropriate
sanctions in place, are likely to assist in having facilities
approved by citizens.
This approach—proper regulation of the treatment, delivering
benefits to human health and the environment—is preferable
to an approach based solely on taxation, though an extension of
the landfill tax to other residual waste treatments should not
be ruled out.
44. We recommend that due attention be paid to the flexibility
of waste management strategies as they are designed. By flexibility,
we mean the ability of the strategy to facilitate increased rates
of source separation over time without compromising investments
in residual waste treatment.
SUPPORT FOR
ENERGY FROM
WASTE (EFW)
45. The incentive structure for waste management remains
"upside down". There are no pecuniary incentives for
recycling and composting, yet through the Renewables Obligation,
residual waste treatments receive support for the energy delivered.
This is despite the fact that European Directives on Landfill,
Incineration and Integrated Pollution Prevention and Control will
require energy recovery for the facilities' operation. What the
Renewables Obligation does is reduce the costs of residual waste
disposal. This is exactly the wrong message to send, it undermines
the credibility of the Renewables Obligation, and it implies that
as the UK renewables target comes into force, electricity suppliers
will transfer revenue to landfill operators, and operators of
gasification and pyrolysis plants. This money would almost certainly
be better spent encouraging the development of "genuine"
renewables such as wind power, solar heating, etc. rather than
providing rents to the operators of facilities who will be required
to generate this energy by law anyway.
46. The Strategy Unit report makes a mistake in, on the
one hand, recommending that DEFRA and DTI take forward a programme
of advice and development of new technologies, and on the other,
failing to recommend the removal of the support for residual waste
management options which occurs through the Renewables Obligation.
In stating that conventional mass-burn incineration would not
eligible to issue Renewables Obligation Certificates (ROCs), DTI
made reference to the conflicts with the waste management strategy.
It is completely bewildering that they should have stopped at
incineration, thus allowing energy generated from landfills, gasification
and pyrolysis facilities to qualify for ROCs, the sale of which
may be worth up to £10 per tonne for some facilities, possibly
more, depending upon the trading price of ROCs. [50]
47. We recommend that if it is intended that new treatments
for residual waste are to be given any form of assistance, this
should not be in a form such that it reduces the costs of the
facility to the local authority. The emphasis should be upon demonstration
facilities and trials. To offer support for the end product—energy—is
not the way to encourage a rational development of these facilities,
not least since local authorities my be seduced into making over-hasty
investments. It should not be the goal of any policy instrument
to make residual waste management cheaper (and definitely not
when no such instrument exists to reduce the costs of recycling).
At the moment, there are too many instruments, often conceived
in the energy field, which do this.
DISPOSAL
48. In the general sense, we welcome the suggestion in
the pre-Budget speech that Landfill Tax will continue to increase
in future. However, we doubt that this measure will have a significant
impact on municipal wastes in and of itself (the implications
for commercial and industrial wastes are likely to be more interesting).
49. The increased tax will be made more effective once
DVR schemes can be introduced. However, at present, most local
authorities are adopting strategies which are heavily shaped by
their wish to meet Landfill Directive targets (potentially making,
it should be added, any emissions trading bill in waste management
a sideshow, since to the extent that all local authorities will
seek to meet targets in their own right, the trading of permits
is likely to be a marginal activity).
50. A much more intelligent of the landfill tax relates
to the structure of the tax. It is our view that if residual waste
undergoes biological treatment such that it is stabilised prior
to landfilling, a lower level of tax should apply than if the
material was landfilled as untreated waste. This is a situation
which already exists in Austria.
51. We recommend therefore that standards be established
for "stabilised biowaste" (as part of the wider set
of standards for biological treatment—see above) such that
material fulfilling these standards qualifies for a lower rate
of tax than the standard rate (which could be the lower rate,
or a separately established rate). This lower rate would enable
continued use of existing landfill void, but in such a way as
to reduce the potential for problems associated with landfilling
of waste.
CONCLUDING COMMENT
52. Countries which have been far more successful in
moving waste up the hierarchy do two things:
— they ensure that residual waste treatment/disposal
is not cheap through a combination of a) regulating residual waste
treatments such that high technological standards need to be met,
b) landfill taxes, and c) taxes on non-landfill residual waste,
such as incineration; and
— they give very clear guidance to local authorities
in terms of the desirability of source separation, using producer
responsibility initiatives, voluntary agreements with local authorities,
and providing advice on implementing collection systems, as well
as DVR charging schemes.
53. This is hardly rocket science. Indeed, it is pretty
obvious that such an approach—make residual waste less attractive,
and source separation more so—will generate the desired
outcomes.
54. A clear problem in England at present is the continuing
process of opting for sub-optimal strategies. The terms "integrated",
and "balanced" have become synonyms for the phrase "we
don't know what we want". The existing equivocation, and
uncertainty in the policy domain, only deepens the state of near
paralysis on the part of those who might otherwise act, if only
because—and no one can blame them for this—it's not
clear to them what they are being asked to do.
55. The truth of the matter is that there are a million
and one ways to do what this Inquiry is seeking to do. But whilst
individual visionaries may be able to do things without government
leadership, policies for which government is ultimately responsible
are the ones which offer the best prospects for forging a more
sustainable path for resource management in the UK. It seems an
appropriate occasion for a House of Commons Committee to ask itself
why, when so much could be achieved through some simple decisions
and a relatively small amount of money, the decisions remain unmade?
Bluntly stated, it's the Government's fault, and there is little
point in denying this. It would be nice to think that another
of these Inquiries as to "why we're still doing so badly"
could be made unnecessary by doing what obviously needs to be
done.
Eunomia
6 January 2003
48
Eunomia, Avon FoE and Network Recycling (2002) Maximising Recycling
Rates, Tackling Residuals, Final Report to CRN, www.crn.org.uk. Back
49
See D. Hogg and J. Hummel (2002) The Legislative Driven
Economic Framework for Recycling in the UK, Final Report to
the National Resources and Waste Forum, www.nrwf.org. Back
50
See D. Hogg and J. Hummel (2002) The Legislative Driven
Economic Framework for Recycling in the UK, Final Report to
the National Resources and Waste Forum, www.nrwf.org. Back
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