House of Commons - Environment, Food and Rural Affairs - Appendices to the Minutes of Evidence

Select Committee on Environment, Food and Rural Affairs Appendices to the Minutes of Evidence

Further memorandum submitted by Renew Trust

1. INTRODUCTION TO RENEW TRUST

Renew Trust is an innovative, not-for-profit social and environmental enterprise set up in 1998. It plays a role in the waste industry by refurbishing white goods. Renew operates in partnership with Comet plc by taking the white goods that Comet collects under its "take-back" scheme.

As well as operating in the waste sector, Renew is also a community organisation. Such organisations are extremely well placed to operate higher up the waste hierarchy by re-using products. Renew's operation provides a number of benefits:

— training and employing long-term unemployed and people with disabilities;

— redistributing reasonably priced white goods to low income households;

— reducing waste going to landfill.

Following from its highly successful operations in Leeds and Gateshead, Renew plans to expand to 11 other parts of the country near to Comet depots. Renew has plans to diversify its activities by expending the range of electrical goods it refurbishes and increasing the range of partners with whom it works (such as local authorities, small businesses). We are also looking at opportunities to expand sales by exporting refurbished goods.

Renew's particular position in the waste hierarchy and its social and community emphasis, enable it to fulfil a number of roles, However, Renew's future success—and that of other refurbishers—could be secured by Government policy and activity. These include:

the future regulatory environment:

funding schemes:

contracting with social enterprise:

consultation with the re-use sector:

For further information about Renew Trust, please see Appendix A.

2. RENEW'S POSITION IN THE WASTE HIERARCHY AND EMPLOYMENT AND TRAINING

Renew is a training organisation with a particular niche in the waste sector ie promoting re-use through refurbishing white goods. It refurbishes both whole appliances for re-use, but through disassembly it encourages the re-use of components. Its particular role can perhaps be illustrated by considering the waste hierarchy—adapted in Table 1 below. Renew's focus in this sector is to re-use as much as possible whether it is complete units or components.

2.1 RE -USE PROVIDES EMPLOYMENT AND SKILLS TRAINING OPPORTUNITIES

  Re-use is a disposal option that provides employment and skills training (see below). The effectiveness of the re-use option both in terms of diversion from landfill and in raising skill levels can be seen in the table below. There is a direct correlation between operating at the highest level of the waste hierarchy and the skills and labour input required—the higher up the hierarchy, the greater the demand for skills and manpower.

Waste disposal options according to the levels in the waste hierarchy Type of skills required

Waste reduction High degree of consultation and communication skills

Re-use of whole units    Renew Very labour intensive. High skills level

Re-use of components    Renew Medium skill level. Labour intensive

Recycling and composting Labour intensive, but lower skill level

Energy recovery with heat and power Lower technical and labour inputs as energy recovery, but high environmental efficiency

Energy recovery Some technical input, lower labour content than Energy for Waste plant

Landfill with energy recovery Less technical input, but low labour requirements

Landfill Minimal skills, lower labour intensity

TABLE 1 RENEW'S WASTE HIERARCHY/LABOUR SKILLS CO -EFFICIENT

The table also highlights the two forms of re-use carried out by Renew: whole units and components. Both require a relatively high skills level but also significantly enhance resource use by utilising products for purposes they were designed and built to achieve.

The re-use option in the waste hierarchy is therefore particularly important, not only for its environmental benefits, but because of the potential it provides for training and employment. Other organisations operating in the waste sector—such as local authorities and private waste companies—do not necessarily provide the training and employment opportunities.

To date we have created more than 80 jobs and training opportunities, including jobs for 20 disabled people. Renew provides real, paid work for people who have limited previous work experience using the New Deal scheme and other training related funding. People develop the basic skills required in work (eg communication and co-operation) and gain a wide range of experience including processing, disassembling, stock management, warranty support, marketing, retailing, office work and customer service. In doing this, they work towards an NVQ in electrical servicing. A measure of Renew's success is that a high proportion of its employees move on to jobs even before completing their initial year. Given the right regulatory environment, Renew could quadruple the amount of training and employment it provides.

2.2 BALANCE BETWEEN RECYCLING AND RE-USE

In considering the future of sustainable waste management, it is appropriate to compare the recycling and re-use operations. The two operate in different ways, but the way recycling operates could impact significantly on re-users.

Re-use: disassembly/refurbishment

Renew has three options in dealing with each domestic appliance; refurbishment as a single unit; disassembly and re-use of component parts; or sale to scrap material merchants for material recycling. Initially this involves the careful sorting of the units to assess their condition. This process requires a considerable amount of skilled manpower.

Recycling

Entire units are shredded in a powerful machine which mechanically separates the material into its constituent parts. This is a capital intensive, large scale operation that can process high volumes of waste. Given the minimal sorting of units of components beforehand, they require substantially less manpower than the re-use option.

By its nature, recycling is not concerned with the quality of the products and therefore handles them with less respect. The regulatory framework or incentives could result in benefiting recycling, whilst "crowding out" re-use.

3. FUTURE ISSUES FOR RENEW

There are a number of Government initiatives which could impact on Renew's future operation including regulations due to be implemented in the UK and also future funding sources.

3.1 WASTE ELECTRICAL AND ELECTRONIC EQUIPMENT (WEEE) DIRECTIVE

The WEEE Directive is due to be implemented in the UK in August 2005. Renew is supportive of the producer responsibility principle enshrined in this and other recent EU Directives. It could provide opportunities for Renew and other refurbishing organisations to flourish. The Government is due to publish its implementation proposals for the WEEE Directive by the end of March. We are looking at the future regulatory environment to ensure it proactively supports and embeds re-use as an environmentally and socially sustainable waste disposal option. It is also important that the regulatory requirements for both the WEEE and Hazardous Waste Directives[51] do not stifle the re-use of appliances.

Specifically, in implementing the WEEE Directive, we call on the Government to:

— require all WEEE recycling contracts to include provision for genuine refurbishment/re-use operations to prevent the "crowding out" of re-use. This could be achieved through in-house or sub-contracted work. This requirement will ensure that the high volume, capital intensive, recycling operations do not "crowd out" the smaller low margin re-use operations. The Directive gives a high priority to re-use as an option, but this must be specifically encouraged by UK regulations and waste policy generally. (For more information see paragraph 1, Appendix B.)

— ensure the requirements to assess the amount of constituent waste, required under the WEEE Directive, should be implemented simply to minimise bureaucracy and cost. In particular we want to avoid the burdensome requirement to weigh the WEEE that comes in and the materials that leave the plant. In addition, the individual producer collection route could create additional burdensome bureaucracy. (For more information see paragraph 2, Appendix B.)

3.2 HAZARDOUS WASTE DIRECTIVE

Exempt re-use/refurbishment activities from complying with the Hazardous Waste Directive. There is the potential that complying with this Directive could be too costly for small-scale enterprises like Renew. Moreover, we feel that provided the refurbisher despatched such waste through appropriate disposal routes there should be no safety requirement for a site licence. (For more information see paragraph 3, Appendix B.)

3.3 FUNDING SCHEMES

Organisations receiving funding for recycling projects, whether it be from lottery funding or the Landfill Tax Credit Scheme, should ensure that the bodies work in partnership with re-use organisations. This should help ensure that the re-use disposal option is not crowded out by recycling.

DEFRA's Waste Recycling and Minimisation Fund already operates along these lines. (For more information see paragraph 4, Appendix B.)

Renew Trust

21 March 2003

APPENDIX A

RENEW TRUST

MISSION STATEMENT

Renew Trust promotes and facilitates training in refurbishment and recycling of electrical and electronic equipment. Its projects are locally managed and aimed at the low-skilled, disabled and long-term unemployed. Renew projects product affordable goods for the social market and provide an environmentally sustainable and socially responsible alternative to waste disposal.

CURRENT OPERATION

Our current operations are:

— Gateshead: employs 30 long-term unemployed people on the New Deal programme and refurbishes 4,000 units pa and recycles around 30,000 units; and

— Leeds: permanently employs 16 people with disabilities (in conjunction with Remploy) and refurbishes 5-6,000 units and recycles more than 40,000 units.

Operations opening soon:

— Preston: due to open April employing people with disabilities (in conjunction with Remploy); and

— Dagenham: due to open in April, employing 17 members of staff, 12 trainees and 15 volunteers. It will operate with Ozone Friends, a Quaker charity.

FUTURE EXPANSION PLANS

We plan to expand Renew depots close to other Comet distribution points: Plymouth, West Bromwich, Bristol, Birkenhead, Nottingham, Thetford, Aylesbury/Luton, Woolwich and Eastleigh. By the end of 2004, we hope to provide training for 600 unemployed and people with disabilities which should underpin full time employment for more than 150 people around the country. Also, the programme should be reprocessing around 488,000 white goods pa with around 20% being refurbished for sales to the community, housing associations and social services.

Not only does Renew have plans to expand its geographical range but also to diversify its activities. It intends to expand the range of electrical goods it refurbishes and the partners with whom it works (such as local authorities, small businesses). We are also looking at opportunities to expand sales by exporting refurbished goods.

CURRENT ECONOMIC VIABILITY OF RENEW

Renew Trust has £1.4 million in total promised from the Landfill Tax Credit Scheme up until the end of March 2004. Renew Trust and the various Renews receive funding from a range of sources including Comet, the Single Regeneration Budget, European Social Fund, European Regional Development Fund and some charitable funds. The New Deal Scheme pays for a significant number of trainees' wages.

Renew schemes are based close to Comet distribution points. We take the white goods that they collect from households under the "take-back" scheme.

This process is currently economically viable because there is no charge for disposing of those goods that cannot be refurbished.

APPENDIX B

SPECIFIC POINTS ARISING FROM THE WEEE DIRECTIVE

1. "Crowding out" of re-use

The Directive indicates that the priority should be on the re-use of WEEE and its components, subassemblies and consumables. Also the intention is that producers should be encouraged to integrate recycled material in new equipment.

However, the Directive states that where reuse is not "preferable" the WEEE should be sent for recovery. As has been mentioned, the recyclers have little incentive to sort out their waste into those units that can be re-used and those that can be recycled. Our concern is that the recyclers could "crowd out" the re-use market. To ensure that the priority should be on re-use, as required by the Directive, we believe that the Government will need to design the regulatory framework to ensure re-use thrives, and contributes to the diversity of waste disposal providers.

It is important to safeguard re-use so that the balance does not tip too far in favour of recycling. "Crowding out" of re-use would be against the spirit of the Directive. This is why we recommend the Government requires recycling companies to incorporate refurbishment into its operations. This could be either by working alongside refurbishing organisations or by extending their own in-house operation to include refurbishment. The refurbishing unit would identify those units and components which could be re-used, and the recyclers would shred the remaining material. They could then work in co-operation rather than competition to achieve the national objectives.

2. Information compliance

The WEEE Directive imposes various requirements on waste operators to record processed material, so the Government can assess levels of overall UK compliance. The way such requirements are implemented at operator level could determine how bureaucratic, impractical and time consuming they might be.

The Directive refers to collecting information according to both the number of items as well as their weight. This should give us the flexibility to quantify the waste in the most practicable way. This is welcome.

Some requirements for recording the amount of material coming in and going out of Renew could be onerous and complicated. For example, if washing machines are deconstructed, and the shells squashed for selling as scrap to the merchants, it would be impractical for Renew to record individual numbers of units. It would be easier for the scrap merchant to give proof of sale by weight and have some idea of what each set of waste is likely to contain. However, as we typically do not have a weighbridge (or are unlikely to afford installing them) we cannot weight the material in.

One way of implementing this requirement would be to follow the precedent set in the waste packaging regulations where processors have agreed with the Environment Agency the proportion of packaging contained in particular waste streams. The formula can be applied to estimate the quantities of plastic, paper, glass etc in any quantity of waste. This formula is now applied to all packaging waste so processors can easily assess the constituent proportions of their waste with the minimum burden.

The same principle could be applied to the implementation of WEEE. The Government should ask the Environment Agency to produce a similar overall formula that could be applied to all WEEE waste.

SPECIFIC ISSUES ARISING FROM THE HAZARDOUS WASTE DIRECTIVE

3. Permits to operate

Under the Hazardous Waste Directive, it is possible that refurbishers might have to meet special requirements so as to gain a permit to operate. This could include proof of technical competence and compliance with certain physical characteristics eg the installation of concrete platforms, provide areas that can be watered down. We do not believe that the refurbishment operations pose significant hazards to the environment and do not need to be licensed in this way. But for a relatively small operation such as Renew, the costs of investing in upgrading existing and future depots to meet these requirements could be disproportionately high, threatening Renew's survival.

This is why we recommend that the Government allows refurbishing activities to be exempt from hazardous waste compliance legislation. The precedent for exemptions already exists with the 1994 Waste Management Licensing Regulations. Section 17 of those Regulations exempts certain waste disposal activities from the licensing process (set out in Schedule 3 of the Regulations). We believe these exemptions should also apply to medium sized disassembly operations.

FUTURE FUNDING ISSUES

4. Funding schemes including the Landfill Tax Credit Scheme

Funding is available from a range of sources for a community waste organisation such as Renew. In the UK, we already receive funding through the Landfill Tax Credit Scheme (LTCS) and the Single Regeneration Budget. But funding for community waste projects could also come via the New Opportunities Fund and DEFRA's Waste Minimisation and Recycling Fund.

Renew has been receiving funding under the LTCS. So far it has earmarked £260,000 and has been promised £1.4 million up until the end of March 2004. Renew falls under category (cc) of the Landfill Tax Regulations (1996): "for the purpose of encouraging the development of products from waste or the development of markets for recycled waste—(i) research and development; (ii) education; or (iii) collection and dissemination of information about the development of products from waste or the development of markets for recycled waste".

The Government proposes to reduce the amount of money going through these qualifying organisations. It is likely that after March 2004, Renew will no longer qualify for funding directly under the LTCS. It will be channelled through other public funding programmes from DEFRA to local authorities and other public bodies. We welcome the Government's recent decision to allow the funding to these qualifying organisations to continue until 2004, so Renew should receive £1.4 million as it was promised until the end of that period.

However, it is disappointing that two thirds of the LTCS "pot" will be channelled through other routes. One way to ensure that the re-use sector is not disadvantaged by this change in funding, is to require organisations that receive funding through the replacement vehicle for the LTCS to work in partnerships with re-use organisations. This could also apply to other forms of funding such as that provided by the Waste Recycling Action Programme. The precedents for this are the Waste Minimisation and Recycling Fund and Transforming Waste. Two of the five priorities for this funding are partnership working and the development of community initiatives. Whilst we have yet to see this work in practice, it is one way of ensuring the future of the community sector in waste management and re-use as a significant contribution.

51 The Hazardous Waste Directive impacts on refurbishing WEEE as these goods often contain hazardous waste covered by this Directive. Back



© Parliamentary copyright 2003	Prepared 22 May 2003