Memorandum by the Environmental Services
Association (RC 17)
The Environmental Services Association ("ESA")
is the sectoral trade association representing the UK's managers
of waste and secondary resources, a sector with an annual turnover
of around £9 billion. ESA's Members seek to align economic
and environmental sustainability through delivering compliance
with relevant EU waste and environmental legislation.
The Committee's inquiry is timely as significant
changes are occurring in the way that local authorities arrange
for waste to be managed. ESA's Members collect the vast majority
of the UK's waste, from commercial and industrial customers and
from households on behalf of local authorities.
In addition to the issues set out in the Committee's
press release of 27 March, ESA suggests that the Committee also
considers the implications arising from the interrelationship
between waste collection services and the subsequent recycling,
recovery and disposal of materials.
Collection practices vary according to local
demographics, scale, and geography and need to be considered in
the context of flexibility, affordability and the requirement
to meet statutory performance targets for recycling and diversion
from landfill.
ESA notes that:
— co-ordinating different waste management
and recycling processes will be crucial if the UK is to comply
with EU law. Collection methods impact on options for treatment,
recovery and disposal of waste. Sorting infrastructure, which
itself needs to reflect global market requirements for materials,
needs material of an appropriate quality to be collected and delivered
in a coordinated manner;
— collection methodology must reflect
local conditions. As recognised in the Inquiry's Terms of Reference,
different types of housing stock call for various waste collection
systems and local demography can influence the composition of
waste: both factors impact on subsequent treatment and recovery
operations;
— local authorities must be adequately
funded to meet the Government's targets. Meeting these targets
raises waste management costs when overall local authority budgets
are constrained by competing priorities;
— new materials are often added to
recycling systems on an "as and when" basis and this
can be less efficient than taking a strategic approach from the
outset: for example, significant capital investment may already
have been made in collection vehicles and receptacles; and
— education programmes should emphasise
that collection of material is the first step in the reprocessing
chain, and focus on the need for new waste management infrastructure
to process materials collected from households.
COLLECTION IS
LINKED TO
TREATMENT
1. Collection of waste from households is
a universal service protecting human health and the environment.
It is also high profile activity: a MORI poll commissioned by
ESA in 2002 showed that two out of every three voters in the UK
consider the collection, management and recycling of waste to
be the most important local service.
2. A local authority's selection of a suitable
collection system will often depend on competing factors such
as affordability and local demography.
3. Collection is the first step in the waste
and resource management process and cannot be considered in isolation
to other parts of the reprocessing chain. Achieving statutory
targets to recycle more materials and divert waste from landfill
is dependent on collection services delivering suitable quantities
of materials to specifications reflecting the needs, which may
change over time, of reprocessors.
4. The interaction between rolling, shorter
term collection contracts and longer term treatment and disposal
contracts (which typically require more substantial investment
in infrastructure) provides scope for flexible arrangements to
manage the risk associated with the changing composition of the
waste stream over time. When such contracts are aggregated, risks
relating to the interface between different elements are managed
fully by the private sector, with operators accepting risks associated
with providing appropriate facilities at different stages during
the life of the contract. Disaggregated arrangements require the
local authority to manage changing relationships between multiple
contracts and changing configurations of infrastructure.
5. Local authorities should understand future
risks when considering the most appropriate arrangements for their
collection and treatment and disposal services and determine the
best balance of risk between themselves and contractors.
ROLE OF
DEMOGRAPHY
6. The press notice describing the Inquiry
notes that local housing stock will influence the type of waste
collection chosen. Other physical factors also impact on choice:
for example, the state of a local road network might also be relevant.
7. Local demography influences the composition
of a local waste stream. For instance, waste from higher socio-economic
groups contains a greater proportion of newspapers and magazines.
8. Such factors impact on the appropriate
choice of collection system.
AFFORDABILITY
9. Local authorities must meet the Government's
targets within spending constraints. There is a direct relationship
between household recycling rates and cost and local factors will
determine for any given authority the optimal trade off between
performance and affordability.
10. Some authorities try to improve affordability
and increase recycling by collecting waste on alternate weeks.
The Local Government Association suggests that local authorities
adopting alternate weekly schemes have average municipal recycling
rates 30% higher than other authorities.[4]
However, the Committee will appreciate that alternate weekly collections
have attracted controversy. While this might be addressed by improved
education and information, such awareness campaigns themselves
represent further costs.
11. Since 2000-01, real local authority
expenditure in England on the collection, treatment and disposal
of waste has increased by 41% and in 2005-06 stood at £2.4
billion, about 2.5% of total council spending in England. This
increase in spending is lower than both the 140% increase in recycling
achieved over the same period and spending in neighbouring Member
States.
12. Adopting alternatives to landfill appears
to be presenting some funding difficulties: the Local Government
Association has reported that Essex is facing an affordability
gap of £4 billion over the 25 year life of its waste management
project, which is the equivalent of 13% on council tax. Similar
gaps have arisen at Cheshire (£480 million), North Yorkshire
(£800 million), and Leeds which has stated that it has a
"frightening affordability gap" that cannot be contained
within capping limits.[5]
13. For five years, ESA has suggested that
direct charging should be piloted as a mechanism to increase investment
in waste management services and provide incentives for householders
to reduce and recycle waste. In 2002 Ernst and Young proposed
a direct charging scheme designed to increase investment in waste
management and generate awareness among householders without providing
incentives to fly tip waste or burn waste in gardens. The downside
is that such flat-rate direct charging provides no significant
incentive to minimise waste generation by households.
14. Ernst and Young also noted that European
experience of variable charging schemes had led to reduction in
the volume of waste produced and increases in the segregation
of recyclables. However variable charging can exacerbate fly tipping
and backyard burning of waste. In Ireland, the introduction of
variable charging immediately increased illegal waste activity,
although this tailed off relatively quickly. Significant education
and awareness raising activity, together with appropriate regulatory
enforcement, must accompany introduction of such schemes.
15. Thought would also need to be given
as to whether operators or local authorities should collect direct
and/or variable charges: local authorities failed to collect 3.2%
of council taxes in 2005-06[6]
and, if operators were asked to collect charges, the question
would arise as to whether operators would be obligated to serve
households which had not paid.
COMMERCIAL AND
INDUSTRIAL WASTES
16. The principal drivers for the management
of commercial and industrial wastes are the need to comply with
regulation—including the waste producer's duty of care—and
cost. By impacting on cost, landfill tax is the principal policy
mechanism through which the Government hopes to stimulate development
of alternatives to landfill for these waste streams. However,
funding and planning constraints mean that the development of
infrastructure has been slow. Without this infrastructure, businesses
are unable fully to respond to the rising price signal by finding
alternative waste management solutions.
17. In any case, since landfill tax was
introduced in 1996, businesses will have identified many of the
low cost opportunities for waste reduction and recycling and this
could create a lag between further rises in waste management costs
and further behavioural change by business. The fact that the
Government's landfill tax revenues fell until 2000-01 but rose
in each subsequent financial year shows that the percentage falls
in tonnages as a result of the escalator are smaller than the
corresponding percentage rises in the cost of landfill.
18. That said, for most materials recycling
rates for commercial and industrial wastes are much higher than
for domestic wastes. Defra's 2002-03 commercial and industrial
waste survey found that an average of 45% of commercial and industrial
waste was recycled, compared to current average household recycling
rates of 27% in England.
THE ROLE
OF THE
PRIVATE SECTOR
19. Private sector companies operate almost
all of the UK's recycling, waste treatment and disposal infrastructure.
In 2006 the Office of Government Commerce found that almost half
municipal collection in England was carried out by the private
sector.
20. In response to the then public policy,
the UK continued to rely on landfill in the last two decades of
the 20th Century when comparable European neighbours were investing
in alternative waste management infrastructure. This saved money
at the time but resulted in the UK's waste management infrastructure
lagging behind that of other European Union Member States. While
recycling performances have been transformed under the present
Government, in large part through reliance on Asian markets for
materials for recycling, the Government has not rushed to introduce
the necessary clear, long term framework to enable the private
sector to make the investments required to meet the UK's obligations
under relevant EU law. The Environment Agency noted in its recent
"Hidden Infrastructure" report[7]
that "the UK has one of the worst records in waste in the
European Union (EU). We are one of only three member states to
fail to meet the 2006 targets to reduce the amount of municipal
waste going to landfill".
21. Defra has stated that the UK still needs
to invest in £10 billion of infrastructure to meet landfill
diversion targets. This investment will have a profound influence
on the choice of waste collection services introduced over the
next 15 years. The private sector's experience and expertise will
enable it to remain best placed to deliver both the infrastructure
and manage the interface risks between waste collection and downstream
waste management and recovery processes.
22. It is possible that delay in developing
infrastructure to manage municipal waste could prevent local authorities
from realising their future preferred waste management options.
For example, the regulatory requirement to pre-treat waste prior
to landfill could enable the private sector to develop merchant
capacity for wastes and unless near term investment is made for
municipal waste, some local authorities could increasingly find
themselves forced to compete for treatment and disposal facilities
with commercial and industrial waste streams. This could reduce
affordability for authorities which fail to contract for the necessary
infrastructure.
WIDER RESOURCE
MARKETS
23. There is insufficient reprocessing capacity
in the UK to process waste being collected for recycling, so the
UK increasingly depends on export markets to maintain and increase
domestic recycling rates. In 2006, in accordance with the Producer
Responsibility Obligations, the UK exported 58% of the packaging
material collected for recycling. Defra's consultation on the
Review of the Waste Strategy proposed that average household recycling
rates in England rise to 40% in 2010 so the UK can meet its landfill
diversion targets. This significant increase on the current level
of 27% would increase further the UK's reliance on overseas reprocessors.
In order to provide confidence to local authorities and UK regulators,
the industry has developed the Recycling Registration Scheme which
independently audits the export of material to ensure it is lawfully
reprocessed to appropriate standards in regulated facilities.
24. Obtaining planning permission for new
treatment and recovery facilities continues to be a major constraint
to development of new infrastructure within the UK so it is likely
that exporting materials for recycling will remain essential to
avoid paying EU fines as a result of failing to divert waste from
landfill. However, to complement collection systems designed to
maximise local household recycling rates, the Government should
through its Waste and Resources Action Programme (WRAP) develop
domestic markets for recycled materials.
INFORMATION PROGRAMMES
25. Recent media campaigns have tended to
focus on sensationalising perceived negative impacts of waste
management, such as increased odour problems and potential health
impacts associated with changes to collection routines. There
have also been attacks on perceived reduction in service levels
coinciding with rising levels of Council Tax.
26. There is a need for wider-based information
programmes explaining the rationale for prospective changes in
waste management practices backed up by robust data. Such programmes
need also to highlight the need for new facilities to be developed
to recycle and recover waste, and reinforce the fact that everyone
is a waste producer.
PLANNING
27. ESA welcomed the publication of PPS10
as an improvement on previous national planning policy guidance.
However in the two years since its adoption, there has been little
evidence that planning for waste management facilities has become
more straightforward. Indeed in its State of the Nation report
for 2006, the Institution of Civil Engineers noted that no major
waste management infrastructure had received planning permission
in the previous year.
28. In broad terms, ESA supports the principles
of PPS10, and believes that the policies, properly implemented
could facilitate the infrastructure need to deliver sustainable
waste management practices. In reality, PPS10 has not yet resulted
in practical policies or faster decision making so we urge DCLG
to carry out a national review of how PPS10 is being adopted by
local planning authorities.
4 LGA Press Release, Wednesday 25 April 2007; data
taken from Defra latest Waste Municipal Statistics in England
2005-06. Back
5
LGA, "A manifesto for recycling", June 2006. Back
6
Department of Communities and Local Government. Back
7
Environment Agency, "Hidden infrastructure: The pressures
on environmental infrastructure 2007 report", March 2007. Back
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