Memorandum by the Environment Agency (RC
28)
The Environment Agency is the Government's principal
advisor on the environment. We regulate waste management activities
and monitor Waste Disposal Authorities' (WDAs) progress towards
achieving landfill diversion targets, we have powers to tackle
fly-tipping and other waste crimes and we are a consultee on planning
applications for waste management facilities.
WDAs and Waste Collection Authorities (WCAs)
are responsible for implementing strategies for the effective
collection and management of household waste within an overall
policy framework set by central Government. We have an interest
in the collection and management of waste because the approach
taken by Local Authorities (LAs) directly affects the number and
type of waste management facilities, along with levels of fly-tipping
and other waste crimes, all of which can have an effect on the
environment and human health.
SUMMARY
— Effective collection of refuse is
key to ensuring its sound management to protect health and the
environment and to prevent fly-tipping.
— Collectively we need to reduce the
amount of waste produced and disposed of, especially to landfill.
We also need to recover more resources from waste.
— Local authorities have targets to
reduce the amount of Municipal Solid Waste (MSW) that they dispose
of to landfill.
— Businesses, especially small businesses,
face difficulties in recycling and disposing of their waste properly.
— Provision of waste management services,
infrastructure and tackling fly-tipping are key LA roles.
— There are some disincentives for
LAs to collect waste from businesses as this counts against their
targets to reduce MSW being disposed of to landfill.
— Targets encourage the international
trade in waste. This can be done lawfully and is part of a global
economy trading in valuable resources. However, there is scope
for illegal exports and LA need to address this through their
contractual arrangements.
— A flexible approach to waste management
services is required to meet the needs of local communities.
— Effective engagement with communities
is necessary to encourage recycling and prevent fly-tipping.
1. INTRODUCTION
1.0 Effective collection of waste (refuse)
from households and businesses is key to ensuring the sound management
of waste to protect health and the environment and to prevent
fly-tipping and other waste related crimes.
1.1 Collectively we need to reduce the amount
of waste we produce and dispose of, especially to landfill. We
also need to recover more value from waste through recovery and
recycling.
1.2 Government implementation of the EU
Landfill Directive has rightly emphasised the need to reduce the
amount of Biodegradable Municipal Waste (BMW) being landfilled.
This is achieved in part through the Landfill Allowances Trading
Scheme (LATS) in England, which allocates allowances for the amount
of BMW that each WDA may landfill.
1.3 There are 121 WDAs in England comprising
81 unitary authorities and 40 second tier WDAs, where separate
WCAs make arrangements for the collection of household waste.
1.4 Landfill allowances may be "traded".
WDAs that achieve high rates of diversion of waste from landfill
can trade their surplus allowances with WDAs that have insufficient
allowances. Some WDAs may consider trading to be the most cost
effective means of achieving their allowance allocations
1.5 WDAs and WCAs have to report the types,
quantities and destinations of MSW that they manage to the Environment
Agency. We act as the monitoring authority for the scheme and
report to Defra on LA performance against the targets. LATS targets
are a key driver for changes in LA waste collection arrangements,
encouraging LAs to develop and implement strategies to divert
waste from landfill through increasing recycling and recovery
rates.
1.6 Whilst trading may seem to discourage
LAs from diverting waste from landfill, its flexibility does address
the very real difficulties some LAs may face in introducing cost
effective diversion schemes due to local circumstances. LATS targets
currently do little to reduce the total amount of municipal waste
produced as they are only concerned with how waste is managed
once collected. Future, tougher targets may result in strategies
that place greater emphasis on waste minimisation.
1.7 Where LAs collect business waste, this
too counts against the LATS targets. Waste that is collected by
a private sector waste management company does not count against
LATS targets. This is a disincentive to the LA to collect business
waste. Removing such disincentives may help improve overall collection
and recycling efficiencies, with more waste being recovered.
1.8 Recycling targets have encouraged the
export of some MSW for recovery. Such international trade in waste
for recovery is part of the global economy and can be done lawfully.
It is part of an important shift in thinking from viewing these
materials as "wastes" to thinking of them as "resources".
However, there are opportunities for illegal exports where those
shipping the waste overseas do not abide by the rules. LAs should
take an active role to ensure recyclates destined for export are
managed legitimately, for example through their contractual arrangements.
1.9 Many of the products UK consumers buy
are manufactured overseas and shipped to this country. Some growing
economies overseas obtain resources from recovery of what to us
are wastes. Provided the governments of the receiving countries
have indicated they will accept the waste, that it can be handled
without harm to the environment or health and the necessary laws
are complied with, exports are permitted.
1.10 The potential for large profits from
exporting wastes, provides an incentive for the law to be broken.
We recently prosecuted one company involved in exports of waste
and we estimated that they made £400,000 through their activities.
They were fined £55,000 and had to pay costs of £85,000.
Such illegal export may harm the environment or health and it
may harm the UK's reputation. As with other waste-crimes such
as fly-tipping, it also undermines both the Government's attempts
to achieve more sustainable waste and resource management and
the investment of lawful waste management businesses.
RESPONSES TO
THE COMMITTEE'S
MAIN ISSUES
2. THE WAYS
IN WHICH
LOCAL AUTHORITIES
COLLECT AND
MEASURE WASTE
AND HOW
DECISIONS TAKEN
BY LOCAL
AUTHORITIES ABOUT
COLLECTION/DISPOSAL
METHODS AID
OR CONSTRAIN
FUTURE COLLECTION
METHODS AND
MINIMISATION
The scale of the challenge
2.0 Defra data[13]
indicates that around 28.7 million tonnes of municipal waste was
collected in England in 2005-06, including waste from households.
However, household waste is a relatively small proportion of the
total amount of all wastes produced. For every tonne of household
waste produced, commercial, industrial and construction businesses
produce another six tonnes.[14]
2.1 Defra data also indicates that the amount
of household waste recycled is increasing. The 2005-6 municipal
waste statistics for England show a further increase in household
waste recycling and composting to 26.7%. They also show:
— a decrease in the amount of municipal
waste sent to landfill, down 1.9 million tonnes to 17.9 million
tonnes;
— a 3% decrease in total municipal
waste collected, reducing from 29.6 million tonnes to 28.7million
tonnes.
2.2 However, Defra also say the long-term
trend in MSW arisings suggests continued growth of around 0.5%
per annum on average over the last five years.[15]
The reasons for annual fluctuations around this trend are complex
and could, according to Defra, reflect a range of seasonal and
other factors.
2.3 In 2006, the National Audit Office (NAO)[16]
estimated, based on 2003-04 data, that LAs in England will need
to reduce the amount of waste they landfill by at least 3.5 million
tonnes to meet the 2010 target. The NAO also estimated the need
for a further reduction of 3.7 million tonnes to meet the 2013
target, plus another 2.3 million tonnes reduction for 2020. LAs
that fail to achieve their targets will suffer financial penalties.
Local authority and householder responsibilities
2.4 WDAs make arrangements for the management
of collected waste. WCAs are required, with limited exceptions,
to make arrangements for the collection of waste from households.
They may do this "in house" or they may employ a private
sector company to provide the service. LAs may charge for some
collections such as bulky household goods. Not all LAs choose
to charge, and of those that do, different LAs apply different
scales of charges.
2.5 Ensuring that the environmental impacts
of waste management are acceptable is important. We have recently
launched a new life-cycle tool, WRATE,[17]
to assist local authorities and other waste managers to make informed
decisions on the environmental impact of a range of waste management
options.
2.6 Research for Defra[18]
suggests that poor waste management services, including collections
of bulky household goods, may contribute to fly-tipping. There
is no direct evidence that for bulky waste collections, charging
alone provides an incentive for fly-tipping. What seems important
to uptake of the service is the level of public awareness of the
services offered and how accessible they are.
2.7 WCAs also have to provide receptacles
for waste, for which a charge may be made. They may provide different
receptacles for different wastes and may require householders
to use designated receptacles—effectively requiring source
segregation of wastes. We believe that source segregation can
improve the quality of materials destined for recycling operations
and can help ensure high-quality recycled materials.
2.8 WDAs may provide "bring sites"
such as civic amenity sites for householders to take their waste
to. Some LAs also allow small businesses to take waste to these
sites, although this is not typical. We return to some of the
waste management issues faced by small businesses later in our
evidence.
2.9 More household waste will have to be
diverted from landfill to meet the required reductions in landfilling
of BMW. This will impact on the collection of waste, since source
segregation can assist with diversion. This could be achieved
through more recycling or other recovery operations or by genuine
reductions in the amount of household waste being produced. Such
"real" reductions in waste produced may depend more
on consumer purchasing choices and product and packaging design
than LA interventions.
2.10 More waste management facilities will
be required to manage the waste diverted from landfill. The Institution
of Civil Engineers has previously estimated that around £10
billion investment is required in waste management infrastructure
to meet the challenges we face.[19]
2.11 LAs have a key spatial planning role
for the provision of waste management sites. This role is normally
exercised by the same tier of LA as that of WDA usually a county
or unitary authority. Waste management facilities are often unpopular
with affected local communities. Whilst they are willing to produce
waste, communities are less willing to host waste management facilities
of any type in their area, despite often wanting to see increases
in recycling of their waste. This may be due to a partial misconception
of what modern, well-run waste management facilities such as recycling
operations are actually like.
2.12 Government planning policy on Planning
for Sustainable Waste Management is contained in Planning Policy
Statement PPS10.[20]
Amongst its key planning objectives waste planning should:
"provide a framework in which communities
take more responsibility for their own waste, and enable sufficient
and timely provision of waste management facilities to meet the
needs of their communities".
2.13 Government policy is clear and we now
need waste planning authorities, and the waste industry, to deliver
the necessary sites through the planning process.
2.14 The Environment Agency has an important
advisory role as a consultee in the planning process. We aim to
influence plan allocations and planning applications so that waste
treatment sites are established in the most appropriate locations
and so that they do not give rise to adverse environmental impacts.
Issues associated with waste collection
2.15 Waste collection is an emotive issue
for householders and businesses. Yet we all produce waste and
we must accept our shared responsibility for its collection and
treatment. Numerous media reports present negative aspects of
waste collection such as "imposition" of recycling requirements,
fortnightly collections, etc. This may be due to negative connotations
associated with "waste" and concerns over visual and
potential health effects of uncollected waste, combined with the
view that it is the LAs "job" to remove whatever waste
people produce.
2.16 The frequency of collections is a matter
for LAs. A variety of approaches have been adopted, sometimes
attracting adverse publicity. There has been an increasing trend
away from weekly collection of unsegregated waste from households.
In recent written response to a Parliamentary Question from Caroline
Spelman MP,[21]
the Environment Minister indicated that 144 LAs now operate alternate
weekly collections.
2.17 Concerns have been expressed regarding
possible health and amenity effects of these changes in waste
collection. However, recent research[22]
found "no significant adverse health effects are likely to
be caused by alternate waste collections of residual and biodegradable
wastes". It advised that "Provided common-sense measures
... [such as keeping waste tightly wrapped and bin lids closed]
... are taken, any annoyance issues (eg due to odour or flies)
can also be controlled." Whilst this research is reassuring,
it is too early to know whether public concerns can be allayed.
2.18 Public understanding of the management
of their waste is limited. Few people know the cost of having
their waste managed or what happens to it once it is collected.
In 2002 most people (56%) thought households pay more than £2
a week and more than ¼ (28%) thought more than £5 per
week.[23]
2.19 Households actually pay around £50-£60
each year in their Council Tax—which is around £1 per
week. By comparison, the average household pays more than £150
every year to have their sewage taken away and managed.[24]
This lack of awareness may adversely affect public attitudes to
waste management in general.
2.20 Successful engagement of the public
and other stakeholders is key in securing effective management
of household waste. High levels of separation of household waste
for recycling can be achieved through planned and sustained information
and education campaigns with local communities. This is even possible
in densely populated urban areas where the housing stock may make
this appear difficult, such as high-rise flats, estates, and other
high-density housing.[25][26]23,
24 LAs have powers to enforce waste separation for recycling,
should they choose to do so.
2.21 Achieving high levels of waste separation
at an economic cost in sparsely populated rural areas is a challenge.
Whilst these areas only contribute a relatively small proportion
of total household waste arising, households in cities and larger
urban areas actually produce the least amount of waste per household.[27]
2.22 It is clear that to be effective, engagement
with communities needs to address the detail of how waste should
be presented for collection as well as simply informing residents
of collection frequencies and the provision of appropriate receptacles
for the waste. LAs will have to continue to be prepared to deal
with any problems arising from waste placed out for collection
such as response to rodent and fly infestations. More effort is
needed to engage the public on the environmental outcomes sought
from changes in collection arrangements.
2.23 Concern has also been expressed that
less frequent waste collections and the introduction of additional
charges for householders, may lead to an increase in fly-tipping.
We return to this below.
Small businesses
2.24 The Federation of Small Businesses
(FSB) has highlighted the waste management problems faced by small
and medium sized businesses:[28]
Almost one third of small businesses are home-based, many produce
volumes of waste similar to householders and often have a similar
level of understanding of the rules. The FSB is also of the view
that poor availability of waste management sites for business
waste has led to an increase in waste crime.
2.25 LAs may charge small businesses for
collection of wastes through trade waste agreements. The Local
Government Association (LGA) highlights work amongst local authorities
to address problems with trade waste.[29]
2.26 Recent research for Defra[30]
identified the lack of affordable and available waste management
facilities and information on their location as contributing to
increases in fly-tipping by businesses.
3. FINANCING
3.1 As highlighted above, the cost of collecting
and managing household waste makes up a small part of the total
Council Tax bill, around £50/year. The Lyons review[31]
recommended that:
"The Government should take new powers to
allow local authorities to charge for domestic waste collection,
developed in close consultation with residents and other key stakeholders"
(recommendation 7.14).
3.2 Whilst collection and management of
household waste is a matter for LAs, and where central Government
sets the policy framework, we welcome measures that encourage
the public to think about the waste they produce and that encourage
them to produce less waste and to recycle more. More visible charging
approaches could help reduce the amount of waste sent for disposal,
increase recycling rates and encourage changed behaviours eg increases
in domestic composting of organic matter.
3.3 One example of such charging is "variable
charging", whereby the charge is based upon the amount of
residual waste requiring collection. Variable charging has been
successful in some other countries, for example parts of Denmark,
Germany, Italy and others.[32]
In some cases recycling has increased by up to 40%.[33]
The question of additional charging schemes such as variable charging
is complex, although useful summaries of key issues have been
published.[34]
We would favour approaches where LAs also introduce incentives
to encourage householders to reduce waste and increase the amount
they recycle.
3.4 Flexibility is required as not all LAs
may wish to introduce variable charging approach, or may not serve
a community whose geography suits high levels (ie high-effort)
of recycling. Some may prefer trading of LATS allowances. Meaningful
trials of variable charging and comparisons with other means of
achieving high recycling rates, such as enhanced engagement with
communities, should take place before a major shift in policy
is imposed.
3.5 We have some concerns that variable
charging, along with other pressures on waste management costs
and availability of sites and services, may lead to an increase
in fly-tipping, burning of waste or other waste problems. The
evidence from Europe is mixed. Some but not all countries introducing
variable charging and other schemes have experienced an increase
in fly-tipping and other problems. Where problems did occur, they
were often short-lived. For example in Denmark a small, short-lived
increase in fly-tipping was reported whilst in Germany, no increase
in illegal disposal was reported.
3.6 Flycapture,[35]
the national fly-tipping database, indicates that tackling fly-tipping
costs LAs around £50 million every year. This is money that
is then not available for other important services. Flycapture
also indicates that over 50% of fly-tips are household refuse
sacks or other household waste. Clearly, any increases resulting
from policy changes on waste collection would be undesirable.
3.7 Joint working is essential in tackling
fly-tipping. Co-operation is required not only between LAs, but
also between departments within LAs and with other regulators
such as the Environment Agency and the Police.
3.8 There is evidence that softer approaches
alone, including door-to-door advice improves recycling in some
communities. Softer approaches seem to produce spin-off benefits
including greater social cohesion and improved feelings of "safety".
This can prevent the public feeling disillusioned with their local
waste management services.
3.9 LAs and the Environment Agency need
adequate funding to underpin any changes with effective enforcement
action against those seeking to avoid the new system. Enforcement
should follow effective communications and engagement with the
community affected to promote correct recycling and waste management.
3.10 Whilst we support the recommendation
of the Lyons' review that "Government should take new powers
to allow local authorities to charge for domestic waste collection",
we have some concerns regarding possible increases in fly-tipping.
In addition, we would be concerned if this exacerbated problems
of social deprivation. We note and agree with the emphasis that
Lyons placed on the need to develop proposals "in close consultation
with residents and other key stakeholders".[36]
4. CONCLUSIONS
4.1 Waste collection is a key public service
that is emotive and attracts a great deal of attention. Failure
to "get it right" can result in communities who are
disengaged from the challenge of waste and escalating problems
of fly-tipping. However, getting it right can result in great
improvements for the environment through reductions in the amount
of waste being landfilled and recovery of more resources from
waste that is produced.
13 Source: Defra, Municipal waste management
survey, published on Defra web-site: www.defra.gov.uk Back
14
Source: Defra web-site: www.defra.gov.uk Back
15
Source: Defra, Municipal Waste Management Statistics 2005-06. Back
16
Reducing the Reliance on Landfill in England. National Audit
Office. HC 1177 Session 2005-2006. 26 July 2006. Back
17
Waste and Resources Assessment Tool for the Environment. Back
18
Fly-tipping: causes, incentives and solutions. Jill Dando
Institute of Crime Science, University College of London. Research
for Defra. Published May 2006. Back
19
The case for a Resource Management Strategy. Institute
of Civil Engineers. January 2006. Back
20
PPS10 Planning for Sustainable Waste Management ODPM July 2005. Back
21
Source: Column 77W, Hansard. 16 April 2007. Back
22
Health Impact Assessment of Alternate Weekly Collections of
Biodegradable Wastes. Defra Waste Implementation Programme for
High Wycombe District Council. Report by Cranfield University
and Enviros Consulting Limited: February 2007. Back
23
MORI survey in 2002 reported by ESA. Back
24
Water and Sewerage bills 2007-2008. Ofwat leaflet. Back
25
Source: Recycling for flats. Planning, monitoring, evaluating
and communication of recycling schemes for flats with case studies
from the UK and abroad. Defra, March 2006. Back
26
Case-studies published at: www.londonremade.com Back
27
Source: Working our how much household waste is produced
in England. Factsheet No 5. The Open University Household Waste
Study. Last updated 15 February 2006. Published by Defra at
www.defra.gov.uk Back
28
Views expressed by the Federation of Small Businesses in their
consultation response to the review of the Government's Waste
Strategy, November 2006. www.fsb.org.uk Back
29
See the National Environment Officers Network (NEON)
position statement on trade waste recycling and managing problems
arising from LATS, available at www.lga.gov.uk Back
30
Fly-tipping: causes, incentives and solutions. Jill Dando Institute
of Crime Science, University College of London. Research for Defra.
Published May 2006. Back
31
The Lyons' Inquiry into Local Government. Final report, March
2007. Available at http://www.lyonsinquiry.org.uk/ Back
32
Waste Collection: To charge or not to charge? A final
report to IWM(EB) by Eunomia research and consulting. March 2003. Back
33
Source: Target Recycling-aiming for 50% and beyond. Friends
of the Earth, December 2904. Back
34
Direct and variable charging for household residual waste-overview
of key issues. Prepared for the Chartered Institution of Wastes
Management by Gordon Mackie Associates Ltd. January 2007. Available
at: www.ciwm.co.uk Back
35
http://www.defra.gov.uk/environment/localenv/flytipping/flycapture.htm Back
36
Source: Recommendation 7.14. The Lyons' Inquiry into
Local Government. Final report, March 2007. Back
| 
