Memorandum by the National Audit Office
(RC 31)
INTRODUCTION AND
SUMMARY
1. The Comptroller and Auditor General reported
on the Department for Environment, Food and Rural Affairs' progress
in reducing the reliance on landfill for refuse disposal in England
in July 2006. The report examined the Department's actions to
help achieve the Landfill Directive targets, local authorities'
progress in developing alternative methods of waste disposal and
progress with recycling and minimisation initiatives.[1]
On the basis of that report the Committee of Public Accounts took
evidence from the Department for Environment, Food and Rural Affairs
in January 2007, although the Committee has yet to issue a report.
2. This memorandum by the National Audit
Office sets out the findings from the Comptroller and Auditor
General's report that related to refuse collection at the time
of publication in July 2006. The memorandum has been prepared
with a view to assisting the Communities and Local Government
Committee in its consideration of that subject.
SUMMARY
The Landfill Allowance Trading Scheme provides a financial incentive for local authorities to divert biodegradable municipal waste from landfill, but the absence of timely and accurate data could undermine the effectiveness of the Scheme (paragraphs 3 to 7).
At the rate of progress found at the time of the NAO report, there was a significant risk of local authorities failing to divert sufficient biodegradable municipal waste from landfill to meet European Union targets (paragraphs 8 to 12).
The amount of waste recycled each year has increased considerably, but it will become more difficult to maintain this rate of increase (paragraphs 13 to 19).
Initiatives to get businesses and households to minimise waste remain at a very early stage (paragraphs 20 to 23).
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THE LANDFILL
ALLOWANCE TRADING
SCHEME PROVIDES
A FINANCIAL
INCENTIVE FOR
LOCAL AUTHORITIES
TO DIVERT
BIODEGRADABLE MUNICIPAL
WASTE FROM
LANDFILL, BUT
THE ABSENCE
OF TIMELY
AND ACCURATE
DATA COULD
UNDERMINE THE
EFFECTIVENESS OF
THE SCHEME.[2]
3. The Department's Landfill Allowance Trading Scheme,
which began in April 2005, seeks to encourage further reductions
in biodegradable municipal waste going to landfill and more effective
local authority collaboration in developing alternatives. Under
the Scheme, waste disposal authorities were allocated allowances
for the tonnage of biodegradable waste they could send to landfill.
The allowances from 2009-10 onwards are based on the proportions
of local authorities' waste arising in 2001-02 (ie if a local
authority had one per cent of the waste arising in England it
has been allocated one per cent of England's available allowances).
To allow a smooth transition into the scheme, allocations between
2005-06 and 2008-09 gradually decrease from the amount of biodegradable
municipal waste landfilled in the base year (2001-02) to the authorities'
2009-10 allocation. Each allowance entitles an authority to landfill
one tonne of biodegradable municipal waste.
4. The Department has confirmed that any English authority
which landfills in excess of the allowances it holds after the
reconciliation period will be liable to a financial penalty of
£150 a tonne.[3] Authorities
who already operate within their allowance could benefit from
further reductions because they are entitled to sell their spare
allowances to other authorities. Waste collection authorities,
responsible for much of England's recycling effort, are not tied
into the scheme by regulation but are encouraged to work with
waste disposal authorities to support landfill diversion and provide
waste statistics.
5. The effectiveness of the Scheme will depend on the
Department's rigour in imposing penalties and other sanctions
and on the completeness and timeliness of the data from local
authorities and waste disposal contractors. There is a potential
risk that authorities might believe the Government would not in
practice impose penalties because of the impact on council taxes,
but the Department confirmed to us that penalties will be imposed
if allowances are exceeded.
6. We found relevant data on amounts of waste sent for
treatment and disposal in the past, however, were neither complete
nor timely. During the first Scheme year many authorities failed
to meet the deadlines for quarterly reporting of waste data. By
July 2006 however, only one of the 121 waste disposal authorities
had not submitted the data for the first Scheme year (April 2005
to March 2006).
7. The Environment Agency's validation of these returns
has been delayed because in many cases the data were not of sufficient
quality to pass the first stage validation process which is required
before the Agency's validation can begin (at 10 July 2006 only
21 authorities had completed this stage for the first Scheme year).
In addition, waste disposal authorities rely on data from their
constituent waste collection authorities before reconciliation
can take place. There is, however, no mandatory requirement for
waste collection authorities to submit such returns (only waste
disposal authorities are required to supply data under the Waste
and Emissions Trading Act 2003).[4]
As a result there is a risk, that the scheme will lose credibility
due to the late or inaccurate notification of validated results
to authorities. In Wales, where the Landfill Allowance Trading
Scheme began six months earlier, the Environment Agency found
a 10% discrepancy in returns between local authorities' recorded
figures and operators' figures in the first quarter. The discrepancy
in England may be larger since in urban areas the link between
collection and final disposal passes through a number of intermediaries.
AT THE
RATE OF
PROGRESS FOUND
AT THE
TIME OF
THE NAO REPORT,
THERE WAS
A SIGNIFICANT
RISK OF
LOCAL AUTHORITIES
FAILING TO
DIVERT SUFFICIENT
BIODEGRADABLE MUNICIPAL
WASTE FROM
LANDFILL TO
MEET EUROPEAN
UNION TARGETS[5]
8. We reviewed the outputs of a Departmental steering
group set up to oversee the development of a model to forecast
the likely impact of different initiatives to reduce reliance
on landfill.[6] The model
takes account of, among other things: disposal method costs; existing
and planned capacity; build times; taxes, penalties, targets and
the Landfill Allowance Trading Scheme; and "pressure factors"
to reflect non-financial issues (eg the political unpopularity
of certain technologies reflecting public opposition).
9. To divert sufficient waste from landfill, the Department's
model indicated the need for:
significantly increased rates of recycling and
composting to around 40% by 2010;
an increased requirement for residual waste treatment,
including energy from waste (using refuse-derived fuels) for post-recycling
residues;
mechanical and biological treatment plants becoming
operational between 2005-06 and 2012-13.
10. Our participation in the Department's development
of a forecasting model enabled us to examine the rigour of the
assumptions used. The Department's modelling indicated that, if
all existing plans for waste treatment facilities were realised
within one year of their planned delivery date, the 2010 target
could be met, implying a national recycling rate of around 40%.
The Department's model implied local authority yearly municipal
waste management costs would rise from just under £2 billion
in 2003-04 to £3.4 billion in 2009-10 and £4.2 billion
in 2012-13 to fund new waste management practices.[7]
Yet such an increase could face opposition. Our survey found 39%
of the public think local authorities should be "most concerned
about minimising the cost to council taxpayers when collecting
and disposing of household rubbish." We also found, however,
that half of the public did not know how much they paid for their
waste collection and disposal. Of those that did, the most popular
choice was over £200 a council taxpayer a year. The actual
average was around £75 a council taxpayer a year.
11. The Office of Government Commerce's survey of waste
disposal authorities in Autumn 2005 asked about progress in developing
the new capacity needed to meet the Landfill Allowance Trading
Scheme allowances. Eighty seven out of 121 authorities replied,
of which less than one in five were entirely confident that they
would divert the required level of biodegradable municipal waste
and some one in three had not yet identified how they proposed
to dispose of waste other than by landfill. Based on their plans
at the time of our report, we estimated that authorities would
miss their 2010 landfill allowances by approximately 190,000 tonnes
and their 2013 allowances by approximately 960,000 tonnes.[8]
Extrapolated to a national level, the figures would be 268,000
tonnes and 1.37 million tonnes, respectively.[9]
On this basis, we estimated potential penalties could be as much
as £40 million for missing the 2010 targets and £205
million for missing the 2013 targets.
12. There is still an opportunity for authorities to
amend or develop their plans to address any shortfall in alternative
disposal capacity, although there is considerably more scope to
do this in relation to the 2013 target rather than that for 2010.
As things stood in Summer 2006, it may be too late for authorities
to bring forward plans for new residual waste treatment facilities
and have them ready in time for 2010, although such action could
contribute to meeting the 2013 target. However, completion of
new recycling and composting plants, as well as mechanical biological
treatment plants, should still be achievable if procurement processes
are already in hand.
THE AMOUNT
OF WASTE
RECYCLED EACH
YEAR HAS
INCREASED CONSIDERABLY,
BUT IT
WILL BECOME
MORE DIFFICULT
TO MAINTAIN
THIS RATE
OF INCREASE[10]
13. According to local authority reports, the proportion
of household waste being recycled or composted in England has
increased by 12 percentage points since 2001. The rate reached
23% in 2004-05, suggesting the Department will meet its target
of 25% by 2005-06.
14. The United Kingdom's recycling and composting rate
lags behind that of leading European countries. Based on 2001
data, recycling rates in the Netherlands, Austria, Germany and
Sweden were almost double the United Kingdom's. For the high waste
generators such as Germany, France and Spain, composting represents
a smaller proportion of the total amount of municipal waste managed,
but still far more than the United Kingdom.
15. Further increases in the aggregate municipal recycling
rate will not necessarily lead to increases in the biodegradable
recycling rate. About a third of household materials are not biodegradable,
such as cans, glass and plastic. The Household Waste Recycling
Act 2003 requires all authorities to collect at least two types
of recyclable waste from households by 2010.
16. Levels of recycling have increased, but local authority
data indicate wide variations in performance in 2004-05 (see Figure
1).[11] Ten authorities
(2.5%), such as St Edmundsbury Borough Council in Suffolk, recycle
or compost over 40% of their waste. In contrast, 70 authorities
(18%), such as the London Borough of Newham, recycle or compost
less than 15%. Authorities with higher recycling rates tended
to collect organic waste (mainly garden waste) directly from households
and had specific facilities to remove recyclable materials from
general household waste.
Figure 1: Differences in recycling rates between local
authorities in 2004-05

Source: National Audit Office analysis of Audit Commission
data.
17. The Department has provided £336 million in
funding between 2002-03 and 2005-06 (through the Challenge Fund)
to encourage local authorities to recycle more waste. The Department
awarded grants on the basis of bids received from high-performing
and low-performing authorities. Targets were set for each project,
although funding was not dependent on their achievement. The Department
distributed £131 million through the Challenge Fund in 2003-04,
which contributed to an increase in recycled tonnage of 166,000
tonnes against a target of 222,000 tonnes (75%). These schemes
should yield greater benefits in future years as they become better
established.
18. Although the grants are likely to have contributed
to increased recycling, there is no clear link between the amount
of the grant and the consequent increase in performance. Our analysis
of the household recycling performance of unitary authorities
between 2002 and 2005 shows that the level of Challenge Funding
received by an authority does not correlate with its recycling
performance during the period.
19. In addition, the Department's Local Authority Support
Unit and WRAP Ltd's Recycling and Organics Technical Advisory
Team (ROTATE) provide advice to local authorities on recycling
practices and to encourage public participation. A review of the
Local Authority Support Unit by BeEnvironmental Ltd in December
2005 found that some 80% of 77 local authorities who offered a
view thought that the direct consultancy support, the largest
part of the Unit's programme, provided "good value for money".
A review of the Recycling and Organics Technical Advisory Team
by Exodus Market Research in September 2005 found most of the
54 local authorities contacted considered the service helpful
and that improvements had resulted, although 12 authorities (22%)
queried the quality of consultancy support. Performance appeared
to have marginally improved when Exodus surveyed local authorities
again in February and March 2006. Exodus found that, of 89 authorities
surveyed, 13 (15%) queried the quality of the consultancy support.
Sixty-six of the authorities surveyed by Exodus (74%) claimed
to have acted on advice given. WRAP commissioned NOP to evaluate
its public awareness campaign and found that by April 2006 the
proportion of people classed as "committed recyclers"
increased from 45%-57%. Almost all local authorities have benefited
from support provided by the Local Authority Support Unit or WRAP
and it is very difficult to separate the impact of these services
from other factors which might divert waste from landfill.
INITIATIVES TO
GET BUSINESSES
AND HOUSEHOLDS
TO MINIMISE
WASTE REMAIN
AT A
VERY EARLY
STAGE[12]
20. Minimising the amount of biodegradable municipal
waste produced is potentially the most cost-effective way of reducing
the amount sent to landfill. There are two main approaches: encouraging
producers to reduce packaging and other materials likely to end
up as waste; and encouraging households to reduce waste (for example,
by having their own compost bin). Both programmes reduce the burden
on local authorities collecting, treating and disposing of waste.
21. WRAP has instigated a number of projects to minimise
volumes of waste generated. The projects could lead to reductions
in waste, but progress is likely to take time:
Home Composting Schemethis is a long-term
scheme to increase diversion from landfill by preventing garden
and kitchen waste from entering the waste stream. In the three
years to March 2006 approximately £30 million was spent on
1.5 million bins, marketing, delivery and support. WRAP estimates
that, over a ten year period, with a reasonable level of take-up,
the scheme could divert 300,000 tonnes of waste a year at a cost
of about £12 a tonne a year. In some areas, though, the Scheme
is in competition with separate local authority initiatives to
collect green waste for composting.
Waste Minimisation Innovation Fund and the Retailers
Initiativethe Fund has a budget of £8 million and
aims to reduce household waste by almost 320,000 tonnes by March
2007 (£25 a tonne) by reducing packaging, preventing food
waste and improving the efficiency of distribution systems. To
March 2006, WRAP has spent some £5.5 million and let contracts
for 25 projects. Based on likely estimates of take-up, WRAP estimates
these projects offer potential savings of 330,000 tonnes, of which
60,000 tonnes would be biodegradable if fully rolled out across
the retail sector.
The Courtauld Commitmentsigned in July
2005 with 13 leading retailers who committed, through individual
projects yet to be announced, to: reduce growth in packaging waste
by 2008; deliver absolute reductions in packaging waste by March
2010; and identify ways to tackle the problem of food waste. It
is too early to assess the impact of the Commitment but it has
the potential to make significant reductions in biodegradable
municipal waste generation.
The Real Nappies Programmeaims to encourage
greater use of re-usable nappies. The programme, estimated to
cost £2.3 million, aimed to divert 35,000 tonnes from landfill
by March 2006 (£65 a tonne). Current estimates suggest that
a cumulative total of 16,000 tonnes of biodegradable household
waste will have been directly diverted by funded projects in England
by the target date at a cost of £912,000 (£57 a tonne).
This estimate does not take account of continued benefits in future
years and wider changes to consumer choices promoted by the programme.
The balance of the programme funding has been directed at these
benefits.
22. Other countries have imposed a charging scheme on
households to reduce volumes of waste and maximise household recycling.
Our consultants found that the most common, and successful, approach
is known as "pay-as-you-throw", whereby households are
charged variable rates according to the weight or volume of residual
waste collected. The general trend was towards "two-tier"
charging in which householders pay a standing charge for waste
collection, plus a variable charge according to the amount of
waste generated. Our consultants found "pay-as-you-throw"
schemes running in Austria, Denmark, France, Ireland, Italy, Germany,
the Netherlands and Sweden. In their view, such schemes could
lead to reductions of up to 40%, but can lead to adverse impacts,
such as increased fly-tipping.
23. The Environmental Protection Act 1990 prohibits local
authorities in England from charging households directly for waste
collection.[13] Some
collection authorities, have, however, used Section 46 of the
Act to charge for additional containers, such as for garden waste,
or to restrict and specify what householders can do with their
waste.[14] In its current
Waste Strategy Review, the Department states that, in the light
of pilot projects currently underway, "Government intends
to consider the scope and desirability for additional pricing
mechanisms, including householder charging, to support the levels
of recycling anticipated to be required."[15]
1
Department for Environment, Food and Rural Affairs, Reducing
the reliance on landfill, Report by the Comptroller and Auditor
General, HC1177 of Session 2005-06. Back
2
C&AG's Report, paragraphs 2.10 to 2.14. Back
3
At the end of each financial year, each local authority has
three months to submit its data returns to the Environment Agency.
The Agency then has two months to calculate how much biodegradable
municipal waste each authority has landfilled following which
there is a one month reconciliation period during which authorities
can bank, borrow, buy and sell allowances to deal with any surplus
or shortfall in allowances. Similar schemes operate in Wales and
Scotland but there are differences regarding the application of
fines and trading of allowances. Back
4
Section 13 of the Waste and Emissions Trading Act 2003. Back
5
C&AG's Report, paragraphs 3.1 to 3.5. Back
6
The Local Authority Waste Recovery Recycling and Disposal Model. Back
7
Costs in constant 2003-04 prices. Back
8
This is net of the tonnage below allowances for authorities
who are forecasting that their target will be met, so takes into
account the impact of trading allowances. Back
9
These tonnages were grossed up to a national level using Landfill
Allowance Trading Scheme allowances for each authority in England. Back
10
C&AG's Report, paragraphs 4.1 to 4.7. Back
11
These recycling rates incorporate biodegradable and non-biodegradable
wastes. Back
12
C&AG's Report, paragraphs 4.8 to 4.11 Back
13
Environmental Protection Act 1990, Section 45 (3) No charge
shall be made for the collection of household waste except in
cases prescribed in regulations made by the Secretary of State. Back
14
Environmental Protection Act 1990, Section 46 states that the
authority may reasonably require the householder to use specific
and separate receptacles for waste to be recycled or not and these
receptacles can be provided free of charge, upon payment of a
single or periodic payment, or by the resident and at their own
expense. The Waste Collection Authority can specify the size of
the containers, where they must be placed to be emptied and what
can be put into each container. Back
15
Department for Environment, Food and Rural Affairs, Partial
Regulatory Impact Assessment of the Review of England's Waste
Strategy Annex A, February 2006. Back
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