Memorandum by the Campaign for Real Recycling
(RC 38)
1. The Campaign for Real Recycling welcomes
the chance to submit this written evidence to this inquiry. We
would be pleased to give oral evidence should this be required.
2. The Campaign for Real Recycling is calling
upon central government and local authorities to act urgently
to improve the quality of materials collected for recycling in
the UK. We contend that real recycling should be about maximising
the economic, environmental and social benefits of recycling for
everyone, from the local council tax payer to the global re-processing
industry. Our concern is that investment in those collection and
materials handling and sorting systems that begin by gathering
a range of different materials in one bag or bin and then compact
them could permanently undermine the environmental and financial
benefits of recycling. Our campaign aims to influence local authority
policy and practice, and build consensus within the UK of the
economic and environmental importance of highly separated collections
and systems that maintain the maximum economic and environmental
value from the secondary resources.
CRR STAKEHOLDERS
AND SUPPORTERS
— Community Recycling Network UK
— Community Recycling Network Scotland
— Cylch—Wales Community Recycling
Network
— Textile Recycling Association
— Tower Hamlets Community Recycling
Consortium
More information can be found at www.realrecycling.org.uk
REFUSE COLLECTION
AS A
TERM OF
REFERENCE
3. We understand that though this inquiry
is titled as looking at "refuse collection", in fact
this means all collections of material subject to discard. So
it also includes recycling collections. This is an important distinction
to make.
COLLECTION METHOD: MATERIAL
VALUES MATTER
4. Put simply, recycling collection is not
some slight variation on waste collection. It constitutes a completely
different business. Its values and pricing are completely different.
Recycling collections place a value on the material, whereas waste
collections place the value on the service. Waste collection is
generally charged per collection visit or "uplift" and
the actual amount of material is not so important. Recycling collections
value the materials and look to collect as much as possible per
visit to achieve efficiencies. The fact that the material values
don't generally cover kerbside collection costs (though they do
cover bring bank costs) in the case of domestic recycling doesn't
mean that the material value contribution should not be optimised.
Commingled systems or any systems that use MRFs have the potential
to drive up costs, if charged on a per tonne uplifted basis, whereas
source separated systems which increase recycling can drive down
costs by increasing efficiency.
5. Local authorities are tuned to spending
money to procure a service. That's what they do for the most part
and it's arguably culturally engrained. When dealing with recycling
collections we believe local authorities should be seeking to
generate revenue in the manner of a business. Currently we do
not believe that many local authorities work in this fashion.
We contend that this lack of understanding is at the heart of
the problems the UK is experiencing with regard to meeting the
Landfill Directive and associated challenges.
COLLECTION METHOD
DECISIONS
6. It is of great concern to CRR that so
many local authorities seem to be opting for commingled collections
requiring subsequent expensive sorting in MRFs. It is true that
Landfill Directive/Defra targets have put some pressure on local
authorities in England. It is also true that commingled/MRF collections
divert tonnage from disposal quickly from a standing start. The
reasons they do so more quickly than source-separated collections
is reasonably obvious: they require less sophisticated behaviour
of the householder, and that collections can be made using existing
refuse compactor vehicles belonging to the council or its waste
collection contractor.
7. From our perspective this is where the
attractions of commingling finish. We contend that selection of
the commingling/MRF approach is short-sighted and unlikely to
be best consideration for the vast majority of local authorities.
We predict that it will look and prove less attractive as time
passes and experience is gained; see paragraph 12, last two bullets.
We find ourselves unable to explain entirely why local authorities
are choosing to use the commingled collection/MRF option.
8. With suitable civic amenity and bring
facilities in support, we advocate source-separated collections
of recyclables at the kerbside. These are those where the householder
generally separates recyclables to take to a bring site, or put
in their crate, or box, such that the constituent parts are clearly
visible and easily further separable onto the collection vehicle.
These appear to us to have several advantages in comparison with
commingled collections:
— Bring sites or source-separation
deliver higher quality materials to reprocessors, and an increased
revenue from the sale of materials. We believe it should be axiomatic
that recycling collections maximise revenue from materials. wherever
possible. Colour- separated glass commands twice the price of
mixed, for example.
— In view of public scepticism about
the costs of recycling collections, we would suggest that looking
after that which the public has sorted and demonstrating having
generated revenue from it would make for good common-sense and
public relations.
— For the same reason, the public and
participating householders will have greater confidence that source
separated waste will be recycled efficiently and according to
their expectation, rather than being shipped to the Far East or
similar destinations for treatment or disposal at lesser environmental
standards than those practiced in the UK.
— Bring banks or source-separation
require much lower capital costs. Investment in bulking facilities
may be required, but this is likely to be an order of magnitude
less than that required for a MRF. Similarly, vehicle purchase
and running costs are likely to be substantially less, with a
customised compartmented truck costing perhaps £40K, by comparison
with a refuse compactor vehicle (RCV), typically costing £130K.
— Source-separation or bring banks
offers much more flexibility for the future. Additional materials
such as batteries, textiles, etc, can easily be added. The householder
can put these in the same box, and the collector can install or
designate an extra compartment on the vehicle. Flexibility for
the future is a key feature of any scheme. The wastestream will
change over time, not always predictably.
— As yet there has been no upper limit
found to the diversion possible using source-separated collection.
Supplemented by kitchen and household hazardous waste collections,
it can address all domestic material streams.
— Source-separated box-type collections
can give immediate feedback to householders by leaving material
which can't be accepted for recycling with a note, while still
taking those materials which can be accepted. Ensuring that the
householder does the first voluntary sort of their average set
out of five kilos of dry recyclables not only educates that householder
but makes, over time, for an easier and therefore more efficient
inspection by the operative.
— Wastage rates (material collected
but not ultimately recycled) are typically less than 0.5%.
9. There is consensus that source separation
protects material quality. However, research is needed urgently
on costs and carbon footprint of collection methods. The lack
of this research by government and the lack of informed debate
by local authorities constitutes an "elephant in the room"
which we hope this inquiry will have the courage to address directly,
at least in cost terms.
10. Such modelling calculations as we have
informally undertaken suggest that at best, commingling/MRF collections
might cost roughly the same as source-separated. There is a myth,
in serious need of debunking, that commingled collections, as
they appear to be simpler, must therefore be cheaper. This is
simply not the case. Indeed, our knowledge suggests that in practice,
rather more is paid for commingled collections than source separated:
see comments on funding below.
11. There are a number of problems associated
with commingled/MRF collections:
— The inflexibility of the system means
that it has an inherent maximum in the amount it can divert. It
addresses volume quickly, but can only address a limited number
of materials. Delicate or peripheral streams will simply not fit.
— MRF wastage rates are much higher
than any incurred by source- separated collections. These are
typically currently 12-15% for English MRFs.[17]
— MRF sorting is undertaken either
by human operatives on conveyor belts, or by expensive mechanical
sorting devices or both. In our view and experience is no machine
or sort line that can provide the essential quality control point
that compares with a kerbside inspection prior to loading by a
trained operative.
— Contamination restricts materials
which can be commingled. In particular, glass and textiles are
mutually exclusive, and paper is seriously contaminated if collected
with glass.
— Mixed glass from MRFs is in most
cases only fit for use as a low grade aggregate in road construction
where the intrinsic value (in carbon terms) of the material is
lost forever.
— As may be imagined, on-vehicle compaction
exacerbates this effect considerably and can cause losses, particularly
of aluminium, plastic and glass.[18]
Lost value due to aluminium contamination was estimated at £800K
last year.[19]
— There are respiratory problems associated
with working in MRFs.[20]
— The trend in recyclate market demand
is likely to be towards higher quality Commingled material may
not always be wanted in the Far East. Indeed, the used newspaper
specification in China is higher than that in the UK.
— Increasing energy prices are likely
to increase prices for recycled materials, particularly those
with high embodied energy such as aluminium, steel, glass, paper,
plastic. This is likely to shift the balance towards separate
collection to maintain quality, the more so as the price of the
materials collected separately comes closer to meeting the cost
of collection, as is happening in some places.
MEASUREMENT METHOD
12. In terms of proper measurement of diversion
from landfill, we believe there is currently some disparity between
government guidance and current practice with regard to measurement
of recycling via MRFs. The DCLG BV82 guidance is clear that "sent
for sorting" is not the same as "sent for recycling".
At least some local authorities using MRFs however would appear
to claim all material sent to the MRF as having been recycled.
At best this appears disingenuous and we welcome a thorough investigation
of the facts. Moreover, reprocessors also reject material contaminants,
which are generally higher in tonnage from MRFs than from source-separated
collections. So "sent for recycling" is still not a
true measure.
13. If these two above effects were fully
rectified, we speculate that this could possibly make a difference
to the national domestic recycling statistic of a percentage point
in a downward direction.
DEFRA ADVICE
ON RECYCLING
COLLECTIONS
14. This below is Defra's advice to local
authorities on implementation of the Household Waste Recycling
Act. As can be read, it is at least as concerned with the economic
as the environmental aspects and so is relevant to this CLG inquiry:
Market research has shown that the value of any
recyclate is significantly reduced if it is contaminated, even
if the contaminant is another recyclate. It follows therefore
that source separation of materials is the first step to maximising
the value of recycling. The Government fully supports this approach
and encourages WCAs to consider this when implementing the Act.
Separate collection of each recyclate is likely to reduce contamination
and increase the value of the recyclate more than collecting two
or more recyclates together but separate from the rest of the
waste. How significant this is depends on what materials are being
collected together and the type of receptacle or vehicle they
are transported in. Textiles, for example, can be contaminated
by liquids seeping from one compartment of the collection vehicle
to another, but even two dry recyclates like metal and glass require
additional resources to handle due to glass breakages for example.
WCAs should consider these factors when implementing the Act.
15. We are dismayed to note that many local
authorities have ignored this sound advice, in some cases completely.
FUNDING WASTE
COLLECTION
16. Local authorities are almost certainly
paying too much for their waste management service, if for no
other reason than that they're almost certainly paying too much
for their recycling collections, which are included in the terms
of this inquiry. We suspect this is the case, on average, by at
least a factor of two; see paragraphs 20 and 21 below. The reason
that it's not more widely and definitively known is that though
data collection systems for tonnage are slowly improving, no-one
is systematically collecting and analysing data on costs. It might
be argued that this is the job of DCLG, Defra or the LGA. Whilst
commercial confidentially generally prohibits formal sharing of
financial information, this should not act as a barrier to government
investigation or audit on the use of public money.
17. No real system exists, which makes comparisons
between the extremes or meaningful averaging impossible. In the
absence of such data and comparators, local authority officers
not unreasonably compare notes informally, and this has the effect
of ensuring that they remain in a comfort zone inhabited by their
peers. Such exchanges are unlikely to result in a collective question
of whether in fact they might all be paying too much. This means
that what might be considered as the going rate becomes reinforced
and unquestioned, even in formal review, when in fact authorities
could and should be seeking and obtaining greater value for money.
18. We should point out that bring bank
systems are generally very cost effective, costing less than half
disposal costs. However they are not always well supported.
19. Our view of the situation has been formed
and informed by:
— our own experience and knowledge
of household collection costs;
— knowledge of material markets, prices
and possibilities via the experience of our partner recyclable
material buyers;
— information shared informally by
authority officers, contractors and others.
20. Our understanding suggests that a local
authority undertaking separation at source kerbside collections
might reasonably expect to pay something broadly in the region
of £100/tonne, within a year after start up. Our experience
of these systems shows that the figures fall as diversion from
landfill increases and the range of materials collected increases.
The lowest we know has been achieved (and verified) is £42/tonne.
This is in Newport, South Wales, where diversion via kerbside
collection is 11,600 tonnes of dry recyclate out of a household
waste tonnage of 56,000 (21%). This cost Newport CC less than
£500K last year.
21. Exact calculations are not possible,
but such figures as we have accessed over the last three years
would suggest that many of those deploying commingled collections
into a MRF are typically paying well in excess of £200/tonne
and in some cases far more. This cost disparity, which in our
view means that many authorities are paying more for an inferior
system, needs urgent attention from DCLG and Defra.
VARIABLE CHARGING
22. The CRR supports direct or variable
charging for residual waste collections as a literal realisation
of the polluter pays principle. From our perspective, the problem
is the collection system, not the incentive scheme. With collections
where the materials are kept separate and the collection operative
has the chance to check what's in the container before accepting
it, we feel sure it will help increase diversion from disposal.
23. However, we question the wisdom of combining
variable charging with collections where recyclable materials
are mixed in one collection vehicle. In particular, our concern
is that some householders, naturally wanting to avoid paying more
for their waste collection, may actually take less care in sorting
their materials as a result, simply putting more material from
the residual bin into the recycling one. As a result, collection
systems where the collection worker is unable to sort materials
or operate any form of quality control prior to loading them onto
the vehicle will collect more of what should have been residual
waste. If on-vehicle compaction is also involved, the problem
becomes even worse. The effects will be felt first at the MRF,
where it will cause extra problems and then by the reprocessor,
who will likely simply reject more loads as being too contaminated.
24. Our summary view is that combining these
sorts of schemes with commingled collections is simply asking
for trouble and that there is an essential incompatibility between
variable charging and commingling of collected materials. Material
quality to the reprocessor will deteriorate further if these are
combined and local authorities deploying commingled collections
will, we suspect, end up paying more in gate fees without a proportionate
increase in diversion. These effects should cause authorities
to reflect on whether they are using the right collection system.
ALTERNATE WEEKLY
AND KITCHEN
WASTE COLLECTIONS
25. We include mention of this issue as
it has enjoyed an unprecedented degree of media attention in the
run-up to the May 2007 elections. In our view, the debate was
poorly informed and very confused.
26. Our understanding of the rationale for
AWC is as follows: as dry recyclable material (paper, glass, plastic,
metals, textiles) is increasingly taken out of the domestic wastestream,
kitchen (sometimes called putrescible) waste becomes a larger
component of the residue. Natural biological processes cause it
to start to smell and attract flies and possibly vermin. At some
point it has to be addressed separately as a wastestream, and
a small number of local authorities have instituted weekly collections
of kitchen waste from households. This is in line with good practice
elsewhere, most notably Italy, where some authorities are EU leaders
in kitchen waste collections. As might be imagined, the Mediterranean
climate necessitates kitchen waste collections more than once
per week.
27. The expectation is that once the kitchen
waste has been removed, the residual waste will be much less likely
to smell or attract flies, as well as being reduced substantially
in weight and volume. This should make it more tolerable to the
householder, and allow the local authority to make the residual
waste collection less frequently, with fortnightly being the logical
first step. There is a financial implication, wherein the authority
realises some savings as a result, which should offset some of
the investments made and costs incurred in the dry recyclable
and kitchen waste collections.
28. This above rationale does not seem to
be widely understood. During the recent media debate we were surprised
that commentators from the LGA and various local authorities did
not call on it to counter allegations that collection frequency
reduction was purely financially driven. Following the above logic,
it is clearly not a reduction in service at all. Comment from
Defra was conspicuous by its absence. Overall the government response
was poor, as testified by the fact that it finished with the Prime
Minister questioning the necessity for collection frequency reduction
when he should have been defending the solid logic of the necessity
for food waste collections.
29. It is worth noting that alternate weekly
collections already increase bring bank collections by a third.
Charging for waste would give them a further boost.
17 Materials Recovery Facilities, Dougherty
Group LLC for WRAP, September 2006, p4. Back
18
MRF Costing Model, Bob Graham, ENTEC Consulting, for
WRAP, September 2006, p21. Back
19
Novelis. Back
20
An Assessment of the Risks to Human Health of Materials Recovery
Facilities, Environment Agency 2004. Back
|
