Memorandum by the North London Waste Authority
(RC 60)
1.1 Thank you for providing North London
Waste Authority (NLWA) with the opportunity to respond to the
consultation on the above.
1.2 The Authority is one of the four statutory
joint waste disposal authorities in London and was established
in 1986 as a statutory waste disposal authority after the abolition
of the Greater London Council. The Authority's prime function
is to arrange the disposal of municipal waste collected by its
seven constituent boroughs. These boroughs are:
1.3 The Authority has a membership of 14
councillors, with each constituent borough appointing two councillors.
A twenty year contract for the transfer and disposal of the Authority's
waste was awarded to LondonWaste Ltd, a joint venture company
between the Authority and SITA UK in 1994. The Authority manages
just under 1 million tonnes of waste per annum and in tonnage
terms is the second largest waste disposal authority in the country,
Greater Manchester being the largest.
1.4 This Communities and Local Government
Committee Inquiry into refuse collection is relevant to the Authority
because the Authority has to provide the necessary services and
facilities to manage the material collected by its constituent
borough councils. The methods and frequency of collections used
by the Authority's constituent boroughs therefore have an impact
upon the Authority's operations and plans to minimise environmental
impact, meet statutory targets and provide maximum value for money
for the rate payers of North London.
1.5 The Authority has the second highest
amount of municipal waste arising in its area of any waste authority
in England and represents over 3% of the total English municipal
waste arisings according to DEFRA's 2005/06 statistics, so decisions
on waste collection services in our area (whether for re-use,
recycling, composting, recovery or disposal) will have an impact
on the country's performance against targets.
COLLECTION METHODS
2.1 The Authority's constituent borough
councils operate a variety of collection systems and collection
frequencies. These include a three times per week pick up of material
from households in one borough (two refuse collections and one
recycling collection per week) as well as the more "typical"
twice per week collections (one refuse and one recycling collection
per week). None of the North London boroughs provides an `alternate
weekly' collection, ie one collection of refuse in one week and
one collection of recyclables the following week.
2.2 Principally, the method of collection
is a matter for our constituent borough councils; however the
Authority has two particular points to make on this issue:
2.3 Firstly the Authority is concerned about
the proliferation of materials used by manufacturers that end
up in waste that councils are then obliged to collect and the
immense difficulty this creates in identifying viable markets
for the genuine recycling of these materials. The Authority notes
the steps that some retailers are making towards a reduction in
the number of polymer types for rigid containers in particular
and welcomes this move. However, it is imperative that pressure
is exerted upon producers to take account of the impact of the
myriad range of materials and mixed materials that they use in
products and the associated onward impacts upon the costs of collection
and reprocessing that this has for local authorities. The Authority
recommends that producer responsibility legislation is extended
to take account of this impact.
2.4 The second point on collection methods
is that the Authority has noted the uptake of "alternate
weekly collections" of municipal and particularly household
waste, elsewhere in the country as a way of increasing recycling
performance and makes the following comments:
2.5 The Authority recognises that many authorities
elsewhere have benefited from a move to alternate weekly collections
and accepts that with sufficient time for planning the transition
to alternate weekly collections, comprehensive management, and
communication, that such systems can offer real benefits in terms
of increased participation in recycling services and resultant
improvement in recycling rates.
2.6 Compulsory recycling has been pioneered
in the Authority's area, and food waste collections are now offered
by nearly all our constituent borough councils, both of which
are probably pre-requisite to a move to alternate weekly collections
(but by no means an inevitable precursor to the same). However,
if any of the Authority's constituent boroughs were to introduce
such a system, our main points of concern would be the potential
for increased contamination in the recyclables stream, as residents
may seek to `hide' particularly potentially odorous or otherwise
inconvenient waste that should be saved for a refuse week within
their recyclables container as a way of getting rid of it sooner.
2.7 The Authority believes that collection
authorities should not be "forced" to move to an alternate
weekly collection system as the only option available to them
to increase recycling rates and as such the Authority welcomes
the recently announced Government consultation on incentives for
householders to recycle.
2.8 The Authority would also suggest that
the Committee notes the potential impact of climate change, with
increasing mean temperatures potentially speeding up the process
of decomposition of organic waste and therefore impacting upon
what might be regarded in the future as the most appropriate collection
systems.
JOINT WORKING
3.1 The Authority supports any encouragement
that Committee wishes to give to joint working. The North London
Waste Authority and its seven constituent borough councils have
been working together since 1986, when the Authority was created.
The Authority would be pleased to share its experiences of joint
working with others.
3.2 In the North London authorities' case,
the ease of joint working is reinforced by "joined up"
financial management, which is not the case in a "two tiered"
county/district arrangement where political management and finances
are separate between the two tiers. Specifically, through a levy
arrangement the North London boroughs jointly pay for the costs
of running the Authority and the recycling, composting and disposal
services it provides for the boroughs. Each borough now pays a
share of the costs, based upon their most recently audited share
of the tonnage of waste delivered, thereby increasingly incentivising
waste prevention work too. The recently announced proposals for
joint waste authorities in other parts of the country would seem
to have recognised these benefits.
3.3 Finally, in the Authority's experience,
joint working often makes sense on a practical, economic and environmental
basis. In North London for example, the partner authorities carried
out an assessment of the best method of achieving the municipal
and household waste recycling, composting and reduction of waste
to landfill targets that have been set by Government. This assessment,
based upon the Environment Agency's assessment tool WISARD,[61]
showed that a joint "partnership approach", with relatively
few shared facilities scored more highly than a "borough
led" approach, which was based upon each borough developing
its own services and facilities independently and therefore needing
relatively more facilities and operating with lower economies
of scale.
INFORMATION PROGRAMMES
4.1 The Authority supports the national
"RecycleNow" campaign and associated "Recycle for
London" campaign on the same basis and welcomes the work
that the Waste and Resources Action Programme (WRAP) has carried
out to improve the quantity and quality of information available.
Both the national and London campaign are important vehicles for
ensuring consistency of messages across the country and for reinforcing
messages to the public and business.
4.2 The Authority urges that such information
programmes continue to be supported by central Government in the
future, but it is also important that they focus messages upon
the importance of minimal contamination of recyclable collections
and the importance of the quality of recyclate for maximising
recycling into the future.
4.3 The Committee may also wish to note
that the Authority is currently leading a campaign involving four
of the constituent borough councils which is promoting recycling
to different communities in North London. This work involves sharing
the development of materials and images to communicate messages
about recycling in 10 of the 200 community languages spoken in
North London and includes advertising on community radio stations,
print advertising and community workshops. This programme is being
funded through WRAP's Behavioural Change Local Fund.
4.4 Finally, the Authority would like to
stress to the Committee the importance of messages about waste
prevention. In many cases collection and disposal authorities
do not provide a service for waste avoidance, reduction or re-use
which can reinforce the written or verbal communication provided.
So it is doubly important that as we focus attention further up
the waste hierarchy, towards encouraging people to avoid waste
production in the first place, to reduce what they throw away
and to re-use things where possible, that comprehensive and motivating
information is provided and extensive communication encouraged,
backed up with real facilities and services.
PLANNING FOR
FUTURE SORTING,
COLLECTION AND
DISPOSAL FACILITIES
5.1 The increasing need to recycle and compost
higher proportions of our waste, and the ever closer relationship
between the specification of waste collection services and various
waste handling and treatment services means that the joint structures
seen in areas such as North London and other joint waste authority
areas are increasingly demonstrating an ability to deliver real
service improvements to residents, particularly when the urbanised
nature of our area is taken into account. The Authority suggests
therefore that the Committee should recommend the Government actively
encourages the creation of new Joint Waste Authorities, rather
than just passively create the option for local authorities elsewhere.
5.2 Secondly, the new English Waste Strategy
2007 notes the importance of business waste, which can be four
to five times the tonnage of municipal material produced in an
area. In London, the London Plan (the spatial strategy for London)
also requires London boroughs as planning authorities to plan
for the spatial development of waste facilities to handle both
municipal (local government collected household and non-household
waste) as well as other types of business waste, and the London
Mayor's emerging Business Waste Strategy appears to encourage
local authorities to move in this direction too.
5.3 However, the new national strategy gives
limited guidance on how local authorities might work more closely
with the private waste sector to finance, build and operate facilities
which process both municipal and non-municipal waste. It is not
reasonable for waste disposal authorities to be forced in any
way to take the risk of commissioning additional capacity for
business waste if it we are not able to ensure that such waste
is delivered to satisfy this capacity. But if the planning system
was to be specified so that tenderers for waste disposal authority
contracts could more easily gain planning permission for facilities
that had a higher capacity than our needs in relation to the municipal
waste stream, so that they could take the commercial risk on attracting
the much larger quantities of local non-municipal waste, and waste
disposal authorities (and our tax-payers) could then benefit from
improved economies of scale, the Authority would support such
change. Delivering change in this way would continue to keep commercial
and industrial wastes predominantly in the private sector, and
thereby ensure that increasing waste treatment and disposal costs
for this sector do not migrate into public sector spending.
5.4 If local authorities are to provide
new waste treatment facilities for commercial and industrial wastes
arising in their areas, the Authority recommends most strongly
that producers should be required to pay for all the associated
costs. Producer responsibility legislation for example will shortly
(from 1st July) require electrical and electronic equipment (EEE)
producers and distributors to finance the free collection and
reprocessing of waste electrical and electronic equipment (WEEE)
collected by local authorities at publicly accessible re-use and
recycling centres (although this regime does impose additional
collection and handling costs on local authorities). There is
therefore no reason why the Government could not raise the necessary
finance from producers and pass this finance on to local authorities
to enable them to provide such services for other types of business
waste, or keep it wholly in the private sector.
FUNDING
6.1 Given that the Government committed
the country to the Landfill Directive and accordingly committed
local authorities to meeting the targets contained within the
Directive, the Authority argues that in line with the New Burdens
Protocol, these new burdens being placed by central government
upon local government should be financed centrally. Accordingly,
funding should be forthcoming from central government to expand
the recycling and composting collection and reprocessing services
required to meet the targets. It is unreasonable of the Government
to impose new responsibilities on local government and require
local government to raise this necessary money to finance these
additional new services from local taxpayers.
6.2 Secondly, in relation to producer responsibility,
the Authority urges the Committee to recommend that Government
extend mandatory initiatives to require producers to fully fund
the collection and reprocessing costs of products that they place
on the market, as noted above in relation to WEEE producer responsibility
legislation. Unlike the new WEEE regime however, the Authority
recommends that collection costs are fully covered by producers
too, as it is not reasonable to expect separate collection services
for increasing types of waste to be established at public expense,
nor for re-use and recycling centres to be expanded with only
cash-limited private sector contributions.
CHARGING
7.1 In North London, the Authority has been
forced to add a "LATS[62]
premium" to its non-household waste charges to the seven
constituent borough councils. Effectively this means that the
constituent boroughs and their trade waste collection customers
are paying for the disposal of their non-household waste, plus
an additional charge for LATS. This is likely to make their services
uncompetitive compared to private sector waste collection companies,
which are not currently faced with landfill limits or fines for
going over those limits. Therefore, there is an uneven playing
field between the private sector business waste collection services
and local authority trade waste services faced with the imposition
of LATS. As LATS values rise this inequality will only increase,
going against the Government's stated aim to encourage a more
holistic approach to waste management by local authorities.
7.2 There is concern within our constituent
borough councils too that any possible proliferation of small
private waste collection companies might mean that the local authority
is less able to manage its street scene (as waste would be left
out for different waste companies at different times on different
days). This would be detrimental to efforts to improve the quality
of streets and public places.
61 Now updated and replaced by the WRATE assessment
tool. Back
62
LATS-Landfill Allowance Trading Scheme. This is the scheme which
allows local authorities with surplus credits for waste which
has not been landfilled to sell these credits to authorities which
are short of credits, ie the authorities which are in danger of
going over their landfill limits set by the Landfill Directive. Back
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