Memorandum submitted by the Environmental
Services Association
ESA is the sectoral trade association for the
United Kingdom's waste and secondary resource management industry,
a sector contributing around £9 billion per annum to GDP.
Our Members wish to recover more of the value contained in the
UK's waste whilst continuing to protect the environment and human
health.
MITIGATING CLIMATE
CHANGE
The waste management industry handles huge volumes
of waste carbon. This carbon can either contribute to UK emissions
of greenhouse gases, mainly as a result of methane emissions from
landfills, although as described below this methane is also one
of the UK's main sources of renewable energy, or it can result
in net reductions of emissions of greenhouse gases through energy
recovery or materials recycling.
The waste management sector has already made
significant strides in reducing emissions of greenhouse gases.
Between 1990 and 2005 methane emissions from landfill fell by
61%. Much of this reduction was a result of methane being captured
for energy recovery, offsetting energy production from fossil
fuels although some methane has been flared. Modern landfills
can capture over 80% of methane generated and as a result produce
about one third of the UK's renewable electricity.
However the UK faces a huge challenge if it
is to comply further with EU law and deliver the Government's
objectives set out in the waste strategy:
— thousands of new, smaller and geographically
dispersed waste management facilities are needed to replace landfills.
National and local government policies must facilitate the development
of such facilities;
— Defra believes the UK must invest
£11b in new waste management capacity by 2020; and
— England must reduce the annual amount
of Biological Municipal Waste (BMW) landfilled to 11.2 million
tonnes by 2009-10, 7.5 million tonnes by 2012-13 and 5.2 million
tonnes by 2020. If it does not, the UK will be liable for EU fines
of up to £500,000 per day.
Since 2002, the Landfill Allowances Trading
Scheme (LATS) and the landfill tax have been the principal drivers
to reduce the landfill of MSW but these policy instruments can
only deliver compliance with EU law and associated carbon savings
if sufficient alternative infrastructure is available to manage
waste.
A more responsive planning system is needed
because obtaining planning permission remains the single biggest
barrier to the timely delivery of new waste management infrastructure.
The Planning Bill currently proceeding through Parliament should
be used to ensure proposed planning reforms adequately address
England's waste management needs in the context of the impending
targets of the EU Landfill Directive.
In principle, the Government's proposals to
devise a National Policy Statement for waste could help to deliver
a range of waste management infrastructure. However, the current
focus on large scale infrastructure is too narrow: instead, policy
should recognise that waste management facilities of varying sizes,
types and capacity are essential.
The reduced biodegradable content of Municipal
Solid Waste ("MSW") being sent to landfill will reduce
methane generation in landfill. However given the lag in waste
disposal, subsequent capping of the site, and the beginning and
peak of gas production, significant volumes of landfill gas will
still be produced for decades.
Operators should be incentivised to continue
to capture and generate energy from landfill gas. However HMG's
Energy Review in May 2007 actually reduced the incentive
for operators to generate electricity from landfill gas by reducing
economic support under the Renewables Obligation.
Given the right economic incentives, much more
energy could be generated from waste—whether from landfill
gas or other sources—using a range of technologies and offsetting
carbon emissions from fossil fuel-sourced energy. The UK continues
to generate much less energy from waste than other Member States
and ESA has called consistently for all energy from the biodegradable
fraction of MSW to be supported by the Renewables Obligation,
no matter what technology is used to recover energy.
ADAPTING TO
CLIMATE CHANGE
While mitigation of greenhouse gas emissions
will continue to be central to the UK's response to climate change,
the high post-industrial levels of carbon dioxide already in the
atmosphere mean that some of the impacts of climate change are
already unavoidable.
Climate change models suggest that flood risk
in the UK will increase, with the likelihood of more intense storms
increasing as well. This will impact upon existing waste management
infrastructure as well as affect the appropriateness of the design
of new facilities. It is therefore essential that HMG provides
the necessary support for planning authorities to consider properly
climate change impacts when making long term decisions about the
location and design of waste management facilities.
The predicted climate change impacts will also
have the potential to disrupt supporting infrastructure and business
continuity. It will become imperative for HMG to have suitable
disaster plans in place to overcome disruption and ensure that
impacts to human health and the environment are minimised. Diverting
waste to alternative destinations in the event of disruption,
coupled with the increasing risk of damage to sites, would also
be likely to raise waste management costs.
21 December 2007
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