Memorandum submitted by the Waste Recycling
Group Ltd/FCC (Waste 03)
1. INTRODUCTION
1.2 FCC (Fomento de Construcciones y Contratas)
is a leading international construction and services company with
operations in Europe, South America and the United States. With
annual sales of €9.4 billion in 2006 and 92,000 employees,
the group brings a wealth of expertise to the UK market.
1.3 FCC, operating in the UK through its wholly
owned subsidiaries Waste Recycling Group Ltd and Focsa Services
(UK) Ltd, offers longstanding technical and management expertise,
a strong operational infrastructure and an innovative and service
oriented culture to help customers develop sustainable approaches
to resource management. Through its purchase of Waste Recycling
Group in 2006, FCC now has a strong investment platform in the
UK.
1.4 The FCC Group has been working with municipal
customers for over 100 years. Internationally, it has a strong
track record in large scale infrastructure projects. In the UK,
it has a growing portfolio of Private Finance Initiative (PFI),
and Public Private Partnership (PPP) contracts, including major
infrastructure and collection contracts.
2. THE WASTE
STRATEGY FOR
ENGLAND
2.1 In our view the Waste Strategy for England
is now a broadly helpful document in mapping out the route to
achieve the short to medium term objectives that are currently
being applied by legislation emerging from the European Union
and, in particular, the Landfill Directive. While there are still
some deficiencies in the strategy—mainly around funding
for the necessary waste management infrastructure and the pace
of development required—these we feel are recognised by
Government and should not stop the targets being met.
2.2 However, this strategy is all about meeting
targets and society must accept that in doing so there may be
a cost associated with it. For example, we believe there will
be a real risk of short-term redundancy being built into the decisions
on certain technologies and there will be a financial cost to
this. This is inevitable when the agenda is driven by the need
to meet short timescales and this should be recognised.
2.3 Therefore, we have to ask the question
whether the strategy addresses the long term management of resources
and materials flows, energy and carbon at a European level. We
believe it does not (it is not its intention) and much more now
has to be done.
2.4 The Government should now be looking
beyond meeting statutory waste targets and should be initiating
a public debate about addressing longer term sustainability needs.
We are, in fact, encouraged that Defra's Neil Thornton has been
given the brief for Sustainable Consumption and Production (SCP),
which recognises that waste is just one part of understanding
society's full impact on the planet.
2.5 Thus far the public debate has been
dominated by the simple imprecation that recycling is good, landfill
is bad. The Government has been successful in encouraging a wider
acceptance of this simplistic message, which we accept has been
necessary to change public attitudes quickly. However, as the
strategy begins to deliver, the weaknesses of this crude message
are beginning to show.
2.6 For the UK in particular, the main target
of a waste prevention and recycling strategy should be to reduce
the volume of untreated waste that goes to landfill and divert
it to recognised waste treatment facilities for recycling and/or
energy recovery. Existing end-of-life legislation should encourage
the development of all recovery options by setting indicative
targets for waste streams and material-specific recovery rates.
Such an approach would be consistent with the EU's Thematic Strategy
on the Sustainable Use of Natural Resources, since waste should
be considered as a significant element of Europe's energy and
material resources.
2.7 For materials such as glass and ferrous
metals, mechanical recycling is the only possible recovery option.
While a material-specific target might be meaningful for some
materials of this group, for others, such as glass, an overall
material target is not appropriate due to the fact that container
glass and flat glass, for example, are separate products serving
different markets, with completely different material requirements.
This means that target setting could encourage recycling in areas
that have no economic or viable market.
2.8 Organic materials such as paper, wood
and textiles offer, in principle, the opportunity for two recovery
options, namely recycling and energy recovery. Paper, for example,
which is readily available in a homogeneous form and for which
sustainable and sufficiently large recycling markets exist, overall
recycling targets may be useful.
2.9 Materials such as plastics, however,
are another matter. PlasticsEurope says[1]
that plastics offer a great diversity of incompatible product
types and numerous applications in complex products, and they
are found in a multitude of waste streams: "Separate collection,
or separation for recycling, is often not justified from an eco-efficient
point of view."
2.10 PlasticsEurope goes on to say
that when the whole life-cycle of a product is taken into consideration,
recycling targets can even be detrimental to the overall environmental
impact. If a car manufacturer replaces a plastic part with a heavier
alternative in order to achieve a higher specific recycling target,
then this will be at the expense of fuel consumption and associated
climate change, due to higher weight during the use-phase. It
is estimated, that plastics as lightweight materials in cars reduce
CO2 emissions by more than 30 million tons per year.
2.11 PlasticsEurope, therefore, see
the recovery of energy from plastics waste as an important option
for the management of the resource locked up in the material.
In 2005 29% (ie 6.4 million tonnes) of post consumer plastics
waste was recovered as energy in the EU25 plus Norway and Switzerland.
2.12 It is the balancing of these complex
issues concerning resource flows that go beyond the boundaries
and remit of the current Waste Strategy for England.
3. BEYOND WASTE
MANAGEMENT
3.1 The UK's "catching up", in
terms of meeting recycling targets, is a transitional period.
The EU identifies Sustainable Consumption and Production (SCP)
as one of the key challenges to be addressed in the context of
its long-standing commitment to meet the overall challenges of
sustainable development. A raft of EU policies now provide the
building blocks for this strategy, including its Thematic Strategy
on Waste Prevention and Recycling.
3.2 The history of UK legislation affecting waste
management over the past 15 years shows that this has been driven
from the EU. The UK must recognise this and engage in the next
round of EU policy setting for sustainable development—something
that is bound to change our environmental legislative landscape
over the next 25 years.
3.3 The next step for the UK is to examine
the role of whole life-cycle thinking for products and material
streams, so that we can better judge the environmental impact
(including that of carbon). By increasing understanding we can
improve the decisions and choices we make for the management of,
and final treatment of, waste streams.
3.4 A clearly stated goal of the EU is to
decouple resource use from economic growth and, at the same time,
decouple environmental impact from resource use. The Government
should develop a "resource map" for the UK that tracks
the flow of both natural and recycled resources. This work would
then link naturally, in our opinion, with the EU's strategic panorama
for sustainable development across Europe and beyond.
3.5 Ultimately, the Government should position
itself to set and drive the European resource management agenda
and through which it can take the lead in developing the systems,
processes and technologies that would encourage positive economic
development in the UK.
Waste Recycling Group Ltd/FCC
September 2007
1 PlasticsEurope's comments on material specific
recycling targets as proposed in the Communication Towards a Thematic
Strategy on the Prevention and Recycling of Waste (COM (2003)
301). www.apme.org Back
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