Memorandum submitted by Professor Chris
Coggins (Waste 08)
INTRODUCTION
In reviewing the responses, I hope the Committee
will bear in mind the need for ascertaining the robust evidence
supported by sound science which should underpin such a waste
strategy for England. Too much attention is often given to un-substantiated
media comments and arguments based on out-of-date science and
data—especially with reference to the energy from waste
debate and thermal treatment of residual waste. All the available
scientific evidence points to dramatic reductions in the emissions
of dioxins from such plants since 1990—in the UK, elsewhere
in Europe and in the USA—and yet there have been proposals
in September 2007 for a UK Without Incineration (UKWIN) Network.
This network opposes waste-burning plants and these using refuse
derived fuels.
Government should take a more proactive role in linking
waste and energy strategies, based on robust scientific evidence,
with energy from waste playing a role in securing a more diverse
and secure energy supply-base at reasonable prices. This also
includes taking leadership on planning issues, balancing national
priorities and local decision-making.
My own thoughts on Waste Strategy for England 2007
and other important Consultations Papers and Research Reports
published in May 2007 are outlined in Annex 1.
Q1. How policies proposed by the waste Strategy
will be implemented and the roles of those responsible for the
production and disposal of different classes of waste—including
industrial, business and household waste. Localisation as opposed
to centralisation of waste management
1.1 There must be clear policies to allocate
waste producer responsibility on both businesses and households,
but also on Local Authorities and public bodies/organisations
in setting examples of good practice.
1.2 There is a clear need to abandon the two-tier
system of Local Authority waste management in England. This creates
anomalies in terms of responsibilities for different waste policies
(eg kerbside recycling targets for WCAs, LATS targets for WDAs).
1.3 Evidence shows that Unitary Authorities
can be more cost effective and deliver efficient and effective
public services.
1.4 The alternative would be to make waste
management the fourth utility alongside gas, electricity and water
and take waste management out Local Authority direct control,
and the problems often posed by local elections creating major
changes in waste management policies at the local level. Public
accountability and local democratic views can still be retained,
as with the example of police authorities. Creating waste utilities
could also help in the implementation of separate charging or
incentives for waste—apart from where water metres are not
installed the other utilities payments are based on the quantity
of the resource used, placing use responsibility on individual
households.
1.5 Scale of waste facilities is a key issue,
and a more robust debate is needed on the comparative advantages
and disadvantages of local, regional and national waste management
facilities and associated transport implications.
1.6 It is frustrating that in a week in
May 2007 when waste and energy policies were published that there
was very limited "joined-up thinking" between them.
At a national level, why not have a Department of Resources and
the Environment, bringing together waste and energy and also covering
climate change?
Q2. The role for and implementation of regulations
and their enforcement
2.1 Regulations must be fair and proportionate,
and where voluntary agreements are deemed appropriate they must
be underpinned by such regulations. Without such underpinning,
free-riders will always find ways of abusing the system—fly-tipping
and "waste displacement" from one managed waste stream
to another must be policed and not allowed to cause unnecessary
problems.
2.2 Beyond regulations, the courts must apply
the most rigorous of penalties.
Q3. The classification of waste
3.1 This has been a well-worn problem for
many years. Inconsistencies between UK and EU definitions of Municipal
Solid Waste (MSW) have not been dealt adequately by successive
governments, leading to confusion, evasion and lack of transparency
and accuracy in waste data management.
3.2 The Defra Consultation on MSW definition
and LATS over the summer of 2007 simply adds to the confusion.
3.3 Another major issue arose with the Waste
Strategy for England 2007 is that the text refers to waste protocols,
and in some instances household waste protocols. This is a profound
retrograde step in the since early 2006 WRAP, the Environment
Agency and Defra have been working to develop Quality Protocols,
as to when waste ceases to be waste and can be regarded as a secondary
raw material. The Compost Quality Protocol was published in March
2007.
Q4. The proposals for financial incentives
to increase household waste prevention and recycling
4.1 The focus should be on transparent charging,
with households charged on the amount of residual waste they dispose
of, and should be set at realistic rates to reflect increasing
costs (investment in infrastructure, increased landfill tax).
Q5. The role of composting
5.1 This question needs to considered alongside
Q 8, with anaerobic digestion being an additional option to those
discussed here.
5.2 Home composting has many advantages in terms
of household behaviour and reducing the amount of biodegradable
waste being set out for kerbside collection. If a model can be
developed which is robust and transparent (such as the one developed
by WRAP), then home composting should play a role in helping Local
Authorities meet their LATS targets—subject to such a model
being approved by the EU.
5.3 Community composting can be very significant
in some local neighbourhoods, being very dependent on keen activists
with support from the Local Authority and the Environment Agency.
5.4 With Best Value performance Indicators
for composting, many Local Authorities introduced kerbside collections
of garden/green waste. Whilst contributing to a composting target,
overall tonnages increased thus offsetting some of the gains.
5.5 Traditional windrow composting can now
only be used with inputs which do not contain animal by-products,
requiring very careful monitoring and control, both with reference
to household behaviour and receipt and processing at the composting
site.
5.6 For garden/green waste containing animal
by-products, the only option is to use in-vessel composting (IVC)
systems—with greater capital cost and less practical experience
in the UK. In addition to processing household food waste, a number
of companies now promote the use of IVC by food handling/processing
businesses, ranging from bakeries to restaurants and large retail
outlets.
5.7 Collecting food waste has led to considerable
media interest in potential problems (smells, flies, rats) where
such waste is collected on alternate weeks. WRAP now advises that
food waste should be collected weekly.
5.8 With reference to food waste, at least
one Local Authority (Hereford and Worcester[13])
has decided to pursue an alternative option, that of kitchen waste
sink digesters or macerators. In the USA c.50% of household have
such systems, whilst the figure in the UK is only 5%. Household
are being offered rebates of £80 to install such systems.
UK water companies have come out against their introduction, quoting
greater water use, problems with sewer blockages, smells, rodents
and impacts on sewage treatment plants (especially screens). The
high carbon content could, however, complement the high nitrogen
content of sewage sludge.
5.9 Apart from home and community composting,
increased quantities of compost or compost-like outputs will require
markets. A Quality Protocol for Compost was published in March
2007, but there have still been concerns as to the quality and
potential end-uses. It is likely that brownfield sites and regeneration
offer more opportunities than agricultural land.
Q6. The Government's approach to waste minimisation,
for example consideration of responsible packaging, including
examination of the different materials used and the potential
for reusable and return schemes
6.1 To begin with, it is frustrating to
see the term "minimisation" used—for fire, crime
and health the term "prevention" is used. Minimisation
is a woolly term which is difficult to substantiate and quantify.
6.2 For packaging, there are the Essential Requirements
Regulations—in existence since but with its powers rarely
used, partly due to the intended role of Local Authority Trading
Standards Officers. It would have been better if the Environment
Agency had responsibility for these Regulations, in addition to
their role with producer responsibility and packaging recycling/recovery.
6.3 Lightweighting has long been practised
in packaging, and will no doubt continue.
6.4 Two recent case studies announceds in
September 2007 concerned PET lightweighting, by Coco-Cola Enterprises
(500 ml bottle reduced from 26g to 24g, while maintaining its
iconic shape) and Easterform Packaging (500 ml bottle reduced
weight by 20% and two-litre bottle by 5%).
6.5 Other industrial reactions to the packaging
debate include shippoing wine into the UK in bulk and bottling
it here, and switching from glass to plastic bottles.
6.6 Although returnable packaging is used
elsewhere in Euruope, it would take a major change in behaviour
supported by appropriate infrastructure and advertising for such
systems to be re-introduced to the UK.
Q7. The potential for the proposals in the
Waste Strategy to tackle the UK's contribution to climate change,
in particular through the reduction of methane emissions from
landfill
7.1 The generation of methane from landfill
is a very small component impacting on climate change. With the
Landfill Directive this will continue to decline, as methane emissions
from landfills in the EU have declined dramatically over the last
20 years—quoted to be by 49% since 1990.
7.2 Whilst very high profile, there is still
debate over appropriate methodologies and robust scientific evidence
to underpin the calculation of carbon footprints, and how different
waste and energy strategies and options impact on climate change—especially
in contrast to other impacts from transport, household and industry.
Q8. The promotion of anaerobic digestion
for agricultural and food waste
8.1 Linking "agricultural and food
waste" is possibly an incorrect link to make, as the generators
are subject to very different regulatory and administrative pressures.
8.2 As a waste management option, anaerobic digestion
has numerous advantages : ability to process animal by-products,
generation of a gas and the production of solid and liquid digestates.
The quality of the digestates can vary, and A Quality protocol
for solid digestate is due to be published in c. March 2007. The
gas can be used to generate electricity, but may need to be cleaned
and there limited opportunities for utilising any surplus heat
during the process.
Q9. The adequacy of the existing infrastructure,
such as energy from waste facilities with heat recovery ; the
UK's capacity to process materials collected for recycling ; and
the potential for Government action to encourage the most efficient
novel technologies
9.1 A report funded by Defra Economies
of Scale—Waste Management Optimisation Study by AEA
Technology Final Report was published in April 2007 which
supports the (economic) need for large waste management facilities.
Modelling was based on 11 million tonnes of residual waste to
be managed in 2010, assuming 20% is diverted organic waste and
25% diverted dry recyclables, and capacity refers to individual
local authorities. However, the report focuses on economics and
limited attention to carbon agenda.
| Practical Optimal Scale
| Local Authority
Capacity 2012
|
| (thousand tonnes pa)
| (percentage below
optimal scale)
|
Energy from waste | 400
| 100 |
| (2007 : 5 open/planned are at this scale or above, with 20 below this scale)
| | |
| ( WS 2007 says typical scale 100—500, 18 operating in UK)
| | |
| (IPC threshold = 50 MW = 1 in UK ?) |
| |
| MBT/RDF | 200 | 60
|
| (2007 : 9 open/planned at 200, 20 at 100, 10 at 50)
| | |
| (WS 2007 says typical scale is 50—250, 4 MBT (2 RDF) operating, 6 (4 may be RDF) under construction))
| | |
| Windrow composting | 50 |
70 |
| In-vessel composting | |
|
| (2007 : 5% open/planned at 50, 20% at 20-39, 75% <20)
| | |
| WS 2007 says typical scale for AD is (modular) up to 250, 3 operating, 6 under construction (none with MBT)
| | |
| MRF | 50 | 70
|
| (2007 5% open/planned at 100, 35% at 40, 60% <10)
| | |
| |
|
9.2 Apart from MBT/RDF, these are traditional waste management
infrastructure options. Energy recovery either directly or using
RDF could offer small but significant contribution to the diversity
and security of UK energy supplies.
9.3 The Government has funded eight New Technology Demonstrator
Projects, four are already operational with four due to begin
operations in 2008. Full monitoring and evaluation studies will
not be completed until 2009, and such new technologies may not
be able to play a leading in the UK until well after 2010.
9.4 A report by Juniper Consultancy Limited in September
2007 evaluated a wide range of waste management technologies (300
processes in 25 countries) and concluded that all 35 energy from
waste (incineration) processes were rated fully proven[14]
or proven, just over half of MBT/MHT processes and almost 75%
of anaerobic digestion processes.
9.5 In terms of efw (incineration) at October 2007 in
the UK, a replacement plant has opened in Sheffield (225,000—Veolia),
new operating/under construction are Hampshire (2 x 165,000, 1
x 90,000—Veolia), Allington (500,000—Focsa, was WRG),
Lakeside (400,000—Grundon + Viridor)
9.6 Approved/signed include Belvedere (585,000—Cory),
Hull (240,000—Viridor). Newhaven (240,000—Veolia),
Exeter (60,000—Viridor), Dublin (600,000—Covanta),
Perth + Kinross (60,000—Sita), Shropshire (Veolia—90,000)
9.7 Announcements have been made for new plants in Cornwall
(240,000—Sita) and Nottinghamshire (180,000—Veolia)
9.8 Commitments have been for made to include efw (incineration)
in starggeies for dealing with residual waste by Buckinghamshire
(200,000), Dunbar (450,000),include Leeds, Plymouth, Shropshire
and Cardiff.
9.9 In August 2007 SEPA announced that modern efw technology
will play an important role in managing residual waste and diverting
such waste from landfill, effectively giving the "thumbs
up" to Scottish councils to look at a new generation of clean,
efficient incinerators. This followed an announcement by the Convention
of Scottish Local Authorities (COSLA) in August 2007 that "EFW
is a safe, tried and tested way to deal with waste that cannot
be recycled and is commonly used across Europe".
9.10 The UK Government is urged to make similar a commitment
to efw (incineration), and other technologies, for treating residual
waste. All available scientific evidence shows that emissions
(including dioxins) have fallen since the early 1990s and such
plants offer little threat to human health and the environment.
The Health Protection Agency published a definitive Position Statement
stating the same in November 2005. This will require leadership
and confronting opposition from various environmental groups.
9.11 Also, as many as possible must be combined heat
and power technologies, to generate electricity (including increased
demands for cooling with climate change forecasts) and also allow
surplus heat to be captured. These plants would then meet EU criteria
as recovery operations, but issues of facility location to maximise
heat recovery and use of local grid networks will need proactive
policies, support from planning committees and relevant access
to investment. Whilst most large waste facilities are being planned
using PFI and long term contracts, Lakeside is the first "merchant"
facility taking waste from a number of Local Authorities and Buckinghamshire
proposes to access funding vie Prudential Borrowing.
9.12 In terms of the UK having the capacity to process
materials collected for recycling, there a number of major problems.
9.13 Re-processing capacity has not matched the growth
in recycling activity, despite the role of WRAP and a number of
regional market development organisations (most operating under
the name of ReMade).
9.14 There is an established and expanding global trade
in resources (but not wastes). Based on HM Customs and Excise
figures, a Parliamentary answer on 12th July 2007 quoted for 2006
8 million tonnes of metal scrap were exported, 4 million tonnes
of paper, 441,000 tonnes of plastic and 136,000 tonnes of glass
cullet.
9.15 For paper and plastics collected for recycling the
following table shows the growth since 1999.
| 1999 | 2000
| 2001 | 2002 |
2003 | 2004 | 2005
| 2006 |
Paper | 6,812 | 13,468
| 694,355 | 1.23 m | 1.99m
| 2.56m | 3.28m | 3.95m
|
| Plastic | 48,227 | 81,293
| 86,919 | 109,543 | 195,888
| | | 441,000
|
| |
| | | |
| | |
(Sources: Environment Agency, Confederation of Paper
Industries).
9.16 Exports in 2006 amounted to 50% of UK mill capacity,
with China accounting for 24%, and most exports have been at premium
prices. Since 1999 six paper/board mills have closed in the UK,
eight in 2006, with a combined capacity of 600,000 tonnes per
annum. For plastics, 75% of that collected is exported.
9.17 Public Sector Procurement is needed to stimulate
demand for recycled paper and also investment in new capacity.
SEPA has set a target of at least 50% recycled paper content for
public organisations in Scotland, and 100% target for tissue paper.
9.18 At a broader level, the ability of manufacturing
industry in the UK to use recycled materials as secondary raw
materials has been undermined by the decline in manufacturing
capacity.
— manufacturing as percentage of GDP in 1960 was
38%, by 2003 it had fallen to 15%
— manufacturing jobs in 1960 were 9 million, falling
by 2006 to 3 million (compared to 5.8 in the public sector)
— off-shoring of manufacturing capacity to countries
with lower labour costs
— manufacturing trade balance was always in surplus
before 1983, by 2006 it was £60 billion in deficit
— UK exports to China in 2005 were £2.8 billion,
whilst imports from China were £16 billion
— for every 10 containers entering the UK, 1 container
leaves
Professor Coggins
October 2007
Annex 1
Consultations Papers and Research Reports published
in May 2007
WASTE, ENERGY,
BIOMASS, PLANNING
Focus on targets and less on delivery strategies:
— weight-based recycling/composting targets dictate/become
policies, and can compromise quality and sustainability : need
for audit trails—BVPIs, LATS, Basle Green Waste
— would "valorisation" of "wastes
as resources" be better, or "outcomes"
— should the waste reduction target be per household
rather than per person ?
— consideration of a greenhouse gas emission PI
for Local Authority performance on waste
Increasing recycling collection rates and maintaining quality:
— contamination of co-mingled kerbside collected
material can be over 10%, hence the emergence of the Campaign
for Real Recycling. Greater attention needs to be paid to education
and publicity. The issues surrounding AWC need to clarified— residual
waste at MRFs sent to landfill can be more than 20% : can technology
improve compared to hand-sorting
— contamination at major re-processors can be high
: quoted as an average of 2% at Aylesford Newsprint in Autumn
2006, but can be 14%
— why have "Quality Protocols", to determine
when wastes cease to be wastes, been changed to "waste protocols"
and "domestic waste protocols"
— no Quality Protocol for SRF, yet SRF quoted in
WIDP leaflet—"Raise awareness amongst industrial intensive
users of the merits of Solid Recovered Fuel (SRF) as an energy
source"
— implementation of EU By-Product recommendations,
and expansion toi include other materials (eg pulverised fuel
ash)
— reference to food waste collections as "the
new frontier", there is no mention of bioaerosols and potential
health impact on households and/or collection operatives
— more waste displacement : household/commercial,
fly-tipping
Concerns over re-processing infrastructure in the UK:
— manufacturing as a proportion of GDP has fallen
from 38% in 1960 to 15% in 2003— manufacturing jobs
have fallen from 9 million in 1960 to 3 million in 2006 (public
sector = 5.8 million)
— the manufacturing trade balance had always been
in surplus before 1987 : in 2006 the balance was £60 billion
in the red
— for every 10 containers entering the UK, 1 container
leaves
— quality recyclables are traded globally as resources
— 50% of paper and 75% of plastics collected for
recycling are currently exported : some concerns as whether all
shipments can be classified as Green Waste under Basle Convention,
TFS notification v. confidentiality
— "piggy-backing" of kitchen waste food
waste with agricultural anaerobic digestion
— extra paper collection for recycling will have
to be exported in the "short to medium future"
Concerns over delivery of new waste infrastructure:
— NIMBYism and planning (see later) — 2,000+
new waste facilities will be needed : 15 million tonnes of new
waste processing capacity + capacity to deal with residual
waste
— the Environment Agency must be more pragmatic,
whilst managing risks to the environment and health through modern
regulation
— the cost will be in excess of £10 billion
— timescales : permission, construction, meeting
targets
— PFI and long-term contracts or "merchant"
facilities ?
— WIDP is concerned with residual waste infrastructure
and PFI
— integration with "new-build" : housing,
commercial development, eco-towns
— further clarification of the greenfield/brownfield
debate
— is the efw threshold at 50 MW too large ?
— national policies are need for smaller waste facilities
— resource and energy recovery parks + reverse-chain
logistics
Concerns over particular policies:
— whilst Annex H covers waste and resources research,
are policies based on existing robust scientific evidence
? — role of government leadership in using such evidence
to promote policies, and counter adverse media coverage
— limited details on delivery of waste prevention
— transparency of methods for charging[15]
households for collection of residual waste (see later) . . .
who pays for delivery of waste policies, landfill tax escalator,
LATS, infraction
— will charging households " . . .
drive waste reduction throughout the chain"
— over-emphasis on Anaerobic Digestion + focus on
farming AD having spare capacity
— lack of clarity on dealing with residual wastes
and balance between small energy from waste plants (no reference
to Decentralised Energy[16]
and local grid networks) and large CHP plants (better for WID)
— can voluntary producer responsibility policies,
voluntary agreements and voluntary codes succeed without safeguards
— failure of essential requirements legislation
to minimise packaging
— biggest pressure is on Local Authorities : to
introduce incentives, pressure from landfill tax escalator and
LATS, siting of new infrastructure
— how to balance national goals, local democracy
and business interests
— how can behaviour change be implemented?
CONCLUSIONS
— more detailed than anticipated, but : — an
opportunity has been lost to integrate the sustainable management
of resources, energy and the environment, together with planning
: carbon, sustainability, quality of life
— referring to "waste" protocols, the
"Waste" Strategy Board and the "Waste" Stakeholder
Group is a retrograde step in terminology
— can the waste industry deliver : capacity, skills,
funding, new entrants
— enhanced roles for the Third Sector and SMEs
— more Consultation Papers : Household Incentives,
definition of MSW for LATS, promise to consult on further restrictions
on landfilling biodegradables and recyclables
Professor Coggins
13
See Evans T (2007) Environmental Impact Study of Food Waste
Disposers. For The County Surveyor's Society & Herefordshire
Council and Worcestershire County Council. Back
14
Fully proven means more than one full commercial reference site
that has been operating for at least two years on a particular
feedstock at a relevant scale. Back
15
There still appears confusion over whether charging or incentivising
will go forward. Back
16
The Mayor of London has set a target of 25% for Decentralised
Energy in London by 2025. Back
| 
