Waste Strategy for England 2007 - Environment, Food and Rural Affairs Committee Contents


Memorandum submitted by Friends of the Earth (Waste 10)

  Friends of the Earth is:

    —  the UK's most influential national environmental campaigning organisation

    —  the most extensive environmental network in the world, with around 1 million supporters across five continents, and more than 70 national organisations worldwide

    —  a unique network of campaigning local groups, working in more than 200 communities throughout England, Wales and Northern Ireland

    —  dependent on individuals for over 90% of its income.

EXECUTIVE SUMMARY

  Sending waste to incineration or landfill is a waste of valuable resources and contributes to climate change. In order to tackle climate change we need a strategy that promotes reuse, recycling, and composting of waste and discourages landfill and incineration.

We therefore welcome the Government's renewed commitment to recycling and composting in the new Waste Strategy for England—particularly the promotion of weekly food waste collections for anaerobic digestion and the proposal to give councils the opportunity to reward those who recycle more.

  However Friends of the Earth was very disappointed in the proposed recycling and composting target of 50% by 2020, when the Government's own analysis has shown that a rate of 60% by 2020 would be much better for the climate.

  We consider that the proposals to deal with business waste are too weak, and too focused on voluntary measures. In particular, we believe that a ban on the landfill and incineration of reusable, recyclable and compostable waste would encourage more sustainable waste management within companies.

  We welcome the plan to set targets for local authorities to reduce residual waste. However, the waste levels suggested are too high—we can recycle, compost and prevent more than is proposed, as the proposal only assumes 50% recycling and composting and a stabilisation of waste quantity.

  Friends of the Earth would like the Government to prevent the amount of total waste produced from rising beyond 2010 by introducing a target for waste prevention. This would require action to cut down on avoidable waste such as excess packaging and wasted food.

  Friends of the Earth's full response to the Government's consultation on the English Waste Strategy is available here: http://www.foe.co.uk/resource/consultation_responses/waste_strategy.pdf

RESPONSE TO TERMS OF REFERENCE

1.   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.  We would like to make the following key points regarding this examination.

2.  We consider that waste policy should be aiming towards two overarching goals:

    —  the phase-out of residual waste, waste that is not reused, recycled or composted.

    —  waste prevention

  3.  In order to promote waste prevention, we believe that the government should adopt waste prevention targets:

    —  Zero growth of all waste by 2010, and by 2008 the Government should identify a waste prevention target for all waste for 2020

    —  A reduction target for municipal waste of 1.5% per year

  4.  The Government's own research shows that a higher recycling rate would be more environmentally beneficial. In our view we should be aiming to recycle or compost at least 75% of waste by 2015.

  5.  The Government displays a touching faith in voluntary initiatives, which is not backed up by any evidence base. Environmental improvements over the last few decades have been led by improvements in regulation. Yet the strategy makes clear that it is not proposing any new regulation on business. Friends of the Earth believes that this is a mistake, and that regulation and fiscal measures will be the most effective methods of driving improvement in the environmental performance of business.

  6.  Additional regulations are required in order to address the current unsustainable situation, including:

    —  A phased introduction of ban on landfilling or incineration of recyclable or compostable material

    —  Additional producer responsibility legislation, including a move towards use of recyclable and compostable materials

2.   The role for and implementation of regulations, and their enforcement.

  7.  We would like to see a phased ban on the landfill and incineration of recyclable and compostable materials to be introduced. The Waste Strategy has proposed a future consultation on a ban on landfill of these materials, with no time line. Such a ban was also proposed five years ago in the "Waste not want not" report, yet is still not in place. We view this as an effective tool to maximise recycling and composting (particularly of commercial and industrial waste), though to be effective there should also be a ban on the incineration of such materials.

8.  Friends of the Earth is very disappointed in the proposed municipal waste recycling and composting target of 50% by 2020, when the Government's own analysis has shown that a rate of 60% by 2020 would be much better for the climate. We therefore believe that council recycling targets should be set at levels that will exceed the Waste Strategy's 2010 average recycling target of 40%, permitting a revision of the 2020 recycling target upwards from 50%. Cambridgeshire County Council already recycles over half its waste, whilst Bristol has recently passed 37% and Flanders in Belgium recycles nearly three quarters. We believe that the UK should be aiming for 75% recycling by 2015.

  9.  We believe that the Government should introduce an incineration tax to discourage the incineration of waste which could be recycled or composted and to ensure maximum recycling (as is done in Flanders).

  10.  We also believe that there needs to be a lower level of landfill tax for non-biodegradable waste from mechanical biological treatment (MBT) facilities, which we view as the preferred interim, flexible, residual waste treatment technology, based on a detailed analysis of the climate impacts of different residual waste technologies[17]. This approach makes sense from a climate and a resources point of view. Work carried out for the Treasury has shown that an incineration tax is justified in environmental and social terms[18].

3.   The classification of waste.

  11.  The classification of waste is determined at European level in the Waste Framework Directive. In this context, Friends of the Earth has been arguing against proposals to provide a new definition of by-products, and for "end of waste" to be defined though directives or regulations (eg a Biowaste Directive), rather than through the undemocratic "comitology" process.

12.  For more information about Friends of the Earth's views on the review of the Waste Framework Directive, see our recent briefing: http://www.foe.co.uk/resource/briefings/stopping_the_waste.pdf

4.   The proposals for financial incentives to increase household waste prevention and recycling.

  13.  We support the concept of providing financial incentives for people to minimise the residual waste they generate and we broadly welcome what the government is proposing. We have submitted a response to the Government consultation on this issue, available here:

http://www.foe.co.uk/resource/consultation_responses/incentives.pdf

14.  We are doubtful whether the government's preferred—revenue neutral—system will give councils enough incentive to implement such an approach.

  15.  It is likely that councils would be discouraged if they have to pay for the running of the scheme from outside the revenue raised by the scheme. This scheme will only be effective if sufficient councils decide to adopt it, otherwise it will be just a theoretical power.

  16.  Such schemes should only be introduced where an effective recycling and composting scheme is in place, and should ensure that poorer families are not disproportionately affected.

  17.  We would also suggest that good quality recycling schemes—for example kerbside separation—can be used to boost recycling rates, as they give people confidence that recycling is really taking place. We would like to see more funding for quality recycling schemes (eg kerbside separation) and the development and communication of best practice for recycling schemes, as part of a move to having fewer systems and therefore making it easier to inform the public of their responsibilities. Councils should be rewarded for quality recycling, not just quality, and the Government (or WRAP) should give much clearer best practice guidance to councils.

  18.  In addition, it is essential that every effort is made to ensure that all recyclables are recycled under good conditions—scandals regarding recycling being processed in poor conditions in the developing world are not going to improve confidence or participation.

5.   The role of composting.

  19.  We are strongly supportive of Councils introducing separate collection of food waste, with the collected food waste being either anaerobically digested or composted.

20.  We also believe that Councils should promote home composting and offer a collection service of garden waste for composting. It is often best if this garden waste collection service is charged for, in order to prevent excess waste generation and encourage home composting.

6.   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 packaging and return schemes.

  21.  We welcome the plan to set targets for local authorities to reduce residual waste (the amount which goes to landfill or incineration). However, the waste levels suggested are too high—we can recycle, compost and prevent more than is proposed, as the proposal only assumes 50% recycling and composting and a stabilisation of waste quantity.

22.  We would recommend that the government improves its data gathering on residual waste, as we found that the data available is poor, and does not currently provide a robust basis for decision making and policy development, for example, to enable links to be made with product policy.

  23.  There should be more investment in waste minimisation, including setting a target for total waste generation to prevent the amount of total waste produced from rising beyond 2010. This would require the development of policy measures to decrease total waste generation year on year, for example to cut down on avoidable waste such as excess packaging.

  24.  In terms of packaging, a second priority should be increasing the recycling targets in the packaging directive, thus ensuring that packaging becomes more recyclable (removing it from residual waste), and helping to support the market for this recycling.

7.   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.

  25.  In Friends of the Earth's view, waste policy is a key component of both climate policy and resource policy—ensuring that the UK is as resource efficient as possible.

26.  Maximising waste prevention, recycling and composting will minimise the climate impacts of our waste.

  27.  Recycling saves energy, reduces raw material extraction and combats climate change. The vast majority of studies have found that recycling our rubbish is better for the environment rather than incinerating or landfilling it.

  28.  Incineration is not a climate-friendly way to deal with the residual waste left over after recycling and composting. Studies have clearly shown that incineration is not a climate-friendly treatment technology. It is much better to deal with the waste left over using mechanical biological treatment (MBT) to removes any remaining recyclables and removes biological activity of the waste, so that it will not release methane when landfilled. These processes should occur in small, localised treatment plants.[19]

  29.  We are very concerned—and surprised—that the government still seems to be promoting incineration (albeit less enthusiastically than in the past), despite its poor performance in climate change terms. Incineration is also extremely expensive and inflexible. For a full analysis of the problems with incineration, see our "Up in Smoke" briefing: http://www.foe.co.uk/resource/media_briefing/up_in_smoke.pdf

8.   The promotion of anaerobic digestion for agricultural and food waste.

  30.  We strongly support the Government encouraging the use of anaerobic digestion to treat agricultural and food waste and we welcome the introduction of separate collections of food waste from households. However, more funding is required for the building of anaerobic digestion plants.

9.   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.

31.  Friends of the Earth does not consider incineration (with or without energy recovery) to be a sustainable way to treat residual waste and we do not wish any more facilities to be built. In Friends of the Earth's view the first priority is to focus on minimising residual waste, through improving prevention, reuse, recycling and composting.

32.  As far as recycling is concerned, we believe that source-separation at kerbside is the best option from both an environmental and economic point of view, and we are supporters of the Campaign for Real Recycling. Such systems require less recycling infrastructure as the main processing is bulking up rather than the sorting that would need to occur if recyclables were collected commingled.

  33.  We would therefore consider that the main infrastructure needs for recycling and composting are anaerobic digesters, composters, and in some cases facilities for bulking up recyclables.

  34.  We consider that the ever-decreasing quantity of residual waste is most sustainably treated in small-scale MBT plants, with the small quantity of remaining non-recyclable waste after digestion going to landfill. Support should therefore be provided for building more of these facilities.

Michael Warhurst and Becky Slater

Friends of the Earth

October 2007

Appendix

  Friends of the Earth's full response to the Government's consultation on the English Waste Strategy:

http://www.foe.co.uk/resource/consultation_responses/waste_strategy.pdf





17   Eunomia Consultants for Friends of the Earth, 2006, "A changing climate for energy from waste?", http://www.foe.co.uk/resource/reports/changing_climate.pdf Summarised in "Dirty Truths: Incineration and Climate Change", http://www.foe.co.uk/resource/briefings/dirty_truths.pdf Back

18   "Combining the Government's Two Heath and Environment Studies to Calculate Estimates for the External Costs of Landfill and Incineration", HM Customs & Excise, 2004. Back

19   Eunomia Consultants for Friends of the Earth, 2006, "A changing climate for energy from waste?", http://www.foe.co.uk/resource/reports/changing_climate.pdf Summarised in "Dirty Truths: Incineration and Climate Change", http://www.foe.co.uk/resource/briefings/dirty_truths.pdf Back


 
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