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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