Memorandum submitted by the Institution
of Civil Engineers (Waste 24)
INSTITUTION OF
CIVIL ENGINEERS
The Institution of Civil Engineers (ICE) is
a UK-based international organisation with over 75,000 members
ranging from professional civil engineers to students. It is an
educational and qualifying body and has charitable status under
UK law. Founded in 1818, the ICE has become recognised worldwide
for its excellence as a centre of learning, as a qualifying body
and as a public voice for the profession.
EXECUTIVE SUMMARY
1. Shared Concerns with CIWM and IMechE
1.1. The Institution is co-ordinating its
waste management sector activity with the Institution of Mechanical
Engineers and the Chartered Institution of Wastes Management.
The three institutions have met to ensure that the Committee is
provided with independent professional input into all issues in
which it has expressed an interest.
1.2. Collectively the three Institutions welcome
the Waste Strategy for England 2007 and believe that the overall
broad strategic approach is the correct one. However, during the
consultation we have identified a number of shared concerns that
we believe will fundamentally affect the ability of England to
deliver against the targets set out in the strategy and those
required by legislation in the form of Directives originating
from Europe.
2. Infrastructure deficit
2.1. The existing infrastructure, and the current
rate at which new infrastructure is being developed, will not
in our view deliver the more sustainable approach to waste envisaged
in the strategy.
2.2. Most importantly, it is clear that future
infrastructure needs to cater for all wastes, regardless of origin
(ie commercial and industrial waste as well as municipal), and
there are four areas in particular where attention needs to be
focused:
— the necessary skills to plan, build
and operate new waste treatment plants;
— an effective planning system;
— communications and awareness raising
to improve co-ordinated action by all parties; and
— decision support tools, including
better data, cost benefit and life cycle analysis, etc.
3. Waste treatment technologies
3.1. The strategy should avoid promoting
one type of technology over another. We believe that local authorities,
either individually or jointly, are best placed through their
strategic planning role to identify what scale and type of technology
best suits their needs.
4. Waste as a resource
4.1. Although the strategy takes a big step forward
by linking waste into the wider environmental agenda—including
resource efficiency, energy policy and climate change—we
wish to see this message driven home through a detailed action
plan to ensure that the concept and practice of using waste as
a resource becomes embedded much more effectively.
IMPLEMENTATION OF
THE STRATEGY
5. National Governance Arrangements
5.1. The Strategy rightly flags the ongoing
and necessary shift from waste management seen as an end of pipe
activity, to resource management, where materials are treated
as valuable resources flowing through the economy. In practice
this means that in addition to traditional waste policy issues
of targets, facility procurement and regulation, the Strategy
is concerned with wider issues around integrating resource management
into the national economy eg through the creation of sustainable
markets for secondary or recycled materials.
5.2. As a result, in addition to DEFRA's role
as lead department, resource management has become a cross departmental
issue, with key roles for the Treasury, BERR, DfT, Cabinet Office
and CLG. There are also a range of publicly funded bodies with
an interest in this agenda, including WRAP, the Carbon Trust,
Envirowise, the National Industrial Symbiosis Programme and the
Environment Agency. Whilst this situation potentially provides
significant capacity to drive change, it also presents major co-ordination
problems.
5.3. In a report issued earlier this year in
conjunction with the Institution of Mechanical Engineers[29],
we advocated the creation of a cross departmental team operating
at a strategic level to spell out clearly the changes required
to deliver a strategy that genuinely treated waste as a valued
resource. The report proposed that this team should be supported
by an organisation to act as its "agent" with a role
of influencing decision making and facilitating the creation of
partnerships in areas such as land use planning, economic development,
statutory delivery functions (eg transport, waste), procurement
and financial management. We are concerned that no single body
has yet been given the "agent" role and the specific
task of making change happen. These functions could be added to
the remit of one of the publically funded organisations listed
above.
5.4. The creation of the cross departmental
Waste Strategy Board is welcomed, although ICE reserves judgement
as to whether it will be effective in driving forward the required
action in key departments. The significant increase in funding
for waste PFI credits announced in the Comprehensive Spending
Review is a positive sign that Treasury spending plans are being
aligned to the goals of the Strategy, although as discussed later,
ICE are concerned that too much focus is being placed on PFI as
a means of delivery. A second test will be the outcome of the
recently closed consultation on the reform of the planning system.
5.5. Lengthy planning processes, with Local
Authorities typically factoring in circa eighteen months for this
stage of the process, remain a significant barrier to the delivery
of facilities and a disincentive to new entrants to the waste
market. ICE were therefore disappointed that this year's Planning
White Paper did not envisage significant numbers of waste facilities
qualifying as Nationally Significant Infrastructure Projects (NISP)
and thus able to be approved by the proposed Infrastructure Planning
Commission. As an example, the White Paper sets a threshold of
50 MWe for energy from waste plant to be considered a NISP. In
our view energy from waste is an example of a technology where
the individual facilities may be relatively small, but taken as
a whole, are fundamental to the delivery of the Waste Strategy.
In this case ICE believes it would be appropriate to lower the
threshold to 20 MWe, or more logically base the threshold on throughput
of waste rather than electrical energy output. More widely, given
the importance of delivering what amounts to a new national network
of facilities over the next decade, it would help if the Committee
seeks to clarify with the Department for Communities and Local
Government what their intentions are in relation to waste infrastructure
and the new procedures for major infrastructure projects.
5.6. In addition, as a professional body
active in the field ICE recognises that it has a role in developing
the knowledge and experience of individuals required to deliver
effective resource management and providing expert advice to decision
makers. The Institution are seeking to carry out this role in
co-ordination with the Institution of Mechanical Engineers and
the Chartered Institution of Wastes Management, enabling us to
collectively encompass infrastructure development, waste technology
and operations and logistics. We would encourage the Committee
to examine if other partnerships such as this are emerging.
6. Localisation and Centralisation
6.1. In terms of municipal waste contracts,
there are real opportunities at the regional level to deliver
both economies of scale and to create contracts that are able
to attract more bidders and deliver better value to the public
purse. In addition, in areas of two-tier local government, potential
bidders must be provided with certainty as to how Waste Collection
Authorities will collect and deliver waste and materials streams,
strengthening the case for increased partnership working.
6.2. In addition, in terms of driving change
across all waste streams, the experience of Hampshire County Council's
Natural Resources Initiative, suggests that Authorities can play
a leadership and facilitation role in bringing together stakeholders
to generate agreement on the rationale for a resource economy
and the infrastructure required to support it.
6.3. In this context the Committee may wish
to examine if Local Authorities (and Regional Development Agencies)
are proactively aligning their "non waste" functions
such as planning/spatial strategies, Local Area Agreements and
economic development to the needs of the Waste Strategy. If not,
this is likely to create a barrier to effective delivery.
7. Lack of Risk Management Arrangements
7.1. Annex A to the Strategy contains four
scenarios setting out possible socio-economic changes over the
period to 2030 and their likely impact on waste arisings. Whilst
ICE applauds the fact that DEFRA has undertaken this work the
Institution are alarmed that it is not clear on which scenario
the measures set out in the Strategy are based. Furthermore, there
is no evidence of any risk management arrangements should the
assumptions in the scenario(s) turn out to be wrong. Promoters
of individual waste projects would be expected to have proper
risk management arrangements in place and the Strategy itself
should follow a similarly professional approach.
ADEQUACY OF
WASTE INFRASTRUCTURE
8. Potential Infrastructure Deficit in 2010
8.1. The Committee will be aware that the
Strategy was originally scheduled to be produced in 2005. ICE
are concerned that while the Strategy was delayed for two years,
key targets for diversion of biodegradable municipal waste from
landfill have long been fixed by the Landfill Directive. Hitting
these targets will require significant amounts of waste handling
and treatment infrastructure to be operational. Furthermore, an
even greater number of facilities will be required to integrate
the Commercial and Industrial, and Construction and Demolition
Waste streams into a functioning and fully effective resource
management economy.
9. Municipal Waste
9.1. Whilst ICE commend the work of DEFRA's Waste
Infrastructure Delivery Programme (WIDP) in facilitating an increase
in the pace of infrastructure investment, it is far from clear
if this will be sufficient for the UK to hit the 2010 targets
for diversion of municipal waste and thus avoid fines under the
terms of the EU Landfill Directive.
9.2. In producing its response to DEFRA's consultation
on the Strategy, ICE engaged Dr Daryl Hill of Environment and
Energy Ltd to carry out research into the number, type and cost
of facilities required to meet its goals.
9.3. Whilst this research suggested that DEFRA's
assessment of the costs of the facilities was credible, ICE expressed
concern as to whether sufficient plant could be made operational
by 2010 to meet diversion targets. Our research suggested that
130 In-Vessel Composting/Material Recycling Facilities would need
to be built and be operational and the logistics for separate
collection implemented within these time scales. In addition,
one would have to assume that these systems would achieve the
level of source segregation of materials necessary. A further
obstacle was finding viable outlets for all the materials generated;
estimated at 5.8 million tonnes of secondary materials, with compost
alone representing 2.1 million tonnes. Furthermore, ICE noted
that DEFRA's model appeared to assume that projects in train at
the time of the consultation would reach contract close and proceed
to build completion and operation within the timescales. A copy
of this research is attached as Annex A.[30]
We would therefore advise the Committee to examine progress towards
delivery of facilities on this scale, the adequacy of logistics
systems, the success of source separation activities and the availability
of outlets for the materials generated.
10. Market Capacity and Barriers to Entry
10.1. The Office of Government Commerce's
(OGC), 2006 report on the Municipal Waste market[31]
found that there were too few suppliers bidding for waste contracts
and that difficulties faced by new market entrants was a factor
in reduced competition. The report also found that many Local
Authorities lacked the specialist skills and experience required
to carry out complex procurement exercises in the waste market,
resulting in a reliance on external advisors.
10.2. ICE is concerned that both of these problems
persist. Furthermore, anecdotal evidence suggests that there is
also a shortage of the very external advisors OGC found were being
used to plug Local Authority skills gaps. This situation limits
capacity to deliver infrastructure and is not conducive to maximising
the value gained from investment.
10.3. ICE would therefore advise the Committee
to consider if the manner in which projects are being defined,
and other procurement practices, are excluding potential new entrants
to the market. The Committee may also wish to examine the
nationwide availability to the waste sector of project management,
procurement and legal skills.
10.4. In terms of capacity to construct
facilities, the Committee should be aware that ConstructionSkills,
the sector skills council for construction is predicting a period
of significantly rising demand, with infrastructure output projected
to rise by 5.2% between 2007 and 2011[32],
with demand significantly higher in London and the South East.
Waste projects are therefore likely to need to be attractive options
for construction firms at a time when there are many other business
opportunities (such as the London Olympics, for example).
10.5. This increase in demand is also increasing
inflationary pressures in the construction sector. New Civil
Engineer has recently reported that tender prices for buildings
and infrastructure are expected to rise by between 4.5% and 5%
over the next two years, whilst in London construction inflation
is projected to stay at 6.5% until 2011[33].
Given that the Consumer Price Index (against which "real
term" increases in spending are calculated) is running at
1.8%, and the pent up demand for spending on waste infrastructure,
the Committee may wish to examine the impact of construction inflation
on the cost of delivering the Strategy.
11. Over Reliance on PFI
11.1. In the context of procurement practice
ICE are concerned that there is a prevailing sense that for larger
projects, PFI is the only realistic option being offered to Authorities.
PFI can result in a lengthy and costly procurement process, which
may not always be the best option.
11.2. ICE would like to see cross fertilisation
of ideas from other infrastructure sectors such as flood defences,
highways and water and waste water where a variety of models have
been used to secure long term private investment in public services.
11.3. In addition, the recent and ongoing
experience of Buckinghamshire County Council suggests there is
potential for well resourced and "educated" Local Authorities
to use Prudential Borrowing to procure individual residual waste
facilities.
12. Non Municipal Waste Streams
12.1. The Strategy largely focuses on the
circa 9% of UK waste arisings that derives from households[34]
and the creation of facilities by Local Authorities to deal with
this material. This approach will not deliver an optimal network
of resource management facilities Whilst there are proposals for
dealing with Commercial and Industrial (C&I) waste, including
a target for reducing the volume of C&I waste going to landfill
by 20% by 2010, there is little detail on how this will be achieved.
The proposals in relation to Construction and Demolition Waste
are more positive and the introduction of compulsory site waste
management plans for projects with a value of over £250,000
should drive more efficient behaviour, particularly if used alongside
such good practice tools as the ICE Demolition Protocol. THE
POTENTIAL FOR
THE PROPOSALS
TO TACKLE
THE UK'S
CONTRIBUTION TO
CLIMATE CHANGE
13. Need for a Strategic Approach
13.1. The Committee has asked for views on the
potential for the Strategy to make a contribution to meeting the
UK's climate change commitments, in particular methane emissions.
The Institution believes that waste management policy should be
much more strongly and explicitly linked to energy and climate
change policy. We must maximise the value that is extracted from
waste, whilst minimising its environmental impact. The logic of
this approach is explored in ICE and IMecHE's study, The Case
for a Resource Management Strategy[35],
which was part funded by DEFRA.
13.2. The report states that the UK should move
away from weight based targets as the measurement of the success
of waste management strategies, and instead adopt a measure of
lifecycle carbon dioxide (CO2) associated with material streams
and types of treatment. Using CO2 as a measurement suggests that
present strategies, while meeting weight-based targets, could
potentially release more climate-changing CO2 into the
atmosphere than some possible alternatives. ICE understands that
the water industry is likely to be asked to include an assessment
of carbon footprint as part of the next cycle of 5 year investment
plans to be agreed with OFWAT. The Committee may wish to explore
the feasibility of a similar approach to the provision of waste
infrastructure.
13.3. In addition, as part of a resource management
approach, policy makers should take explicit account of the contribution
Energy from Waste can make to energy policy goals of increasing
diversity of supply and electricity generation from renewable
sources. An ICE and (then) Renewable Power Association report[36]
has demonstrated that energy generated from residual Municipal
and Commercial and Industrial waste could account for a theoretical
maximum of 17% of UK electricity generation in 2020 and therefore
make a major contribution to meeting our targets under the EU
Renewables Directives. There are sound practical reasons why this
theoretical figure will not be reached but it does demonstrate
the scale of the potential of energy from waste.
13.4. More fundamentally, it is not clear
what the rationale is for the particular targets for EfW and recycling
in the Strategy. The CO2 emissions-based approach set out in The
Case for a Resource Management Strategy provides such a rationale
for target setting and would create a link in the public mind
between waste, energy and climate change policy which in turn
could deliver increased popular support.
4. The Promotion of Anaerobic Digestion
14.1. ICE would support the use of Anaerobic
Digestion for the treatment of agricultural waste.
14.2. In relation to food waste, to produce a
high value product, source segregation will be required, with
a knock on impact to the costs and practicalities of collection.
Without this approach, much of the material produced will be of
poor quality and suitable only for landfill cover.
14.3. In addition, further work is required
to assess the carbon impact of domestic food waste collection
and processing.
14.4. Overall Anaerobic Digestion needs
to be seen as part of a network of resource management facilities
and cannot obviate the need for significant numbers of residual
waste facilities, which ICE believes will need to include "mainstream"
energy from waste technology.
Institution of Civil Engineers
October 2007
29 Institution of Civil Engineers/Institution of Mechanical
Engineers (2007), How to Deliver a Resource Management Strategy,
ICE/IMechE, London, UK. Back
30
Not printed. Back
31
Office of Government Commerce (2006), Improving Competition
and Capacity Planning in the Municipal Waste Market, OGC,
Norwich, UK. Back
32
Construction Skills (2007), Blueprint for UK Construction Skills
2007-11, ConstructionSkills, London, UK. Back
33
More Cash, Less Spend, New Civil Engineer, 18 October 2007. Back
34
Environment Agency (2007), The Environment in Your Pocket 2006,
Environment Agency, London, UK. Back
35
Institution of Civil Engineers/Institution of Mechanical Engineers
(2006), The Case for a Resource Management Strategy, ICE/IMechE,
London, UK. Back
36
Institution of Civil Engineers/Renewable Power Association (2005),
Quantification of the Potential Energy from Residuals in the
UK, ICE/RPA, London, UK. Back
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