Memorandum submitted by Land Network International
Ltd (Waste 34)
1. Some years ago, when I was developing
Land Network on the instructions of the DTI under the Enterprise
Initiative, I discussed how much was waste was available and could
go to land with Professor Lynn Frostick of the University of Hull.
This would be more than 10 years ago and she then thought that
it was "a little over" 100 million tonnes per annum.
I am now of the view, on evidence, that we could recycle possibly
more than 150 million tonnes per annum to land. Incidentally,
we never use the word "dispose", we regard these "wastes"
as a resource and there to replace, and do a better job, than
the importation of around £1 billion's worth of mineral fertilisers.
The main barriers to recycling are out of date, technically
inadequate and restriction-orientated regulation from DEFRA, interpreted
by an Environment Agency which has a culture of "obeying
the letter of the law" to the point of completely forgetting
about enabling the good guys in order to try and catch the bad
guys. What this civil service-orientated attitude fails to realise
that prescriptive regulation progressively restricts the good
guys and makes them less and less profitable, therefore forcing
them to make a choice between getting out of the business or stretching
the rules and gradually becoming the bad guys. My guess is that
the performance of the Environment Agency is significantly less
than HM Customs in their efforts to control and catch the importation
of illegal drugs. The Environment Agency has very little idea
of what is going on, on the ground and that is not improved by
having "mileage targets" for officers; one of the officers
on the ground recently told us that he had been told not to go
out more than 4 times a month in order to try and control the
mileage bill! If our Environment Agency thinks they can catch
the bad guys by issuing typewritten notices and shuffling them
about whilst sitting at their desks, they are even more naive
than I thought they were.
The whole of the policy is concerned with environmental
protection rather than environmental management.
Where Land Network is aiming at is to manage
the environment and make a major, positive contribution to Carbon
management. The photograph [Annex C[112]]
attached shows a 200 horsepower tractor on a Land Network farm,
it is ploughing oil seed rape which was harvested in the autumn
of 2007, the grain was crushed and then the oil was processed
to produced the biodiesel which is now driving the tractor. The
land on which the oil seed rape was grown, has had compost made
from "wastes" for the last 5 years and has not used
mineral fertiliser for the last two. The Carbon footprint figures
on this setup show that we take over 43 tonnes of Carbon dioxide
out of the atmosphere on every hectare that we carry out this
operation and (not often spoken about) we pump Oxygen back into
the atmosphere. For those that have time to read it, also attached
is a draft of a paper on how this all fits together [Annex B[113]].
Its contribution to the management of the atmosphere in terms
of Carbon dioxide and Oxygen, written for the journal ICE—proceedings
of the Institution of Civil Engineers, "Waste and Resource
Management".
2. The Role for Regulations
As discussed in item 1 above, I have grave doubts
about how the Environment Agency is set up and how it operates.
I recently, (18th October 2007) filed 11 formal complaints with
the Environment Agency as a result of many months, or even more
than a year, of frustration. I filed them with the Agency's Technical
Manager, for whom I have a good deal of personal and professional
respect and, therefore, I wish to make it clear that in no way
am I attacking this officer who I regard as a good officer labouring
under the strain of a very difficult system. Because he asked
me, I then stressed what I felt was the problem of why these difficulties
occurred and what could be done about it. Somewhat later on (12th
November 2007), I used my experience to suggest how things might
be wrong. I don't suppose anybody will take any notice, but in
the last 39 years I have been in over 2500 companies at Board
level with a decision to be made. Many of these were one-man-bands
(farms for example), many were larger farms and machinery dealerships,
some were helicopters, food factories, clothing and all sorts
of things, some were ICI (when John Harvey-Jones sorted it out)
and British Steel (when that was sorted out) and a good many more
as well. I have no doubt whatsoever than the growth in cost of
running the Environment Agency could be held for several years
ahead and the outfit would do a better job if my recommendations
were at least thought about and at least in part implemented.
I do not believe that they are catching anything but a very small
percentage of people who are breaking regulations and damaging
the environmental, I do believe that they are significantly inhibiting
people who are honestly trying to comply with the law and do a
good job.
3. Classification of Waste
The EWC (European Waste Catalogue) is inadequate,
incomplete and substantially illogical. Further, the blind adherence
to its use by the Environment Agency neither protects the Environment
nor encourages recycling. I would much prefer to see an open minded
classification which provided a positive link between the original
material (regarded as waste in law) and the route by which it
could be recycled. With respect to recycle to land, some progress
has been made in recent years with the introduction of a Standard
and, in particular, PAS 100. The problem with Standards is that
they again, because of the "says here, jobs worth",
culture that far too often exists, the Standard then becomes in
itself a barrier. PAS 100 is not particularly related to agriculture
and the offer of our Environment Agency to allow us to develop
our own standards, is of no practical value simply because of
the resource cost of developing these for commercial operations.
4. Financial Incentives
Household recycling is inevitably linked to waste
collection by local authorities. The problem with source separation
is that none of us on the receiving end of it can trust it. Source
separation is never 100% and is frequently far too far from it
to allow quality production to proceed. While, in principle, I
am overall against centralising operations (because of trucking
costs, road congestion, fuel use, loss of local jobs, etc, etc)
I am able to observe that we can have medium scale use of new
technologies coming through to separate at relatively local level
within some form of MBT plant. I am therefore of the view that
we are likely, within a few years, to abandon source separation.
The problem with MBT is that it means different things to different
people. There is also an unnecessary and unhelpful regulation
that says that materials which are not source separated and fed
into a MBT plant which produces a compost, that compost cannot
be put on agricultural land. DEFRA's consultation on this matter
something over a year ago was not helpful in that it decided to
go to the expense of having a consultation and just shelving the
results. If the output needs a Standard, then either the Standard
is inadequate (in which case revise it), or it is adequate in
which case we should be allowing that material to go to food producing
land.
I am of the view that source separation can never
be trustable, it is very expensive and further proposals are likely
to produce serious political backlash. We now have the technology
to take material as complete garbage, in one collection, to facilities
where it can be handled safely.
5. The role of composting
Probably something around 150 million tonnes
of wastes a year can be composted in the UK. We have the technology.
We can do it safely. We can make a significant contribution to
reducing greenhouse gas emissions and to improving the Oxygen
content of the air in the process. The atmospheric management
is done by PCCS (Photosynthetic Carbon Capture and Storage). Again,
see Annex B[114].
6. In my view, the Government can do a good deal
to encourage a more sensible approach to packaging and, where
it is necessary, insist on formulation which allows some route
towards recycling. As an example, John Deere (the biggest farm
machinery manufacturer in the world) have for several years had
a range of combine harvesters, marketed worldwide, where the none
structural body panels are made from soya protein. We can recycle
those to land! It is quite possible to go a lot farther with making
sure that packaging is recyclable by one route or another.
7. Read the attached paper for the ICE.
[Annex B[115]]
8. Anaerobic Digestion
I worked inside several of the water companies
for several years. They all use anaerobic digestion and this works
quite well where the inputs are up to about 10% dry matter. Above
this, the process gets increasing difficult to manage and increasing
expensive. Until quite recently, despite what DEFRA has been encouraging
us to do for 5, 6, 7 years, it really didn't work very well. Now,
we have got new technologies coming through which will help process
much higher dry matter contents. One of the most encouraging is
AAAD, this mean aerobic digestion to start off with to get the
temperature up, anaerobic digestion to take perhaps 60% of the
potential methane off, and then back to aerobic digestion in order
to get the smell out of the material. I am quite hopeful about
this sort of technology and it is likely that we will be putting
in one of these on one of our farms in the not too far distant
future.
There are alternatives which are not anaerobic digestion
which will yield methane for energy or some other route which
allows the sterilisation, recycling of various fractions and energy
production. One of these is autoclaving and there are some plants
coming on stream soon, notably one at Rotherham from Sterecycle.
Anaerobic digestion, of the liquid type may
be particularly useful on farms producing animal slurries and
where on-farm biodiesel production is started up. The biodiesel
production delivers bioglycerol and a by-product and one of the
ways of dealing with this is to digest it anaerobically. This
is probably the sort of plant that we will put in very shortly.
Full integration of recycling to land, abolition of the use of
mineral fertilisers, production of biofuels, production of electricity
from AD, all built into recycling with PCCS, is an integrated
system that we can now deliver.
9. Energy from Waste.
Energy from Waste, EfW, is a disaster. Have
a look at the following equation which is based on a large Carbon
molecule, in fact one from petrol, but it applies to burning any
Carbon material including garbage; C36H74 + 54O2 → 36 CO2 + 37 H2O. Burning anything produces Carbon dioxide
and consumes Oxygen. Nobody is talking about it much yet but,
if we get the greenhouse gas, we loose the Oxygen. So, if we burn
all the fossilised fuel reserves, it's not just going to be hot
and clammy, it is going to be a bit difficult to breath too! See
Annex A[116].
SUMMARY
It isn't the answer to everything and all our
recycling needs and waste problems. However, there is one thing
that is staggeringly important and that is PCCS. We can delivery
fully integrated systems, right now, which will recycle very large
quantities of material, take Carbon dioxide out of the atmosphere
and turn some of the Carbon dioxide being produced by other methods
back into Oxygen for us to breath.
Bill Butterworth
Land Network International Ltd
21 November 2007
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