Memorandum submitted by the Green Alliance
(Waste 35)
INTRODUCTION
1. Green Alliance is an independent charity
with a central role in the UK environment movement. We work closely
with decision-makers in government and business, and with other
environment groups, promoting policies for a better environment.
2. We welcome the opportunity to contribute to
this enquiry. The review of Waste Strategy 2000 and the subsequent
publication of Waste Strategy 2007 has been the focus of our work
on waste and resource policy over the last two years. In 2006
we published A Zero Waste UK,[117]
jointly with the Institute for Public Policy Research (IPPR).
This pamphlet set out the vision of a zero waste UK and ten steps
the Waste Strategy could take to get us there.
RESPONSES TO
QUESTIONS
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
3. We are pleased that the government has
resisted pressure to drop its plans to allow local authorities
to develop financial incentive schemes for households. We think
that such charging is a vital tool for local authorities to have
at their disposal. We are clear that there are pre-conditions
if such schemes are to work well—these include provision
of clear, convenient recycling services and adequate resources
to deal with fly-tipping. Provided such conditions are met, we
see charging for residual waste as an entirely logical way to
incentivise recycling.
4. We think that neither the recycling targets
(40% by 2010 and 50% by 2020) nor the residual waste targets (29%
reduction by 2010, 45% reduction by 2020—from 2000 levels)
are stretching enough to stimulate the innovation needed. Over
25 local authorities already have recycling and composting rates
of 40% or more and a couple have reached 50%.[118]
The Netherlands and Germany currently have recycling and composting
rates of over 60% and in 2005 the then-environment minister Ben
Bradshaw cited 60% recycling as achievable.[119]
Despite this, the targets in the Strategy seem to have been based
on a calculated "economic" level of recycling which
takes no account of the possible benefits of innovation which
might result from more ambitious targets. This has been a central
theme for the government's Commission on Environmental Markets
and Economic Performance (CEMEP),[120]
of which Julie Hill of Green Alliance has been a member, and which
is due to report in November. Green Alliance hopes that the messages
from the CEMEP report will be heeded in on-going implementation
of the Waste Strategy.
5. Equally, we were disappointed that there are
no targets in the Strategy for commercial and industrial (C&I)
waste, and believe that it is time to consider whether sectoral
targets could be set and monitored, possibly through business
associations or independent bodies. Furthermore, the target for
the construction sector of halving the amount of construction,
demolition and excavation waste (CD&E) waste going to landfill
by 2012 does not seem to have been fully thought through. There
is a lack of clarity about the nature of this target (ie whether
it is mandatory or voluntary), how it fits together with a number
of other targets for construction waste proposed by both the Waste
Strategy and the forthcoming Sustainable Construction Strategy,
and who will have ownership of the target(s). For more information
on this see the outcomes of a seminar Green Alliance held in July
2007 at http://www.green-alliance.org.uk/grea1.aspx?id=1960.
6. We need innovation, particularly in products
and systems of consumption, if we are to aspire to the "one
planet living" ideal. Our thinking on this has been influenced
by the work of American architect William Mc Donough and German
chemist Michael Braungart: their book Cradle to cradle: remaking
the way we make things envisages the consumption and production
practices of humans being no more damaging to the planet than
any other consumption and production that takes place in nature.
They propose two cycles: a biological cycle, where resources drawn
from the land are returned to the land; and a "technical"
cycle, where non-renewable resources essential to industrial activity
are used and kept in circulation ad infinitum. Unless we accept
the need to keep resources in use far longer than we do presently
we are going to encounter increasing problems of resource scarcity,
as well as the problems that arise from overuse of what are theoretically
renewable resources. It has been estimated that after six months
as little as 2% of the input resources by mass are retained long-term
within the economy and 98% emerge as waste.[121]
This is not a sustainable situation.
7. To achieve a "cradle to cradle"
or "closed loop" economy two kinds of innovation are
needed: in products and materials, and also in downstream materials
handling. However, the way the economy is organised at present
provides no mechanisms for tying up upstream innovation with downstream
processing. The decisions are made by different groups of people—manufacturers
and retailers on the one hand; local authorities and waste companies
on the other. Compostable packaging is a good example of a new
material introduced on its apparent green merits but without adequate
consideration of end-of-life processing. Compostable packaging,
generally plastic-like materials from renewable feedstocks such
as starch and cellulose that break down in either aerobic or anaerobic
composting conditions, have been used by some retailers for nearly
two years despite unfavourable conditions for downstream processing.
Few local authorities were separately collecting food waste for
composting and not all packaging marked as "compostable"
broke down on home compost heaps. Few packages carried labels
explaining how they should be treated at end of life. There was
(and still is) a lot of potential for consumer confusion. Worse,
cross-contamination presents waste processors with additional
problems—compostable materials in conventional plastic recycling
streams (such as PET) undermine its quality; equally conventional
plastics mistakenly sent down the municipal composting route will
have to be identified and removed at extra cost.
8. Green Alliance is initiating work to
explore how upstream innovation and downstream waste infrastructure
commissioning can be better coordinated.
The role for and implementation of regulations,
and their enforcement
9. We note that the pre-treatment regulations
for non-hazardous waste to landfill that came into effect on 30
October have the potential to drive significant increases in business
recycling rates as businesses will have more of an incentive to
segregate waste materials on-site. There are also significant
opportunities for the waste industry in meeting the needs of those
businesses that either don't want to or can't segregate wastes
on-site; this may drive investment in material recovery facilities
(MRFs) and/or recycling infrastructure. However, for these benefits
to be realised the regulations must be adequately enforced.
10. We believe there may also be a role for product
regulations: these would be specific product standards for whole-life
performance on energy, water and resource efficiency as well as
the impacts of final disposal of the product. This could be a
precursor to a situation where producers have responsibility for
the impacts of their products at all stages of their lifecycle,
not just through the standards to which they are manufactured
but by conditioning their use and having responsibility for a
closed-loop, zero-waste system. This would require regulations
but most importantly it would need unprecedented buy-in from industry.
The classification of waste
11. We welcome the recent Quality Protocol
for compost and the forthcoming Quality Protocol for anaerobic
digestate. Both these protocols will make it easier for closed
loop resource flows to take place.
The proposals for financial incentives to increase
household waste prevention and recycling
12. As noted under Q1 we are strongly in favour
of financial incentives. However, we believe that the condition
that they be entirely revenue neutral could limit their potential.
Our full responses to the proposals can be found in our response
to Defra's consultation: see the "recent news" section
at http://www.green-alliance.org.uk/grea1.aspx?id=102.
The role of composting
13. There needs to be much more clarity with
regards to the role of home composting. WRAP says, "Promotion
of home composting to those households with gardens makes sense
and should be a common element in virtually all authorities' programmes",[122]
and the government is currently considering whether home composted
waste should be included in the new performance indicator for
local authority performance on recycling and composting.
14. However, in a recent speech, the environment
minister Joan Ruddock said, "Central government doesn't usually
have a preference when it comes to how leftover waste is dealt
with as long as all the options higher up the waste hierarchy
have been exhausted first . . .. But when it comes
to food waste we do have a preference. We think anaerobic digestion
is the best process to use, and that local authorities need to
collect food waste separately for this purpose".[123]
15. Clarity about the role of home composting
important for local authorities, some of whom might be giving
disproportionate emphasis to collecting green waste to improve
recycling tonnages, when home composting might be the better option.
It is also important to give clear signals to the retailers about
the likely disposal routes for compostable packaging. As already
noted, some retailers are aiming for fruit and vegetable packaging
to be home compostable whereas others are using materials that
will only compost under the higher temperatures of a commercial
composting facility or anaerobic digestion plant, thus requiring
food waste collection systems to be in place. Clarity about home
composting also means the government taking a position on whether
potential downsides, in the form of methane emissions from badly
managed compost heaps, outweigh the benefits.
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
16. Waste minimisation can only be seriously
tackled through action on products and materials. Despite the
welcome emphasis of the Strategy on products and materials, there
is very little in the way of policies to address them. We are
particularly concerned that the products and materials unit does
not yet seem to be fully up and running—it is vital that
this unit is properly resourced.
17. We are also concerned that there is insufficient
emphasis on producer responsibility as a way of organising recovery
and recycling, and, crucially, stimulating product re-design.
In our 2005 report Return to Sender we set out some of
the shortcomings of current approaches to producer responsibility.
We concluded that while such initiatives have improved collection
rates and recovery of materials, resulting in improved recycling
rates, they have often managed to fragment and dilute responsibility
through the involvement of third party organisations. Instances
of genuine re-design of products are still rare. The main point
of producer responsibility measures has seemed to be to shift
end-of-life costs from public authorities to the private sector
and it is clear that product re-design needs additional, specific
policies to stimulate innovation. Product standards and product
levies should both be explored.
18. For more on this point, please see our
recent submission to the House of Lords Enquiry into Waste Reduction.[124]
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
19. We clearly have to move away from landfill,
a form of disposal which is a waste of resources, and thus a waste
of carbon because of the energy that went into extracting raw
materials, manufacturing and transporting products (assuming the
energy has come from fossil fuels). The issue of landfill methane,
and the targets arising from the Landfill Directive on limiting
biodegradable waste to landfill, confirm that move since methane
capture is unable to capture all emissions.
20. However, as noted above, we do not think
that the recycling targets in the Waste Strategy provide a sufficiently
ambitious framework for moving away from landfill. We welcome
the suggestion in the Strategy that the government may consult
on banning the disposal of some materials to landfill. This would
offer greater certainty to businesses and local authorities and,
if bans are signaled sufficiently far ahead, should help with
the planning of new recycling infrastructure.
21. Studies show that most recycling saves
carbon,[125]
however, we are concerned that a short-term focus on carbon could
lose the bigger picture—for example retailers are encouraged
through the Courtauld Commitment to lightweight packaging, however
in general this involves using very thin plastics, which are very
difficult to recycle. A focus on carbon above all else ignores
renewability of feedstock and the impacts of its extraction, as
well as toxicity, and water use and pollution.
The promotion of anaerobic digestion for agricultural
and food waste
22. We welcome the government's promotion
of anaerobic digestion for agricultural and food waste as a "closed
loop" approach although there is a need more demonstration
technology. As mentioned before there is a need for the government
to clarify the role of home composting vis-à-vis
in-vessel composting or anaerobic digestion.
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
23. Despite the sterling efforts of WRAP, the
UK's capacity to process materials collected for recycling is
currently low, particularly for plastics, and we export a considerable
amount to countries like China. Demand for our secondary materials
may well start to decline as the Chinese start to produce a lot
more of their own, particularly as poor segregation and contamination
with biowastes in the UK leads to lower quality recyclate which
restricts its use and lowers its value. Much larger incentives
are needed to stimulate investment in re-processing infrastructure
in the UK. At the same time, greater clarity and uniformity is
needed at the household and commercial level around how materials
for recycling are collected and segregated. Experience from other
countries suggests that improving recycling rates beyond 50% is
dependent on good, consistent segregation of materials at source.
24. Green Alliance's view is that energy from
waste should have a limited role and recycling should always take
precedence unless there is a very detrimental effect on the carbon
equation. The Waste Strategy is clearer on this point than previous
policy documents, which we welcome. We also welcome the emphasis
on anaerobic digestion as a form of energy from waste because
the residue should be a usable product (a type of compost) rather
than a hazardous waste that must be disposed of to special landfills
(which is the case with at least a proportion of the ash from
combustion processes).
25. As noted in several places above, innovation
in materials, products and re-processing technologies are all
badly needed, and at present are proceeding slowly thanks to a
history of delayed implementation of regulations and poor economic
incentives. This situation has improved somewhat with the more
recent increase to the landfill tax escalator, but is still not
driving investment and innovation on a scale that will get us
near to the ideal of the "closed loop" economy. Green
Alliance's work on CEMEP has sought to suggest ways in which both
environmental policy and innovation policy can help remedy the
UK's lack of innovation in this area, including setting longer-term
targets, introducing product standards that are steadily improved,
and using the government's buying power to create "lead markets"
for new products and processes.
Green Alliance
November 2007
117 http://www.green-alliance.org.uk/grea_p.aspx?id=956 Back
118
http://www.defra.gov.uk/news/2006/061215a-table.pdf Back
119
http://www.gnn.gov.uk/content/detail.asp?ReleaseID=169769&NewsAreaID=259&NavigatedFromSearch=True Back
120
http://www.defra.gov.uk/environment/business/commission/terms.htm
(although out of date). Back
121
The Mass Balance Movement, 2006, p3. Back
122
http://www.wrap.org.uk/downloads/Biowaste_Summary_Report_Final_240507.30dec004.pdf,
p3. Back
123
http://www.defra.gov.uk/corporate/ministers/speeches/joan-ruddock/jr071016.htm Back
124
Under "recent news" at http://www.green-alliance.org.uk/grea1.aspx?id=102 Back
125
http://www.wrap.org.uk/downloads/Recycling_LCA_Report_Executive_Summary_Sept_2006.6d4e980b.pdf Back
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