Memorandum submitted by ECT Recycling
(Waste 42)
INTRODUCTION
ECT Recycling is the largest not-for-profit
community waste management business in the UK, having entered
the market as a specialist recycling contractor in 1994. ECT Recycling
was created to promote more sustainable waste handling methods
at a time when the mainstream industry had no interest in recycling.
ECT Recycling welcomes this opportunity to contribute
to this inquiry. We would be happy to provide oral evidence to
the Committee in due course if invited to do so.
For clarity, an annex at the end of this submission
defines some of the terms used in this memorandum.
EXECUTIVE SUMMARY
ECT Recycling currently provide kerbside recycling
services on behalf of 17 local authorities and collect and market
over 300,000 tonnes of recyclable materials a year. ECT has pioneered
the separate collection of food waste from households in England
and currently collects from 60% of all households with this served
by separate food waste collections.
We are also the first waste contractor in the UK
to have introduced a carbon accounting system alongside service
provision. The greenhouse gas offset value of ECT's recycling
services is estimated to be over a third of a million tonnes of
CO2 equivalent per annum. This calculation is made possible through
ECT's collection and marketing strategy: as all materials are
kerbside sorted and as much as possible consigned directly to
UK reprocessors. The certainty of end-markets and the quality
of materials collected ensure that the environmental benefits
from recycling are maximized and transparent.
Although our client authorities share this focus
on the environmental benefits of recycling, Defra's Waste Srategy
for England 2007 (WS 2007) has not risen to the challenge of making
explicit the links between these benefits and collection system
characteristics, material processing and type of end-market. Instead,
these issues have been side-lined with the consequence that co-mingled
collection systems are on the increase, yet they mostly consign
materials of a lower quality for export. The most recent data[131]
show a 30% year-on-year increase in co-mingled kerbside tonnage
feeding into materials recycling facilities (MRFs).
WS 2007 highlights the role that the waste management
sector should play in the recovery of resources in ways that deliver
cost-effective reduction in greenhouse gas emissions over the
lifecycle. However, WS 2007 lacks connection between the main
drivers for municipal waste diversion, (primarily the Landfill
Directive), and the materials and options that deliver the most
cost-effective carbon reductions. This is a lost opportunity,
as carbon benefits are unlikely to be optimized without direct
incentives for local authorities to go beyond LATS targets. The
latter only impinge the biodegradable fraction of the waste stream
(about 63% of municipal waste in England[132],
not 68% as assumed by WS 2007).
WS 2007 takes the view that choice of collection
system is primarily a concern for local authorities, yet in our
experience, these local decisions have a significant cumulative
impact on the environmental outcomes. As more materials are collected
through co-mingled systems, the environmental, social and economic
benefits of recovered materials are greatly diminished. Growing
reliance on export markets for low-quality recyclates should be
regarded as a short-term strategy as the Asian economies will
demand tighter material specifications in the near future.
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
ROLES OF
THOSE RESPONSIBLE
FOR THE
PRODUCTION AND
DISPOSAL OF
DIFFERENT CLASSES
OF WASTE
Local authorities
1. As a supplier of local authority services,
our response will address household waste. Our discussions with
potential local authority clients indicate that in many cases
local authorities consider WS 2007 irrelevant to their local situations
and are driven by the requirement to meet their LATS targets,
stay within their budgets and meet the service expectations of
their local residents. Budgetary considerations, for example,
can determine whether the waste management solution most likely
to be procured is infrastructure/capital focused or collection
system/revenue focused. Local authorities are being sold "novel"
technologies, such as MBT, as a convenient solution for mixed
waste, yet such technologies have been developed in their countries
of origin as "systems of last resort" to treat the remaining
residual waste after all clean recyclable and compostible materials
have been separated. The application of such technologies to unsorted,
or semi-sorted waste complies with the need to meet targets but
provides very little, if any, environmental payback for the millions
of pounds of investment over long depreciation periods.
2. The objectives of WS 2007, therefore, cannot
be met simply by setting and achieving targets. Local authorities
are faced with a range of systems and technologies that can be
procured to reach these set targets, every one of which has a
distinct environmental profile. Recycling and landfill diversion,
are not activities that can be seen as beneficial in their own
right; public investment in meeting these targets should also
be required to demonstrate tangible benefits that are measurable
in energy/carbon savings, conservation of scarce resources, the
safe handling of hazardous substances; regeneration and employment
creation.
3. WS 2007 envisages an ideal view of a "carbonized"
waste sector, striving to diminish greenhouse gas impacts of current
waste management practices. However, there is a basic contradiction
between the "end of pipe" view of greenhouse gas emissions,
centred on diverting biodegradable materials from landfill, and
the "lifecycle" view of resource management, where the
carbon priority is the recycling of quality materials back into
reprocessing (ie the main benefits are outside the immediate waste
sector). As the main lever on local authorities is currently the
achievement of their LATS targets, the sector is unlikely to realize
the full environmental benefits of recycling through any redoubled
efforts to recycle non-biodegradable materials with high embodied
energy and high carbon dioxide offset values per tonne recycled
(metals, glass, textiles and plastics).
4. In theory the UK's implementation of
the Packaging Directive supports investment in local authority
collections through PRN/PERN revenues. In reality this policy
instrument has been disappointing and the reprocessing and export
sectors have not been transparent in how revenues from PRNs/PERNs
have been invested. The priority for most packaging recovery has
been to tackle the cheaper commercial sources—mainly leaving
local authorities to fund the recycling of household packaging.
Currently less than a third of the 4.3 million tonnes of readily
recyclable packaging materials found in the household waste stream
is recycled[133].
5. This situation contrasts with systems elsewhere
in Europe, where industry pays for the collection of post consumer
packaging. The PRN/PERN system should be revised to ensure that
local authorities receive the direct support that they need in
order to capture a higher proportion of packaging materials from
the municipal waste stream. PERN revenues should finance a verification
system for export markets, to ensure most robust accounting of
what actually gets recycled and improve the credibility of UK
packaging waste exports.
Householders
6. Effort versus convenience: Grasping
the nettle of householder involvement in separating materials
for recycling not only ensures better quality recyclate but also
makes us more conscious of how much we waste, which in turn makes
a significant contribution to waste minimization.
7. Frequently multi-million pound recycling infrastructure
is procured on the false premise that householders prefer to put
their recyclable materials "co-mingled" in a wheeled
bin rather than into a box and/or bag from which materials are
then sorted at the kerbside by the recycling service provider.
More importantly, would householders with co-mingled recycling
collections prefer this system if the implications for the environmental
benefits of their efforts in separating their waste were fully
understood? Clearly, suitable containerization for separated recyclable
materials is an issue that must continue to be considered and
developed.
8. Cost: The cost of recycling collections
is generally much lower than Council Tax payers realize. The most
elaborate source separated collection system—including colour
separated glass, aluminium and ferrous cans, aluminium foil, newspaper
and magazines, textiles, plastic bottles, cardboard, food waste
and various items of hazardous waste such as batteries and engine
oil would struggle to reach an overall cost of £1 per household
per collection. This includes all bulking, marketing and haulage
cost and there are no gate fees or disposal costs other than those
associated with bio-processing of food waste.
9. The "Third Sector" is particularly
efficient at providing high quality recycling collections at low
cost. A recent report to the Welsh Assembly Government revealed
a wide range in recycling system costs, with the average for local
authority operated schemes of over £300/tonne, compared with
social enterprises providing recycling services at on average
a third of the cost (£96/tonne)[134].
10. Outcomes and confidence: ECT
considers this element to be of equal importance to cost and convenience
in recycling systems. Our environmental awareness as a nation
is increasing, and households participate in recycling schemes
in the belief that this helps them to reduce their impact on the
environment. However, this could be seriously undermined by scandals
involving illegal movements of waste collected for recycling or
the consignment of materials to end markets that result in no
environmental gain.
11. However, contaminated mixed recyclate
that leaves the UK counts towards local authority recycling targets,
making it counter-productive for them to ask too many questions
of their contractors. A recent statement by the Environment Agency
and Local Government Association[135]
blamed MRF contractors for hiding behind the cloak of commercial
confidentiality in not disclosing the end markets for the materials
collected. Authorities need to be more aware of their Duty of
Care obligations and the Environment Agency needs to be far more
vigorous in enforcement of these obligations and in the investigation
of recyclate exports.
Localisation as opposed to centralisation of waste
management
12. The UK is over-reliant on distant foreign
markets for its poorer quality recyclate—more so than any
other EU country—with the inherent risk that, should these
markets start to demand higher quality materials, our recycling
systems would rapidly fail.
13. Source separated collection reduces the infrastructure
and capital investment required to separate, bulk and market materials.
These systems enable recyclate to be handled locally in facilities
that can be relatively easily accommodated—ie no special
planning requirement and they are able to operate under a waste
management licence exemption.
14. A popular misconception is that a MRF
situated within the boundaries of a particular local authority
constitutes "localisation" of waste management. In fact,
MRFs achieve no more (and in quality terms, considerably less)
than is achieved by the collection crews deployed on a source
separated collection system. The output of a MRF is likely to
travel many times further to find an end- market than the output
from a source separated collection system. This is not so much
in response to a "global" market as a need to find a
market for materials of inferior quality.
15. There are three main aspects to the
reduction of quality in MRF outputs: the relative inefficiency
of the sorting system to eliminate contaminants from the product
streams, cross-contamination of product streams by each other
and the flow of mis-sorted product into the residual stream. As
paper, cardboard and 50% of textiles are regarded as biodegradable
for the purposes of LATS, it is particularly important for these
materials to be properly accounted for in relation to MRF throughputs.
Without proper enforcement and monitoring by the Environment Agency,
there is little or no incentive for local authorities to insist
on recyclates of higher quality and better environmental outcomes,
as they are more preoccupied with overall recycling rates and
LATS compliance.
16. Most of the 70 MRFs in England and Wales
export recyclate, with 4.7 million tonnes exported in 2006. Although
the prices paid are generally above what UK reprocessors pay,
there is a trade-off between security of the home market (greater
long-term security with UK contracts) versus price. As economies
in the Far East develop, more material will become available for
recycling from domestic consumption, thus reducing the demand
for imported material from Europe, particularly of the lower quality
materials typically consigned by UK MRFs[136].
During this transition it is important that the needs of the UK
reprocessing sector are not irreparably damaged. Whilst WRAP and
other organisations have a role to play in this strategic issue,
it requires overall leadership from Defra to ensure that longer-term
objectives are met in relation to recyclate market development
that more fully acknowledges the wider economic benefits of the
UK reprocessing sector.
2. The role for and implementation of regulations,
and their enforcement
17. Lack of regulation is not the primary
threat to the integrity of recycling systems in the UK, but the
lack of enforcement and the belief in the primacy of meeting targets
over all other considerations. 75 per cent of containers inspected
at a UK ports by the Environment Agency's dedicated illegal waste
enforcement team in October 2005 were found to break the Shipment
of Waste regulations[137].
This is just one example of widespread and systematic movements
of unsorted and partly sorted waste. This translates into a serious
competitive disadvantage for operators who obey the regulations.
Local authorities need to ensure that contracts with MRF service
providers should make transparency of end markets a condition
of the contract.
3. The proposals for financial incentives
to increase household waste prevention and recycling
18. Compulsory recycling is surprisingly well
received in those local authorities that have implemented it.
It puts everyone on an equal footing and should be seen as a policy
that unites residents in a common effort and ensures adherence
to reasonable standards as to how to set out waste for collection.
19. A recent Defra study[138]
has shown that financial incentives contribute little to increased
recycling and may not be a very cost-effective option compared
with the introduction of residual waste alternate weekly collections,
compulsory recycling and charging. It is widely recognized that
waste charging systems in other European countries have been a
significant element in improved recycling rates. Current recycling
infra-structure is not being fully utilized by the public because
of its discretionary nature. ECT's experience indicates that it
is more effective to establish recycling as a matter of good citizenship.
20. Although WS 2007 pays lip-service to
household waste prevention, there are few practical instances
of this in action. One of the policies that has had a significant
impact on household waste arisings has been local authority support
for home composting through the scheme operated by WRAP. This
provides no financial incentive to householders to participate,
yet the statistical evidence[139]
suggests that authorities that have promoted home composting and
not collected garden waste free of charge have experienced less
growth in waste arisings than authorities that have introduced
free kerbside collections of garden waste. Currently the workings
of the LATS mass-balance acts as a disincentive to home composting.
Although this problem was highlighted to Defra in 2005, it has
still not been resolved.
4. The role of composting
21. Second to home composting, windrow composting
is the best solution for garden waste that doesn't contain any
animal by-products—it is cheap and the output is marketable.
However, more control is needed over open windrow processes to
ensure that they are environmentally safe, particularly with respect
to fugitive emissions, bioaerosols and ammonia emissions. Food
and garden wastes should not be mixed as this captures very little
food waste but requires the entire waste stream to be processed
in more expensive ABPR compliant facilities, such as in-vessel
compost technologies and anaerobic digestors.
22. With the rapidly growing interest in food
waste collection, both separately and mixed with garden waste,
there is a need to diversify into anaerobic digestion in order
to ensure markets and the best environmental outcome. The emphasis
on separate food waste collections is particularly pressing given
that the most recent national data on municipal waste composition,
reveals that food waste comprises a much higher proportion of
waste arisings compared with the compositional statistics presented
in WS 2007 and is therefore of far greater importance in meeting
LATS targets.
5. 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
23. Waste minimization is generally taken
to include activities such as packaging weight reduction, home
composting and nappy services. However, there are also waste collection
policy options available to local authorities that have the effect
of reducing waste.
24. An example of a highly effective policy measure
is that of separate collection of food waste on a weekly basis
with alternate week collection of residual waste. A scheme of
this kind has now been fully rolled out by ECT across three contract
areas in Somerset and is exceeding all expectations in participation,
capture rates and customer satisfaction. South Somerset now has
the lowest residual waste per head of any English authority, according
to 2006-07 statistics.
25. This has been achieved through a recycling
rate close to 50% which is not dependent on free collection of
garden waste; a reduction in residual waste to final disposal
to 180kg per person per annum, ie already meeting the Waste Strategy
2007 indicator target for 2020; and an overall reduction in the
amount of waste under management. The evidence suggests that the
reduction is at least partially due to changes in householders'
behaviour caused by greater awareness of their own food waste
arisings.
6. 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
26. The Landfill Directive was originally
envisaged as a necessary measure to reduce methane emissions from
landfill, particularly in response to the historical legacy of
poorly regulated landfill. Landfill gas extraction is relatively
inefficient even when designed in, so diversion of BMW (biodegradable
municipal waste) is a good policy. However, technologies that
merely stabilise waste prior to landfill are themselves energy
intensive, thereby meeting the targets but failing to improve
on the environmental performance of a well managed landfill site.
Each BMW waste stream needs to be addressed so that the most energy
efficient processes are adopted.
27. In relation to the waste management sector's
overall contribution to the reduction in greenhouse gas emissions
it is necessary to take a "lifecycle" view of the materials
that become waste and the overall significance of their environmental
impacts at different life cycle stages. The main benefits of recycling
reside in the reprocessing sector where the displacement of virgin
material inputs brings benefit through significant energy savings
and reduced environmental impacts. The greatest greenhouse gas
savings for the materials that pass through the waste sector (tonne
for tonne and in absolute terms), are associated with returning
quality materials (metals, plastics, textiles and paper) back
into manufactured products, rather than through the diversion
of potentially methanogenic material away from landfill (which
is also worth doing, particularly through separate food waste
collection delivered to AD).
7. The promotion of anaerobic digestion for
agricultural and food waste
28. ECT welcomes the fact that WS 2007 signals
the clear benefits of anaerobic digestion (AD) as a carbon saving
technology producing gas from a renewable source. In countries
where it has been applied most successfully, such as Denmark,
there has been an ability to source feedstock from non-municipal
sources (such as farm slurries) in order to improve operating
performance. Currently, it is not clear how such cross-sectoral
working can be achieved in the UK context. Defra's Waste Infrastructure
Delivery Programme (WIDP) mentions the need for such arrangements,
but this is totally alien to the way in which local authorities
currently procure waste infra-structure.
29. In order to realize the full benefits of
AD technologies, food waste and garden waste should be treated
as completely separate waste streams. Although WS 2007 acknowledges
this fact, 75% of systems in place collect co-mingled kitchen
and garden waste. Another case of opting for simplified collection
logistics without considering the impact on the cost of onward
processing. Food needs to be collected at least weekly and has
to be processed in accordance with the Animal By Products Regulations.
Garden waste is drier, can be collected less frequently and does
not need to be processed to ABPR standards—and it does not
need to be a free service as such collections end up collecting
additional materials that are better composted at home and should
remain outside the municipal system.
8. 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
30. Ensuring the quality of recyclable materials
is a function of the collection system; more effort needs to be
made to address collection systems with less reliance on "end
of pipe" technologies which can only salvage low quality
product from key materials such as paper and glass.
31. The UK's capacity to process materials
collected for recycling: Paper—there is not a great
deal of capacity left in the UK market. However the declining
quality of paper collected for recycling is a matter of concern
for the UK industry and increases the risk inherent in our dependency
on export markets, as these markets can at any time raise their
required specification.
32. Aluminium—there is capacity to
reprocess much more. Again, the industry is concerned about the
poor quality of aluminium collected for recycling as this can
render it unusable.
33. Glass—there is plenty of scope
for reprocessing more glass into containers in the UK, particularly
clear and brown glass. However, co-mingled collection systems
do not deliver colour separated glass and so the tonnage is diverted
into "open loop" alternative markets that result in
significantly less beneficial environmental and economic outcomes.
34. Novel technologies: To maximize
carbon savings, novel technologies such as MBT should be used
for residual waste only. Currently these technologies are being
promoted as contributing to recycling/composting targets. However
the markets for these inferior quality outputs are uncertain and
such markets have not been realized in other countries. Elsewhere
in Europe MBT is regarded as a "last resort" technology
applied to municipal waste only after recycling options have been
exhausted and there are very strict prohibitions over the application
of "compost like products" from MBT to land. ECT is
concerned that Defra's Waste Infrastructure Delivery Programme
(WIDP) is not paying sufficient attention to the market experiences
elsewhere in relation to MBT.
ECT Recycling
November 2007
Annex
DEFINITIONS
There are a number of terms used in this submission,
so for clarification, these are defined here.
Co-mingled collection:
collection of materials presented by householders for recycling
which are transported to a mechanical sorting facility where a
combination of optical, magnetic, electrical, screening and hand
picking systems are used to produce marketable materials. A significant
percentage of the tonnage collected is contamination and half
of this remains in the materials that are sold. For this reason,
these systems are heavily dependent on foreign, mostly far eastern
markets, as the quality is poor. Currently a third of local authorities
in England use this approach and this proportion is rising rapidly
(between 2005-06 and 2006-07 co-mingled tonnage increased by 30%,
twice the rate of increase in kerbside tonnages overall).
Source separated or "kerbside sorted"
collection: collection of materials presented
by householders for recycling which are separated into separate
compartments on a purpose-designed vehicle by the collection crews.
Any contamination is simply left behind. These systems supply
mostly UK and some EU reprocessing markets as the quality is high.
The glass container, aluminum and paper industries are particularly
dependent on the materials supplied by these collection systems.
42% of local authorities currently use these systems.
Closed loop: a recycling process that
can be repeated over and over again. In the case of glass and
metals, this is infinite, whereas with paper fibres and plastic
polymers the quality will gradually degrade after repeated reprocessing.
Open loop: a recycling process that cannot
be repeated. Examples include the use of glass cullet as a construction
aggregate and recycled plastics in underground drainage pipes.
In some cases, when a full lifecycle analysis is performed, these
options may be more detrimental to the environment that landfill.
Crushed mixed colour glass sent into low grade applications in
the construction sector would be a case-in-point.
ECT Recycling
November 2007
131 http://www.defra.gov.uk/environment/statistics/wastats/bulletin07.htm Back
132
Based on ECT compilation of compositional data from 115 local
authorities. Back
133
Based on ECT compilation of compositional data from 115 local
authorities. Back
134
Survey of Funding of Municipal Waste Management Kerbside Collection
in Wales, WAG 2007. Back
135
ENDS 391, Article 17. Back
136
UK plastic waste -a review of supplies for recycling, global market
demand, future trends and associated risks, WRAP; Assessment of
the UK export market for recovered paper, WRAP; Assessment of
the international trading markets for recycled container glass
and their environmental implications, WRAP. Back
137
ENDS 370, 14, IMPEL-TFS threat assessment project: the illegal
shipment of waste amongst IMPEL member states, May 2005. Back
138
Evaluation of the household waste incentives pilot scheme, July
2006. Back
139
Eunomia: Managing biowaste from households in the UK, 2007. Back
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