Memorandum submitted by the National Industrial
Symbiosis Programme (Waste 43)
EXECUTIVE SUMMARY
1. The National Industrial Symbiosis Programme
(NISP) is a business led programme which maximises the use of
resources which would otherwise be consigned to waste through
the profitable creation of business partnerships. Where material
requires conversion to a form more suitable for use by the receiving
business or process novel technologies may be indentified and
implemented, particularly by working in partnership with the Resource
Efficiency Knowledge Transfer Networks.
2. We welcome the recognition that commercial
and industrial waste forms a major element of hazardous waste
and of the waste sent to landfill and proposed setting of targets
for reduction.
3. NISP works on a regional basis and strongly
believes that the recovery of resources is most effectively done
at local level. This not only avoids the problem of long journeys
neutralising the saving of carbon through resource recovery but
gives the greatest efficiency of material and resource usage.
We are increasingly working with local government to develop partnerships
for the collection of commercial waste and have sponsored the
successful creation of the BREW Centre in Oxfordshire to provide
more information and advice to local government. NISP also works
with Regional Development Agencies (RDAs) to reach businesses
at a local level. Although we welcome the targets given to local
government for waste reduction, in Annex C2 the targets are set
out for the reduction of waste by government departments we believe
that there is some inconsistency between the additional funding
which is now being provided to the RDAs for commercial and industrial
waste reduction and the fact that no targets are set at this level.
4. Material waste can be described as a
resource in the wrong place. By not defining it as "waste"
until all viable resources have been recovered and all options
exhausted would make it far less onerous to recover those resources.
This builds upon the work being led by the Environment Agency
to simplify and improve the definition of waste consistent with
low risk regulatory principles. More work on defining such products
can in any case improve on the problem of over regulation.
5. NISP is actively involved with novel
solutions for the treatment of agricultural and food waste. In
particular we are actively working with Severn Trent and other
sewerage undertakers to exploit their existing anaerobic digestive
capacity. NISP is also working to identify where industrial food
wastes are located to advise providers of anaerobic digesters
of these opportunities. Such work is important to promote the
use of AD technology within the food and drink sector.
ABOUT NISP
6. The National Industrial Symbiosis Programme
(NISP) is an innovative business led programme which delivers
environmental, economic and social benefits across the UK. NISP's
mission is to effect a long term cultural change in business to
view all resources as an asset with a value which should not be
wasted or discarded. Such "waste resources" include
energy, water, materials, logistics, assets, expertise etc. NISP
operates firmly within the business opportunity agenda, thus maximising
on the benefits to business of industrial symbiosis.
7. By working across business sectors NISP members
form partnerships to make maximum use resources which would otherwise
go to waste. NISP works at a local level through 12 regional offices,
each having a Programme Advisory Group (PAG) drawn from regional
business. In England NISP receives funding from Defra's BREW (Business
Resource Efficiency and Waste) programme as part of the return
of Landfill Tax to industry.
8. Since its National launch in 2005 NISP
has grown rapidly, and today has in excess of 9,300 industry members
drawn from across the UK. NISP's holistic approach enables it
to actively deal with all resources and by working successfully
across the entire resource (and waste) hierarchy NISP has demonstrated
successfully that business opportunity can be realised through
greater resource efficiency.
9. Now in its third year of operation, NISP
is delivered by International Synergies Limited (ISL) who also
provides support internationally to Defra through the Sustainable
Development Dialogues (SDD) in both China and Mexico. Cited as
an exemplar programme by the European Commission (ETAP), International
Synergies Limited have also received considerable interest for
the potential replication of NISP across Europe, The United States
of America, China, Mexico, India, Brazil and Australia.
10. Between April 2005 and Oct 2007 NISP
has delivered, through its common sense industrial symbiosis approach
to the better management and sustainable use of natural resources:
— engagement with over 9,300 industry
members;
— more than £108 million in additional
industry sales and costs saving of over £89 million;
— secured £68 million private
capital investment in reprocessing and recycling facilities;
— diverted over 2.5 million tonnes
of waste from landfill;
— saved over 5.1 million tonnes of
virgin raw materials;
— eliminated a further 310 thousand
tonnes of hazardous waste;
— reduced industrial water use by over
2.5 million tonnes; and
— reduced over 2.55 million tonnes
of CO2 emissions.
11. NISP is a positive net contributor to
the Treasury (a result of additional tax paid by companies enjoying
higher profits, new solutions creating business start-ups, and
by taxes paid by those people whose jobs have been saved/created
by the programme.) whilst also continuing to contribute to the
balance of payments whereby imported virgin materials are replaced
by UK supplied by-products.
12. A feature of the Programme to date has
been its ability to deliver proportionally more output for each
unit input of funding. From an input of £9million BREW funding
over the first 24 months NISP has not only exceeded delivery on
all contracted metrics and helped create over 1,360 jobs, but
has also:
— delivered a total economic value
added (TEVA) of £117 million;
— a net fiscal impact of over £10.3
million; and
— net economic gross value added of
£53 million to UK PLC.
13. In the current year 2007-08 NISP once
again is confident of exceeding all targets eg based on current
capacity expected year-in out-turn for 2007-08 CO2 is 1.19M Te.
14. Due to the programme's impressive results
and positive impact, NISP's terminology, commercial approach,
business engagement model and efficacy are increasingly being
emulated by other programmes both in the UK and internationally.
Q1: 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
15. NISP welcomes the proposals in the
Waste Strategy which place an increased emphasis on waste as a
resource, the need to reduce commercial and industrial waste and
for a broader local government role in waste streams beyond municipal
waste.
16. NISP welcomes the intention to end landfill
of biodegradable and recyclable waste in landfill, and an enhanced
emphasis on the increasing use of waste to energy but only after
waste reduction and significant increase in resource recovery.
We recognise that if resources can be re used this avoids the
use of virgin materials, which not only have an economic cost,
but also in many cases a higher carbon cost than that of recovered
resources. NISP also welcomes a greater emphasis on anaerobic
digestion (AD) and combined heat and power (CHP) than on traditional
mass burn incineration.
17. A better integration of municipal and
commercial waste could provide economies of scale for both the
private sector and local government, whilst also benefiting the
small business sector that currently faces major difficulties
in tackling waste as a resource.
18. We support the approach which takes
National Policies down to a local level. Promoting the reduction
of waste per se enables improved reduction of CO2 as well as valuable
asset recovery of resources. However current practises for transportation
of waste over long distances (even internationally in some instances)
often offset any carbon saving potential. A localised or regionally
focused approach to resource recovery and waste policy is to be
strongly encouraged not only for household but also for commercial
and industrial wastes equally.
19. Working through a regional model (delivered
through 9 regional offices across England) NISP has both a strong
and very successful experience in building localised business
to business partnerships to realise the value of materials which
would otherwise go to waste. Both large and small business have
a part to play, and in particular in the recovery of materials
for reuse.
20. Smaller scale infrastructure in anaerobic
digestion and advanced thermal treatment plants for example are
potentially suitable for industrial areas where waste that is
locally produced can be treated on site and the energy produced
can be used in industrial processes or utilised as district heating.
21. We also welcome increased opportunities
to work with local government. Local Authorities have a strategic
role as planning authority and/or strategic commissioner of services
to their local communities. They also have considerable commercial
procurement capacity as well as powers to trade which are currently
underutilised.
22. We welcome the allocation of targets
to local authorities for the reduction of waste to landfill, but
are concerned that if funding for waste reduction is allocated
to Regional Development Agencies (RDAs) that this should be similarly
accompanied by targets. Efficient resource management is both
an economic as well as an environmental opportunity, and therefore
by working with organisation such as NISP and other BREW bodies
the RDAs can help to drive the changes needed. We are surprised
that Annex C2 (Table C2.1) requires RDAs to " Co-ordinate
business waste and resource management in partnership with local
authorities (and other regional and sub-regional bodies) and the
third sector" Further clarification is required that
this includes the delivery agents mentioned separately on that
page.
23. The Waste Strategy for England 2007
encourages Local Authorities to:
"use their role as local community leaders
in partnership with businesses, other local, sub-regional and
regional public sector organisations and third sector organisations
to achieve a more integrated approach to resources and waste in
their area"[140]
24. In April 2006, a consortium was formed
between the National Industrial Symbiosis Programme, the Local
Government Association and Oxfordshire County Council to provide
a central support service for Local Authorities. The resulting
BREW Centre for Local Authorities provides specific support
and guidance to enable Local Authorities across England to develop
and provide better waste (and resource) services, strategies and
infrastructure for their local business community. In short, such
activities further help both the Local Authority and the business
community to become more resource efficient, reduce waste and
improve overall profits in the local area.
25. Since the Centre was launched in June
2006 they have developed an active network of over 600 local authority
officers and funded localised "trailblazer" resource
efficiency projects in over 35 Local Authorities.
26. NISP recognises the particular problems
of SMEs and is now working with it's larger member organisations
to encourage more sustainable resource use through the supply
chain and sustainable procurement practices.
Q2: The role for and implementation of regulations,
and their enforcement
27. No response.
Q3: The classification of waste
28. NISP views waste (in the widest sense) as
simply a resource in the wrong place. However, NISP operates across
the entire resource supply chain providing both solutions and
opportunities in order to release the value embedded within inefficient
[resource] supply chain practices. In so doing, the programme
can operate across the entire industrial economy—upstream
and downstream—and its effects are therefore measurable
across the complete spectrum.
29. By delivering business opportunities NISP
both encourages and helps companies to understand the environmental
impacts of their "wastes" and resource inefficiencies
through an economic lens. Supporting companies to address resource
inefficiencies throughout their entire supply chain, NISP's activity
delivers greater benefits than traditional bilateral waste reduction
or recycling approaches. Without NISP's innovative approach and
proven methodologies these opportunities for change would simply
not be identified or undertaken. By providing resources to NISP,
BREW generates both significant industry additionality, increased
resource efficiency per se and subsequent fiscal flows back in
to Government.
30. NISP therefore feels strongly that material
wastes should not be classified as a "waste" until all
viable resources has been recovered, and that all potentially
"useful" options have been exhausted. Such a legislative
approach would make it far less onerous to recover such "useful"
resources'.
31. The BREW Waste protocols project is
starting to help business by providing clear guidance on various
waste streams that:
— Defines the point of full recovery
from a waste back into a product or material that can be reused
by the business or industry, or sold into other markets; or
— Defines when wastes are recovered
to a state where the Environment Agency considers their use is
acceptable in accordance with its low risk regulatory principles;
or
— Confirms what legal obligations remain
to control the reuse of the treated waste material.
32. Waste oil, for example, is one of the
waste streams addressed by the protocols project to date. Technical
Advisory Groups (TAG) have been set up to bring together representatives
from the Environment Agency, NISP, WRAP and industry looking specifically
at waste lubricating oils and waste food oils. The TAG`s role
are to produce technical report, to would enable the subsequent
development of a quality protocols, setting out the process and
controls necessary to determine at which point the processing
of waste oils gives an end product that:
— will not cause harm to human health
or the environment;
— meets a defined standard and requires
no further processing;
— has a market giving certainty of
use.
33. Unfortunately, due to time constraints
and the scale of the project, the waste food oil TAG have initially
decided to limit their study to waste vegetable oil only.
34. The low impact register is also a useful
step toward helping businesses to re-utilise "wastes".
However getting materials and processes listed can be an onerous
process which would benefit significantly from being streamlined.
Q4: The proposals for financial incentives
to increase household waste prevention and recycling
35. No response.
Q5: The role of composting
36. NISP welcomes the intention to end landfill
of biodegradable waste in landfill and views composting as a useful
recovery route for dry organic materials such as garden wastes,
which AD plants will not treat particularly well.
Q6: 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
37. We feel that more needs to be done to encourage
the re-use of recovered plastics back into the food industry—particularly
with respect to allowing its use more freely into food contact
materials. Care would be needed for the return/re-use schemes
to take into account the carbon involved in transport around the
return infrastructure.
Q7: 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
38. Paragraph 10 identifies some of the environmental
benefits of Industrial Symbiosis. These techniques together with
application of other strategies to reduce biodegradable waste
arising from significant waste streams and especially food waste
will make a significant contribution to the reduction of methane.
The waste strategy makes a number of mentions of the contribution
of methane to greenhouse gases, but does little to link this to
a practical response. However we warmly welcome the specific emphasis.
Q8: The promotion of anaerobic digestion
for agricultural and food waste
39. NISP has identified a significant and existing
anaerobic digestion capacity within the water sector and we are
actively working with Severn Trent and other sewerage undertakers
in this area to make this capacity available to the business community
(specifically the agricultural as well as food & drinks sectors).
This has the benefit of not only optimising the use of existing
infrastructure but also increasing the efficiency of the anaerobic
digestive systems through the input of higher calorific waste
than just sewage sludge.
40. We are also currently working with our industrial
members to promote and install advanced innovative digestive systems
which improve the functionality of conventional AD processes.
This leads to higher gas yield for conversion to energy whilst
enabling the AD plant to operate more economically.
41. NISP are working with Food and Drink
Federation (FDF), British Frozen Food Federation (BFFF) and others
to help pull together a picture of where industrial food wastes
are located. The intent is to use this information to best advise
its AD developer members where to put new plants and facilities
to treat these wastes. This activity is helping to both promote
and realise the use of ad as a treatment option for all sectors
of the food and drink industry.
Q9: 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
42. The recent Intergovernmental Panel
on Climate Change Fourth Assessment Report (IPCC AR4) confirmed
the contribution of landfill methane to global green house gas
emissions and a summary of adaptation, mitigation and sustainable
development issues for the waste sector. Innovative practice in
the sector could put the UK at the forefront of technology provision
with consequent economic benefits.
43. The Environmental KTN have stated that
"the competitive edge in technology and
manufacturing in the UK in the future is likely to come from smaller
companies innovating in the areas of advanced thermal treatments
and anaerobic digestion for specific industrial waste streams
which are treated on site or in small merchant plants or for particularly
hazardous and toxic wastes which are difficult to treat and command
a high gate price"[141].
44. Such innovators for new technologies
are amongst the membership of NISP including Pyrolysis, gasification,
and advanced anaerobic digestion, linking these systems with our
network for finance, infrastructure, land, planning, resources
and end markets.
National Industrial Symbiosis Programme
November 2007
140 p 89 Waste Strategy, England 2007. Back
141
The business case for Energy from Waste (EfW) Knowledge Transfer
Networks, Accelerating Business Innovation; a Technology Strategy
Board Programme 2007. Back
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