Memorandum submitted by the Composting
Association (Waste 44)
1. INTRODUCTION
1.1 The Composting Association works on
behalf of over 500 UK members to raise awareness of the benefits
of the recycling of biodegradable resources. It aims to act as
an advocate for the wider composting and biological treatment
industries and to represent their views in a constructive dialogue
with policy makers. The Association envisages an industry in which
best practice is shared, standards are maintained and surpassed
and which makes a positive contribution to safeguarding the environment.
1.2 Food and garden wastes (biowastes) are thought
to comprise in excess of 30% of the municipal waste stream. As
they are biodegradable this represents significant opportunities
for local authorities to collect them separately for composting,
anaerobic digestion (AD), or other biological treatment processes,
in order to meet their Landfill Allowance Trading Scheme (LATS)
obligations.
1.3 Currently over three million tonnes of biowaste
are composted every year, producing in excess of two million tonnes
of compost[142].
These figures are set to rise substantially as local authorities
strive to meet their LATS targets. Estimates of up to six million
tonnes a year of municipal biowaste and at least a million tonnes
of commercial and industrial biowaste to be diverted from landfill
by 2020 may well be conservative.
1.4 The Composting Association believes
the underlying principles set out in the 2007 Waste Strategy for
England have set a course for improving the way waste is managed
in England. DEFRA has endeavoured to address a number of inherently
complex, interrelated issues in a concise manner. In particular,
we welcome the:
— Revised composting and recycling
targets for local authorities
— Acknowledgement of the impacts of
managing waste on climate change
— Proposal to consult on banning untreated
biodegradable waste to landfill
1.5 Notwithstanding, there remain some significant
issues that necessitate swift action if the vision in the Strategy
is to be realised. In particular, there appears to be a disparity
between the stated aims of the Strategy and the timeframe within
which the policies will be delivered realistically; the urgency
of the situation has not been addressed adequately.
1.6 We have set out our specific comments
below in response to the Committee's suggestions, focussing on
the biological treatment of biodegradable wastes. However, a number
of our comments also impact on recycling more generally.
2. SPECIFIC COMMENTS
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
2.1 The Strategy has acknowledged the importance
of managing waste from municipal, commercial and industrial sources
in a sustainable manner. However, the principal focus of the Strategy
remains the municipal sector and the role played by local authorities.
In realising greater resource efficiencies and economies of scale
it is envisaged that a nation-wide network of biological treatment
facilities will be required to treat biowastes from a range of
sources; some of these will be small-scale decentralised facilities,
some will be larger, providing centralised processing capacity.
We anticipate that existing composting sites will diversify their
activities and build on their materials-handling competencies
to establish integrated biowaste treatment facilities, encompassing
in-vessel and windrow composting, anaerobic digestion and biomass
burning. To realise this, further action is required:
2.2 Co-ordinating biowaste collection rounds
to maximise efficiency—The Strategy has emphasised the
importance of food wastes, but has focussed principally on household
waste, and the impact on alternate weekly collection schemes.
It has been estimated that there may be an equivalent amount of
commercial food waste to that in the municipal waste stream, which
presents significant potential to recover value. However, it is
unclear how businesses will be incentivised to do anything other
than continue with their current disposal arrangements in the
short to medium term. Local authorities could play a significant
role by integrating existing household collection schemes with
the business community. Appropriate incentives would need to be
set in place.
2.3 Procuring infrastructure—At
present most biowaste processing sites have been established on
the basis of local authority contracts for municipal waste. Synergies
with commercial and industrial waste sectors will add value and
reduce business risk for operators. In order to achieve this,
facility design and procurement will need to accommodate a range
of waste streams (this will be particularly important for anaerobic
digestion—see comments below), but it is unclear how this
will be realised. Government has recently announced in its Comprehensive
Spending Review an extra £2 billion for Private Finance Initiatives
(PFI) credits. Welcome though this intention is, it may well have
the unintended consequences of:
— Selecting contracts with larger operators
due to the very high transaction costs involved, thus reducing
competitiveness within the sector
— Local authorities engaging in very
long term contracts (25 years) that may prove inflexible to respond
to changing needs in the future. (We only have to look back at
the last 25 years and witness the massive change that has occurred.)
A 10-15 year time frame would appear to be more appropriate
— Procuring infrastructure that would
be unable to accommodate commercial or industrial wastes. Given
the pressure on the land use planning system and the scarcity
of suitable, affordable sites, this could unwittingly exacerbate
the current infrastructure short-fall. Local authorities should
be encouraged to consider non-municipal waste arisings during
contract negotiations
— Selecting larger centralised infrastructure
that may not offer the most suitable environmental or cost-effective
solution when collection distances and market outlets for treated
materials are accounted for. We believe that a range of facilities
of different sizes will provide the most diversified and reduced
risk approach
The role for and implementation of regulations,
and their enforcement
2.4 The Composting Association believes
that effectively enforced, appropriate regulation is necessary
to safeguard the environment and human health. Crucially they
also ensure there are appropriate "barriers to entry"
so as to enable legitimate businesses to compete on a level playing
field and not be undermined by unscrupulous operators.
2.5 We would welcome formal acknowledgement by
the regulator of industry codes of practice and voluntary schemes
that have been developed in partnership between the industry and
regulator. The Composting Association launched its Code of Practice[143]
in conjunction with the Cabinet Office, DEFRA, Environment Agency
and devolved administrations in 2005. This sets out good practice
guidelines that can be used as a benchmark by local planners,
regulatory authorities and industry.
2.6 We welcome the intent of the Environmental
Permitting Programme (EPP) to streamline waste permitting. However,
our members need assurances that the Environment Agency will be
sufficiently resourced to regulate and take enforcement action
against illegal operators; they should not be reliant upon fees
generated by licensed sites to undertake this duty.
2.7 Likewise, effective enforcement requires
an adequate knowledge base by front-line Agency staff. As the
waste industry becomes more complex and technical, it is paramount
that the Agency retains technical experts who can advise and impart
knowledge to front-line staff. In a rapidly changing industry,
we remain concerned that lack of technical competence by the regulator
may result in inappropriate enforcement action being taken and
poor operational decisions made. Funding of the Agency to enable
this is imperative in this regard.
The classification of waste
2.8 The Composting Association has been
instrumental in helping develop and deliver the Compost Quality
Protocol (QP) with the Environment Agency and WRAP. This built
upon the original compost quality standard developed by the Association,
which was subsequently translated into the British Standards Institution's
Publicly Available Specification (PAS 100). The launch of the
QP has helped remove a significant barrier that prevented many
of our members market their composted products. We are working
closely with the Agency and WRAP on QPs for anaerobic digestate
and uncontaminated top soils.
2.9 The issues surrounding the development and
implementation of the QPs are complex: we therefore urge Government
to consider ongoing financial support for this work in the future
through the Business Resource Efficiency and Waste (BREW) programme.
As the European Commission, through the Joint Research Council,
is currently reviewing end-of-waste criteria, it is paramount
that we engage actively to ensure that the work on the QP is acknowledged
fully in that process.
2.10 Although the Quality Protocols have
had a major impact in defining full recovery of composted materials,
there remains considerable uncertainty about the landspreading
options for Compost-Like Outputs (CLOs) from Mechanical Biological
Treatment (MBT) plants. MBT is currently receiving considerable
interest by local authorities to recover value and reduce the
biodegradable content of residual waste. The way in which systems
are designed and configured has a significant impact on the rates
of recovery of materials and the quality of recovered materials,
including CLOs: procurement decisions through PFI contracts are
currently being made which will therefore impact on operational
effectiveness of these plants. Furthermore, as Waste Strategy
2007 suggests that Government intends to consult on introducing
further restrictions on the landfilling of biodegradable wastes,
should this happen, the role of MBT seems likely to increase further.
We therefore urge Government, in conjunction with industry and
the Environment Agency, to establish guidelines on the landspreading
of CLOs.
The proposals for financial incentives to increase
household waste prevention and recycling
2.11 Incentives to promote recycling need
to be well planned and executed. This means that householders
participating in separate collection schemes need to be adequately
informed about acceptable wastes and unwanted contaminants.
2.12 The biological treatment sector has grown
on the basis of it manufacturing a range of products specifically
tailored for different market sectors. Quality here is the key:
operators are only able to manufacture quality products if the
input feedstocks are of sufficiently high quality with the minimal
level of contaminants, otherwise quality reduces and operating
costs increase markedly. Separate collection schemes are essential
to deliver this.
2.13 The rise in interest in biodegradable
and compostable packaging creates some opportunities and threats.
On the one hand, biodegradable bags that have been certified independently
to meet the European standard BS EN 13432 will play an important
role in helping to facilitate the hygienic collection of food
wastes. On the other hand, an increase in biodegradable packaging
sent for composting could present unacceptable levels of contamination
at sites, unless a clear communications campaign to inform the
public of the difference between compostable and non-compostable
packaging is established.
The role of composting
2.14 The composting industry has come a
long way over the past decade, currently treating in excess of
3.4 million tonnes a year. It is a tried and tested method for
transforming biowastes into marketable products, and has been
proven to be dependable globally. Since the introduction of the
Animal By-Products Regulations in 2003, the UK has developed a
number of sophisticated in-vessel systems that rely on complex
engineering solutions and operation by technically competent personnel.
Composting is no longer a cottage industry: it has a proven track
record for delivering a competitive biowaste treatment service
in the UK and thus represents a low risk approach for local authorities
and business.
2.15 Composting will have an important role to
play in helping local authorities meet their landfill diversion
targets. Rather than being a stand-alone operation, it will increasingly
form part of integrated biowaste processing sites, in addition
to AD, wood chipping, biomass generation etc. Whilst the Strategy
has focussed on anaerobic digestion, composting will need to remain
the process of choice for most woody wastes, as these cannot be
broken down anaerobically.
2.16 The markets for compost have developed
in parallel with the industry, and have been boosted by the compost
QP. As discussed previously, the continued success of the composting
sector to market a range of environmentally beneficial products
will rely upon the delivery of clean, uncontaminated feedstocks.
Integration with appropriate collection systems will therefore
be critical.
2.17 The benefits of using composts appear
to have been undervalued in the Waste Strategy, with greater emphasis
placed on promoting renewable energy derived through AD. Compost
use has two very important roles to play in helping deliver Government's
sustainable consumption and production strategy:
2.18 Agriculture—The benefits
of compost applied to agricultural land (in particular arable
crops) are significant and play an important role in the sustainable
management of soils and food production.
2.19 The benefits of using composts have
been realised by farmers for over 4,000 years. They play a vital
role in sustainable agricultural systems by returning nutrients
to the soil and arresting the decline in soil quality. Composts
help improve soil functionality and resilience, and sustain biologically
diverse habitats. This will help buffer soils against the predicted
increased frequency of intense rainfall events and prolonged summer
droughts. Some of the nutrients supplied can substitute for artificial
fertilisers and improved soil buffering capacity can reduce the
leaching of nitrogen and other nutrients. Recent studies in the
UK have shown that over a five year period with annual compost
applications, average yield increases of 7% over the whole period,
compared with conventional fertiliser applications, were observed.[144]
2.20 Horticulture—Compost has
the potential to replace about a million m3 of peat per annum,
thereby helping it to meet the UK's obligations under the Biodiversity
Directive. Furthermore, certain composts can suppress crop diseases
and other nuisances: thus reducing the use of synthetic fungicides
and other agrochemicals.
2.21 Landscaping—Compost also
has a potentially large market in restoring and "repairing"
soil on brownfield sites such as former factories and industrial
areas, as it can be an ideal component in topsoil manufacture
where existing soil is scarce or of poor quality. This is important
in terms of the current house building programme.
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
2.22 Proposals in Waste Strategy 2007 have
focussed on reducing methane emissions from landfill through alternative
treatment methods and strengthening the role of renewable energy,
such as anaerobic digestion.
2.23 Whilst we recognise the recent policy incentives
for renewable energy, the role of composts in helping to stem
carbon losses from soils appears to have been overlooked. As the
UK has experienced significant organic matter loss during the
last century, this benefit cannot be overstated. Figures from
England and Wales show that percentage of soils with less than
3.6 % organic matter rose from 35 % to 42 % in the period 1980-1995[145].
Research published in Nature suggests that loss of soil
carbon is linked to climate change.[146]
By inference, the controlled application of compost can help counter
some of this loss, thus mitigating carbon dioxide emissions. The
Composting Association has provisionally calculated that composting
an estimated 15 million tonnes of biowaste could have the potential
to off-set carbon dioxide emissions equivalent to those of over
a million cars a year.
2.24 We would therefore welcome better integration
of the Waste Strategy not only with emerging energy policies,
but also with the sustainable farming and food strategy. There
is a real need to establish policy drivers that provide a coherent
link between bio-resource and soil management practices.
The promotion of anaerobic digestion for agricultural
and food waste
2.25 Waste Strategy 2007 has placed a great
deal of emphasis on the potential for anaerobic digestion to be
employed as a treatment method for biodegradable (especially food)
wastes. We recognise that this has significant potential, and
Composting Association members are well placed to provide solutions
as part of integrated biowaste processing sites. However, in order
to realise this two issues need to be addressed:
2.26 The capital costs of investing in new infrastructure
are far higher than those for in-vessel composting. Even with
the proposed support through the double Renewables Obligation
Certificates per MWh in the Energy White Paper, additional support
may be required.
2.27 Support to assist the industry gain
the necessary skills and technical expertise in operating AD systems
and applying digestates to land will be required. AD is a technically
demanding process and it will take some time for operators to
gain the necessary skills to operate these systems effectively
under varying conditions. Unless both the industry and regulator
receives appropriate support, it seems likely that mistakes will
be made that may disadvantage the effective implementation of
this technology.
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
2.28 To meet the binding landfill diversion
targets, in the region of 150—200 new biological treatment
facilities are needed within the next decade, equivalent to about
three a week (source: Environment Agency). Despite a greater than
20% year-on-year increase in the quantities of biowaste composted
over the past decade provision of in-vessel and anaerobic digestion
facilities currently lags far behind that required to manage this
important waste stream.
2.29 Problems stem from:
— The inherent inflexibility of the
plan-led system to respond to changing circumstances and delivery
of the Waste Strategy—Regional Spatial Strategies and local
development documents take years to develop, resulting in a mismatch
between future provision and immediate needs
— Resistance to proposed infrastructure
by local residents, politicians and businesses—Uncertainty
and concerns about loss of amenity and environmental impacts fuel
a "NIMBY" attitude, which can "de-rail" even
the best application. Building trust and understanding within
local communities and elected members is a time consuming and
resource intensive process that can represent a disproportionate
burden for small businesses.
2.30 The lead-in time to establish new facilities
can be in excess of two years. Unless the planning process can
be improved, it seems likely that targets will not be met and
the environmental, social and economic benefits of improved resource
use will not be realised.
2.31 We suggest that Government establishes
a task force to review current policies and practices, and make
clear recommendations regarding a delivery timetable to establish
new infrastructure. Similarly, in order to improve knowledge and
understanding by elected members and local residents we would
like to see Government establish a Waste Planning Education Programme.
The Composting Association
November 2007
142 Market survey of the UK composting industry-2005-6.
The Composting Association and Waste and Resources Action Programme.
In Press. Back
143
The Composting Association (2005) Composting Industry Code of
Practice. Back
144
Wallace, P. (2006) Compost Use in Agriculture. Enviros Consulting
Ltd. Back
145
Favoino E. and Hogg D. (2006). The potential contribution of biowaste
to tackle climate change: shortcomings of life cycle analysis
concerning biowaste and relevance to policy-making. Orbit 2006
Proceedings. Back
146
Bellamy, P., Loveland, P.J., Bradley, I., Murray Lark, R. and
Kirk G.J.D. (2005) Carbon losses from all soils across England
and Wales 1978-2003 Nature Vol 437. Back
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