Memorandum submitted by the CBI (Waste
49)
1. As the UK's leading business organisation,
the CBI speaks for some 240,000 businesses that together employ
around a third of the private sector workforce, covering the full
spectrum of business interests both by sector and by size. Member
companies, which decide all policy positions, include 80 of the
FTSE 100; some 200,000 small and medium-size firms; more than
20,000 manufacturers; and over 150 sectoral associations.
2. CBI members include waste producers, waste
managers and companies developing waste treatment technology.
Waste and resource efficiency is a major business issue and CBI
welcomes the opportunity to submit written evidence for the Committee's
Inquiry.
3. As the Waste Strategy recognises, we
have achieved a partial decoupling between the trend in waste
arisings and economic growth. Total business waste arisings have
been broadly stable in recent years. But we agree with the Government
that we need to go further. The CBI believes that in doing so
we should focus on reducing CO2 emissions from waste and on reducing
the total volume of virgin resources used by the economy. On this
basis we support the aims of the Strategy as set out on page 9
of the document.
WELCOME ASPECTS
OF THE
WASTE STRATEGY
4. The Strategy brings together a series
of existing and new policies which it expects to reduce business
waste arisings by 20% over 5 years. Many of these policies are
welcome, for example:
— Recognition of existing drivers for
better business waste management: the enhanced Landfill Tax escalator,
the Renewables Obligation as it applies to energy from waste (EfW),
the introduction of Site Waste Management Plans, and the Landfill
Directive requirement to pre-treat non-hazardous waste.
— Materials-specific initiatives: There
are also a number of welcome smaller scale initiatives on matters
such as packaging and plastic bags, and specific materials such
as plasterboard that will affect business.
— Encouragement of synergies between
municipal and business waste treatment: The Strategy suggests
that facilities for municipal waste should have spare capacity
for merchant availability for business waste and the CBI would
support this.
AREAS OF
CONCERN
5. Despite the many welcome benefits, the
Strategy is weak in three areas, which together may threaten the
achievement of the 20% reduction of business waste arisings:
— Level of support for business resource
efficiency
— Planning system
6. Support for business resource efficiency:
In terms of business waste, the Strategy focuses on measures to
constrain the ability of business to landfill waste. But by itself,
may not be enough to generate the identification of and investment
in opportunities to improve resource efficiency and alternative
waste management options. While there are sizeable theoretical
savings from improved resource efficiency which can be made in
many sectors, these may not always be realised due to a mix of
upfront costs, low scale of benefits compared to turnover (for
example, for most sectors analysed in a Cambridge econometrics/Envirowise
study, potential savings were less than 1% of GVA), or lack of
senior management awareness (42% of SMEs in a YouGov survey never
discussed recycling at Board level).
7. The Business Resource Efficiency and
Waste (BREW) programme, funded by landfill tax receipts, is intended
to help business identify waste minimisation opportunities. However,
since the launch of the Strategy it has become clear that the
BREW budget no longer has direct access to landfill tax receipts
and is likely to face funding cuts.
8. Planning: Likewise, the Strategy fails
to fully address the need to enable the planning system to deliver
increased deployment of waste facilities. This remains a barrier
to waste recycling and recovery. CBI Members have reported delays
of 2 years for a materials recycling facility and even longer
for other disposal facilities. It is estimated that there is a
need for some 1,000 to 3,000 new facilities to handle even municipal
waste. However, since municipal waste only accounts for some 9%
of total waste further major investment will be required to re-use
and recycle business waste.
9. The Strategy also argues that municipal
facilities should have spare merchant capacity. The CBI supports
this, but it is not clear how it would be achieved. It is important
that there should be no cross-subsidy of business waste processing
and municipal waste activity or vice versa.
10. Regulation: Too often waste regulation
has created unnecessary bureaucracy or frustrated business action
that would have had an environmental benefit (eg reuse of material
classified as waste). Business is not convinced by the Strategy's
assurances that the waste regulation has been successfully reformed.
Progress has been made, but the Waste Framework Directive revision
was a missed opportunity to develop a better legal definition
of "waste". It is still the case that even with such
initiatives as the EA/WRAP protocol project (which determines
when substances cease to be waste), everything has to be taken
on a case by case basis meaning that every substance has to be
considered separately. This causes delay and legal uncertainty.
11. The Strategy may also be overoptimistic
in the impact it hopes the EU Energy Using Products Directive
(EuP) will make. This is the first Directive to enshrine "life-cycle
thinking" and thus covers design of equipment for end of
life as well as during construction and in service. However, the
CBI believes that actions under this Directive are initially being
targeted on products for which energy use during service are dominant
and that it will take a long time before actions under the Directive
will address resource efficiency in terms of material.
12. Other concerns: Annex F of the Strategy
addresses the issue of the enforcement of regulations against
waste crime, such as fly-tipping. Given that a number of the drivers
in the Strategy eg Landfill Tax are likely to stimulate such crime,
it is not clear that the proposals in Annex F are sufficient.
13. The CBI supports the "waste hierarchy"
as given in the Strategy as a valuable guide to the priorities
of waste handling. However, it should not be regarded as an absolute
rule. For example, although EfW is towards the bottom of the hierarchy,
it can both be a sensible waste treatment option for some wastes
and make a contribution to UK energy policy. And placing landfill
at the bottom of the hierarchy is understandable, but it must
be remembered that modern, well engineered landfill with high
levels of methane capture poses only a limited environmental threat,
and will always be needed to some extent both for certain wastes
and given the current requirement for restoration of mineral workings
of some 60M te per year.
FURTHER ACTION
NEEDED
To address these weaknesses in the strategy,
and improve the likelihood of the hoped-for 20% fall in business
waste arisings being achieved, action is needed in three areas:
— Reforming the planning system
A more rigorous approach to tackling environmental
crime is also needed.
INCREASING DEMAND
FOR SUSTAINABLE
PRODUCTS
14. The most effective way to encourage
resource efficiency is to increase demand for sustainable products,
ie those which use less virgin material. This creates a market-driven
"virtuous circle" where manufacturers have an incentive
to produce more resource efficient products, and also the demand
for recyclates is higher and there is more incentive for all players
to segregate and collect waste streams which can be recycled.
Several things can be done to stimulate this demand for sustainable
products.
15. First, there needs to be proper promotion
and demonstration, by Government if necessary, to show sustainable
products are "fit for purpose". A business to business
example would be the promotion by BRE and WRAP of recycled aggregate,
as a result of which 70Mte of recycled aggregate was used in the
UK in 2006, equal to 26% of the market (and three times the EU
average of 8%) Government should support this phase of development
together with the production of procurement specifications that
can be used by both public and private purchasers. Public procurement
can then "kick start" the market and the product may
then become competitive. For consumers, it is equally important
that the product is well designed and fit for purpose.
16. Second, despite significant work by
the British Retail Consortium and WRAP, current labelling systems
for recycled and recyclable products are confusing. The development
of clear, simple and meaningful labelling would assist the green
consumer. Even a simple product may have several environmental
labels (for example a ballpoint pen refill from one manufacturer
carries 4 separate environmental advice labels on its packaging,
none of which are explained).
17. Third, incentives for householders to
produce less waste (eg rebates on Council Tax), could further
stimulate demand for sustainable products.
18. Fourth, it should be remembered that
sustainable products from recycled materials need to be competitive
in the market place whether in the business to business market
or the consumer market. In general, this drives a global resource
flow that must be available for recyclate resources as well. For
example, about 60% of metals for recycling are exported. The administrative
burden arising from the implementation of the new EU Transfrontier
Shipment of Waste Directive should be reduced.
Improving support for business resource efficiency
19. Many of the programmes under the BREW
umbrella have shown themselves to be effective in realising the
potential resource-efficiency gains available to business. Defra
calculates that the BREW programmes would account for about one
fifth of the 20% fall in business waste arisings it expects to
see. On this basis, there seems a good case not for cutting the
programme budget, as seems likely, but for some expansion where
the cost-benefit data from the programmes justify it. NISP is
an example of a programme which has proved cost-effective and
probably has potential to scale up.
20. There is also a need to clarify what assistance
is on offer and the differences of responsibility between the
deliver bodies. For example, there are several separate Government-funded
websites offering resource efficiency advice (eg the resource
Efficiency KTN web site, is funded by DBERR, but the Waste Matters
and NetRegs websites, are funded by DEFRA, yet they do not even
cross-refer). It is to be hoped that the Business Support Simplification
initiative will help address this issue.
Ensuring the planning system stimulates the provision
of waste facilities
21. There is a need for increasing availability
of waste treatment facilities if the aims of the Strategy are
to be met. The Strategy references work being undertaken by the
recently established Waste Infrastructure Delivery Programme (WIPD)
to ensure the coordination of regional and local planning strategies
to ensure necessary waste infrastructure is planned for, and delivered
in a timely manner. But the Government must go further if the
planning system is to deliver the volume of waste investment required.
22. Timeliness of plans: The Barker Review detailed
the difficulties that local authorities have faced in migrating
to the new Local Development Framework plan making process (introduced
by the 2004 Planning Compulsory Purchase Act), arguing that the
procedures were "over engineered" and took too long
for delivering new plans. The statistics bear this out. By November
2007 264 local development plan documents were due to be submitted
to DCLG ministers, but only 119 had been submitted. Of the 22
waste development plans to have been submitted; only half had
been. Given the pressing timescales in the Waste Strategy, the
Government must find a way to ensure plans are delivered on time.
23. Guidance to local authorities: Local
authority planning Committees are often reluctant to approve applications
for waste facilities due to public opposition. For renewable energy,
where the issues are similar, the Government has taken a very
proactive stance with the draft Planning Policy Statement (PPS)
Planning and Climate Change, which states that planning
authorities should: "look favourably on proposals for
renewable energy, including sites not identified in development
plan documents;", "not require applicants to demonstrate
overall need for renewable energy . . . and
"avoid policies that set stringent requirements for minimising
impact on landscape and townscape if these effectively preclude
the supply of certain types of renewable energy". A similar
approach may be needed for waste, if PPS10 proves insufficient.
24. Public information: The CBI believes
that local opposition to planning applications is sometimes distorted
by lack of factual information on health and environmental impacts
of waste technologies. If business provides this information it
can be accused of bias in the results. Government funded research
such as the health impacts study of waste management activities
can assist in such cases.
Reducing the impact of environmental crime
25. Criminal activity, such as fly-tipping,
frequently gives business a bad name and undermines the responsible
businesses that comply with the regulations. To gain a level playing
field, responsible business wants strict and fair enforcement.
However, a distinction must be made between these deliberate offenders,
and businesses with good environmental records which make a genuine
mistake or administrative error.
26. The Strategy made none of the improvements
to the enforcement system that are required. The CBI believes
that a major deterrent should be the certainty of being caught
and regulators must be sufficiently funded for their enforcement
role. Unfortunately, the fines imposed by the courts for environmental
offences are frequently insufficient to act as a deterrent, sometimes
being less than the costs of legal disposal for the waste. Business
suffers twice, once by being undercut and once by having to pay
for clearance of own sites. Improvements in the training of magistrates
may improve this situation.
CBI
November 2007
Annex
CBI responses to the Committee's specific
questions
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
27. See main response.
Q2. The role for and implementation of regulations,
and their enforcement
28. See main response.
Q3. The classification of waste
29. Materials should be classified as waste only
where there is need for it to be controlled eg to avoid fly-tipping
or for disposal. Waste sold for use/recycling will not be fly
tipped. It should be noted that other authorities than the Environment
Agency may exert control, such as the Health and Safety Executive
30. Within this classification waste should be
classified according to its actual properties eg lead glass does
not leach lead and is not hazardous. The current European Waste
Catalogue is not helpful as it is not user friendly and classifies
wastes by the industry producing them. The same material may have
more than one classification if it is produced by more than one
sector.
Q4. The proposals for financial incentives
to increase household waste prevention and recycling
31. The CBI supports the principle of this
initiative.
Q5. The role of composting.
32. Composting is only one of a number of valuable
routes to produce products from biodegradable waste, others exist
such as Mechanical Biological Treatment, Anaerobic Digestion etc.
The Government should resist the temptation to favour any particular
technology. The recyclate market should determine the technology.
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
33. See main response.
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
34. The Strategy rightly makes the important
link between reduced landfill and reduced virgin resource use,
and carbon abatement. The detailed impact is complex, given that
there are cases where recycling can actually be more carbon intensive
than used/production of virgin material, and also that modern
landfill employs methane capture for a significant amount of methane
emissions. It should be noted that Landfill gas generation uses
methane. Between one half and three-quarters of landfill gas methane
is collected for this purpose, thus minimising methane emissions
and producing renewable energy at the same time. Therefore while
the Strategy can and should make a small but important contribution
to meeting carbon targets, it is important that the cost/tonne
of carbon saved of proposed waste measures is compared with alternative
polices developed through the Climate Change Programme and the
Energy White Paper, to ensure cost effective policies.
Q8. The promotion of anaerobic digestion
for agricultural and food waste
35. Anaerobic digestion (AD) is a very suitable
technology for producing energy and recyclate from biodegradable
waste. It is capable of diverting large quantities of biodegradable
waste from landfill and saving on the emission of greenhouse gases.
Further technological development may provide competing technologies
to AD. Provided both the carbon footprint and resource efficiency
of the process is taken fully into account, the Government should
allow the market to decide the technology that is actually used.
(see paragraph 32 above).
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
36. See main response.
CBI
November 2007
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