Memorandum submitted by the National Farmers'
Union (Waste 51)
The National Farmers' Union (NFU) is pleased
to respond to the Environment, Food and Rural Affairs Committee
inquiry on Waste Strategy for England 2007. The NFU has some 55,000
farmer and grower members in England and Wales and represents
the great majority of fulltime commercial farmers.
EXECUTIVE SUMMARY
1. The NFU generally welcomes Waste Strategy
for England 2007 as a step forward. However, the strategy still
has a huge imbalance towards household wastes and local authorities.
There is little new outside the domestic sector and it fails to
offer the necessary level of increased support for business. While
the statements to achieve synergies from the better integration
of municipal and commercial waste facilities and the encouragement
given to Local Authorities to take wider role in working with
industry are welcome, very little detail is given on how this
is to be achieved. The NFU is pleased the Strategy acknowledges
the work of the Waste Protocols Project. We would like to see
Defra commit further long-term funding to ensure the continuation
of this important initiative.
2. The Strategy is disappointingly short on action
to tackle the growing problem of fly-tipping. While we support
many of Government's proposed actions to reduce fly-tipping, it
is hard to see how these will be achieved without the commitment
of the necessary resources, especially to investigate and enforce
serious incidents of fly-tipping on private farmland where it
is clearly the work of organised criminal elements. We are confused
as to why the Strategy is proposing the introduction of financial
incentives for household waste prevention in the face of overwhelming
advice to the contrary from the Communities and Local Government
Select Committee. We are concerned such developments may contribute
to increased levels of fly-tipping and thereby compromise the
ability of Defra to deliver its policy objectives for the prevention
of illegal waste activity.
3. The NFU welcomes the setting of higher
targets for the composting of household waste and believes that
the on-farm composting sector can make a significant contribution
to help Government achieve these targets. However, we have concerns
that reform of the Waste Management Licensing regime may result
in regulatory barriers that restrict the development of the on-farm
sector. Similarly, we welcome the Strategy's strong support for
anaerobic digestion (AD) and believe that the farming sector can
play a key role in the development of the technology by offering
on-farm sites and facilities. We believe that AD technology has
considerable potential to reduce net methane emissions from management
of agricultural manure and slurries to help tackle the UK's contribution
to climate change. However the key issue of land use planning
matters seems to have been overlooked in terms of the ability
of the UK's capacity to develop the necessary infrastructure required
to deliver the objectives set out in the Strategy.
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
4. The NFU welcomes the Strategy's generally
broader scope to consider all wastes. However, the strategy still
has a huge imbalance towards household wastes and Local Authorities.
If Government is serious about tackling the large volumes of waste
produced by business and industry more detailed proposals to drive
commercial and industrial resource efficiency are required.
5. We welcome the fact that the strategy clearly
encourages joint planning and procurement between Local Authorities—both
between waste disposal authorities and waste collection authorities
in two tier areas and between groups of adjacent authorities.
We are also pleased that the strategy also encourages broader
roles for local authorities in planning for waste management and
infrastructure for all wastes not just municipal. A welcome statement,
if it is achieved, is the intention to achieve synergies between
municipal and other waste treatment through joint merchant/municipal
facilities. The NFU believes resource-based strategies and infrastructure,
regardless of sectors/sources of wastes are vital in delivering
a proper resource economy in England for the future. There are
however, again, no firm proposals to require, support or facilitate
this broader role in the strategy. Also, the crucial issue of
land use planning is not sufficiently addressed. The Strategy
merely reiterates the current Policy Planning Statement, PPS 10.
Meanwhile the recent planning white paper only concentrates on
very large waste facilities.
6. While we are aware that some examples
of co-operation and collaboration exist throughout England, these
tend to still be in the minority and much potential remains for
joint working. However, we feel that if this to really be achieved
then the strategy needs to go further than simply encouraging
joint working. Again firm and detailed proposals to either directly
support or facilitate such plans are required.
7. We feel strongly that Local Authorities
need to take some responsibility to help SMEs (including farm
businesses) with waste management. For instance, there are currently
very few easy options available for SMEs, especially those that
work from home even though much of the waste they produce may
be very similar in nature to household waste. An ideal approach
would be for this source of waste to be collected from the property
by the Waste Collection Authority, or delivered to a nearby Local
Authority household disposal site by the SME home worker/householder
along with household waste from the same property. For instance,
Local Authority household collection sites could work with SMEs
to accept small amounts of commercial waste and to issue waste
transfer notes. This would not have to be at a scale that would
disrupt the daily workings of the site or distract the site from
its primary aim of dealing with household waste. For example,
this facility could be made available for one day of the week
and only apply to smaller volumes of waste.
8. In most cases, home-based businesses
(we include farmers in this category) would be prepared to a pay
a small fee in return for the receipt of a waste transfer note
and the peace of mind that they have fulfilled their legal duty
in passing their waste to a licensed and responsible contractor/site
that will dispose of their waste. Unfortunately, doing the right
thing is often made the most difficult thing to do. Therefore
this has to be the best option for all involved here and would
be a huge help in leading businesses towards compliance whilst
helping prevent illegal waste disposal. Clear instructions or
guidance from central government are needed here to encourage
Local Authorities to take a more pro-active approach in helping
SMEs manage their waste.
9. The NFU is also pleased that the strategy
seems to support more localised resource management facilities
and solutions fit to meet local circumstances. As we point out
during the course of this submission, the agriculture sector has
a key role to play in offering sites, facilities and infrastructure
to offer local solutions to local waste management issues.
The role for and implementation of regulations,
and their enforcement
10. The NFU is supportive of Defra's move
towards simplifying the regulatory system and making it more proportionate
and risk-based. Yet for farmers and landmanagers, perhaps one
of the biggest disappointments is that the Strategy fails to give
sufficient enough attention to the widespread problem of fly-tipping.
While we support the proposals for tackling illegal waste activity
that are set out in the Strategy, we nevertheless feel it is desperately
short on detail as to how these actions will be implemented.
11. While the NFU welcomes any measures that
might help alleviate the problem and any steps to encourage good
practice, ultimately we believe that serious incidents of fly-tipping
can only be tackled with more resources. Proper support and resources
must be made available to the Environment Agency and Local Authorities
to ensure, as the Strategy states, "that the Environment
Agency and Local Authorities can do their job as effectively as
possible" We believe that the extent of resources within
Local Authorities and the Environment Agency to pursue serious
incidents of criminal activity to be one of the main limiting
factors. We do not feel confident that the Strategy puts forward
a sufficient and clear commitment to make the necessary resources
available. The Strategy talks of "ensuring better enforcement".
But regulators need full resourcing, not just via fees and charges,
to regulate the unregulated and ensure that enforcement can be
expanded.
12. The Strategy rightly points out new
powers to tackle illegal waste crime are available to police,
Local Authorities and the Environment Agency. But it is essential
that they must make much greater use of these powers. Therefore
training must be available for enforcement staff and the judiciary
to ensure that they are aware of policies and procedures and that
they are adequately prepared to bring cases against fly-tippers—particularly
those persistent offenders. The level of fines for those convicted
of fly-tipping are woefully inadequate to act as a sufficient
deterrent. The NFU feels that until fines are increased to match
the seriousness of the crime, offenders will continue to repeat
offend.
13. More "visible" enforcement
is needed and Local Authorities must be encouraged to develop
a strategic approach to fly-tipping at a local level building
on existing frameworks for tackling crime. There needs to be greater
provision at civic amenity sites for longer service hours and
inclusion of commercial waste facilities (either additional to
household sites or incorporated within household sites). The Environment
Agency's BREW-funded, area-based targeted waste crime initiatives
have achieved much in a relatively short period of time. E.g.
The progress made in the Derby/South Derbyshire area is just one
example of how the provision of more resources to the Environment
Agency and Local Authorities can enable new approaches in partnership
working and more innovative approaches to tackling waste crime.
14. The Strategy talks of "improving
the data and knowledge base". While we recognise that
the development of the Flycapture database represents a considerable
step forward in this regard, it must be stressed that the database
fails to record fly-tipping incidences taking place on private
land. Therefore the knowledge base in this area is unclear. In
response to parliamentary questiosn in March 2003, Michael Meacher
stated that an estimated 618, 000 tonnes of waste was tipped on
agricultural land during 2001. A further breakdown in the figures
indicated that some 380 000 tonnes of construction and demolition
wastes were tipped, some 118 000 of cars, 94 000 tonnes of green
wastes, 8 700 tonnes of tyres, 8500 tonnes of household waste,
5600 tonnes of furniture and 2900 tonnes of household goods. It
is thought that half of the estimated £100 million spent
dealing with fly-tipped rubbish is born by private landowners
themselves. In the absence of little official data, the actual
figure could well be more. Therefore the Environment Agency and
other enforcement authorities need to be equally aware of the
extent of fly-tipping taking place on private farmland. This information
is not currently captured by Flycapture.
15. More importantly, if the problem of
fly-tipping is to be genuinely tackled, resources must also be
available to investigate serious incidents of fly-tipping that
occur on private land as well as public land. Although Local Authorities
can be sympathetic about the problems of fly-tipping on private
land and may remove fly-tipped waste in some cases, in the majority
of cases it is left to the farmer to remove and manage and pay
for the disposal of dumped waste. In the case of serious incidents
which are clearly the result of organised criminal activity, the
costs of removal can be substantial. This is neither fair nor
helpful; nor is it in the public interest. Landowners are happy
to work with authorities to help identify criminal elements and
cooperate with surveillance activities but the will and the commitment
from the authorities must be there.
16. One must also bear in mind that there
are synergies between potential increases in waste crime, new
proposals put forward in the Strategy and future increases in
landfill tax. As the cost of waste disposal increases the likely
increase in environmental crime needs to be controlled. Therefore
it is only fair that some of the extra revenue from any increase
in landfill tax should be used for better enforcement to prevent
this possible knock-on effect. At the very least, Defra's BREW
programme must continue to fund work on tackling waste crime.
The classification of waste
17. It is well acknowledged that the classification
of material as a "waste" can act as a huge barrier to
its re-use. Businesses have to negotiate their way through much
confusion and conflict when it comes to the definition of waste
in particular circumstances. In many cases European and national
legislation act as disincentive in the reuse or recovery of waste
material which otherwise has the potential to be a valuable resource.
18. The NFU therefore welcomes the work of the
Waste Protocols Project as an innovative approach to define the
route to full recovery and take materials outside of regulatory
waste control. The NFU has been involved in this project both
through the project advisory board as well as being more directly
involved in the development of specific protocols, such as the
Quality Protocol for PAS100 Compost.
19. Against the backdrop of the current
European Waste Framework Directive, we believe the protocols route
is the way forward. Agreed standards and protocols provide users
with assurance and confidence—especially since some of the
recovered products may be applied to agricultural land and it
is farmers who manage much of this country's "landbank".
It is therefore essential Government ensure continued funding
is made available through Defra's BREW programme—not only
to enable this project to continue, but to make sure it is adequately
resourced to do so efficiently.
The proposals for financial incentives to increase
household waste prevention and recycling
20. The NFU understands that this topic
has been examined in depth in the Communities and Local Government
Select Committee report on Refuse Collection. Government will
be aware that the committee argued:
— The introduction of financial incentive
schemes will merely be seen as an additional charge for a service
most householders believe they already pay for through their council
tax;
— Revenue-neutral financial incentive schemes
does not necessarily mean "cost neutral" and will raise
little money for councils to help them manage their waste budgets
in the face of rising costs;
— Sums a householder may gain will
be comparatively small (Between £20 to £30 per year)
and arguably insufficient to change behaviour;
21. The Committee concluded that it was
hard to see why any council would want to set up a complicated
charging scheme that earns it no money and risks widespread disapproval.
The Committee's conclusions were based on wide variety of submissions
and evidence and it is hard to disagree with the findings. Therefore
while we agree it makes sense for Government to give Local Authorities
flexibility to determine how they respond to their waste management
challenges, it would seem foolhardy to pursue the introduction
of such incentive schemes.
22. Most importantly it was recognised that
such schemes could result in perverse effects such as potential
increases in fly-tipping. Therefore such proposals for financial
incentives might seriously compromise the ability of Defra to
achieve the waste crime policy objectives set out in the Strategy.
As we outlined previously, fly-tipping is a crime which can seriously
impact on farmers and rural landmanagers and more must be done
to address this problem.
23. We cannot help but feel that it would
be more worthwhile for Government to focus on incentives for waste
prevention and recycling by all sectors, not just for household
waste. While household refuse generates considerable political
and media attention it only represents around 9% of the total
national waste stream. Financial incentives are likely to deliver
more impact if focussed upon reducing, recycling and reusing waste
in the commercial and industrial sector. Offering forms of capital
relief can be a good way of incentivising investment.
The role of composting
24. The NFU welcomes the higher targets
set out in the Strategy for the composting of household waste.
We strongly believe the agricultural sector is well positioned
to play an important role in managing societal waste through on-farm
composting. On-farm composting of biodegradable waste can provide
a cost-effective, environmentally favourable waste management
option, which is already being successfully employed to deal with
various biodegradable waste streams such as green garden waste.
The Composting Association's 2004-2005 survey on the State of
Composting and Biological Treatment in the UK showed on-farm enterprises
to represent around 30% of composting sites across the UK. Collectively,
on-farm sites are thought to have dealt with around 13% of the
overall organic waste processed in 2004-2005 and the on-farm sector
saw a 40% increase in the quantity of waste managed between 2003-2004
to 2004-2005.
25. Many farmers have taken the opportunity to
diversify into small-scale on-farm composting. On-farm sites provide
valuable recycling facilities close to the source of the waste
and play an important role in those rural and semi-rural districts
to which they are particularly suited. In addition, on-farm composting
in many cases offers farmers and landowners an alternative source
of much needed income and can stimulate additional employment.
Farmers naturally make ideal waste managers as they have many
of the resources needed—space, machinery, land and existing
hard standing and building infrastructure. Crucially they also
have the inherent knowledge, understanding and experience of managing
biological systems.
26. The NFU therefore feels that the continued
contribution from the on-farm sector will be crucial in achieving
the targets set out in the Waste Strategy. However we are concerned
that significant changes to the regulations governing composting
may lead to the curtailing of activities in the on-farm sector.
The majority of on-farm outfits (around 80%) operate on waste
management exemptions as opposed to full waste management licences.
As part of Defra's Review of Exemptions and the introduction of
the new Environmental Permitting Programme (EPP), Defra and the
Environment Agency are looking at options such as reducing the
yearly limit and introducing new charges for registration and
notification. Although at present the quantity limits and costs
associated with the current exemption lie right on the edge of
what can be viable, they still manage to provide for a scale of
composting that can be carried out at a sustainable level. Moving
into full Waste Management Licensing/Environmental Permitting
is a major step change and the costs and time involved will mean
such a route is simply not viable for many farmers. The future
for on-farm composters therefore is either going to mean farmers
investing with significant financial cost to comply with new conditions
and controls or either dramatically reducing the amount of waste
they recycle to a token gesture. The affect of such changes, may
be to squeeze out many farm composing units. Entry costs may become
too prohibitive for those farmers looking to get into composting
as a viable diversification while any reduction in limits may
make them an unattractive option for councils. A fact that sadly
tends to be overlooked in all this is how such smaller, local
farm operations are vital to a sustainable rural economy. Most
importantly, if such regulatory changes hinder the development
of smaller-scale on-farm composting, we feel Defra will struggle
to meet the ambitious targets set out in the Strategy.
27. Another point to consider is that the
main market for finished compost is agricultural land. Use of
the material on land on the same farm on which it has been composted
can save on energy usage and transport costs. Finished compost
is a well recognised soil conditioner and therefore can play an
important role in enabling landmanagers to meet other Defra policy
objectives such as Cross Compliance requirements for soil management.
However Defra's proposed changes to the Nitrate Vulnerable Zone
(NVZ) Action Programme pose a considerable regulatory barrier
to the agricultural market for finished compost. Proposed changes
to closed periods and whole farm nitrogen loading limits may considerably
restrict the use of organic materials on farmland. This in turn
could also have a serious affect on the ability of Defra to meet
the targets set out in the Waste Strategy.
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
28. The NFU is pleased to see that Government
is putting in place a statutory producer responsibility scheme
for non-packaging farm plastics. We feel if such a system is implemented
in the correct way it will lead to further recycling and recovery
of waste plastics and the diversion of such material from landfill.
The NFU is working closely with Defra and other stakeholders to
develop a workable scheme. While the producer responsibility concept
puts the onus on the producers of the plastic material to pay
for the cost of the recovery and recycling/disposal, some costs
may be passed back to farmers in the form of increased plastic
costs. We encourage Defra to do what it can to monitor or ensure
that such costs are not too excessive as this will only hinder
the development of the scheme. This would be in nobody's interest.
29. We understand the House of Lords Science
and Technology Select Committee have appointed a sub-committee
to look waste reduction with a focus on sustainable product design,
products and production processes. It will be interesting to see
the information gathered as a result of this inquiry.
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
30. Proposals set out in the Waste Strategy
have the potential to reduce greenhouse gas emissions from waste
management—particularly from the development of localised
solutions to for local problems, eg as outlined previously, on-farm
composting of waste from the local vicinity and the subsequent
use of the finished material on the same farm can save on energy
and transport and some of the associated greenhouse gas emissions
involved.
31. If the strategy is sincere in its support
for the development of anaerobic digestion (AD) then there is
considerable potential for reducing methane emissions. The NFU
feels AD appears to be the most promising mitigation option for
reducing net methane emissions from management of agricultural
manures and slurries. This is arguably both more energy-efficient
and economic than composting of such residues, since it yields
a source of income from energy recovery, while retaining the nutrient
value of the digestate or "biofertiliser" by-product.
32. However it is important more work is
undertaken to develop greater understanding in this area. We generally
need to learn from methane mitigation knowledge in other countries,
especially work done on-farm within the EU. More research is needed
on the use of digestate from anaerobic digestion as a fertiliser,
including its effects on all greenhouse gas emissions, environmental
impacts, etc.
The promotion of anaerobic digestion for agricultural
and food waste
33. The NFU welcomes the Strategy's strong
support for anaerobic digestion (AD) as we feel that the agricultural
sector has an important role to play both in supplying waste inputs
and also providing some of the infrastructure for AD plants. The
farming sector can offer sites and facilities for such plants,
in much the same way as it currently does with composting units.
34. Such on-farm AD plants can contribute to
rural diversification as well as playing a useful role in improved
manure management. However, they have previously proven uneconomic
except where other (waste or non-waste) matter is "co-digested"
with the manures in order to boost gas and therefore energy yield.
35. While the measures set out in the waste
strategy are supportive and send out positive signals we are concerned
that much more needs to be done if the technology is really going
to take off. The NFU believes that future deployment of AD technology
in Britain is likely to involve:
— On-farm digesters utilising manures
and farm-based feedstocks like silage maize. These will not utilise
"waste" and so can operate without the need for a waste
management licence or environmental permit. Income will come from
sale of energy and possibly digestate—should markets develop
as a result of the AD Digestate Protocol. Therefore, while we
appreciate that this inquiry is focusing on waste issues, we must
stress that the NFU believes it is critical that AD is not regarded
solely as a waste management option, but also a way of adding
value to a by-product.
— Larger centralised waste-licensed
"merchant" plants, accepting multiple biodegradable
wastes (manures, food packing or processing wastes, supermarket
waste food, local authority green waste or food wastes), with
income from both energy sales and gate fees;
36. The NFU is aware of examples at both
of these scales. The former are likely to be around 250-500 kW
electrical capacity, while the latter would be more like 500 kW-10
MW. On-farm digesters could be shared between several nearby farms,
subject to regulation of movements and landspreading of manures
and digestate between farms. Centralised AD plants might be located
on rural industrial estates or close to food processing facilities,
and could perform a role in localised treatment of municipal wastes,
eg at the scale of a market town. Centralised AD plants are likely
to be more profitable than single-farm plants, although they will
have a longer design/planning lead time. Technologically, there
is no reason why AD should not succeed in the UK as it has in
Germany, where 3500 single-farm units have been installed with
a combined capacity of 1100 MW.
37. The NFU welcomes the proposed doubling
of the Renewables Obligation Certificates (ROCs) for AD technologies.
While this sends out a positive signal to the industry, Government
still needs to do much more if it is serious about incentivising
take-up, particularly at the smaller on-farm scale. This could
include offering capital grants, forms of capital relief, low-interest
finance, or project development support and assistance with the
development of market infrastructure (E.g. electricity network
access, markets for use of digestate etc.) If Government really
wants to AD take off it must do more to raise awareness of the
need for the technology. Awareness raising initiatives need to
be targeted in particular at planning authorities but also regulators
and communities as gaining support and understanding from all
these stakeholders will be key to overcoming current barriers.
38. The NFU is pleased that Defra is supporting
the development of a standard and protocol for the production
and use of anaerobic digestate. However it is essential that the
proposed digestate standard reflects both ends of the scale—ie
smaller AD units with agricultural inputs only, as well as larger
centralised AD plants (for which the digestate standard may require
more comprehensive proof of inputs and processing conditions).
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
39. It is well acknowledged that the existing
waste management infrastructure in England cannot currently deliver
the objectives of the Waste Strategy. The NFU supports the Chartered
Institution of Waste Management (CIWM) on this point, which argues
that strong historic reliance on landfill in this country means
that we must choose, design, build and commission new waste treatment
facilities of significant size at a rate of one per week for the
next decade. Facilities will be needed to meet the EU batteries
directive whose first target date is 2012 but with almost no facilities
to manage batteries anywhere in the UK. We will need an adequate
network of hazardous waste treatment facilities, WEEE processing
plants and liquid waste treatment facilities. The strategy also
proposes exploration of general landfill bans—as are used
elsewhere in Europe—which could require much more rigorous
sorting and/or treatment of commercial and industrial wastes before
the residues can be landfilled. In aggregate, these changes will
mean even faster development of infrastructure than suggested
above, involving all types of technologies and capacities as well
as greater transportation of materials—locally, regionally,
nationally and internationally.
40. The critical issue that has to be addressed
is planning. The planning system for waste facilities in England
will prove to be the rate determining step in developing new infrastructure.
The Planning White Paper issued in May 2007 seeks to streamline
the planning system but this is likely to only have an impact
on the development of particularly large-scale, strategically
important waste infrastructure.
41. Following the introduction of the Agricultural
Waste Regulations in 2006, agricultural waste is now classified
as industrial waste. This means there is a need within the sector
for appropriate facilities in rural areas for handling, recycling
and recovery of agricultural waste. Defra and the Environment
Agency are playing their part in encouraging secure, sustainable
farm waste management in line with farmers' agricultural business
needs and consistent with government policy on planning and waste
management. This includes providing advice for those farm businesses
looking to become "hubs" for farms in a locality participating
in "waste clubs and recycling schemes". Such clubs or
schemes would typically involve collection and delivery of small
amounts of solely "agricultural wastes" from local farms
to central farm collection site where it can be sorted or cleaned
and bulked up to sufficient enough volume so that it then becomes
economical to move it to a proper waste management/disposal site.
Such activities will be fairly seasonal by nature as they will
correspond with the annual agricultural production cycle.
42. However anecdotal evidence suggests
that while farm businesses are interested in diversifying into
this area many are dissuaded due to the administrative burdens,
costs and lengthy delays associated with engaging with the planning
and pollution control interface. This means there is a real threat
that such necessary infrastructure will not develop at all in
some areas. We would encourage government to consider relaxing
the requirement for express planning permission for certain developments
of this kind. Since such activities will typically involve relatively
small volumes of specific agricultural waste types, we instead
urge government to view this as agricultural activity not needing
planning permission or alternatively to explore ways that mechanisms
such as local development orders or permitted development including
prior notification can facilitate the development of farm waste
infrastructure. Communities and Local Government recently commissioned
a study for extending permitted development rights for non-household
development. We believe that any review or revision of permitted
development provides an ideal opportunity for Government to take
this point forward.
43. In our response to the joint DCLG &
Defra Consultation on options for improving the way planning and
pollution control regimes work together in delivering new development
we identified many barriers facing planning and waste management.
However since the consultation in 2006, we are yet to hear of
firm proposals or new developments from government on how such
land use planning issues are to be reconciled with the need for
new waste infrastructure. Until such issues are properly addressed
we feel that England will struggle to develop the adequate infrastructure
required to deliver the objectives set out in Waste Strategy for
England 2007.
National Farmers' Union
November 2007
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