Waste Strategy for England 2007 - Environment, Food and Rural Affairs Committee Contents


Memorandum submitted by the Environmental Industries Commission (Waste 54)

  EIC was launched in 1995 to give the UK's environmental technology and services industry a strong and effective voice with Government.

With over 330 Member companies EIC has grown to be the largest trade association in Europe for the environmental technology and services (ETS) industry. It enjoys the support of leading politicians from all three major parties, as well as industrialists, trade union leaders, environmentalists and academics.

  EIC's Waste Resources Management Working Group represents over 80 companies involved in sustainable waste management and the response below is provided in the context of planning for waste treatment infrastructure.

  I would like to take this opportunity to respond to each of the areas of the area the Committee is focusing its inquiry on.

1.   How policies proposed by the Waste Strategy will be implemented and the roles of those responsible for the production and disposal of different classes of waste—including industrial, business and household waste. Localisation as opposed to centralisation of waste management

MUNICIPAL WASTE MANAGEMENT

  Municipal waste management is the responsibility of local authorities, and the provisions of the Waste Strategy are discharged through a range of measures, particularly the Landfill Allowances scheme.

However, the deliverability of the timed aspects of the targets set out in the Strategy is intrinsically linked with issues such as the planning, the availability of finance for new waste management facilities and the technical performance of these facilities.

EIC's Waste Resources Management Working Group believes that it is crucial that these three issues (planning; finance and technical performance) are tackled together to ensure that the necessary waste management facilities are in place to meet the targets set out in the Waste Strategy.

  For example, those facilities that often have highest levels of technical performance, and greatest bankability, are also those frequently attracting the greatest opposition during the planning process. This can delay the overall delivery of the necessary infrastructure, thereby jeopardising the achievement of the statutory targets.

  Facilities that appear to offer more rapid progress through the planning process offer less certain, or incomplete, solutions, such that they may still need, to process their output, the use of facilities such as those described above that may be slower to deliver.

  Whilst EIC supports the objective of making the planning system timely, cost effective, transparent and efficient (as set out in the recent Planning White Paper), our Members believe that it crucial to ensure that any changes to the planning system that streamline the delivery of waste management infrastructure are not at the expense of the key role planning plays in protecting the natural capital provided by the environment on which our economic system rests.

  However, to ensure that the Directive targets are met on their due dates, EIC recommends the development of contingency planning, to be implemented incrementally, should progress be less rapid than necessary.

  EIC also believe that the planning system could further facilitate the delivery of the Waste Strategy through the provision of recovery facilities in new developments.

  EIC recommend that the provision of recovery facilities is included in relevant Planning Policy Statements to ensure that when a local authority approves planning permission for a new development it is on condition of suitable recovery facilities being put in place.

  As part of the Waste Strategy the Government announced the launch of a Waste Stakeholder Group to provide external advice, challenge and assistance with delivering the objectives set out in the Strategy.

  EIC has been invited to sit on the Stakeholder Group and looks forward to contributing to the delivery of the Waste Strategy.

COMMERCIAL AND INDUSTRIAL WASTE MANAGEMENT

  Commercial and Industrial (business) waste management is not the responsibility of a specific authority, other than the responsibility of the originating companies to comply with the Duty of Care.

Business make decisions on their waste management primarily on the basis of cost and EIC believe that the Landfill Tax is the crucial measure to drive the development of non-landfill solutions for business wastes.

  This year's Budget announced that from 1 April 2008 and until at least 2010-11, the standard rate of Landfill Tax would increase by £8 per tonne each year to £48/T in 2010-11.

  EIC has engaged in a high-level lobbying campaign calling for a faster rate of increase in the Landfill Tax and welcomed the announcement on Landfill Tax in the Budget. However, Members believe it is crucial that the rate of increase in the Landfill Tax continues after 2011 to ensure it is successful in diverting waste streams away from landfill.

  A higher rate of Landfill Tax is likely to achieve an increase in:

    —  Resource efficiency, though the adoption of more efficient business practices.

    —  Recovery and re-use of materials and equipment, in preference to discard.

    —  Non-landfill treatment and recovery options including:

    —  Composting of green wastes

    —  Energy generation via Anaerobic Digestion, or Gasification/Pyrolysis, of wastes suitable for use as biofuels

    —  Energy generation via Solid Recovered Fuels derived from paper and plastics

  EIC supports this simplicity of driver towards improved resource management, and does not propose any further direction from Government.

2.   The role for and implementation of regulations, and their enforcement

  High environmental standards will be at the centre of a successful resource efficient economy.

EIC supports the consistent and appropriate regulation of resource management activities, but cautions that this should support realistic recovery of resource materials and not be based on a slavish defence of a legal position.

  Regulation needs to be designed to encourage the reuse of materials.

  Furthermore EIC recommends the improvement of knowledge sharing (in respect of decisions) amongst regulators. Our Members have reported that decisions made by one section of a regulator often conflict with those made in another as there are no suitable methods to facilitate knowledge sharing and, therefore, consistent enforcement of regulations.

  Lastly, the present risk-based approach to regulation should be reinforced, to support a high degree of self-regulation amongst practitioners with good track records, with greater regulatory efforts focused on poorer performers.

3.   The classification of waste

  No comment.

4.   The proposals for financial incentives to increase household waste prevention and recycling

The Climate Change Bill will allow up to five local authorities to pilot incentives schemes to encourage people to reduce, reuse and recycle their waste.

EIC welcomes proposals for incentive schemes that will allow local authorities to charge for waste collection by weight or volume, provided that these are supported by a major campaign of public education.

5.   The role of composting

  EIC supports the use of composting where appropriate to the feedstock and intended product.

However the term is ambiguous, and it should be clarified whether the process is to produce a useable compost, or is one of partial biostabilisation to reduce the biodegradability of the waste prior to further processing or disposal.

  Decisions over comparative performance in respect of carbon emissions should only be made after detailed Life Cycle Assessment using consistent boundaries.

6.   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

  Resource efficiency offers the opportunity for Government to promote greater productivity in business and reduce the burdens on the environment at the same time.

There can be no doubt that the opportunities for resource efficiency are huge. However, the current policy framework is fragmented, confusing and occasionally contradictory. This disincentivises businesses who need clear direction.

  A clear, demanding and long term Government policy framework should be agreed—and stuck to. This will encourage investment in the resources and technologies needed to drive waste reduction.

  The most important Government policy in this area is the Landfill Tax, which provides a direct signal of the cost of waste back to waste producers. The recent announcements of a faster rate of increase in the Landfill Tax is a welcome step forward.

  The Government can set clear and consistent policy with targets that can be measured in terms of waste minimisation. The Waste Strategy for England 2007 could have made the case for waste minimisation far stronger through targets at national and sectoral levels, including for commercial and industrial waste.

  Waste minimisation is still the poor cousin to recycling/recycled content due to these issues being over-emphasised in the past.

  The Government as a client and major specifier /procurer can lead the way in waste minimisation. This means working out the best way to set standards for others to follow. Where obstacles or confusion arise, this should be flagged as an issue that needs to be resolved, ie obstacles or confusion are preventing action being taken by the Government then they are also likely to be preventing action by everyone else.

7.   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

  EIC welcome the Government's decision to take a lead on setting statutory targets to reduce carbon dioxide emissions. This will play a crucial role in the transition towards a low carbon economy.

Tackling climate change is crucial for the future of our planet. Without decisive and urgent action climate change has the potential to be both an economic disaster and an environmental catastrophe. It is crucial, therefore,that every sector of the economy contributes to meeting the UK's statutory targets, and the waste sector is no exception.

  EIC believes that the compliance with the Landfill Regulations, which require that Biodegradable Municipal Waste landfilled is progressively and dramatically reduced, are leading to a significant reduction of methane emissions from landfill. Furthermore, via PPC Regulations, landfill gas is being captured, extracted, and where practicable used for energy generation, or burnt.

  These developments are, of course, welcome and will make an important contribution to meeting the UK's climate change targets, particularly when you consider that methane is 23 times as damaging a greenhouse gas as carbon dioxide.

  However, there is more that can be done.

  Landfills are currently responsible for 40 per cent of all UK methane emissions. EIC believes, therefore, that the Government should consider calling for the inclusion of landfills in future trading periods of the EU Emissions Trading Scheme.

  A central principle of emissions trading is that it allows for required savings to be achieved in the most cost-efficient way—thereby helping to resolve concerns about the impacts on competitiveness in Europe.

  For this to be the case the EU ETS must include as many sectors as is practical.

  Furthermore, the inclusion of landfills will have the added advantage of diverting waste away from disposal options towards recovery options.

8.   The promotion of anaerobic digestion for agricultural and food waste

  EIC considers that agricultural and food waste management should be considered separately: anaerobic digestion (AD) works best with a consistent quality and rate of feedstock, and produces a compostable residue in addition to gas which can be converted to energy. It is, therefore, well suited to the treatment of agricultural wastes.

Food wastes may, dependent on their source, be equally suitable for AD, but where their arisings are more variable, and the generation of a compost of less value, then alternative thermal processes using the food waste as a biofuel, such as Gasification or Pyrolysis, may be more suitable.

9.   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

  As aforementioned, EIC is concerned that there is a potential for missing the target in the Waste Strategy as a result of failing to deliver the necessary waste management infrastructure in time.

There are several estimates of the numbers and types of facilities required, and within the constraints of our market economy EIC recommends that closer consensus be reached of the rate of delivery and distribution of the facilities required.

  Government action to encourage the most efficient novel technologies has been focused on the New Technology Demonstrator programme, now coming into operation. EIC believes that this is a useful programme but it is now too late to start further physical exemplar facilities.

  Instead Government should focus on reducing the deliverability risks described in our answer to question 1.

Merlin Hyman

Director

Environmental Industries Commission

December 2007






 
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