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
| 
