Memorandum submitted by City of London
Corporation (Waste 56)
The City of London Corporation welcomes this
opportunity to offer its observations to the Committee as part
of its inquiry into the Waste Strategy for England. The City Corporation
is not in a position to respond to all of the questions posed
in the Committee's call for evidence but I hope these comments
will prove useful. May I also take this opportunity to offer my
thanks for allowing us a short extension in the Committee's deadline.
It is noted that, on the whole, the strategy is mainly
concerned with domestic waste collection whereas the City's main
concern is with commercial and industrial waste. The overwhelmingly
commercial nature of the City provides for a very different environment
in which to operate a cleansing and refuse collection service
when compared with other localities even those which include commercial
centres. By way of example, the City has well under 10,000 residents
but the City of Westminster has over 230,000. In addition to the
concentration of business premises, there is of course the large
volume of people who enter the City during the day for work, as
tourists or en route for other destinations within London. Together,
these present a challenging task for the City's cleansing services
but, nevertheless, the City of London is pleased to have received
Britain's Cleanest City award in 2001 and 2005, and being runner-up
in 2003 and finalists in 2007.
The City does however have some concerns over
the proposed changes to performance targets which could unfairly
reflect the performance of the City. The City would suggest that
more individualised targets should be set to take account of the
different characteristics of different authorities. Alongside
these, figures for recycling, composting and reuse should be shown
separately. Household waste composted in home schemes should not
be included as it is very difficult in the City's view to develop
a practical and robust method of measuring the mass of home waste
composted at a cost which will not exceed the value of the information.
Similarly, there are also concerns over the recovery of metals
from household waste. These should not be included due to the
problems of re-attributing them to the appropriate authority given
that most incineration plants incinerate waste from more than
one source. More generally there are also arguments for the inclusion
of contextual and explanatory information to be published alongside
performance results.
The other main concern is over the definition
of "municipal waste". There is a developing consensus
that the current definition is too vague and has led to too many
interpretations and variations amongst authorities, not just for
the purposes of the Landfill Allowances Trading Scheme (LATS).
Existing LATS targets are based on the current Waste and Emissions
Trading Act definition of Municipal Solid Waste (MSW). Any changes
to the targets without any corresponding change to the definition
of MSW would be of concern. Proposals to amend the definition
are therefore welcomed but the suggestion to describe municipal
waste as "to explicitly encompass all waste which comes into
the possession of or under the control of waste disposal or waste
collection authorities, with the exception of municipal construction
and demolition waste" still leaves aspects which are subject
to interpretation.
For example, does the term "control"
refer to an authority having "control" of third party
commercial waste using a transfer station or disposal site; does
an authority have "control" on any or all wastes generated
in its own local area [buildings, premises, open spaces, etc]
even if that waste is managed by outsourced contractors and does
not use any of its own authority provided resources; or does an
authority have "control" on waste generated on land
owned by itself but situated outside its boundary in other authority
areas? If the answer to any of these questions were "yes"
then the City of London Corporation could be negatively affected
to the proposed changes and, indeed, could face significant extra
LATS costs.
If you have any further queries in connection
with the City's interests in this field, please do not hesitate
to contact me or Bruce Hunt who has been responsible for the preparation
of this submission.
City of London Corporation
December 2007
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