Memorandum submitted by the Zero Waste
Alliance UK (Waste 63)
UK NATIONAL WASTE POLICYA BRIDGE HALF
BUILT
In July 2002 the Zero Waste Charter was launched
at the House of Commons, and has since received wide national
and international backing. It argued that there was a growing
environmental imperative for the reduction, recycling and composting
of waste to reduce:
the dangers to human health of incinerators
and landfills,
CO2 emissions, and
the pressure on virgin forests, on
minerals and on rapidly degrading soils.
The 10 point charter set out a strategy for
moving to Zero Waste in the UK, notably by:
maximising the recycling of dustbin
and of bulky waste,
introducing the doorstep collection
of organic waste and a composting infrastructure,
banning the thermal treatment of
mixed waste and the landfilling of untreated biological waste,
limiting waste disposal authorities
to 10 year contracts to ensure flexible facilities to complement
the growth of recycling and composting,
introducing a disposal tax and earmarking
its proceeds to promote Zero Waste, and
accelerating and extending producer
responsibility legislation.
After the launch of the Charter, the Government's
Strategy Unit supported many of the principles of the Charter.
It led to a radical increase in the landfill tax. It supported
increased rates of recycling and composting, secured additional
funding for WRAP to engage in waste prevention and recycling,
and for the first time recommended Mechanical and Biological Treatment
as an alternative to incineration and landfill as a means of handling
residual waste.
But it left a bridge half built. And policy
has in the meantime slipped back to its previous groove: timid
on targets, and a promoter of incineration.
Climate change will not be countered by limited
ambition. Leading countries and regions in Europe are now recycling
and composting 60% of their municipal waste. The UK remains a
straggler. Recycling has doubled in four years, but still stands
at no more than 23.5% in 2004-05. DEFRA's current review proposes
a maximum target of 50% by 2020, a level that the best UK authority
is already meeting. This sets the bar too low. It offers too little
too late.
Holding back recycling and composting and promoting
incineration will not reduce CO2 emissions. Yet this has been
the consistent thread of Government policy since the Strategy
Unit Review:
The UK government is notorious in
Europe for its opposition to the EU Bio waste directive, and has
had it shelved.
The UK Animal By-Products Regulations
have set levels of treatment way beyond those operating in the
rest of the EU, raising the cost and discouraging the composting
of domestic and commercial food waste.
The Government is pressing the EU
Commission to redefine incineration as recovery rather than disposal.
Funds for PFI waste disposal contracts
have been increased, encouraging large scale, capital intensive
disposal technologies and 20-25 year contracts and reducing the
incentive to maximise recycling.[177]
In proposing long term national targets
for incineration, but only modest short term recycling and composting
targets for individual local authorities (a maximum of 30% for
2007-08) Government encourages disposal authorities to crowd out
recycling and composting by the construction of large scale incinerators.
The escalating landfill tax coupled
with LATS, without graduated taxes on other forms of disposal,
encourages a switch from landfill to other disposal options rather
than the maximisation of recycling and composting.
DEFRA has substituted a tick box
sustainability appraisal for the Best Practical Environmental
Option, which has facilitated proposals for incineration at public
enquiries.
In spite of massive local opposition
the DTI has approved the proposal for a giant incinerator at Belvedere
in East London (up to 800,000 tonnes, making it the largest incinerator
in Europe), so creating a long term appetite for paper and plastic
from Greater London, that should be recycled to save CO2 emissions.
Belvedere's approval sets a precedent for giant schemes throughout
the country.
DEFRA's current Review is strong on the rhetoric
of recycling, but it fails to will the means. It remains a charter
for incineration not for Zero Waste. It argues for incineration
as a means of countering climate change on two grounds: that it
replaces methane producing landfill, and that it substitutes carbon
neutral electricity production for fossil fuel power stations.[178]
But it under-estimates:
The loss of stored up energy embodied
in recyclable materials prematurely incinerated (notably paper,
aluminium, organic waste and plastic).
And it takes no account of:
the capture of methane from landfill,
which at the high rates assumed elsewhere by DEFRA makes landfill
broadly comparable in terms of net CO2 emissions to electricity-only
incineration;[179]
the fact that electricity-only incinerators
generate4 more fossil CO2 than gas fired power stations and more
in total than coal power stations, while CHP or heat only incinerators
are only marginally better than gas fired stations even if the
heat is put to good usenot always possible even in areas
like Scandinavia where the demand for heat is higher than in the
UK;[180]
the sequestration of carbon in depleting
soils through the application of compost, or stabilised residues
from MBT plants; and
the lifecycle energy costs involved
(and the waste generated) in the production of the incinerators
themselves.
Incinerators are producers of brown energy not
green. They do not reduce green house gas emissions but increase
them, both because of the overall CO2 emissions at their strikingly
low current levels of efficiency of 25% or less, and because their
destruction of the "grey energy" embodied in the materials
they burn increases the need for new energy intensive virgin materials.
The incentive structure and the process of decisions
on disposal of waste are tilted towards incineration. Whereas
stabilised residues from MBT that are landfilled are subject to
the full landfill tax, bottom ash from incinerators is classed
as inert, and charged only £2 a tonne.
Far from facing a graduated tax as a means of
disposal, incinerators receive more Government funding, and have
greater access to private finance, than recycling or composting.
Accordingly they remain the technologies of choice for disposal
authorities which the Government have left with the decisive institutional
power in municipal waste management.[181]
Even where, because of public opposition, disposal
authorities have fought shy of incineration or its modern variants
pyrolysis and gasification, they have continued to negotiate 20-25
year inflexible contracts, incorporating Mechanical and Biological
Treatment (MBT) plants, that produce "refuse-derived fuel"
as a feedstock. They have made MBT, a potentially more flexible
means of stabilising residual organic waste and suitable for the
transition to Zero Waste, into a processing arm for incineration,
and a barrier rather than a support to Zero Waste strategies.
ZERO WASTE
ALLIANCE PROPOSALS
Zero Waste policies have had to swim against
the institutional and policy tide, rather than being carried along
by it. The Zero Waste Alliance therefore urges the Government
and local authorities to re-orient their policies in the direction
of Zero Waste, in line with leading regional and national governments
overseas, and further to the 10 points of the original charter,
adopt the following specific measures:
1. Set long term recycling and composting targets
of 75% for all local authorities by 2015, (and a minimum of 60%
for each individual local authority) along with waste minimisation
targets, to prevent their crowding out by local and regional long
term disposal contracts.
2. Press the EU to introduce the Biowaste Directive,
and its requirement for kerbside kitchen waste collections in
all cities, towns and villages with over 1,500 population.
3. Switch the government subsidy of PFI schemes
to the start up costs of food waste collection and composting,
as part of the Treasury's forthcoming Comprehensive Spending Review.
4. Extend the grant of carbon credits to recycling
and composting to reflect their impact on the reduction of CO2
emissions generated by the production of virgin materials.
5. Extend Producer Responsibility Legislation
to cover all materials in the household waste stream, and raise
the targets for recycling of plastic packaging, glass and metals
under existing legislation to those set by the leading countries
in Europe.
6. Recognise incineration as disposal not recovery,
in line with the EU Waste Framework Directive and rulings of the
European Court of Justice.
7. Fund a major research programme to identify
the hazards of nano particles, particulate aerosols, and brominated
flame retardants that arise from the burning of mixed waste.
8. Introduce an incineration tax of at least
£12 per tonne.
9. Charge incinerator bottom ash at the full
level of landfill tax (rather than the £2 a tonne which it
currently enjoys by virtue of its unwarranted classification as
inert waste) and reduce the landfill tax to £6 a tonne for
bio-degradable waste, stabilised to the levels set out in the
2nd draft of the Biowaste Directive.
10. Require compulsory insurance against future
pollution and health claims for all disposal and recovery facilities.
The past four years have not been wasted. The
ground for a radical increase in recycling and composting is now
prepared. St Edmundsbury has become the first council to pass
the 50% recycling and composting target. The leading continental
and North American authorities are now reaching 75%. They mark
the path to Zero Waste.
The imperative of climate change has, too, at
last been unequivocally recognised by scientists, by the media
and now by all major political parties. But it is not reflected
in waste policy. In spite of the evidence that recycling and composting
lead to major CO2 savings relative to incineration and landfillWRAP
estimates the savings of current levels of recycling and composting
at 10-15 million tonnes of carbon equivalent per year[182]
and in spite of its higher CO2 emissions relative to gas fired
electricity generation, the Government is still promoting incineration
as a source of green energy.
What is required is return to the boldness of
the Strategy Unit's policy, and a shift of finance and incentives
towards composting and recycling. Climate Change policy calls
for it. The Government should respect the evidence, free itself
from the disposal centred waste industry, and complete the work
that was left half finished after the Strategy Unit's Review.
The Zero Waste Alliance
November 2008
Annex
ZERO WASTE CHARTER
The organisations, groups and individuals who
have signed this charter are committed to achieving Zero Waste
in Britain by 2020. Zero Waste is a new concept being pioneered
by leading corporations, municipalities, and now provincial and
national governments. It entails re-designing products and changing
the way waste is handled so that products last longer, materials
are recycled, or, in the case of organics, composted. Waste is
in the process of being designed away.
The immediate imperatives behind the drive for Zero
Waste are environmental. There is a new awareness of the dangers
to human health of waste landfills and incinerators. Landfills
are major producers of methane, and polluters of water tables.
Incinerators produce greenhouse gases, and are a source of heavy
metals, particulates and dioxins. Zero Waste strikes at the cause
of this pollution.
It also lightens the ever growing pressure on
the world's forests, soils, and mineral resources by making more
with less. Doubling the life of a car saves the 15 tonnes of materials
required to make a new one. Recycling paper gives wood fibres
six lives rather than one. Increasing the productivity of resources
in this way also leads to major savings in energy. Zero Waste
will play a central role in cutting CO2 emissions and sequestering
carbon in the soil.
There is a further economic dividend. Redesigning
production and increasing recycling to eliminate waste is stimulating
a green industrial revolution. New materials and growth industries
are emerging, together with a growth in jobs. In Germany recycling
already employs more people than telecommunications. In the US,
it has overtaken the auto industry in direct jobs. Governments
that embarked on policies to reduce waste in order to combat pollution
and climate change, are now realising that zero waste is a key
element in any post industrial economic strategy.
Municipalities and companies overseas are well
on their way to zero waste. They have shown that it is possible
to recycle and compost 70% or more of their waste streams with
existing product design. Residual materials which are hazardous,
or are costly to recycle can then be phased out and replaced by
new clean materials that can be returned to use efficiently and
effectively.
Increasing numbers of cities and states have
adopted the goal of Zero Waste, including Canberra, Toronto, the
state of California, and most recently the Government of New Zealand.
This charter seeks to extend these pioneering practices to all
the municipalities and producers in the UK.
Our starting point is to create zero waste areas
where we live and workin our streets, and villages, in
our schools and hospitals, in municipalities and our many different
workplaces. We invite local communities, elected councils at every
level, and our major institutions and corporations to sign up
to these goals, to put in place measures to reduce their waste,
and to expand recycling and composting with the goal of achieving
Zero Waste by 2020.
By ourselves we can only go so far. The current
waste regime still favours disposal over recycling. The Government
must change this. Many products are difficult or too hazardous
to recycle. The Government can change this, too, by making the
manufacturers who produce them responsible for the waste that
results, and for redesigning products so that they are safe, long
lasting and can be easily recycled.
We call on the Governments of Britain, Wales,
Scotland and Northern Ireland to end a decade of policy timidity
and give a lead to the promotion of Zero Waste by adopting the
following 10 point plan to transform Britain's waste economy:
1. Set a target of Zero Waste for all municipal
waste in Britain by 2020 (50% by 2010 and 75% by 2015).
2. Extend the doorstep collection of dry recyclables
to every home in Britain without delay.
3. Provide doorstep collection of organic waste,
and establish a network of local closed vessel compost plants.
4. Convert civic amenity sites into re-use and
recycling centres.
5. Ban from 2006 the landfilling of biological
waste which has not been treated and neutralised.
6. Ban any new thermal treatment of mixed waste
and limit disposal contracts to a maximum of 10 years.
7. Extend the Landfill Tax into a disposal tax.
Increase its level, and use it to fund the Zero Waste programmes.
8. Extend Producer Responsibility legislation
to all products and materials that are hazardous or difficult
to recycle.
9. Open up waste planning to greater public participation
and end the commercial confidentiality of waste contracts.
10. Establish a Zero Waste Agency to promote
resource efficiency and act as a guardian of public health.
177 The National Audit Office report notes that PFI
deals take longer to bring to financial close than other types
of procurement, and that after nine years, only six residual waste
plants are in place or under construction. Back
178
Defra (2006) Review of England's Waste Strategy: A Consultation
Document, February 2006. Its wording is: "EfW reduces emissions
of greenhouse gases in two ways: because the wastes could otherwise
go to landfill and generate methane; and because emissions from
the biomass fraction of the waste, which are carbon-neutral, are
likely to replace those from fossil generation." p 60 Back
179
Eunomia, A Changing Climate for Energy from Waste, Friends of
the Earth, May 2006. Back
180
Eunomia, p6 Back
181
DEFRA's lack of clarity on MBT residues and composting requirements
is a further discouragement to disposal authorities seeking an
alternative to incineration. Back
182
WRAP, Environmental Benefits of Recycling. An international review
of life cycle comparisons for key materials in the UK recycling
sector, May 2006. The study was based on a comparative review
of 55 international life cycle studies, assessing 200 scenarios. Back
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