Memorandum submitted by the Chartered
Institution of Wastes Management (Waste 22)
The Chartered Institution of Wastes Management
(CIWM) is the professional body which represents around 7,300
waste and resource management professionals, predominantly in
the UK but also overseas. The CIWM sets the professional standards
for individuals working in the waste management industry and has
various grades of membership determined by education, qualification
and experience.
CIWM's special interest group for Sustainable Management
of Resources and Waste Strategy were consulted on this inquiry
and their comments helped form the response for CIWM. CIWM's Biological
Treatment special interest group informed CIWM on the responses
for questions 5 and 8.
EXECUTIVE SUMMARY
In preparation of this evidence CIWM has worked
with the Institution of Mechanical Engineers and the Institution
of Civil Engineers and welcome the Waste Strategy for England
2007 and believe that the overall strategy is the correct one.
However, during the consultation we have identified a number of
shared concerns that we believe will fundamentally affect the
ability of England to deliver against the targets set out in the
strategy and those required by legislation originating from Europe.
Infrastructure deficit
The existing infrastructure, and the current rate
of growth of infrastructure, will not deliver the more sustainable
approach to waste envisaged in the strategy.
Most importantly, future infrastructure needs to
cater for all wastes, regardless of origin (ie commercial and
industrial waste as well as municipal), and there are four areas
in particular where attention needs to be focused:
— the necessary skills to plan, build
and operate new waste treatment plants;
— an effective planning system;
— communications and awareness raising
to improve co-ordinated action by all parties; and
— decision support tools, including
better data, cost benefit and life cycle analysis, etc.
Waste treatment technologies
The strategy should avoid promoting one type
of technology over another. We believe that local authorities,
either individually or jointly, are best placed through their
strategic planning role to identify what scale and type of technology
best suits their needs.
Waste as a resource
Although the strategy takes a big step forward by
linking waste into the wider environmental agenda—including
resource efficiency, energy policy and climate change—we
want to see this message driven home through a detailed action
plan to ensure that the concept and practice of using waste as
a resource becomes effectively embedded.
The following is specific to CIWM:
The new Waste Strategy for England successfully identifies
the need to integrate three important policy and delivery issues:
— Climate change, energy and resource
efficiency
— The need to include all wastes, not just
municipal wastes, as parts of sustainable resources management,
and
— The need for partnership working—between
public, private and third sectors as well as between different
tiers and areas of local government—and an integrating role
for local authorities.
Having painted this broader picture it is vital
that Government keep up the momentum to deliver on the 94 proposed
actions in Chapter 8 of the strategy. Only co-ordinated and sustained
action by all stakeholders will deliver the more sustainable resources
management vision. In this, co-ordination through the Waste Strategy
Board and the Waste Stakeholder Group will be vital.
More encouragement and direction to adopt a
broader role is now needed for local authorities to help deliver
this strategy. Previous waste strategies have focused on the "waste"
function of local authorities. Now, the resources agenda means
more corporate interests will develop. This is as much about economic
development opportunities and social engagement as it is about
waste management. The authorities will need to show innovation,
leadership, and partnership with others—involving the private
and third sectors; joint working with other authorities and vertical
governance within the regions to plan, procure and provide for
wastes and resources; and land acquisition, strategic and spatial
planning to support development plans. Local authorities can do
this, but they need to be properly resourced to do so, and—as
with national Government—will need to communicate outside
of the "normal" set of stakeholders.
The Committee advised they will consider nine
particular points and CIWM would comment as follows:
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.
1. CIWM supports the strategy's promotion
of shared responsibilities for waste by all parts of society.
2. CIWM also welcomes the strategy's broader
scope to all wastes. Previous strategies focussed almost entirely
municipal waste which represents less than 10 percent of the total
tonnage.
3. However, most of the early action under
the strategy again focuses on municipal wastes and local authorities.
The strategy does contain proposals to drive commercial and industrial
resource efficiency and more sustainable waste management but
these tend to be longer term and less detailed. Notable exceptions
include construction and demolition wastes targets under the draft
Strategy for Sustainable Construction and proposals for statutory
Site Waste Management Plans.
4. The strategy encourages joint planning
and procurement between Waste Disposal Authorities and Waste Collection
Authorities in two tier areas and between groups of adjacent authorities.
CIWM believes this will drive benefits from common practices,
streamlined and better value procurement and improved economies
of scale for some solutions. CIWM also believes the strategy rightly
supports more localised resource management facilities and solutions
fit to meet local circumstances.
5. Notable examples of co-operation and
collaboration exist throughout England, but much potential remains
for joint working. Although the strategy encourages such joint
working there are no firm proposals to either require, directly
support or facilitate these plans.
6. The strategy encourages authorities to
provide better waste management/recycling services for businesses
in their areas. There are examples of good practice but widespread
delivery of such services by the public sector, either direct
or via private sector contractors, requires full funding for the
authorities. Following the Chancellors pre-budget report in October
CIWM has highlighted concerns about the level of funding available
to local authorities to deliver infrastructure and services needed.
Copy attached Annex 1.
7. The strategy also encourages broader
roles for local authorities in planning for waste management and
infrastructure for all wastes not just municipal. CIWM believes
resource based strategies and infrastructure, regardless of sectors/sources
of wastes are vital in delivering a proper resource economy. There
are however, no firm proposals to require, directly support or
facilitate this broader role in the strategy. Waste contractors
advise that, because of the way in which the infrastructure is
funded (eg PFI/ PPP) local authorities are often a reluctant to
allocate capacity to treat commercial waste, especially any outside
of their own "trade waste" collection service.
8. The strategy encourages third sector
involvement in service delivery through medium term proposals
to assess and support. CIWM agrees the third sector adds value
in terms of services and social benefits unlikely to be satisfied
through either the public or private sector. CIWM would welcome
clearer proposals to support third sector involvement where their
"added value" is most appropriate.
9. Delivery of the strategy's objectives
will involve co-ordinated and sustained action by all parties,
including permanent behavioural change and perceptions by the
public at work and at home. This strategy stands or falls on the
strength of leadership by Government from the highest level and
through many of its departments working in close co-ordination.
Also, given that Government has not created any formal strategic
waste authority to monitor and manage the strategy, the arrangements
for the Waste Stakeholder Group will need to be robust and clearly
co-ordinated and lead by Defra. CIWM and other professional institutions
will be pleased to commit to the work of this group and offer
its information or skills wherever appropriate.
2. The role for and implementation of regulations,
and their enforcement.
10. The strategy highlights Government's
intention to review and streamline waste regulation. CIWM supports
this work to maintain proper protection for people and the environment
whilst keeping regulatory burden on compliant waste businesses
to the minimum necessary to achieve this.
11. The strategy specifically proposes new legislation
eg review of the waste Duty of Care, statutory Site Waste Management
Plans and waste carriers/transboundary movement controls. CIWM
supports these proposals.
12. The legitimate resources and waste industry
cannot compete with criminals. Regulators need full resourcing
to combat all forms of environmental crime. This cannot come just
via fees and charges paid by regulated businesses. This has been
a consistent theme to recent CIWM consultations and inquiry submissions.
13. As the cost of responsible waste management
rises any increase in environmental crime must be tackled. More
resources are needed for the Environment Agency and local authorities
to ensure that enforcement can be expanded, alongside provision
at civic amenity sites for longer service hours and inclusion
of commercial waste facilities (either additional to, or incorporated
within household waste sites).
14. All local authorities should ensure
that their enforcement officers have the necessary skills (similar
to those in the Environment Agency). CIWM has worked with Defra
and ENCAMS to deliver the FlyCapture training programme to help
build these skills.
3. The classification of waste.
15. The European Waste Framework Directive
is being reviewed and will include EU-wide protocols to identify
when wastes have been fully recovered to a standard where they
no longer need to be treated as "wastes". This will
support secondary materials markets, and reduce regulatory burdens
and stigma associated with waste materials which are often indistinguishable
from virgin materials.
16. This important work will pick up on development
of protocols in the UK via WRAP, UK Environment Agencies and the
industry, eg compost, anaerobic digestion (AD) and wood. CIWM
fully supports this work and its recognition in the national waste
strategy and wants to see Business Resource Efficiency and Waste
(BREW) support continued for protocol development.
4. The proposals for financial incentives
to increase household waste prevention and recycling.
17. CIWM responded in full to Defra's consultation
on Incentives for Household Recycling. The main points raised
(attached in Annex 2) were:
18. Incentives to recycle or reduce will
only work if proper separation and collection systems are available.
CIWM wants to see greater co-operation and collaboration between
authorities to procure and operate common collection mechanisms
to support public participation.
19. CIWM wants to see action under the strategy
to incentivise waste prevention and recycling by all sectors,
not just for household waste.
20. The increased landfill tax escalator
to £48/tonne by 2010 is a crude economic instrument. It will
influence householder behaviour, but only indirectly, although
it is already beginning to have a direct impact on commercial
and industrial waste production. CIWM wants transparent decisions
on how the increased tax yield will be used and the local authority
element fed back to support better service delivery by local authorities.
5. The role of composting.
21. Composting is a relatively low capital
and revenue cost treatment for a broad range of organic wastes
from all sectors and infrastructure can be developed quickly to
help divert waste from landfill.
22. Control over inputs and process—for
windrow and in-vessel composting—are vital to assure product
quality. Composts produced could be beneficial to UK soils which
have lost important organic content but only if quality is high
and sustained through standards and protocols and market confidence
is maintained. The emerging EU Soil Strategy recognises the need
for targeted quality inputs to soils.
23. Composting biowaste to produce independently
certified, quality assured compost can reduce greenhouse gas emissions
through increasing soil organic matter and carbon sequestration.
Compost can also help protect soil from heavy rainfall and prolonged
summer droughts and helps reduce the need for chemical treatments.
24. Government must ensure that standards
developed to protect soil quality and animal health are maintained
and adequate to satisfy market requirements. If outlets for "compost"
products are uncertain composting will be compromised as a sustainable
resources solution.
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.
25. The strategy includes proposals to support
resource efficiency in all sectors, eg the new Products and Materials
Unit, packaging standards & targets and extended Courtauld
Commitment. However, CIWM is not clear on how or when these proposals
will impact on resource efficiency, or whether they will be enforceable.
26. Packaging is an easy target in this enquiry
but whilst further progress can be made on packaging design, CIWM
also believes that packaging plays a vital role in preventing
product loss. Government needs to show leadership in focusing
on priority issues, including the need for careful assessment
of least environmental cost solutions.
27. CIWM also called for new extended producer
responsibility to be developed within this strategy for priority
wastes/products. CIWM's submission to Defra at the beginning of
the strategy development is attached as Annex 3.
28. Waste minimisation for businesses tends
to be driven by cost reduction for businesses. Stimulating household
waste minimisation will be more complex and will need a range
of complementary measures, relying heavily on sustained and co-ordinated
communications. CIWM will be happy to work with Government and
stakeholders to prepare and spread these messages.
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.
29. Existing measures including the Landfill
Directive, landfill gas control and use at existing landfills
and the Landfill Tax are already driving improvement. CIWM believes
Government must maintain support for power generation from landfill
gas through the Renewable Obligation Certificate (ROCs) scheme
to maximise methane collection from landfill.
30. Measures in the strategy will put additional
pressure on waste to landfill generally and reduce future methane
potential from this source.
31. CIWM supports development of product/service/waste
strategies with least environmental cost. The science and supporting
information behind life cycle assessment (LCA) are maturing and
although important steps are being taken to support such decision
making, Government must maintain its support to the development
of LCA techniques and skills.
8. The promotion of anaerobic digestion for
agricultural and food waste.
32. CIWM supports use of a broad range of
technologies to manage organic wastes. Of these, AD is a medium
cost and relatively straightforward reliable technology to treat
many wastes (including food) which can yield valuable energy.
In all likelihood, AD facilities will be supported by composting
of the digestate prior to the material being recycled to land.
However, CIWM also believes that local authorities, jointly or
individually are in the best position to identify which waste
treatment technologies are appropriate to meet their needs and
at which scale.
33. Significant potential exists to segregate
and treat organic wastes from commercial and industrial as well
as municipal sources, (Up to 20 million tonnes per year from all
sources). As with compost, the key to success will be to maintain
high quality outputs and therefore market confidence.
34. The potential exists to review the ROCs
scheme to investigate the potential for biogas to be distributed
via the gas distribution network to improve the flexibility of
this technology.
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.
35. The existing waste management infrastructure
in England or the UK cannot deliver the objectives of the waste
strategy (ies). 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. The facilities are needed to deliver
much more than landfill directive biodegradable municipal solid
waste (Article 5) targets. 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.
36. The firm targets in the strategy, including:
— doubling municipal waste recycling
by 2020
— more than doubling municipal waste
recovery—including energy by 2020
— twenty percent reduction of commercial
and industrial waste to landfill by 2010
— construction waste targets in the
draft Strategy for Sustainable Construction
confirm the general scale of new waste treatment
capacity development needed in England and the UK.
37. Energy recovery and materials processing
facilities will be important parts of this infrastructure development.
CIWM believes that energy recovery from residual wastes will be
important—not just to meet landfill diversion targets, but
also to gain carbon management and security of energy supply benefits—using
a variety of technologies. Energy recovery will also be an important
step in treating wastes already subjected to minimisation, reuse
or recycling to allow the final residues to be landfilled. A copy
of the CIWM position statement is attached as Annex 4.
38. The high rates of recycling envisaged
in all UK waste strategies will hinge on a mix of careful separation
of recyclable wastes by householders and businesses and mechanised
sorting and separation from mixed wastes through specialised facilities.
This is because the value of secondary resources and secure markets
to use them depend on quality—which is often driven by preventing
contamination in any form—eg mixing different plastics or
allowing food to contaminate paper.
39. Technologies to separate "co-mingled"
wastes are improving and can be cost effective. The "best"
solution in any area will hinge on local circumstances but in
terms of maintaining market confidence of the recovered materials
consistent and high separation quality will be vital.
40. The resources and waste industry is
becoming a "resource" industry—reprocessing materials
to a standard acceptable to a range of markets. With limited manufacturing
markets in the UK for secondary materials this means we are re-processing
materials for re-introduction to global materials markets.
41. Current capacity to process recyclable
materials is not adequate to meet future demand in terms of capacity,
technologies or assured quality output. Early development of these
capacities will be needed to support delivery of the waste strategies.
CIWM identifies four critical issues in developing waste treatment
infrastructure:
42. Information and skill
All parts of this industry need new skills and
information to move away from transfer and landfill towards alternative
treatments. CIWM has worked closely with Defra and others to support
their New Technologies Demonstration Programme and to build and
deliver education and training packages to build this skills base.
A promotion flyer, developed under our MOU with Defra, is attached
as Annex 5.
43. Decision support
Agreeing future strategies for sustainable management
of resources and waste from all sectors will involve complex assessments
and comparisons. CIWM believes that strategies should aim to manage
these resources at least overall cost to the environment and health—locally
and globally. Such decisions need skills and tools and data to
support them and CIWM is working to spread awareness and use of
tools such as WRATE developed by the Environment Agency.
44. Planning
The planning system for new waste infrastructure
in England will be the rate determining step. The Planning White
Paper (May 2007) sought to streamline the planning system for
strategically important infrastructure but, as proposed, will
fail to do so for waste. Proposals for a national planning statement
and streamlined process for hazardous waste treatment (threshold
20 000 tonnes tonnes/year) will probably help, but for all other
waste streams the most important infrastructure development will
fall outside of the proposed threshold (>50 MW generation capacity).
CIWM accepts concerns over dilution of local accountability implied
by "streamlined" planning processes but has urged Government
to reconsider improvements to the planning regime to support new
waste infrastructure. Of particular importance is the need for
integration of Economic Development policy and Housing policy
where the potential to embed CHP infrastructure and other emerging
energy from waste technologies at the start of new developments
is a major opportunity for the UK.
45. Communications
The strategy promotes "shared responsibility"
for wastes at all levels—from waste prevention through to
accepting responsibility for residual waste treatment capacity.
CIWM believes that the consequences of waste production are often
a forgotten issue for businesses and individuals alike.
46. Delivering the laudable objectives of this
strategy will depend on mass behavioural and attitude changes
in this country which can only be achieved through sustained and
co-ordinated communications from the highest level of Government
and through a broad range of stakeholders including CIWM. This
Institution has stressed the need for a communications strategy
and plan to accompany the waste strategies and has offered its
input as part of making this happen.
Chartered Institution of Wastes Management
October 2007
Annex 1
Thursday 11 October 2007 Press Release
PFI funding increase is welcome but sustainable
waste management could still feel the squeeze
The Chartered Institution of Wastes Management
(CIWM) has expressed concern that sustainable waste and resources
management has been short changed in the Government's Comprehensive
Spending Review delivered this week.
"Building a more sustainable approach to waste
and resources management means high quality collection and recycling
services for householders, high quality sorting and treatment
facilities, and high quality recovered materials for industry—and
there is an unavoidable cost attached to meeting these fundamental
needs," says CIWM chief executive Steve Lee.
The CIWM believes that the 1% real term increase
will not be enough to help local authorities absorb rising waste
management costs, meet national landfill diversion targets, and
deliver higher statutory recycling and recovery targets—particularly
given that overall funding is predicated on efficiency savings
that could put waste management services under even more pressure.
In addition, although it welcomes the increased
flexibility afforded by the removal of ring-fencing and other
grant controls, the CIWM is concerned that the Government has
focused heavily on the Private Finance Initiative as the key funding
route for infrastructure development.
"The increase in PFI funding is welcome
and much needed if we are to deliver the long term increase in
infrastructure that is required. However, PFI is a complex and
lengthy process that is unlikely to meet short and medium term
infrastructure needs and will not always provide authorities with
the flexibility to develop appropriately sized facilities to meet
local requirements and circumstances. PFI is not a universal solution
and the CIWM is keen to see sufficient choice in funding mechanisms
when more detailed spending plans become available," says
Steve Lee.
Annex 2
Consultation on the Incentives for Recycling
by Households
QUESTION 1:
Do you agree that local authorities should have
the power to introduce financial incentives for promoting recycling
and reducing household waste? Why?
CIWM agrees the option to use such a power should
be available to local authorities. Recently a few local authorities
have used different tactics to encourage residents to recycle
and found themselves frustrated by the law and unable to proceed
as they originally intended.
Other systems, such as alternate weekly collection
of residual waste and reducing the size of the residual waste
bin have proven successful in encouraging householders to think
about recycling and reducing waste. The incentives scheme could
have a similar effect.
Financial incentives give local authorities another
option once they have tried others.
QUESTION 2:
(a) Do you agree that a power to introduce
financial incentives would help local authorities to meet their
recycling targets and their obligations under the Landfill Allowances
Trading Scheme?
CIWM does not completely agree that by introducing
financial incentives local authorities will meet their recycling
targets and achieve their LATS obligations. A number of local
authorities are close to or have already achieved recycling targets
without even considering financial incentives or penalties.
LATS will be achieved by diverting biodegradable
waste from landfill, not by rewarding or penalising residents
for participating in recycling schemes or not. Garden waste is
not considered part of the five waste streams so how can there
be an incentive for diversion of biodegradable material from landfill.
Paper, card and textiles (if collected) would be a part diversion
from landfill if the material is recycled, composted or reused.
This incentives scheme does not consider rewarding home composting
in any way. CIWM understands it is difficult enough to count home
composting towards BVPIs let alone determine incentives.
The power would be welcomed but there is hesitancy
about Government making the assumption that local authorities
are implementing such schemes when they are not. Local authorities
would need confirmation that money will not be held back from
the central fund on such assumptions.
(b) Are there other barriers that Government
could address to help authorities boost recycling and meet their
obligations under the Landfill Allowances Trading Scheme?
The UK recycling and composting achievements
are always being compared with our European neighbours. One of
the main differences with most of our European neighbours is that
they have landfill bans that drive recycling, composting or energy
recovery because certain material types cannot go to landfill.
These landfill bans are implemented in addition to those within
the Landfill Directive. National policy is decided by each country
dependent on their circumstances and desired outcomes.
Whilst much good work has been achieved by WRAP,
there remain concerns over the sustainability of local and international
markets for recyclables.
QUESTION 3:
Do you agree that a waste financial incentive
with net neutral impact upon local residents (Option C) is the
best of the three options outlined in paragraph 5.2?
Option A of doing nothing is not really an option,
resource and waste management has to move on from where it is
now to achieve targets as set out in Waste Strategy 2007.
Option B is the preferred option for CIWM. Experience
from overseas shows that charging for household waste has an impact
on waste arisings and recycling. The resource and waste management
industry and Government should be looking at what it wants and
what it needs to do to get there and not start with a "we
cannot do" attitude. If the current council tax system does
not allow for direct charging do not rule it out because of this,
look at what needs to be changed and how.
CIWM agrees that a direct charging scheme apart from
the council tax may have an impact on central grant funding. This
would at least make people finally realise what it does cost to
collect, treat and dispose of THEIR waste.
Option C, CIWM has the tendency to agree with
the House of Commons Refuse Collection report that says:
"The proposals fall short of recommendations
made by Sir Michael Lyons and appear complex and timid. Rewards
of as little as £20 a year are unlikely to prompt mass recycling
and as every winner will require a loser, those who end up paying
even £20 more for a service most believe they pay for through
taxation is likely to be significantly more aggrieved than the
gainers are pleased".
CIWM would not support a bag based system as
this would be a backward step in terms of health impacts and environmental
protection.
CIWM favours Option B but could accept Option
C as a stepping stone to the final outcome of charging. CIWM supports
the idea as put forward by one of its members to pilot both options
B and C (response to Q8).
QUESTION 4:
(a) Do you agree that any financial
incentive scheme should be revenue neutral?
Cost neutral is more the issue for local authorities?
To set up any scheme will involve funding for capital and administration.
Residents are not to be charged anymore for waste management services
but ultimately there will be increases in budgets which will lead
to an increase in Council Tax.
The system needs to be simple and Option C does not
appear simple. For two-tier authorities there will be added aggravation
from residents about costs and stealth tax as highlighted by media
reports. Disposal authorities are likely to gain from the reduction
in waste not being landfilled (even though they may see increased
activity at CA sites). If there are any increases in fly-tipping,
collection authorities would have to foot the bill of clearance.
(b) Do you agree with the Government's
definition of revenue neutrality?
CIWM finds it very difficult to understand revenue
neutrality for the option put forward.
The paper indicates cost savings in the years following
the scheme introduction; one assumes this is from landfill cost
savings as there is theoretically less waste being presented for
disposal. Collection authorities do not incur disposal costs they
incur collection costs and these will still arise unless waste
is not collected.
(c) Do you agree that local authorities
should be free to determine the level of charges under a financial
incentive scheme?
Charges should be set at a local level; this
will enable local authorities to take account of local circumstances.
QUESTION 5:
Apart from the "recycling incentive scheme",
what other models might meet the aim of incentivising behavioural
change without increasing the overall cost to local residents?
Local authorities could look to gain sponsorship
for prizes to allow residents to enter into competitions, or have
giveaways—tickets to the cinema, shopping vouchers, etc.
Further incorporate waste and recycling into the curriculum, at
all age levels. Have a street competition—"our street
is better than your street", or name and shame the worst
street(s).
QUESTION 6:
The Government's view is that it would be essential
for local authorities to have good recycling services, fly-tipping
prevention and enforcement strategies and measures to help disadvantaged
groups in place before introducing financial incentive schemes.
Good communication with local communities before the implementation
of any scheme will be also be critical.
(a) If the Government were to allow
financial incentives, what requirement should the Government place
on local authorities as regards:
(i) existing recycling services—do
you agree with the proposal to require authorities to offer a
recycling/composting service for at least 5 waste streams to any
household covered by a financial incentive scheme?
Any local authorities that would be considering
going down this route of incentivising householders would be doing
so after they have considered and implemented all other options.
They would already have looked at how much material they could
collect and how. To achieve a good recycling rate the full complement
of materials would already have been targeted.
Including a specific five stream requirement would
disadvantage those authorities that have decided to use waste
from energy as an option. Instead of picking up plastic for recycling
taking plastic in the residual and using the calorific value may
well be more environmentally acceptable then transporting the
recyclate across the country. (The research report modelled carbon
impact and this should be considered in the waste stream options).
Five stream criteria are limiting and guidance should
be issued and this should not be part of the framework.
(ii) waste crime strategies, and
This would be an important part of any local
authority strategy involving change to a collection system, whether
it is alternate weekly collection, charging for garden waste collection
or incentives.
(iii) disadvantaged groups?
What is a disadvantaged group? The consultation document
suggests it could include householders receiving council tax benefit.
If the scheme is revenue neutral (as suggested) then their ability
to pay is not compromised and they have the same potential to
reduce residual waste as other householders.
The research report highlights that there is no statistical
link between income and waste generation and the more likely relevant
link is to household size. The more disadvantaged groups might
then be those households with more that three occupants and families
with small children; not one person living in a flat or those
of a low socio-economic status.
(b) How far should these issues be
determined by the Government, and how far at local level?
These are all local issues and would be difficult
for the Government to have an accurate picture of the situation
for each individual local authority. They should be determined
at the local level.
QUESTION 7:
(a) Do you agree that waste disposal
authorities should have the power to implement financial incentive
schemes at civic amenity sites?
If the power is granted to collection authorities,
there is no way the disposal authorities could operate without
a similar power to civic amenity sites. One does not work without
the other.
(b) If so, how could financial incentives
be administered at civic amenity sites?
There are already situations of queuing at CA sites
and this is usually exasperated by the addition of permits, as
used by some London boroughs. To have a system for incentives
could be similar to the permit one and increase queuing time at
all CIA sites that introduced it. This is likely to add to potential
fly-tipping and waste migration.
QUESTION 8:
Are there other issues that Government needs to
consider concerning financial incentive schemes?
Piloting options B and C to see which achieve
the best recycling or minimisation of residual waste, or both.
For local authorities that have transient populations,
chasing bad debt is already a full time job and if the cost of
administering the system to reclaim is more than the debt the
local authority will not bother. Local authorities have a duty
to collect household waste and so there is a strong message being
sent to residents that do not wish to participate—there
is nothing the local authority can do about it. Fixed penalty
notices could be served if these were allowed by the legislation
but again there is the issue of non-payment.
Responsibilities on landlords would help with student
populations who reside in many local authority areas.
Improving the message of Recycle Now, to include
other materials and how the public can do their bit in the local
area. If more materials are being targeted to increase recycling
then maybe it is time the resource and waste management industry
responded to the retail industry. Retailers have now moved away
from mixed plastic pots for their yoghurt but there are no mechanisms
for true collection and processing and sending to markets.
If more materials are to be targeted the logo
on the material has to be accurate and easier to find. The public
do not want to be hunting around the packaging to determine if
it is compostable or recyclable. This limits the level of contamination
in the recyclable container when processors are already calling
for cleaner materials and setting specifications.
There have been increases in violence on collection
crews over AWC, what will be the impact on the ground if incentives
are introduced and the public don't get what they think they are
getting? The day to day impact is important.
Definitions of what is meant by waste streams,
does cardboard count as one if mixed with paper or green waste
or not count at all if included in green waste.
The term "good service" would need
to be determined. Local residents might like the service they
receive and BVPI shows good feedback but is this understanding
the same as implied in this consultation.
Local authorities could give preferential planning
for waste minimisation. If there were developments that included
retail shops that used Weigh "n" Save (food sector)
this would aid waste minimisation with food packaging.
The political angle of waste with Members is
crucial. Many officers may support the idea of an incentives scheme
but there may well be no political support and the scheme would
not be able to gain financial support; the budget would not be
allocated.
QUESTION 9:
Are there any powers, currently not available
to local authorities, that would help them:
(a) encourage greater recycling and
waste minimisation by households and
Using the Waste Minimisation Act 1998 in its
original format so that more "teeth" was available for
local authorities to move towards more minimisation of waste.
(b) manage waste more effectively and
efficiently?
A number of local authorities feel that some clarification
on the legality of "side waste" policies is required.
Government might like to consider re-addressing the waste types
that a charge can be made for, ie updating the Controlled Waste
Regulations 1992.
Annex 3
National Waste Strategy for England 2005
Review
The Chartered Institution of Wastes Management
Lessons Learned Report
http://www.ciwm.co.uk/mediastore/FILES/12157.pdf
Annex 4
Chartered Institution of Wastes Management
Position Statement
Energy Recovery From Waste
The UK's capacity to recover valuable energy from
its waste is under-developed. Rapid planning and commissioning
of appropriate plants and technologies is needed to support three
vital policy areas: meeting tough landfill diversion targets;
combating climate change; meeting carbon management needs and
helping satisfy future sustainable energy demand. The Chartered
Institution of Wastes Management (CIWM) is urging Government to
recognise the important contribution of energy from waste in addressing
these issues and to take practical steps now to support its expansion.
WASTE RECYCLING
With concerted efforts by many authorities,
England now recycles 27% of its household waste—Scotland,
Wales and Northern Ireland are close behind. With a sustained
drive to improve recycling the UK should match good practice elsewhere
in Europe—recycling up to 50% of its municipal waste. However,
even with this level of performance a wide gap remains between
what we must stop sending to landfill and what we can achieve
through a commitment to waste prevention and recycling. High performing
European States close that gap through energy recovery from waste.
CIWM believes:
— experience throughout Europe shows
that high recycling performance is compatible with efficient energy
recovery from waste; for example Denmark and the Netherlands recycle
45% and 65% respectively of their municipal waste, whilst thermally
treating 50% and 30% respectively [from Eurostat data 2003].
— preventing, re-using and recycling
wastes are usually more environmentally beneficial, so energy
recovery should be from "residual" waste (ie after economically
viable removal of recyclable materials) wherever possible.
ENERGY
Only 10% of UK municipal waste is currently
managed through energy recovery [from Defra 2005-6 data]. Government's
Energy Review is considering security and diversity of energy
supply, influenced by higher oil prices, ageing coal-fired and
nuclear-fired power stations and concerns over future reliance
on coal, oil and gas imports. Given that across Europe 48% of
our energy has to be imported, this review must recognise the
energy value of what we currently discard as "waste"
to landfill, as recommended in the EU Thematic Strategy on the
Prevention and Recycling of Waste. Biomass is an important fuel
of the future and our residual waste in the UK has the energy
equivalent of 5 million tonnes of coal—after having used
the recoverable materials like paper for other purposes. Other
wastes, such as wood could double that energy value. Energy from
waste could therefore replace up to one-third of the coal used
to generate electricity in the UK and easily satisfy Government's
2010 target of 10% of electricity generated from renewable sources.
However, it is unlikely to do so unless waste and energy markets
are positioned to achieve this outcome.
CIWM was disappointed to note the lack of substance
in the mid 2006 Energy Review document regarding the contribution
energy recovery from residual waste could make, or positive steps
to encourage its development. Preparation of the Government's
Energy White Paper in mid 2007 will provide an opportunity to
link future energy strategy with development of waste strategies
throughout the UK.
CIWM believes:
— national security of energy supply,
especially for industry, means that we should exploit the energy
value of UK generated waste before disposal;
— generating both power and heat from
waste is typically up to 2-3 times as efficient (over 80%) as
generating only electricity (approximately 25%). Wherever possible,
appropriately scaled combined heat and power generation schemes
from waste should be favoured;
— Combined Heat and Power schemes will
also offer more stringent emissions control at a single centralised
plant than is possible at heat / power sources for individual
organisations or buildings. CHP also avoids the CO2 omissions
from those local boilers etc.
— Further clarification by Government
is needed regarding proposals in the 2007 Budget to use Enhanced
Capital Allowances to help fund such schemes.
— Government should increase its support
for CHP in general and particularly urgently for the development
of district heating networks—these may then provide a platform
for the development of a competitive "heat supply" industry
in which waste and other forms of biomass may compete as local
providers.
— Government should provide further
support for the development of district heating via the planning
system—new developments and substantial regenerations should
be given suitable incentives to provide district heating
— Government, through the Renewables
Obligation, has also considered the preferential (higher) rate
paid for electricity generated from renewable sources, in proportion
to the biomass remaining in the residual waste fuel to incentivise
removal of plastics in particular. CIWM supports this decision
and believes it encourages the manufacture of "clean"
waste derived fuels and their efficient use. We understand that
Government is actively considering clarification of the ROC System
and this would be welcomed.
— Clear links will be needed between
the mid 2007 Energy White Paper and future waste strategy development.
— Government should carefully consider—in
the longer term—diversion from landfill of wastes other
than biodegradable municipal waste. Significant energy-rich
fractions exist in non-municipal and non-biodegradable wastes
which are not permitted to be landfilled in many EU member states.
CLIMATE CHANGE
Even if we meet the Landfill Directive targets,
50% of biodegradable municipal waste will still go to landfill
in 2013 and 35% in 2020. The carbon in landfilled residual waste
is turned into roughly equal amounts of methane and carbon dioxide
over a protracted period. Only a proportion of this gas can be
collected and used as a fuel, and the fugitive methane has over
20 times the climate change impact of carbon dioxide. Energy recovery
from residual wastes will therefore have less climate change impact
than burning fossil fuels.
CIWM believes:
— government should stimulate energy
recovery from residual waste to increase the likelihood of meeting
its short to medium term climate change targets;
— government should continue to incentivise
the collection and use of landfill gas methane through continued
support of the renewables electricity tariff for this energy source
— Future strategy development should
be underpinned by reliable life cycle assessment and carbon footprinting.
CIWM will support the development and use of these approaches,
and the inclusion of wastes and resources management into future
carbon trading schemes.
TIMING
Early Landfill Directive targets are set for
2010 and 2013; Kyoto targets are set between 2008-2012; design,
approval and commissioning of new energy from waste plants takes
at least 5-10 years.
CIWM believes:
— government policy should promote
new infrastructure development for energy recovery from wastes.
Even if this is done quickly, the full effect may not be felt
until the middle of the next decade;
— government policy should promote
use of existing power generation and industrial energy use infrastructure
to recover energy from residual waste where this use provides
for an efficient use of the energy value of the waste, at least
for the medium term to realise the energy supply, climate change
and waste management benefits as soon as possible.
INTERPRETATIONS,
DEFINITIONS AND
STANDARDS
Burning waste derived fuels as a "waste"
requires stringent emission controls under the European Waste
Incineration Directive (WID), regardless of how highly processed
or refined that "waste" is. Under the Large Combustion
Plant Directive other fuels such as coal do not have to meet such
stringent standards until 2015
Industry and regulators should cooperate to agree
protocols and quality criteria for waste derived fuels that when
combusted inherently produce less damaging emissions than many
coals. Full consideration should be given to using this specification
within the UK and Europe as the criteria to accept the resulting
fuels as "fully recovered" and not subject to further
control as a "waste", other than the requirement that
they should still be burnt in WID compliant plants to avoid a
lowering of the presently applicable emission requirements..
Changes to the Waste Framework Directive (WFD)
under Article 11 include a system of quality criteria for wastes
processed to the degree that they are comparable to virgin raw
materials and no longer need to be treated and controlled as wastes.
The UK should seize the opportunity of the WFD Review to promote
"end-of-waste" quality criteria for high specification
waste-derived-fuels under Article 11.
The "best" technology for recovering
energy from residual waste will depend on local, technical and
financial circumstances. Strategic choices should be made on the
back of detailed life cycle, environmental and health impact assessments
of all options available.
CIWM therefore urges Government to:
— assess the current and likely future
market for waste derived fuels that are still "waste"—especially
in high energy use industries where security and diversity of
fuel supply could be seen as a commercial advantage;
— promote the energy efficient use
of "waste" as a fuel in industry, eg through enhanced
capital allowances and differential tariffs for renewable energy;
— support Europe-wide standard setting
for waste derived fuels and to set the standard high, thus helping
to ensure customer confidence in them, and to avoid the possibility
of such use resulting in increased polluting emissions;
— urge MEPs, and through them the European
Parliament to treat high specification waste-derived-fuels as
a priority for examination under Article 11 of the WFD Review.
— explore opportunities through Defra
and the Environment Agency to set standards and waste recovery
criteria in the UK as an interim position. The objective being
to set the standard high—to encourage waste processing to
a fuel and its use in an efficient way in industrial and power
generation plants or new plants.
— prioritise the re-definition of energy
recovery from waste as a true "recovery" rather than
"disposal" operation under the Waste Framework Directive,
based on energy efficiency criteria, to remove unnecessary barriers
to transfrontier shipment of valuable waste derived fuels while
they are still classed as "waste".
— Urge the European Parliament and
UK Government to support R&D to increase the proportion of
waste derived fuels that can be successfully co-fired with coal.
SUMMARY
— Energy recovery from waste in the
UK lags behind best practice in other European states. — It
is needed to help reduce our reliance on landfill, our greenhouse
gas emissions and reliance on other fuel sources—be they
fossil fuels or nuclear.
— Public perception and understanding
of energy recovery from waste is poor. Government policy and leadership
is needed to support it—the review of national waste strategies
alongside the energy review is an ideal opportunity to do this.
— Government policy and support for
district heating needs to be strengthened
— Long delivery times for new infrastructure
mean Government should encourage use of existing industrial and
power generation infrastructure to recover energy from high specification
residual waste derived fuels, but ensure that this support only
extends to schemes that are able to demonstrate high levels of
energy efficiency
— To develop standards for such high
specification fuels from residual wastes, it is necessary to include
waste-derived-fuels amongst the waste streams to be examined under
art. 11 in the revision of the Waste Framework Directive.
— Even where high specification RDF
is no longer classified as waste—the standards specified
for the burning of wastes in the WID should continue to be applied
(as they represent the Best Available Technique in accordance
with the IPPC Directive) to avoid a lowering of emission standards
— The need for prompt action should
not be used as an excuse to relax overall standards of environmental
or health protection.
— Industrial & Commercial and non-biodegradable
wastes have a significant energy recovery potential. UK policy
is needed to help divert these materials away from landfill as
well as biodegradable municipal wastes.
10 November 2006
Chairman of CIWM Thermal Treatment Special Interest
Group
Annex 5
Defra/CIWM New Technologies Training Courses
How can we move away from landfill?
VRQ Level 3—Principles and Practices of
Sustainable Waste Management
HLA Level 4—Waste Treatment Technologies
The above flyer is downloadable from: http://www.ciwm.co.uk/mediastore/FILES/15512.pdf
The website link is: www.ciwm.co.uk/newtechnologies
Chartered Institution of Wastes Management
October 2007
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