Supplementary memorandum submitted by
the Chartered Institution of Wastes Management (Waste 22a)
CIWM would like to thank the Committee for giving
the Institution the opportunity to submit oral evidence towards
its Inquiry and in allowing the submission of further information.
Regarding "resources" needed to make the
National Waste Strategy work, there are two high level issues.
The first relates to skills and people. The resource and waste
management sector needs to show that it can operate a "value-added"
service. This will include resource efficiency/management advice
to customers and moving towards planning for and managing wastes
as a strategic resource. This sector is hungry for skills. CIWM
has supported proposals for a National Skills Academy and will
continue to drive for skills and professionalism across the sector.
Secondly it is clear that the ambitious programme
set in the 2007 Strategy review will have to be delivered through
Government departments and agencies with the right resources to
either undertake or commission the appropriate work. In short
this means money.
CIWM recognises pressures on Government finances
but believes that adequate funding of work to support and develop
the waste and resources strategy should be available through the
landfill tax if necessary. CIWM believes it is time for a thorough
and transparent review of the collection, likely value of, and
use of landfill tax monies. The purpose of the tax is to help
direct materials way from landfill—preferably helping to
put waste back to work or otherwise regain value from it. Compared
to the rigorous assessment of the tax on its introduction, CIWM
believes a lack of transparency has developed around the final
destination and distribution of the revenue, despite the fact
that the tax has increased significantly since its introduction.
Alongside this assessment CIWM believes that
everybody—Government, the resources/waste sector, local
Government and waste producing businesses—needs a longer
term plan for the future of the landfill tax. There is a clear
plan to 2010-11 when the tax will reach £48 per tonne for
"active" waste. There is a need for a 10 year plan for
landfill tax. CIWM recognises this as a tax plan bigger than a
single government, but such is the scale and importance of managing
resources wisely. It has been shown that where businesses can
anticipate future costs, they can and will make better plans in
advance of those costs being imposed. Anticipation of the landfill
tax is as effective as the tax itself.
In addressing the question posed at the end
of the evidence session: "What good ideas within the Strategy
have yet to be put into practice, or where their implementation
could be speeded up or improved" CIWM has submitted additional
comment under the priority activities proposed in the 2007 review
table 8.7 High-level Implementation Plan as follows:
— Action 1 Increase the standard rate
of landfill tax by £8 per year from 2008 to at least 2010.
As above, CIWM believes there is a lack of transparency
on how this money is used. A longer term programme is required,
extending beyond the term of one Government. A 10 year plan of
landfill tax would enable local authorities and the waste industry
to take this on board and plan its future resource management.
— Action 9 Establish domestic waste
protocols to determine when certain categories of waste cease
to be waste.
Defra have given confirmation that the existing
programme of work is secured and CIWM believes that the current
protocols are the right priorities and should continue to complement
work carried out by SEPA. CIWM believes there should be early
confirmation about Government's financial support for the Environment
Agency and WRAP to secure and expand the programme as it is vital
within the UK as well as feeding into the "End of Waste"
EU Waste Framework discussion.
— Action 11 Review controls on handling,
transfer and transport of waste including consultation.
Early enhancement of the waste "Duty of
Care" will help data generation and prevent waste crime.
The long gestation period of this initiative is an example of
good and important work hampered by a lack of or turnover in skills
and specialists in and around Defra.
— Action 12 Develop and implement an
action plan to tackle illegal waste activity.
CIWM feels that the deployment of skilled staff
by local authorities to help prevent and enforce against waste
crime is held back by a lack of resources to maintain training.
Local authorities are not investing in Defra/EA (now ENCAMS/CIWM)
Fly-capture training.
— Action 19 Implement pre-treatment
requirement for non-hazardous waste.
CIWM feels that a light touch implementation
is holding back development of treatment technology and infrastructure.
All policy implementations must be backed by Defra-led sustained
and co-ordinated communications, and by regulators in the Environment
Agency and local authorities with the skills and resources to
enforce properly.
— Action 22 Consider the introduction
of further restrictions on the landfilling of biodegradable wastes
and recyclable materials.
— Action 87 Set targets for reducing
commercial and industrial waste landfilled.
This is key to reducing industrial and commercial
waste going to landfill and in driving the management of resources
regardless of their origin. CIWM would like to see Defra fully
resourced to pursue this policy initiative—using consultants
if necessary and fully co-ordinating data research and development
modelling etc of impacts with Welsh Assembly Government and SEPA/Scottish
Government.
— Action 34 Develop evidence base and
methodologies to identify products with the most significant environmental
impacts over their entire life cycle.
— Action 74 Consider reflecting impacts
from wider embedded emissions, including from waste, in carbon
dioxide calculator.
CIWM believes that LCA is the right way to go
and CIWM fully supports the approach as set out in the July 2008
consultation Progress Report on Sustainable Products and Materials.
CIWM wants to see Defra, WRAP and the Environment Agency funded
to undertake research and development and life cycle assessment
tools and skills developed to put these concepts into action.
— Action 41 Establish a statutory producer
responsibility system for managing waste batteries; transpose
EU Batteries and Accumulators Directive.
Implementation of the EU directive and producer
responsibility schemes is already delayed and Defra must be fully
supported by adequately funding WRAP. As with ozone depleting
substances regulation, delayed implementation often frustrates
development of domestic (UK) technologies and expertise in a likely
high growth international market of the future. In general, the
Inquiry should clarify with WRAP and the Environment Agency which
actions under Chapter 8 of the Strategy are postponed or delayed
through lack of resources.
— Action 68 Continue to increase awareness
of consumer impacts on the environment of resource consumption
and waste management|
CIWM would like to see a more comprehensive
communications plan to complement the Waste Strategy. This plan
should identify priorities in terms of awareness and outcomes
or actions by other stakeholders and resources required to plan,
co-ordinate, etc and deliver a sustained communications programme
to change behaviours.
— Action 70 Launch zero waste places
initiative to incentivise excellence in sustainable waste management.
Defra has recently announced the launch of six
zero waste places projects. Whilst CIWM applauds this work, it
is one year later than suggested in the Strategy Action Plan.
Defra should confirm what resources it requires, directly or indirectly,
to drive its own action plan for the Strategy.
— Action 90 Publish second three-year
Research and Development Strategy.
— Action 92 Further develop evidence
base to underpin policy development and evaluation.
CIWM is happy to collaborate with projects under
this programme wherever possible and sees research and development
as an essential input to evidence based policy development. CIWM
notes within the Waste and Resources Evidence Strategy for England
2007 an allocation of £12M over three years and would be
concerned to see a reduction of such resources below that level.
— Action 93 Develop regular and robust
waste data to underpin national targets, indicators and analysis
of impacts of the Strategy.
CIWM has repeatedly identified (including in
its written evidence to this Committee) collection analysis and
reporting/availability of waste/resources data and information
as fundamental to developing more sustainable resources management.
Ideally this needs to embrace resources flows on a regional or
sub-regional basis and Government funding or resource flow programmes
should be made a priority using landfill tax based monies.
In closing the Institution would like to reiterate
that cash needs to be directed for delivery. Not at Government
level as with PFI credits but to enable regional level teams to
facilitate delivery based on the type of skills developed by NISP
and many other NGOs. Perhaps the Pathway to Zero waste pilot starting
in the South East (as mentioned in our oral evidence) is the model,
where based on the work of the Environment Agency/WRAP and taking
the policies from Defra and BERR, the RDA is taking the lead to
facilitate supply chain partnerships to ensure delivery and matching
private and public sector together, to derive the full benefits
of spatial delivery/logistics as well as market based infrastructure
solutions.
Chartered Institution of Wastes Management
November 2008
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