104.Beyond the core proposals set out in the Government’s consultations, we also sought evidence on other issues addressed within the Waste Strategy, including the possibility of introducing an incineration tax in future, and the potential for improved joint-working between local authorities.
105.Incineration is the burning of waste to reduce its volume, so that the remaining ash can be more easily disposed of. Energy from Waste (EfW) takes this process further by recovering some of the energy contained in the waste. As outlined earlier in this report, the Waste Hierarchy ranks waste management options according to what is best for the environment. If waste is not able to be prevented, the Hierarchy gives priority to preparing it for re-use, then recycling, then recovery, and last of all disposal (e.g. landfill). Dr Gover, from WRAP, told us that incineration should be considered from this perspective:
Energy from waste has a role. It is better to recover energy than to put it to landfill. That is why we brought in the energy from waste plants, not just to reduce the landfill cost, but because it is a better outcome. They are part of the solution, but we need to make sure we are pushing up the hierarchy as far as we can.
106.However, it is clear that many groups are strongly opposed to incineration and have called on the Government to do more to discourage its use by local authorities. For example, the United Kingdom Without Incineration Network (UKWIN) told us that the Government should introduce a moratorium on new waste incineration capacity, ensure that local authorities are not incentivised to incinerate waste, and support councils to renegotiate or terminate contracts that are barriers to managing waste at the top tiers of the Waste Hierarchy.
107.Professor Gregson told us that there was a “very clear link” between incineration and recycling. She provided a graph (below) which showed “that regions with high levels of incineration have lower rates of recycling, and the converse, that those regions with high rates of recycling tend to have lower rates of incineration.” Professor Gregson noted that correlation was not causality and emphasised that she was not suggesting that high levels of incineration caused low levels of recycling:
Data source – Defra 2017/18 – Table 2a.
108.Other witnesses strongly disputed the premise that high levels of incineration caused low levels of recycling. Jacob Hayler, from the ESA, told us that this was “just completely not true”:
[ … ] some of the best recycling counties, like the Oxfordshire’s, the Buckinghamshire’s, combine very high levels of recycling with energy from waste for the treatment of the residual. It is fundamentally wrong to suggest that energy from waste competes with recycling. Energy from waste competes with landfill for non-recyclable waste. That is the whole point of it.
He also argued that there were several examples in other EU countries where high levels of recycling were complimented by high levels of EfW. Indeed, we note that Germany has the highest rate of recycling in the world (68 per cent), while at the same time operating 68 waste incineration plants and sending 31 per cent of its waste to energy recovery.
109.Proponents of incineration told us that Energy from Waste (EfW) was also a much cleaner technology than opponents claimed. Lee Marshall, from LARAC, told us that modern incinerators were “very clean”:
They are highly regulated and highly scrutinised, so there is probably an out-of-date view about what modern energy-from-waste plants are and what they do. They are very clean and the contracts nowadays, compared to maybe 20 years ago, are done in such a way, with high recycling in mind [ … ] I appreciate there are public health concerns that people will have, but when you look at the monitoring data and the evidence behind it, they are very good.
Similarly, Gurbaksh Badhan from NAWDO argued that modern incineration plants were under a great deal of scrutiny and, consequently, “the emissions are far cleaner than what is coming out of your car exhaust.”
110.It is clear that many people are strongly opposed to incineration and want the Government to do more to discourage its use. We heard some evidence to suggest that Energy from Waste technologies are cleaner than some campaigners claim, but this is still in dispute. The prevention of waste and recycling should always be the highest priority, but incineration does have a role to play within the Waste Hierarchy.
111.The Waste Strategy raises the possibility of introducing an incineration tax in the longer-term if other policies did not achieve the Government’s objectives:
Should wider policies not deliver the Government’s waste ambitions in the long-term, we will consider the introduction of a tax on the incineration of waste. Incineration currently plays a significant role in waste management in the UK, and the Government expects this to continue. However, Budget 2018 set out the Government’s long term ambition to maximise the amount of waste sent to recycling instead of incineration and landfill. Any consideration would take into account how such a tax would work alongside Landfill Tax and the possible impacts on local authorities.
112.However, we heard clear opposition from the majority of our witnesses to proposals for an incineration tax, including from the Renewable Energy Association and NAWDO. Jacob Hayler, from the ESA, told us there were two potential dangers from an incineration tax:
It would penalise those local authorities that have done a good thing by making the investment and the commitment to put in place these energy from waste facilities. It would be an additional cost burden on those local authorities. At the same time, there would be a danger that it would put off investment in future facilities, in which, as shown by DEFRA’s own figures, we are going to be 7.5 million tonnes short of capacity.
Similarly, Ian Fielding from ADEPT said he “very firmly” did not believe an incineration tax would be appropriate, arguing that it would be unnecessary in the context of the new EPR scheme, it would change the economics of waste disposal, and there would need to be great care that it would not incentivise the wrong behaviours, such as landfilling and fly-tipping.
113.We do not believe that an incineration tax should be introduced in the short term, as this would simply increase costs for local authorities and council tax payers. However, the Government is right to keep an incineration tax under review, but only insofar as it will encourage local authorities to prioritise long-term investment in recycling infrastructure, and not lead to a transfer of waste from incineration to landfill.
114.As outlined in the Government’s Waste Strategy, around 350 local authorities have responsibility for the collection or disposal of household waste, of which 90 are responsible for both collection and disposal (Unitary Authorities) and the remainder are ‘two-tier’ authorities where a waste disposal authority is responsible for disposing of waste collected by smaller district authorities (waste collection authorities). The Government proposes to encourage greater collaboration and partnership working among local authorities in the area of waste collections and recycling. The then-Minister for Local Government was clear that, while the Government was keen to promote joint working and provide advice to Councils, they were “not, at this stage, going as far as mandating.”
115.The Local Government Association highlighted that the sector already has a range of partnerships across the country. All of the boroughs in London are in waste partnerships with at least three or four other London boroughs, while this is also seen across many of the counties such as Somerset, Hampshire, Leicestershire and Dorset. The District Councils’ Network noted that 80 per cent of its members are involved in a waste partnership in some capacity. Jacob Hayler from the ESA told us that the main opportunities arising from joint-working were around “efficiencies and savings.” Similarly, Martin Curtois from Veolia said there would likely be more joint-working as the Waste Strategy is implemented and services become more consistent, and highlighted other benefits of joint-working:
You could have a situation with a larger area being communicated to. There are going to be economies of scale in terms of similar communications if they all have the same recycling system. You could have benefits in terms of ICT, in terms of technology. You would have the initial investment in, say, fleet performance, the fleet systems that go in, if they are the same across two different boroughs, if they are working more closely together. It is something we could see more of in the future. It is one to watch out for.
116.However, we also heard that, while joint working could lead to several benefits, there were also examples of local authority partnerships which have not achieved desired outcomes and have had to be discontinued. Veolia noted that “such partnerships can [ … ] be prone to be affected by different political agendas, priorities and funding.” LARAC members identified some of the main barriers to two-tier working, including: different contract expiry dates, the need for long-term commitment, different financial positions of authorities, local political differences and that savings from one party may be to the detriment of another.
117.During our inquiry, we asked whether the Government should do more to require local authorities to work together, particularly where adjacent local authorities are having different levels of success with recycling targets. Martin Curtois said that the benefits of partnership working should be demonstrated to local authorities, but the decision should ultimately be left to them:
I do not think it should be mandatory, but clearly there are authorities, or neighbouring authorities, that can see a logic, so they are the ones that start talking to each other and start doing the process. If they can see economies of scale, if they can see overall benefits to their residents, they take it further. We should leave it as free will as far as that is concerned.
Cathy Cook from LWARB told us that, while mandating joint-working might lead to operational efficiencies, it would probably not lead to an improvement in recycling rates. She explained that differences in recycling rates and services between local authorities was more likely to be due to housing types and other geographical considerations, for which joint-working would not make a significant difference.
118.The Government is right to encourage greater joint working between local authorities, although the decision to form partnerships should ultimately rest with the local authorities concerned. While joint working might lead to operational efficiencies, it is unlikely in itself to lead to higher levels of recycling.
119.We also heard calls for a fundamental review of delivery and governance models for the management of waste in two-tier areas. Ian Fielding from ADEPT told us that, “the structure and the governance [of two-tier authorities] are perhaps rooted in the 1970s almost, when landfills were plentiful and local arrangements were very different from now.” ADEPT have called for a fundamental review of delivery and governance models for the management of waste and resources in two tier areas:
We want to see responsibilities moved to upper tier authorities and/or the statutory combining of authorities at regional or sub regional level. Pending such a review, improved partnership working should be incentivised by flowing funding through upper tier authorities, giving them increased powers to compel lower tier authorities to move to consistent collection systems.
Jeremy Jacobs from the REA agreed, telling us that there “certainly needs” to be a review. He expressed his view that the system was “more complex than it needs to be”, with some local authorities failing to deliver services due to the complexity in the system. He reported that the two-tier system was also disproportionate in terms of the cost allocation of collection versus treatment, with collection authorities generally bearing the highest burden of costs.
120.However, local authority representatives disagreed that there needed to be such a review. Councillor Fleming, representing the District Councils’ Network, told us that this was a “huge red herring”, and it was too easy for people to simply claim that “Two-tier areas are all too difficult.” The Mayor of Hackney, Philip Glanville, representing the Local Government Association, agreed that there did not need to be a review:
I do not think there does [ … ] The most important thing is understanding the democratic ability, the recognition of place and encouraging partnership, as we have been discussing, rather than saying that a fundamental review of two-tier systems is right, unless you are talking about an even broader review of local government, which we know has pitfalls to it.
122.The Government should undertake a review of whether the existing models of delivery and governance for the management of waste in two-tier areas continue to be appropriate. The Government should include this in its programme of Waste Strategy consultations that are due to take place over the next 12 months.
161 See , House of Commons Library, 13 July 2011
162 (Dr Marcus Gover, WRAP)
163 United Kingdom Without Incineration Network (UKWIN) (), para 8
164 (Professor Gregson, University of Durham)
165 Professor Nicky Gregson, Durham University (), para 3
166 (Jacob Hayler, Environmental Services Association
167 Environmental Services Association () and Waste Management in Germany 2018: Facts, data, diagrams, , March 2018
168 (Lee Marshall, Local Authority Recycling Advisory Committee)
169 (Gurbaksh Badhan, National Association of Waste Disposal Officers)
170 , Department for Environment, Food & Rural Affairs, December 2018, page 79
171 (Jeremy Jacobs, Renewable Energy Association) and National Association of Waste Disposal Officers (), para 1.8
172 (Jacob Hayler, Environmental Services Association
173 (Ian Fielding, Association of Directors of Environment, Economy, Planning and Transport)
174 , Department for Environment, Food & Rural Affairs, December 2018, page 73
175 DEFRA (), para 41
176 (Rishi Sunak MP, then-Minister for Local Government)
177 Local Government Association (), para 7.1
178 District Councils Network ()
179 (Jacob Hayler, Environmental Services Association
180 (Martin Curtois, Veolia)
181 Veolia ()
182 Local Authority Recycling Advisory Committee (), para 31
183 (Martin Curtois, Veolia)
184 (Cathy Cook, London Waste and Recycling Board)
185 (Ian Fielding, Association of Directors of Environment, Economy, Planning and Transport)
186 Association of Directors of Environment, Economy, Planning and Transport (), para 39
187 (Jeremy Jacobs, Renewable Energy Association)
188 (Councillor Peter Fleming, District Councils’ Network)
189 (Mayor Philip Glanville, Local Government Association)
Published: 5 September 2019