Environment Bill

Written evidence submitted by the Severn Trent Group (EB36)

Summary of position:

· Severn Trent Group is the largest producer of green biogas in the UK.

· We very much support the Bill and its commitment to introducing separate food waste collections in England.

· We believe the Bill could be made more effective with a modest tweak to the TEEP clause in part 3 section 54, making it clear that recyclable waste streams can only be collected together if …"

· We also believe the Bill should include a maximum time within which ministers should introduce the necessary secondary legislation to ensure alignment with the government’s green gas strategy.

Position in more detail:

Severn Trent Green Power (STGP) owns and operates 9 largescale AD plants, 2 IVC’s and 3 open windrow composting sites. As part of the Severn Trent PLC group, which includes sewage AD, we are the largest producer of green biogas in the UK.

We recycle food waste from 50 local authorities and are responsible for treating a quarter of the food waste collected from local authorities in England and close to half of the total in Wales. We also recycle around 60,000 tonnes of garden waste and 75,000 of combined garden and food waste from 14 authorities at our composting facilities.

We overwhelmingly support the government’s proposals for weekly food waste collections in England and believe it to be essential to help minimise edible food waste and its impact on the environment. We also believe keeping food and garden waste separate is the key to maximising the resource value of the inedible food waste fractions.

In respect to Part 3 the Environment Bill and relevant sections on food waste collections from domestic properties, we would like to draw attention to the clause that allows waste streams (garden and food waste in particular) to be collected together where it is not technically, economically or environmentally practicable (TEEP).

We understand the need to have flexibility, for instance to cover very remote areas. However, our feeling is the wording for this exemption is very similar to that found in the waste hierarchy legislation and we are concerned there may be an initial perception that nothing needs to change.

We take confidence from government’s proposals in the waste and resource strategy to fund the cost of any new statutory duties that fall on councils and understand there will be statutory guidance to follow later. However we see real value in creating clarity for local authorities as early as possible, especially as they will have an immediate need to start engaging with industry in earnest to secure future capacity, due to long lag times for example in developing new AD capacity. To achieve these aims we would like to recommend modestly differentiating the wording of the TEEP clause. We feel this will be effective in preparing waste controllers towards the necessary future changes without any undue delay.

One suggestion for a change in TEEP wording is to simply insert the word ‘only’.

Recyclable household waste in two or more recyclable waste streams may only be collected together where….

Secondly, we also believe there should be a maximum time within which ministers should introduce the necessary secondary legislation. This is important again to ensure industry is ready to deal with future market needs, operators like us want confidence on the timeline for new feedstocks in order to start developing new projects. This timeframe should be aligned with the governments heat strategy so that any new support mechanisms align with the growth in market demand.

We will look to respond to the relevant future government consultations and are committed to supporting the best environmental policies that help towards our collective journey to net carbon zero. Please do not hesitate to contact us if we can be of any assistance.

Kind regards

STGP

April 2020