Environment Bill

Written evidence submitted by Veolia (EB50)

Contribution to the Public Bill Committee’s inquiry into the Environment Bill

Veolia is the UK leader in environmental solutions, providing a comprehensive range of waste, water and energy management services designed to build the circular economy and preserve scarce raw materials. The company’s purpose is to reduce the impacts of human activity. Veolia does this by recycling waste, producing renewable energy and treating wastewater.

Veolia is committed to protecting the environment and improving the lives of the communities in which it operates. Veolia’s business strategy - "Resourcing the World" - is focused on manufacturing green products and generating low-carbon energy, and helping its customers and suppliers to reduce their carbon impact.

In the UK, Veolia employs 15,000 employees and has invested £2bn to date in vital and much-needed infrastructure. Veolia collects 2m tonnes of recyclates per annum across more than 30 contracts with local authorities. Veolia operates 10 energy recovery facilities (ERF) across the country, treating a total of 2.4m tonnes of waste per year. By diverting waste from landfill, Veolia saves over 252,000 tonnes of CO2 whilst exporting over 1.2TWh of electricity to the Grid and feeding 0.15TWh of heat to district heating networks.

Veolia welcomes the opportunity to input to the Public Bill Committee's inquiry into the Environment Bill.

In light of recent events, we must kickstart the economy with the environment and climate change as priorities. The only way to "build back better" is to have a green deal and a green transition in the UK and also globally. We agree with the recent Government’s statement during the Petersberg Climate Dialogue that investing in innovation and shifting investment to green technologies is going to be absolutely vital. As we come out of the current phase of the COVID-19 era our economies will be at a historical crossroads whereby we will be under enormous pressure to resort to extreme measures of frugality in order to pay off the enormous debts created by the pandemic, and the necessity to reinvent the economy as a green, better economy built on sustainability. Veolia supports the direction of a clean, climate-friendly and resilient recovery from COVID-19.

We believe that the reform of the packaging extended producer responsibility (EPR), the plastic packaging tax, the harmonisation of collections, the net zero target by 2050, biodiversity protection and enhancement are now critical missions for the economy and the Government to prevent us from a downward spiral. A clear example of this is the tonnage of commercial waste that has dropped by 50% while the household waste has gone up by 25%. This reality is unlikely to reset in the near future and local authorities are going to be saddled with these extra costs, raising general taxation or drawing off other essential services. The solution is to push that cost onto the producers directly - which is not an increased cost, but rather shifting the cost to where it can be reduced, since only the producers can change the design of products, not the local authorities. Likewise, the COVID-19 pandemic has shown the short supply chains we currently have and rely on returning short rotation materials quickly back to where they were first used, providing resilience and investment in circular economy jobs.

With regard to the general scope of the Environment Bill and the framework for environmental governance that will be in place, we understand the Government long-term direction for the UK’s environmental policy and welcome that fundamental environmental principles, such as the polluter pays principle, will now be enshrined in law.

We will have to see how in practice the Office for Environmental Protection (OEP) will operate but the intention is the right one i.e. to hold the Government and public bodies to account, including through the Courts if necessary. There needs to be an absolute independence of the OEP in the power to run its own investigations and effective ability to enforce environmental law. We see the free-to-use complaints system as a positive development as it is expected to allow anyone (organisations/people) who believes that a public body is not adhering to environmental protection regulations to challenge the situation by approaching the OEP for advice, investigation and enforcement. It is also important to clarify the role that this new Regulator will have in relation to holding the Government to account in delivering the net zero commitment by 2050.

In terms of environmental protection, we recognise that the comprehensive range of environmental protections in the four key areas will guarantee legal certainty and stability while enabling competitive markets to develop. For the Resources and Waste industry, the Bill provides a necessary legal underpinning to the 25-Year Environment Plan and ultimately the Resources and Waste Strategy - which our industry desperately needs. It addresses, from an overarching perspective, a lot of the bottlenecks that currently impede our recycling rates, product recyclability and innovation, as well as investment in domestic recycling infrastructure.

With regard to the level of ambition, the Environment Bill sets out a progressive set of proposals which at the moment match EU protections. Two more important elements are to be considered for the future: (1) whether this Bill will allow some future flexibility in legislative frameworks to surpass EU protections in some areas but also (2) whether the Government’s commitment to be a world leader in environmental protection, through this Bill, will be preserved in trade negotiations with other major global economies.

Should the Government want to surpass the EU level of protections, we would recommend considering the two following suggestions which would position the UK on a higher level of ambition:

• Addressing Peatlands: the long-awaited Peatlands Strategy for England represents an opportunity to cover this topic but a reference to peatlands as carbon sinks - retaining carbon, stabilising the carbon cycle and mitigating climate change - in the Environment Bill would be an important landmark.

• Considering Indoor Air Quality: relatively little is known about invisible indoor air pollution and its potential health effects, but it is thought to be eight times more dangerous than outdoor conditions.

With regard to the Waste and Resource Efficiency provisions, the Bill reflects the Resources and Waste Strategy which is primarily focused on prevention, reuse and recycling. As the UK leader in recycling solutions, Veolia supports a legislative framework that will improve recycling rates while enabling a competitive and high quality recycling market.

If the proposals in the Resources and Waste strategy are delivered, there will be more recyclable material and enhanced collections - and if the material has a financial value (meaning a viable end market), it will be recycled. Recycling rates have indeed hit a plateau due to (1) the motivation of individuals to recycle - after 20 years of pushing the message, we have reached the natural limit, and (2) a low recyclability of products. An incentive like a deposit return scheme (DRS) will get industry and public support, provided it is well-designed, and help achieving a higher collection and recycling rate with around 95% bottle recovery. Complementarily, the new packaging EPR scheme presents fundamental changes and if implemented will lead to more recyclable packaging, allowing us to recycle over 70% if fully and timely implemented. If these are combined with the Treasury’s plastic packaging tax, which will require manufacturers to buy recycled content for new products, and more harmonisation of collection and labelling, these measures will make the circular economy viable.

We believe that the ultimate aim is to push the way materials are handled up the waste hierarchy. However, we would like to underline that the issue of managing the UK’s residual waste is now reaching a dangerous tipping point - landfill capacity is nearly depleted in the South, Refuse Derived Fuel (RDF) exports are no longer viable and there is a shortage of Energy from Waste (EfW) capacity. We must not ignore the residual waste stream and as such we recommend a holistic and practical approach to all waste streams while fully respecting the waste hierarchy. The UK needs an effective plan to manage its residual waste - not everything can or should be recycled - in which case EfW is the most optimal, sustainable and environmentally sound treatment option.

May 2020