Memorandum by Biffa
Biffa Waste Services is one of the largest waste
management companies operating in the UK and can justifiably claim
to be the most diverse in terms of its spread of interest in industrial/commercial
and domestic collection, landfill, liquid waste and specialist
hazardous waste management systems, and has a turnover of just
under £800 million at a current annualised rate. We have
over 150 operating centres throughout the UK and handle 14 million
tonnes of material that is treated, landfilled or recycled on
behalf of an extensive customer base exceeding 95,000 in the public,
commercial and industrial sectors plus collection services to
1.3 million households. On the face of it it may seem strange
that a waste management company should take an interest in waste
minimisation but we do so on the basis that to do otherwise would
amount to burying our head in the sands of progress. It is for
this reason that we have invested substantially in responding
to the challenge of future change impacting on the sector, most
specifically in terms of resource flow accounting, carbon pricing,
diversion of material from landfill and the adoption of low carbon
emission innovative technologies as substitutes to landfill.
1. BETTER DESIGN
AND THE
USE OF
MATERIALS
1.1 Improved product design is of most notable
relevance in relation to longer lived consumer durables where
life expectancy is often shortened as a result of failure by a
specific component in the design. As a result—in the absence
of any nationwide cost effective repair and maintenance infrastructure—entire
products are scrapped. Lifetime longevity could be extended if
products such as electrical and electronic white goods, and IT
equipment were modular.
1.2 The implementation of Producer Responsibility
in the UK since 1997 has been disjointed and not integrated in
terms of methodology, process or structures. In consequence, there
is a major disconnect between ownership of end of life waste streams
and the design/production process. Whilst this process is now
becoming more rational (in the case of electrical goods, batteries,
and automotive, for example), we believe that the failure by HMG
to apply an integrated approach to Producer Responsibility financial
liability has resulted in a "lost" two decades in which
end-of-life management processes could have been integrated into
the design and manufacturing process. Over the years we have regularly
made Parliamentary submissions on this theme on the basis of our
observations of end of life management. We can forward these should
you wish to consider IPP in greater depth.
1.3 There needs to be an involvement with
academics possessing specialist skills in holistic lifecycle accounting
which accounts properly for the trade-offs between extended product
longevity (for instance, washing machines lasting two decades
or more) against the benefits of ongoing technical developments
(which materially improve in-use energy consumption, for instance)
to establish, on a product by product sector basis, trade-offs
between embedded carbon inputs in manufacture, use, and end of
life destruction. These balances alter significantly between different
categories of consumer capital goods (including housing).
1.4 It is our view that product designers
and engineers are blissfully ignorant of end of life impacts arising
from the products they design and that this connectivity can best
be established by transparent, economic, Producer Responsibility.
1.5 In terms of knowledge gaps, we believe
there needs to be more government leadership on the development
of holistic British Standards in relation to calculating carbon
equivalents for different products in their manufacturing, use,
and end life phases. This work should be developed in conjunction
with initiatives aimed at standardising approaches to corporate
carbon accounting as propounded by the Aldersgate Group. This
has started in the form of the proposed PAS 2050 standard but
the process needs to be accelerated.
2. BUSINESS FRAMEWORK
2.1 Our comments above apply—particularly
in relation to Producer Responsibility and Integrated Product
Policy (IPP), and the carbon agenda.
2.2 Government needs to establish longer
range policy frameworks which involve:
— First, implementing integrated resource
flow accounting systems across public and private sectors.
— Second, confirming transparent standards
to convert that resource flow data to carbon equivalents via PAS
2050.
— Third, driving national and international
agreements on Tradeable Permit regimes which create price transparency
for every tonne of carbon equivalent emission.
As a consequence, businesses would then be able
to arrive at strategic assessments of their externality as well
as internality financial exposure.
2.3 We would refer you to the work being
undertaken on sustainable consumption and production and IPP in
the EU context. The level of awareness and understanding among
businesses—possibly with the exception of FTSE100—is
poor.
3. GOVERNMENT
POLICY
3.1 Government policy on waste reduction
needs to be integrated coherently into a wider approach to sustainable
consumption and production. Both Defra and BERR are moving in
this direction and have addressed SCP in the context of industrial,
as well as consumer understanding. This work is at an early stage,
however, and there are opportunities for closer integration, particularly
with regard to allaying fears that waste minimisation and IPP
is somehow a threat to UK sectoral or national competitiveness
in the international arena.
4. CONSUMER BEHAVIOUR
4.1 Professional trade bodies such as the
Chartered Institute of Marketing and the Chartered Institute of
Purchasing and Supply need to adopt a far higher profile in relation
to emergent environmental pressures, particularly with regard
to carbon dioxide impacts and the significance of embedded carbon
footprints at all stages of the product lifecycle in different
sectors. We would suggest that at present this is little understood
or appreciated.
4.2 Improved design is often a collateral
process to establishing products as a fashion item rather than
a functional product. As a consequence, fashion drives in its
wake a tendency to shorter lifecycles and higher levels of disposability.
The positioning of different manufacturers in similar product
segments is often illustrative of the nuances of their differences
to environmental impacts and awareness. It is difficult to regulate
public consumption and potentially dangerous. Companies will drive
that process through internality carbon costs and increasing that
on their market plans.
4.3 On an optimistic note, the oligopolistic
market structures of traditional consumer capital goods and consumer
goods supply chains is often more likely to predispose them to
accelerated change through the natural process of incorporating
environmental claims into the competitive process. As exemplars
we would cite the fortunes of Ford/GM and Toyota in automotives,
Tesco/Marks & Spencer and Walmart in carbon labelling, B&Q
and Homebase in eco-labelling and PepsiCo/Coca-Cola in soft drinks.
The supply of consumer goods markets has moved heavily in terms
of embedded values in brands and environment is the latest component
which has to be taken into account and developed as part of that
brand awareness. As a consequence, main board directors of these
oligopolies are increasingly concerned with the role of design
and end of life impact in the context of balance sheet goodwill
represented by the brand. Get it wrong and the market value of
the company rapidly erodes. Government needs to recognise that
process and identify the appropriate budgetary, fiscal and regulatory
balance of policies most appropriate to engender and accelerate
that awareness at the highest level.
October 2007
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