MEMORANDUM BY THE ENVIRONMENTAL SERVICES
ASSOCIATION (DSW 88)
The Environmental Services Association ("ESA")
is the trade association for the waste management and secondary
resource industry, a sector that contributes more than £4
billion to the United Kingdom economy, about 0.5 per cent of GDP.
Our members provide integrated solutions to waste across the full
spectrum of biological, thermal and mechanical treatment options
and are consistently achieving more sustainable waste management
ESA welcomes the opportunity to submit comments
on the Select Committee's inquiry into sustainable waste management.
Sustainability is an opportunity for our industry. The development
and growth of the waste management industry resides in higher
added value and continuing evolution of a dynamic and vibrant
resource management industry.
Consequently, there is much for our Members
to welcome in the aspirations of the Government's Waste Strategy
for England and Wales ("Waste Strategy 2000"). However,
whilst being stronger on the vision, Waste Strategy 2000 is less
effective in supplying the mechanisms to initiate the necessary
behavioural, environmental and economic changes that will facilitate
the growth of secondary resource industry.
The direction of Waste Strategy 2000 is clear.
What remains uncertain is the pace of the change and how the Government's'
vision will be delivered. Only by working in partnership with
ESA's Members can the Government lead the Country to sustainability.
Q1. More efficient use of resources and a
consequent reduction in the amount of material entering the waste
ESA Members do not see perpetual growth in waste
arisings as the future of the waste management industry. Growth
lies in higher added value and the evolution of a dynamic and
vibrant secondary resource industry. Growth therefore lies with
what industry is enabled to do with waste through sophisticated
management techniques rather than with unit volumes.
The Landfill Directive and Waste Strategy 2000
are helping to drive this trend. However, it is only if the Government
creates a framework where sustainability is profitable that industry
can help the Government, through sustainability, to demonstrate
a decoupling of waste production from economic growth.
Again, the Government's only chance of enabling
the UK to comply with the Landfill Directive is to treat the waste
management industry as a responsible partner and to create the
conditions to enable the industry to provide what is needed.
Waste minimisation can be compatible with the
growth and development of the industry, arising from increasingly
treating waste as a resource to which value is added. However,
ESA Members deliver solutions to the problems of waste and both
regulation and public attitudes to production of waste will significantly
determine the shape of the industry. We agree with the observation
at ESA's 1999 Annual Conference of Mr Chris Mullen MP that the
public consciousness of waste as a problem is broadly analogous
to that of smoking in the 1960s.
Reducing primary resource consumption by changing
the behaviour of waste producers is crucial to delivering real
change and we welcome new initiatives outlined in the Strategy.
The implementation of the Pollution Prevention and Control Regulations
will assist this by bringing a more holistic approach to the regulation
of industry. However, ESA is unconvinced that the Strategy is
sufficiently potent to drive the necessary change.
If the primary intention of Waste Strategy 2000
was to reduce the amount of waste society produces, a system of
waste minimisation credits could have been introduced. This goes
further than the indicator A1 of the Government's sustainable
development strategy. The scheme could resemble the recycling
credits system with credits awarded to local authorities where
the quantities of total waste within their areas decline from
the previous year. Reducing the amount of waste produced by local
authorities would allow more to be spent on the development and
growth of the secondary resource industry.
If the Government were willing to trust a combination
of market and regulatory mechanisms, there could be a positive
role for direct charging. For example, each household could be
issued with a notional voucher entitling it to free disposal of
a certain weight of waste per year. Excess waste would then be
liable for direct charging. Such a mechanism could avoid regression
and, if designed in the right way, could help in generating the
motivation that is essential to changing behaviour. ESA supports
a controlled test to see whether a household charging scheme could
be successfully applied to UK households.
ESA's Members already deliver expert advice
to a range of industries on issues such as waste minimisation,
higher resource use and selection of the waste-specific Best Practicable
Environmental Option ("BPEO"). The decision making process
can be assisted by such environmental management tools as Life-Cycle
Assessment and we hope businesses will increasingly seek the help
of our Members.
New technology will have an important role to
play, not only in facilitating more sustainable and environmentally
friendly design and increasing extract value from the product
but also in monitoring resource wastage and changes in behaviour
of waste producers. Government can use regulation to promote new
technologies that will offer exciting opportunities to indigenous
capital equipment manufacturers able to compete in the market.
Q2. An increase in recycling of waste, particularly
by greater development of markets for recycled material (including)
compost and the use of producer responsibility measures
ESA supports an expansion in recycling and composting
as well as the introduction of statutory targets.
However, statutory targets by themselves do
not deliver an increase in recycling. An economy that effectively
recovers resource from wastes needs a process from waste producer,
to reprocessor and on to the end market with adequate transport
throughout. For long-term viability, recycling must be seen as
a sophisticated industrial process, provided by a profitable and
ESA's Members are investing heavily in recycling
infrastructure and it is for Government to create the conditions
for this sector to grow without destabilising existing infrastructure
in which the industry has invested.
Large amounts of commercial waste are recycled
because it is economically viable. Provided it works with the
grain of the market, the Waste and Resources Action Programme
("WRAP") in overcoming market barriers to promote, re-use
and recycling could make a positive contribution and ESA is willing
to help. The Government has wisely chosen to work with representatives
from the waste management industry and ESA hopes that this partnership
will deliver real solutions. ESA asked the Government to include
market development as a criterion under the Landfill Tax Credit
Scheme and our Members have contributed substantial funds to initiatives
such as ReMaDe.
However, markets in recyclates are often global
and ESA would have welcomed complementary new policy and market
instruments. For example, Waste Strategy 2000 could have built
on the voluntary minimum recycled content established by the Newspapers
Association of 70 per cent by 2006 and introduced similar initiatives
across other industries to significantly stimulate demand for
secondary materials and products.
Ultimately, increasing household recyclingthe
visibility of which exceeds its proportionate sharewill
largely depend on the behaviour of consumers: their participation
in recycling schemes, inclination to purchase recycle products
and willingness to pay higher costs. Changing the perceptions
of householders will significantly impact on developing markets
and increase certainty to invest in recycling facilities.
The greater the confidence that financial institutions
have in the growth of recycling, the lower the cost of raising
capital and the more cost-effectively our Members can deliver
innovative recycling and composting solutions. However, the failure
to meet the recycling targets of "Making Waste Works"
demonstrates the cultural change needed to deliver the Waste Strategy.
We hope the pilot schemes announced in paragraph 5.7 Part 2 will
prove to be effective.
ESA supports the duty which producer responsibility
places on producers to accept responsibility for their management
of waste and the generation of an economic incentive to maximise
the life of a product.
For example, with our Members, we are already
working in partnership with the Lighting Industry to develop a
recycling scheme for end of life fluorescent lamps to meet the
requirements of the prospective Waste Electrical and Electronic
Directive even before that Directive has been implemented.
However, as the Committee noted in their previous
report into sustainable waste management, producer responsibility
initiatives only cover specific waste streams and cannot alone
reduce excessive consumption. Producer responsibility is part
of the solution and may need to be accompanied by economic incentives
at the end of consumption.
However, sustainability is not the inherent
property of any one particular waste management option and it
is very important to be aware that recycling will not always represent
BPEO. It is therefore important that the industry is able to offer
a spectrum of sustainable waste management options to complement
materials recovery and dispose of the residue created by reprocessing
and recycling. This will eventually include the product: there
is a limit to how many times a recyclate can be re-used.
Q3. Increased use of incineration as a waste
The experiences of countries such as Sweden
and Switzerland demonstrate that recycling and composting will
not deliver in isolation and ESA therefore supports the integrated
approach and Waste Strategy 2000.
Energy from waste is complementary to management
options such as recycling and an environmentally and economically
sustainable waste strategy involves a portfolio of waste management
We expect more energy from waste facilities
to reduce the Country's reliance on landfill, but incineration
is not the answer to the Country's problem: it is part of a co-ordinated
solution. For this reason, and because we expect recycling to
grow so rapidly, ESA does not agree with the introduction of an
In contrast to past reliance on landfill we
do not expect any option to account for more than 50 per cent
of municipal waste management activity. If, as a matter of public
policy, there was a move to limit the capacity size of an energy
from waste facility to encourage the growth of smaller scale plants,
the public would also need to appreciate the implications for
Energy from waste offer one route to sustainability:
not only do facilities provide solutions to the waste created
by society but they also prevent the release of hundreds of thousands
of tonnes of non-renewable carbon dioxide through using municipal
waste rather than fossil fuels to generate energy. Residues from
energy from waste can also be re-used in construction, preventing
the use of virgin materials. Ultimately, the contribution of EfW
will be dictated by whether waste management or renewable energy
policy represents the primary driver.
ESA Members' energy from waste facilities are
operated to the highest standards and are tightly regulated by
the competent authorities. The operational standards for energy
from waste plants have been agreed democratically in Europe, a
process in which all parties have been able to add value. To protect
the environment, ESA has supported a level playing field to bring
environmental standards up to that expected of ESA's Members.
All waste management options have an impact
on the environment. A waste specific BPEO seeks to optimise the
balance between environmental performance and economic cost: energy
from waste should be considered within this context. What is best
for the environment might not always be necessarily the option
which seeks to maximise the resource. As the Committee noted in
its report in 1998 on sustainable waste management, there is no
point in durability for durability's sake: re-use must be consistent
with BPEO. Similarly the Committee noted the sustainable role
of high temperature incineration in destroying those wastes where
value is unable to be added and where the primary requirement
is for the destruction of harmful substances.
Q4. A reduction in the amount of waste that
is sent to Landfill
The Landfill Directive is the primary driver
for the diversion of biodegradable municipal waste from landfill.
However, well-engineered and maintained landfill sites will continue
to play an important, albeit reducing role within an integrated
framework of solutions to waste. Notwithstanding some media coverage,
there will continue to be added value in ongoing improvement of
The setting of statutory recycling targets will
spearhead the diversion of waste from landfill sites and is welcomed
by ESA. However, there must be widespread political acceptance
of the need for new facilities if the resource management industry
is to grow. Sustainable waste management will not be possible
without an efficient and responsive planning system. ESA is therefore
disappointed that Waste Strategy 2000 contains no new initiatives
to improve the speed of the planning system and is concerned that
this might cause failure to meet the targets of the Landfill Directive.
The voluntary contributions of hundreds of millions
of pounds by ESA Members through the Landfill Tax Credit Scheme
have contributed significantly to research into sustainable waste
management and added considerable value to local communities,
the environment and in helping to develop a more sustainable society.
An advantage of the scheme to the Government
is that the scheme does not fall within total public spending.
This facilitates macro-economic management by the Treasury and
probably increases total funding of environmental enhancement
ESA itself established two independent object
"C" EBs to promote knowledge and awareness of sustainable
waste management: the Environment Services Association Research
Trust ("ESART") and the Environmental Services Training
and Education Trust ("ESTET"). ESA hopes both will develop
strong synergies with WRAP.
ESA offered some time ago to work with the Government
in setting indicative targets for the distribution of Landfill
The Government and others must be realistic
as to what the Scheme can deliver: the Landfill Tax Credit Scheme
makes a positive contribution but will never be large enough to
pay for the UK's Landfill Directive obligations or to achieve
ESA believes that there is now sufficient practical
experience of the Landfill Tax Credit Scheme to justify an industry
code of conduct to supplement and support the role and duties
of the regulator. ESA's code will:
draw on existing best practice and
improve the rigour and professionalism between landfill operators
reinforce integrity in the relationship
between local authorities and Landfill Operators; and
apply the proven General Principles
of financial regulation of the Financial Services Authority.
The integrity of the Landfill Tax Credit Scheme
is critical: the Scheme must be and must be seen to be clean.
The industry supports consistent and reliable
regulation and expects the regulator to draw on the expertise
of those best qualified as regards its core task.
As at the date of submission of this evidence,
ESA is awaitingtogether with the Institute of Wastes Managementa
meeting with ENTRUST to discuss matters including its corporate
governance. Pending the outcome of that meeting it is not appropriate
for ESA to offer further comment.
Q5. A reduction in and the better management
of hazardous waste
The Waste Strategy 2000 rightly acknowledges
that BPEO should underpin the management of all types of waste
and we welcome the commitment within Waste Strategy 2000 to determine
BPEO for the management of key hazardous wastes.
Landfill will remain an important management
solution for hazardous waste and ESA Members are working in partnership
with the Government and the Environment Agency to implement the
requirements of the Landfill Directive. The work of this partnership
will have important implications for the landfilling of hazardous
High temperature incinerators also offer a highly
effective management solution for many hazardous wastes: simply,
they destroy them. A drive to higher environmental standards is
profoundly influencing the nature of this sector of the industry,
leading to a limited number of large, more centralised and highly
capital intensive facilities. As the Landfill Directive takes
effect, this infrastructure will probably need to be viewed as
a "UK resource" to which prohibited waste streams are
re-directed. This will require a sufficiently flexible approach
to proximity as the capital intensive nature of the plants will
mean that it is extremely expensive to develop a large number
of smaller and more regionalised high temperature incineration
plants and other hazardous waste plants. Standards rather than
geography should be the over-riding factor.
The Landfill Directive imposes a requirement
for pre-treatment for the landfilling of most hazardous wastes
and we agree with the view of the Waste Strategy that implementing
the Directive will develop new waste management options for pre-treatment.
It is important that the Government ensures that regulation encourages
market conditions to permit a range of alternatives to develop.
Without this, innovative treatment methods will not emerge.
Effective and transparent regulation of hazardous
waste is vital. The Landfill Directive and IPPC will be huge undertakings
for the Environment Agency and we are concerned that sufficient
resources are made available to allow them to regulate effectively.
Q6. Significant action to improve the example
set by Government in exercising "green" procurement
Environmental policy needs to be a key consideration
of public procurement decisions and we are pleased that the Government
wants to go further than current public procurement policies in
purchasing recycled products.
Adding environmental consideration as a more
significant component of economic decisions is a central tenet
of sustainable development and the Government must be seen to
drive movement in this direction.
Leading by example, the Government will demonstrate
its confidence in recycled products and help to create stable
markets for recycled product by, for example, sending a reassuring
signal to other consumers. ESA suggests that to further strengthen
the markets for recycled products, the Government consider awarding
medium to long term contracts to facilitate greater investment
in new technologies, innovation and research and development.
A problem in "green" procurement has
traditionally been the cost and quality of recycled product and,
again, the Government should act to change this perception. There
are many high quality recycled products and if the Government
wants to develop a strong secondary resource industry it must,
as the of the largest purchasing organisations, be ready to pay
higher costs. It is also important that the Government's procurement
policy is not confined to a limited number of easily recyclable,
visible and high profile products.
We would encourage the Government to consider
"green" procurement as a grant or tax credit to develop
a more sustainable part of the economy. The Government should
show the same willingness to develop this market as it does in
trying to stimulate e-commerce. The Government has made a commitment
in Waste Strategy 2000 to introduce more sustainable procurement
policies and we hope that these will have positive impact.
It is important for businesses to follow the
lead of the Government in their procurement choices and we hope
that the initiatives listed in Waste Strategy 2000 will prove
to be successful in encouraging businesses to adopt more sustainable
procurement policies. As waste producers, they have a role in
helping to support the growing evolution of a resource management
industry. However, the Government must monitor this activity of
business closely and, if necessary, consider mandatory procurement
Q7. Significant action to educate the public
about the importance of sustainable waste management.
The public is a key partner in the evolution
of a secondary resource industry. Public commitment and support
is critical in delivering the aspirations of Waste Strategy 2000.
Increasing household recycling needs consumers to recognise their
role and responsibilities as waste producers and in regarding
landfill as a valuable and finite resource. Sustainability is
part of the quality of life and the public will need to pay for
the Country's future resource management industry which ESA's
Members are ready, willing and able to develop.
Success will largely depend on ceasing to think
about waste as the end product of consumption and more as a resource.
As suggested above, this is a huge cultural shift and comparisons
are often made with the early stages of the drink drive campaign
in trying to change attitudes.
Effective, honest and influential initiatives
to educate and energise the public are therefore vital and ESA's
Members have already contributed millions of pounds through the
Landfill Tax Credit Scheme to raise awareness and increase knowledge
of sustainable waste management. ESA's Research Trust ("ESART")
has this year contributed £50,000 to the National Waste Awareness
Initiative. Waste Strategy 2000 rightly acknowledges the important
role and strong contribution of education programmes and our Members
remain committed to working with partners in demonstrating the
environmental impact of waste producers. It is crucial that the
public is aware of the need for sustainable waste management and
able to express their choice. This will only happen if the public
feeds connected to the vision of the Waste Strategy 2000.
However, it is crucial that educating the public
on the importance of sustainable waste management is done in a
mature and honest manner, based not on flimsy and anecdotal evidence
but on rational and scientific grounds with a clear understanding
of the real choices to be made. Again we emphasise that only in
partnership can the United Kingdom develop sustainability.
Based on the experiences of our Members and
the failure of the recycling targets of Making Waste Work, ESA
is unsure whether the mechanisms contained in Waste Strategy 2000
will be sufficiently strong to change behaviour. We would have
also liked to have seen a commitment to introduce fiscal instruments
where sufficient progress was not being made, in order to add
some bite to the commendable initiatives outlined in the strategy.
ESA offers further views on matters fundamental
to the delivery of a sustainable society:
Whether Waste Strategy 2000 will lead to a more
efficient and responsive Planning System
ESA believes that Waste Strategy 2000 does not
provide real solutions to increase the efficiency and responsive
of the planning system in implementing the vision of Waste Strategy
2000. Part 2 of the Waste Strategy shows that new facilities will
be needed to meet the targets of the Strategy and the Landfill
Directive. This is of particular concern as our Members' experience
of the planning system in processing applications for a range
of facilities, including Material Recycling facilities and composting
stations, is dilatory, expensive and unpredictable. We are unpersuaded
that the Strategy creates the planning system that is urgently
needed and there is a real danger that new facilities will not
be provided or that they will not be placed in the most suitable
Particular problems include the failure of the
plan led system to produce plans and the failure of local authorities
to accept ownership of a problem they themselves create. Whilst
the need for new facilities is often agreed at regional level,
delivery at a local level is far more difficult, with political
considerations often obstructing delivery. The motivation for
local authorities to deliver must be stronger and ESA believes
it is vital for the recycling performance indicator to be underpinned
by a tough sanction where compliance is not reached.
ESA would have liked to see statutory recycling
targets supplemented with other mechanisms. To improve the speed
of the plan led system, ESA would have warmly welcomed a deadline
for the production of plans supported by placing the stage of
development of each plan in the UK on DETR's website to facilitate
transparency and monitoring. A strong sanction would need to underpin
this deadline to ensure that there is the necessary motivation
to complete the plan within the permitted time. The Government
may have missed an opportunity to improve the certainty of the
Raising awareness of sustainable waste management
and increasing knowledge of the responsibilities partners have
in delivering the vision of Waste Strategy 2000 may help to improve
efficiency but there is growing concern that decisions are being
made in favour of public perceptions even when they are profoundly
mis-informed. Ultimately it is not in the interest of society
to erect barriers against the development of new facilities as
by doing so, industry is prevented from adding higher added value
and the evolution of a sustainable society is decelerated.
ESA's Members need to work in partnership with
the Environment Agency to meet the challenges ahead: only a broadly
consensual approach can deliver a more sustainable society within
a reasonable period of time. The challenges associated with delivering
the National Waste Strategies within the framework of sustainable
development are significant as regards both their nature and the
timescale for delivery. There has never been a more pressing time
for an effective and clearly focused regulator to underpin the
delivery of the Waste Strategy 2000. ESA looks forward to working
closely with the Environment Agency in negotiating the many challenges
Waste criminals prevent waste from being managed
to the high environmental and regulated standards under which
ESA's Members operate. ESA is working in partnership with agencies
including Interpol, the police and the Environment Agency to try
to eradicate criminals which unfairly tarnish a highly regulated
industry. The public must have confidence in the waste management
industry and when waste criminals have the highest profile, this
reflects negatively and unfairly on ESA's Members who operate
to the highest technical standards. ESA is therefore disappointed
that Waste Strategy 2000 did not allocate extra resources to combat
waste criminals whose activities will otherwise rise as the Government,
regulators and membership of ESA seek to achieve sustainability.