Select Committee on Environment, Transport and Regional Affairs Fifth Report



MEMORANDUM BY THE INSTITUTION OF CIVIL ENGINEERS (DSW 91)

OVERVIEW OF THE STRATEGY

  The Institution welcomes the broad thrust of Waste Strategy 2000. We are particularly pleased that the underlying philosophy of the strategy is a holistic view of resource use and not simply of waste management as an "end of pipe" activity. However, while we agree that the aims and targets set out in the strategy are laudable we have doubts as to whether the proposed actions will be sufficient to meet these targets within the timescale demanded. A number of issues raise particular concern:

 (i)   Moving from Waste Management to Resource Management:

  The strategy encourages:

    —  Designing products so that they use fewer materials and the use of manufacturing processes that result in less waste;

    —  Better utilisation of waste through recycling, composting and energy from waste;

    —  Increased use of products made from recycled materials;

  In practice what is being called for is for resource use to be better managed at all stages of a product's life from conception to end use. However, if this approach is to be successful a far wider range of organisations and individuals will need to be engaged than those currently involved directly in what is normally thought of as waste management. Product designers and manufacturers, retailers, consumer groups and people responsible for public and private sector procurement will all need to play a major role. Government needs to explain how this process of engagement will be driven forward.

  In this context while it is important to encourage individuals to reduce waste, greater emphasis should have been placed on the role of manufacturers and retailers in making it easier for consumers to produce less waste eg by reducing packaging.

  We would also argue that the strategy focuses too heavily on household waste (which amounts to around a quarter of total waste arisings) at the expense of commercial and industrial waste.

 (ii)   Planning Approval for Waste Facilities

  The strategy envisages a significant move away from landfill towards reuse, recycling, composting and where this is not possible, energy recovery via incineration. All of these options will require a significant investment in new infrastructure if targets are to be met. The Institution is also concerned that the Strategy is vague on the amount of waste that will not be suitable for reuse, recycling or composting and will need a source of final disposal via landfill or incineration, which we believe will be significant. It is therefore disappointing that the strategy has very little to say on the difficulty of securing planning approval for any new waste facility. We feel that Government must acknowledge that it understands this problem and work with Local Authorities, developers and local communities to help overcome this situation.

 (iii)   Availability of Reliable Data/Research & Development

  The lack of reliable data on the relative impact of different waste management options on the environment and the risk they may pose to human health exacerbates the difficulty of securing public acceptance for waste facilities. The Environment Agency has a role to play in the area of providing data which it has struggled to fulfil. However, it is also beholden on waste producing industries and the waste management industry itself to sponsor more independent research in these areas, particularly via the Landfill Tax Credits Scheme. Only when this type of data becomes readily available will it be possible for legitimate public concerns to be answered.

  Lack of investment in Research and Development is also holding back the development of possible new technologies such as anerobic digestion. Until such technology is demonstrated on a commercial scale in a UK environment the private sector view it as a risky option and add a cost premium making it unaffordable.

 (iv)   Market Development for Secondary/Recycled Materials:

  The strategy will not succeed unless very large new markets for recycled materials are opened up. The enquiry should satisfy itself that the proposed Waste Resources Action Programme (WRAP) will have sufficient resources and expertise to make a major contribution in this area. Industry must also play its part by developing the necessary specifications and standards for recycled materials that will give manufacturers and consumers the confidence to use these products. ICE is currently investigating how it can help with the development of such specifications in relation to construction materials.

  In response to the seven specific questions posed by the Committee:

Will the Strategy Result in More Efficient Use of Resources and a Consequent Reduction in the Amount of Material Entering the Waste Stream?

  It could be argued that a more efficient use of resources will not necessarily lead to a large reduction in the amount of material entering the waste stream in the first place if that material is then recovered for reuse and recycling. The fundamental aim should be to reduce the quantity of material from which no value is ever recovered.

  This point aside it will be crucial to reduce resource use by manufacturers who have perhaps the most significant impact in terms of waste production. We would again note that the focus on household waste is misleading as this amounts to a relatively small percentage of the waste stream and is affected by the nature of the products produced by manufacturers and packaged by retailers.

  There is unfortunately little in the strategy to suggest that beyond the normal working of market forces more sustainable product design will move up manufacturers agendas. We would therefore encourage government and Landfill Tax Credit support for research and development work on product design. We would also welcome proposals for wider use of producer responsibility schemes where it can be shown that they would encourage manufacturers and retailers to take a "whole life cycle" approach to their products and would not impose an unreasonable burden on business.

Will the strategy in an increase in recycling of waste, particularly the greater development of markets for recycled material (including compost) and the use of producer responsibility measures?

  As stated above we welcome the formation of WRAP but note that it faces an enormous task if it is to create sufficient markets for recycled materials to enable government targets to be met.

  Statutory recycling targets for Waste Disposal Authorities (WDAs) will almost certainly lead to an overall increase in recycling. However, if the required increases are to be achieved in the timescale set out in the strategy there will need to be large scale investment in infrastructure. Given the problems of securing the necessary investment and planning permissions the targets for 2005 appear very optimistic.

  We are also concerned that the use of strict recycling targets may conflict with the principle of adopting Best Practicable Environmental Option (BPEO). WDAs may adopt recycling for waste streams where a different route would be more sustainable. Particular attention should be paid to the cost and environmental impact of transportation of material. If large numbers of small scale local recycling enterprises are envisaged these costs could be very high. The environmental and health and safety standards of new recycling facilities will also require careful monitoring.

  This highlights two areas where the strategy is lacking:

    —  There are no specific proposals for meeting the costs of new initiatives

    —  There remains no guidance or code of practice to help Local Authorities establish how they should be implementing sustainable waste management in line with BPEO.

  Centralised composting of green garden waste can be expanded but will require the creation and adoption of best practice to ensure that a quality product is produced.

  As stated above we support the expansion of producer responsibility schemes where they can be shown to be effective. However, we note that the scheme for packaging has not been entirely successful and has proved difficult to police.

  In areas of two tier local government, co-operation between WDAs and Waste Collection Authorities (WCAs) will be vital. We welcome the promise to structure Best Value performance indicators to encourage this co-operation. We also suggest that government should provide early guidance on the contribution. WCAs should make to meeting the recycling targets in a WDA area.

Will the Strategy result in increased use of incineration as a waste disposal/ recovery option—the Sub-committee would also wish to examine what the implication of such an increase would be.

  We believe that an increase in incineration with energy recovery will be necessary if the UK is to meet its Landfill Directive obligations. These obligations notwithstanding we also believe that incineration with energy recovery has an important role to play in an integrated waste management strategy. It is therefore disappointing that while the strategy recognises a role for incineration it backs away from stating what government believes this role will be. This will undermine the efforts of developers to introduce the necessary new facilities over the coming years. We are disappointed that the government is not providing leadership in this area.

  Incineration is a relatively inflexible technology which requires long-term investment. Accepting that incineration plants will be required it would be useful if government produced planning guidance on the minimum incineration capacity that should be available by region. Such guidance would need to be set in the context of predicted waste arisings after recycling targets have been met if it is to be acceptable to the public.

  Any new waste facility tends to face public opposition but we recognise that an incineration plant can be a particularly emotive issue for local communities despite the advances in emission standards of incinerators in recent years. There remains a need for data on the comparative risks of various waste management options which could be used to address public concerns over incineration.

Will the Strategy achieve a reduction in the amount of waste sent to landfill? In this context, the Sub-Committee would welcome views on the effects of the Landfill Tax and its associated credits scheme.

  It is difficult to make a final statement on this subject until the government produces its detailed plans for implementing the Landfill Directive, particularly its proposals for the application, monitoring and enforcement of targets.

  As stated above we have concerns as to whether the strategy does enough to ensure that the financial, planning and implementation hurdles to putting in place the required new waste infrastructure will be in place in time to meet the government's targets for reduction of landfill.

  Landfill Tax has focused attention on alternatives to landfill, particularly for active waste. Government's intention of increasing the tax annually up to 2004 will speed this process.

  However the lower rate of tax for inert waste while having some impact has not provided as great an incentive to divert the 70 million tonnes of construction waste produced annually in the UK to landfill. 30 per cent of this waste stream still goes to Landfill with another 30 per cent used for landfill engineering. There is enormous scope for making better use of this material but this will require the introduction of new standards and specifications if there is to be widespread confidence in recycled construction materials.

  The landfill tax credit scheme has had a positive impact but there is a lack of co-ordination of its initiatives. This not only results in duplication of proposals but also the continued underfunding of waste management research and development which we believe to be vital to delivering the aims of the strategy. We therefore welcome the proposed review of the operation of the landfill tax credits scheme. We would like to see government or ENTRUST have a enhanced role in the direction of these funds and suggest that there should be wide consultation on what should be the priorities areas for funding.

Will the Strategy result in, and better management of, hazardous waste?

  We are unclear as to the impact of the strategy of the management of hazardous waste. Where this waste falls under the category of special waste it will continue to be subject to a special regulatory regime. With regard to hazardous waste arising in the general household waste stream there is again a problem of a lack of clear standards or a national strategy for dealing with this material. Where hazardous household waste is not suitable for recycling it will move down the waste management hierarchy towards incineration and landfill which will raise public concerns. If public confidence is to be maintained there must be clear guidelines for the safe handling, storage, transport and disposal of these wastes.

Will the Strategy result in significant action to improve the example set by Government in exercising "green" procurement policies

  The Institution would welcome clear guidance on best procurement practice from an environmental and sustainability perspective and hope that WRAP will make producing such guidance a priority.

  A key barrier to more sustainable purchasing is the previously mentioned lack of standards and specifications for many recycled materials. As stated above ICE is looking at ways of addressing this problem in relation to construction materials and would call on other industry sectors to take similar action.

Will the Strategy result in sufficient action to educate the public about the importance of sustainable waste management?

  Public education and changing the behaviour of individuals is of great importance and we support the setting up of new education campaigns including the "Doing your Bit" campaign which anecdotal evidence suggests is having an impact in raising awareness of resource use issues. Government and Landfill Tax credits should be directed towards this and similar campaigns.

  However delivering major shifts in public perception and behaviour is likely to take some time, possibly up to a generation to achieve. Faster results in terms of better resource management can be achieved by targeting the practices of manufactures and retailers.


 
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