MEMORANDUM BY THE INSTITUTION OF CIVIL
ENGINEERS (DSW 91)
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
(i) Moving from Waste Management to
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
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
(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
(iii) Availability of Reliable Data/Research
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
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
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
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
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
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 optionthe Sub-committee would
also wish to examine what the implication of such an increase
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
Will the Strategy result in significant action
to improve the example set by Government in exercising "green"
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 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
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