Select Committee on Environment, Transport and Regional Affairs Fifth Report



MEMORANDUM BY THE ROYAL TOWN PLANNING INSTITUTE (DSW 103)

INTRODUCTION

  1.  The Government's Waste Strategy 2000 (for England and Wales) (Cm 4693) was published in May. The Environment Sub-committee of the House of Commons Select Committee on the Environment, Transport and the Regions has resolved to inquire into the progress that has been made since publication of its own report on Sustainable Waste Management, in June 1998.

  2.  The Sub-committee is to examine whether the policies set out in the Waste Strategy are sufficient to deliver sustainable waste management, and whether the necessary measures, including the provision of financial resources, are in place for those policies to be implemented.

  3.  In particular, the Sub-committee wishes to examine whether the Waste Strategy will result in:

    —  more efficient use of resources, and a consequent reduction in the amount of material entering the waste stream;

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

    —  increased use of incineration as a waste disposal/recovery option—the Sub-committee would also wish to examine what the implications of such an increase would be;

    —  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 Credit Scheme;

    —  a reduction in, and better management of, hazardous waste;

    —  significant action to improve the example set by Government in exercising "green" procurement policies; and

    —  sufficient action to educate the public about the importance of sustainable waste management.

  4.  Waste management is a broad field, including much that is of a specialist technical or regulatory nature. It impinges significantly however on the scope of the Institute's principal interest in town and country planning. Following general comments on sustainable waste management, this memorandum addresses in turn those areas of interest to the Sub-committee on which the Institute has a view.

GENERAL COMMENTS

  5.  The Institute has been an enthusiastic supporter of the development of a waste strategy for England and Wales. It sees this as a major plank in the move towards sustainable development, and there is a vital need for an overall planning framework for waste. It is regrettable that Waste Strategy 2000 has taken over five years to emerge from the consultation started by the previous Government. The strategy is well intentioned, and sets out to address the management of all waste arisings, but its focus is very much on the household waste stream. This constitutes only a relatively small proportion of total waste arisings. It is here, however, that the targets are mandatory, and intended to bite on local authorities.

  6.  The targets will only be achieved if there is both a reduction in the total amount of waste produced and an increase in the proportion that can be diverted away from final disposal to more productive re-use. Experience suggests that education alone, without effective penalties, will be insufficient to produce the desired results. The Landfill Tax provides an incentive to industry and commerce to perform, but has little impact on the domestic waste stream. Local authority waste disposal costs have risen substantially since the inception of the Tax, but the increase is not faced directly by the household waste producer, only indirectly by the council tax payer perceiving reduced levels of service in other areas. The Government decided not to pursue the proposal in the consultation draft strategy—Less Waste, More Value—for some form of kerbside collection charge, scaled to penalise high waste producers.

  7.  The town and country planning system has a vital role to play in delivering sustainable waste management, ranging from the provision of a regional waste management strategy in regional planning guidance (RPG), through structure plans and waste local plans, to planning permissions for individual waste management facilities. In the past, RPG has been woefully lacking in setting an adequate strategic context for the treatment of waste. The consultation draft of the new PPG 11 Regional Planning Guidance (February 1999) signalled a welcome improvement, but the final version of the guidance has yet to be issued, almost two years later.

  8.  Equally welcome was the new guidance included in PPG 10 Waste Disposal and Management (issued in September 1999). However, it will clearly take some time for the new guidance to work far enough through the system to be helpful in informing local planning authorities on site specific proposals. This is a cause for concern in the light of the urgent need for new facilities to help meet the targets set out in Waste Strategy 2000.

  9.  A holistic approach to waste management is required—one that regards waste as a resource rather than a problem—that strengthens linkages to the conservation of minerals and fossil fuels. In practice, waste management will have to be tackled through a combination of methods and options, requiring co-operative working between many key players.

DETAILED COMMENTS

The efficient use of resources

  10.  The Institute has long been clear that the key to sustainable waste management is waste minimisation. There is an obvious and direct relationship between the overall amount of waste arisings and the economics and environmental impact of management and disposal. This is everyone's responsibility and an extensive public education and information programme is required, directed at all sectors of society and the economy.

  11.  At present, however, there is a tendency for Government policy to see the problem only as a responsibility of the consumer. Sticks and carrots might be used to encourage industrial and commercial operations to adopt a more responsible attitude towards the re-use or recycling of materials, but this option is generally not available to householders. Particularly with regard to the impact on household waste arisings, much more than has yet been achieved by the Packaging Directive could, and should, be done to discourage manufacturers from using unnecessary packaging. The extent of the problem is evident to the person in the street buying anything from confectionery to television sets.

  12.  The Landfill Tax, though generally sound in principle, has had some undesirable effects. Much inert material is now disposed of outwith licensed sites, through land raising, "landscaping", and other innovative means. Elsewhere, fly-tipping is a major environmental and financial problem for local authorities.

Recycling

  13.  In its submission to the Sub-committee in January 1998, on this same subject, the Institute observed that "the environmental cost of recycling may be greater than that of using virgin materials, and that there is often considerable economic and environmental cost in collecting materials in sufficient quantities to enable them to be recycled. " This remains the case. There are two basic dilemmas facing any policy that seeks to increase the proportion of waste that is recycled:

    —  how to increase the efficiency of the collection of recyclable materials, so that overall refuse collection costs do not increase; and

    —  how to develop markets for recycled materials in ways that do not increase the overall cost to the environment.

  14.  Society may be gradually adopting a recycling ethos, as evidenced by the popularity of the facilities often provided in supermarket car parks. Local Agenda 21 has raised the profile of recycling in many areas, and we are probably pushing at an open door. But this particular exercise is often an example of how recycling can increase environmental cost. In environmental terms, the fuel cost in getting to the recycling point is greater than the saving from the small-scale recycling it facilitates.

  15.  Many local authorities are developing innovative approaches to their waste collection arrangements—often as Local Agenda 21 initiatives—that seek to separate the various recyclables at source, without greatly increasing collection costs. This is an area where Government might devise financial incentives, to encourage higher performance, and look to the better dissemination of good practice. If it is economical for the doorstep milkman to take bottles back, why not the brewery, wine-maker, or soft drink manufacturer from at least the point of sale? Many drinks and food products now come in plastic containers, that are difficult or impossible to recycle, and which create problems of disposal because they are mostly non-biodegradable. Glass containers are readily recyclable if collection and return can be organised. Why are most retailers or manufacturers reluctant to take back obsolete "white" goods on supply of the new? Recycling of a whole range of goods and containers ought to be commercially viable, but there is currently little incentive to establish such operations. Car manufacturers are perhaps now beginning to take the lead, and show that there are more efficient recycling methods than the traditional scrapyard.

  16.  If industry and commerce face a direct cost, they will seek to minimise it. These sectors currently do relatively little to either minimise or recycle waste, and there is clearly scope for a twin-track approach by Government that:

    —  uses fiscal mechanisms to vary the costs of waste disposal, dependent on recycling and waste minimisation performance; and

    —  provides better information on waste avoidance.

  17.  A related issue is the need to give more attention to waste collection facilities in housing design—an issue highlighted by the aspirations towards both better design, and higher densities, in the revised PPG 3 Housing. Historically, little thought has been given to accommodating the refuse bin in housing design. This assumes greater significance with the prospect of multi-bin systems to accommodate enhanced recycling regimes.

Incineration

  18.  The Landfill Directive targets cannot be met without a significant contribution from incineration. Whereas A Way with Waste was specific about what was required (and attracted the inevitable press coverage as a result), Waste Strategy 2000 does not refer to incineration by name, preferring the euphemism "waste as fuel". There is no practical guidance to help stiffen the resolve of local councillors when addressing the issue in waste local plans, nor when faced with a planning application for an incinerator.

  19.  It is vital that there is a change in the public's perception of incineration, as this represents the only real alternative to landfill for a large proportion of waste arisings. How this might be tackled is a difficult question. The Institute made the point, in commenting on A Way with Waste, that the language of the draft strategy reinforced the hostile perception that prevails. It suggested that the final strategy needed to be much more positive about the important public service role performed by the waste management industry, for a society which produces ever increasing amounts of waste. Waste Strategy 2000 does not do this. Until public perceptions are altered, the timescale from inception to commissioning of new waste management facilities will continue to be measured in years.

  20.  A further dilemma is that the Government, through a series of initiatives, is attempting to re-invigorate local democracy, and increase participation in local decision-making. Success here will lead only to further resistance to waste management facilities—particularly incinerators, and the other more controversial types — and restrict the numbers that can be produced on the ground, in the timescale necessary to meet the obligations under the Landfill Directive. Figures from A Way with Waste, albeit expressed as wide ranges, indicate the scale of the problem, nationally—28-165 new incinerators; 100-200 new waste recovery facilities; and 150-300 composting facilities. None of these is likely to be regarded as a good neighbour!

Reduction in landfill

  21.  In the Institute's view, landfill will continue to be an important part of waste management strategy in the UK, if only because of the high point from which we are starting. Landfill represents the current disposal route for 85 per cent of municipal waste. The Landfill Directive's targets—75 per cent of 1995 tonnage by 2010, 50 per cent by 2013, and 35 per cent by 2020—represent a huge challenge, which can only be met if:

    —  the overall amount of waste produced is reduced, or, at least, stabilised at present levels;

    —  there is a step change in the volume of waste that is recycled; and

    —  new options are developed quickly, to deal with the waste that is produced.

  22.  The EU Directive seems to be driven as much by a lack of landfill capacity as by any clear analysis and comparison of alternative waste management strategies. If it is going to be difficult to move quickly from the past reliance on landfill, it is important that development plans continue to identify sufficient landfill capacity. This is especially important given the long lead times required by major new developments, such as incinerators. Even in the very long run, some landfill will always be required, if only for the incinerator residues that cannot be further recycled. The other, more positive, side of the coin is that restoration of mineral workings, which can be anticipated well into the future, will continue to require a supply of suitable—inert and non-biodegradable—fill material.

  23.  A general diversion away from landfill will require the construction of large numbers of new, and possibly innovative, waste management facilities. However, because of the Government's late start in updating policy and guidance, the Institute must reluctantly come to the conclusion that the town and country planning system will be unable to deliver the necessary facilities in time to meet Waste Strategy 2000's targets. The Institute has always supported the plan-led system, and equally can identify with the approach set out in the Waste Strategy for sequential planning. But that sequence—regional planning guidance, structure plan and waste local plan—will take too long to put in place (see paragraph 7, above). Even when it is there, experience suggests that there will be public opposition to most proposals. Simply recognising the problem (Waste Strategy 2000—part II, paragraphs 3.32-3.34), without offering guidance to local authorities on how to deal with the issues, leads nowhere.

  24.  There are clear differences between waste management priorities in densely populated urban areas and in rural areas. In the latter, volumes of waste are much smaller, transport distances are greater, and the market for recycled materials is small or non-existent. These differences need to be clearly recognised, and addressed, in regional planning guidance and development plans.

CONCLUSIONS

  25.  The Institute is an enthusiastic supporter of a strategy for waste management. This is a key element in progress towards a more sustainable future, and it is regrettable that it took five years to move from the earliest consultations by the previous Government to the publication of Waste Strategy 2000 in May of this year.

  26.  The town and country planning system has a vital role in delivering sustainable waste management, and it is equally unfortunate that it has taken so long to put much of the necessary policy framework in place. Now that this is happening, it will still take some time to work down to the level of determination of planning applications for individual waste management projects. At this level, local planning authorities have an equally important enabling role, but they require sound guidance and support. Waste Strategy 2000 summarises the issues well—what needs to be done, and why—but it is short on this necessary guidance and support for planning officers and local authority councillors trying to play their part in the provision of the sustainable waste management facilities that are needed.

  27.  Notwithstanding the future impact of more extensive recycling, there will remain a direct link between the requirement to reduce landfill and the consequential increase in incineration capacity. Waste Strategy 2000 not only fails to recognise this, but remains very non-committal about the future role of incineration. At least partially because of this, it is unable to take the holistic view, embracing all sectors, that is required.

  28.  The Institute's members, whether working in local government, consultancies, or waste management companies, often find themselves in a policy vacuum, at the interface between the technical experts and a sceptical, or even hostile, public. This is not always the most productive situation.

October 2000


 
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