MEMORANDUM BY ECT RECYCLING LTD (DSW 109)
Will Waste Strategy 2000 result in:
efficient use of resources and reduction of materials
entering the waste stream
There is a tendency in waste management to argue
for regional facilities integrated with regional contracting.
This is linked to the issue of which part of local government
should be made responsible for meeting the targets.
Waste disposal authorities have had almost no
positive impact on UK recycling rates. In many cases they have
been, and are, an obstacle to progress. The implied power of "direction"
set out in the Environmental Protection Act (EPA) has been used
by some disposal authorities to block recycling options that adversely
affect disposal arrangements. For example, recycling has been
limited to areas not serving an incinerator.
In one case involving ECT Recycling, we were
informed that recycled materials must all be delivered to the
disposal authority or its nominated reprocessor. The authority
implied it held exclusive rights to market recyclable materials
derived from constituent local authority areas. This was clearly
against the interest of the local collection authority in which
we work and is a restrictive practice. We were prepared to test
the matter in the courts if necessary and the disposal authority
concerned did not subsequently pursue the matter. We also have
recent experience of a similar difficulty whereby a LAWDC has
claimed exclusive rights to newspaper and magazines. In this case
the collection authority indicated that any recycling option must
exclude the material concerned from any multi-material collection
proposals. The LAWDC has effectively claimed a monopoly over the
material to the exclusion of all other potential recycling options
and providers. In this case it is clear that the experience and
expertise of the LAWDC in the recycling collections field is very
limited. This is clearly a restrictive practice and we believe
it to be in breach of European competition and procurement law.
However, many local authorities have been intimidated by these
claims and inefficiencies will occur in consequencedouble
handling of materials, additional collection systems over that
which is necessary etc.
Almost all the most progressive work has been
initiated and commissioned by collection authorities or unitary
authorities acting in support of local policy. The collection
authority has a closer relationship with the public. The type
and scope of collection service impact on the standing of the
collection authority and not the disposal authority.
In this context we believe the statutory targets
should be set for collection authorities and that the tradable
permits for landfill should be made available to collection authorities
rather than the disposal authority. A further option would be
to extend the tradable permit system to include recycling as well
as disposal to landfill.
Waste management companies and many local authorities
remain convinced that recycling can only be undertaken by developing
large scale MRFs in conjunction with long-term disposal contracts.
The argument is not convincing. It is made simply because shareholder
return is earned in relation to the amount of capital deployed.
Simple depot facilities and low-tech collection infrastructures
work very well, they are also robust and offer decent jobs rather
than unpleasant, poorly paid work within mixed waste MRFs.
Waste reduction is not likely to be greatly
impacted by the strategy. Reform of the producer responsibility
system will be the key.
an increase of recycling of waste, particularly
by greater development of markets for recycled material (including
compost) and use of producer responsibility measures;
Statutory targets will make a difference to
local government attitudes. One of the excuses given for not meeting
the previous targets is the fact that other services are deemed
statutory and those that are not have received fewer resources.
Market development is vital to ensuring that
the push of statutory targets is not accompanied by stockpiling
recyclables that have no market or market failures resulting in
excessive additional cost to local government or the operators
of recycling collection schemes.
We welcome the creation of WRAP and the prospect
of new investment in diversifying the market. The limited number
of reprocessing facilities compared to the large diversity of
collectors has given the reprocessing industry disproportionate
influence to fix the market.
We would also welcome additional investment
on the large scale reprocessing capacity. The investment decisions
of major international paper reprocessors are largely dictated
by the availability of grant support. New capacity will not be
created without matching investments offered in the rest of the
If this is not forthcoming it is highly likely
that over-supply will cause a collapse in UK markets. This may
create an indirect subsidy encouraging new investment decision
due to the cheap secondary material available. However, existing
operators and the local authorities will bear the consequences
and both company failures and the withdrawal of schemes may result.
Disruption of this type will clearly impact upon meeting the targets.
increased use of incineration as a waste recovery
optionthe Sub-committee would also wish to examine what
the implications of such an increase would be;
The strategy is likely to result in an increase
in the amount of incineration. This waste management option will
also be at the centre of political opposition to waste management
plans and local authorities deciding upon this option.
ECT Recycling does not oppose the incineration
with energy recovery of "residual waste" where the alternative
is landfill onlyneither is particularly attractive. However,
the structure of many existing contracts involving incineration
can create obstacles for other more sustainable waste management
options. In particular, earning a return on capital requires that
significant capital is deployed, predicating private waste management
companies towards promoting incineration and mass burn solutions.
Significant capital investment is not a necessity for a successful
recycling strategy, although the entire private sector promotes
the development of large regional "Material Reclamation Facilities"
MRFs, using relatively expensive vehicles for collections that
replicate existing waste collection techniques. Return on capital
is the primary motivation for the favoured solution. This inevitably
results in the call for very long contracts25 years or
more with guaranteed throughput, minimum tonnage guarantees, minimum
calorific values, exclusive rights to the waste etc. These factors
become an obstacle to recycling.
a reduction in the amount of waste sent to landfillin
this context, the Sub-committee would welcome views on the effects
of the Landfill Tax and its associated credit scheme;
Assuming the statutory targets are enforced
the strategy will reduce the amount of waste taken to landfill.
The landfill tax credit scheme is operated almost
exclusively in the interest of shareholders. ECT Recycling has
previously lost landfill tax credit funding for a project funded
by "Biffa Ward" following the award of a recycling contract
to ECT Recycling where Biffa lost the contract. Given that the
provision of the credit is at the discretion of the landfill operator
the "independence" of the trust or body making the award
is a fiction.
The scheme shares the worst aspects of the "planning
gain" system. Contracts are increasingly evaluated on the
basis of the "landfill-tax package" associated with
it. This clearly favours large landfill operators and discriminates
against providers that have no landfill tax to give or do not
wish to engage in this practice.
Direct commercial benefit is derived from most
landfill tax funded projects working in the recycling or waste
management field, whether it is improved chances of receiving
contracts or from the projects themselves. For example, a waste
management company funding a kerbside programme using landfill
tax in an area within which it holds the waste collection contract
will benefit from the recycling undertakenit will have
less waste to collect, perhaps fewer trips to the transfer station
and a cost saving. The value of the contract will not reflect
this change. We are clear that in places that we operate, waste
collection costs have been reduced. In Hounslow, a beacon council
for waste management in which we work, the DSO state without the
recycling service they would require between one and two additional
RCVs to collect the household waste. The general claim of waste
management companies and DSOs that recycling has no impact on
wider waste collection costs is erroneous.
a reduction in, and better management of, hazardous
If the strategy delivers a source separation
kerbside infrastructure, there will be significant potential to
include hazardous items within these systems. The addition of
batteries within a box based, kerbside-sorting operation is relatively
cheap and efficient, assuming the reprocessing facilities exist.
The development of processing capacity is essential.
significant action to improve the example set
by Government in exercising "green" procurement policies;
There has been significant resistance to the
adoption of "green purchasing" with local and national
government on the grounds that such a strategy will involve increased
cost. The CCT framework was also used to obstruct the adoption
of policies that would improve environmental performance.
We welcome the new direction and believe that
the Government can influence purchasing strategies throughout
the public and indeed private sector. The adoption of ISO 14001
or EMAS within government will move the supply chain, if it is
made clear to suppliers that they will also need to control inputs
to ensure good environmental practice.
sufficient action to educate the public about
the importance of sustainable waste management;
The budgets committed to education and marketing
have been derisory in the UK compared to countries with more successful
recycling strategies. The procurement process has been part of
the problem at the local level. Local authorities have generally
sought service provision at the cheapest cost, spending on marketing
is therefore seen as a luxury despite the impact this can have
on recycling performance. Lambeth Community Recycling, part of
the ECT Group has undertaken work with Waste Watch to test and
measure the impact of marketing. The result demonstrate the success
of this programme at a local level.
We have achieved year on year growth in tonnage
collected in every local authority within which we work, however,
the actual results in each are a function of the marketing input
of the local authority and amount of marketing specified in the
However, local marketing must be augmented by
national campaigns that use television. Whilst we have seen some
improvement we need much more. Increasingly large parts of the
country will have access to kerbside schemes and the performance
of those schemes will be improved by national awareness raising.