WRITTEN EVIDENCE SUBMITTED BY LONDON COUNCILS

WASTE MANAGEMENT IN ENGLAND

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London Councils is committed to fighting for resources for London and getting the best possible deal for London’s 33 councils. Part think-tank, part lobbying organisation, and part service provider, London Councils formulates policies, organises campaigns and runs a range of services all designed to make life better for Londoners.

Our response to EFRA’s inquiry on waste management in England has been developed following consultation with London boroughs. It includes ten recommendations to government on how to better support local authorities in delivering high quality and efficient waste services for residents.

London’s local elections will be taking place on 22 May. Should you be interested in inviting London Councils to give oral evidence, please contact London Councils after the elections to discuss further.

Cllr Catherine West

Chair of London Councils’ Transport and Environment Committee

House of Commons Select Committee Environment, Food and Rural Affairs (EFRA) Inquiry on Waste Management in England – Call for Evidence

London Councils submission

Introduction

1. Over the past decade, England has significantly improved the way waste is managed and disposed. Services and arrangements set by local authorities have led to an increase in recycling and a reduction in the amount of waste sent to landfill. These improvements were primarily driven by EU policy, transposed into national legislation, and specific measures such as the introduction of the landfill tax. However, England still lags behind other European countries which have gone beyond EU targets, especially in relation to municipal waste management.

2. Also over the past decade, London has seen unprecedented levels of population growth. With a forecast to reach 10 million people by 2031, London’s demographic pressures are increasing the demand for housing and consequently for the collection, treatment and disposal of household waste.

3. Local authorities are responsible for managing household waste as well as part of the commercial waste generated in England. Until recently, the government has been supporting local authorities in improving waste management, through policy, funding and specific support programmes such as WRAP (Waste and Resource Action Plan) and in London through the London Waste and Recycling Board (LWARB). As of April 2014, Defra is ‘stepping back’ in areas of waste management, significantly reducing the funding available.

4. The on-going pressures on local authorities’ finances diminish their capacity to respond. In London, the annual bill for waste management is £720m, making it the third largest area of local authority expenditure after social care and education[1]. In order to keep these costs down, councils need to reduce the amount of waste sent to landfill and incineration (the two most expensive options) and invest in waste prevention, re-use and recycling. However, improving waste services is challenging in the current climate where councils are having to focus on finding efficiencies that enable them to secure front-line services. Whilst understanding that Defra also has to operate with a constrained budget, the current lack of an ambitious and coherent national policy on waste hinders the capacity of local authorities to further improve waste services.

5. Further, local authorities are often at the receiving end of conflicting messages and policies coming from different government departments. In this context, London is setting its own agenda, both in terms of managing waste better and planning ahead for the challenges population and economic growth pose for the future.  London Councils set out its key challenges for waste management in a report to its Executive in November 2013[2]. These focus on improving collection services, providing the right mix of treatment facilities to service the Capital, increasing recycling rates, reducing food waste and promoting re-use.

6. London boroughs would like to see a series of changes in the direction of national waste policy that enable them to deliver high quality and efficient waste services. These are listed below:

Recommendations

1. First and foremost, national waste policy should be more coherent and ambitious, recognising local decision-making and enforcement.
2. Greater priority needs to be given to waste prevention and re-use, which are more cost effective and higher up the waste hierarchy but do not always receive the same attention as recycling.
3. Regarding recycling, the government needs to recognise the difficulties in achieving the current recycling target and devote the necessary funds and support to local authorities to improve infrastructure for both collection and re-processing.
4. Measures aimed at improving recycling rates should focus on addressing current barriers to recycling (contamination, flats, public perception), especially in densely populated areas.
5. The government should support SMEs and the third sector to make their products easier to re-use or recycle.
6. To minimise investment needs on waste infrastructure and increase utilisation rates, London and other English regions should follow a more regional approach on waste infrastructure investment, which is coherent with national policy. A coordinated approach would avoid creating overcapacity in some technologies.
7. Regional strategies for waste infrastructure investment could follow the London Waste and Recycling Board (LWARB) model. Defra should consider it as a vehicle to deliver waste management infrastructure and tailored local authority support. Such an approach would decrease local authorities’ reliance on central funds.
8. The government should consider devolving the landfill tax to London in a similar way to the new Scottish landfill tax and the proposed Welsh landfill tax. The tax revenue could then be reinvested in waste treatment infrastructure and better recycling services in the Capital.
9. The government should further support separate organic waste collection services to increase recycling, with material treated through anaerobic digestion and in-vessel composting.
10. Before introducing a ban on landfill and/or incineration, the government should consider to what extent it would be practicable and enforceable.

7. These recommendations are detailed further in our response to the specific inquiry questions below.

Questions

The ability of existing recycling policy measures to ensure that England reaches the EU target of recycling 50% of household waste by 2020;

8. According to the latest figures published by Defra on local authority collected waste[3], recycling rates are flattening both nationally and in London.

9. In 2000/01, London used to recycle 9% of its household waste compared with the England rate of 11.2%. In 2012/13, these percentages had gone up to 34% for London and 43.2% nationally. Whilst this is a major improvement, figures from the last three years only show minor increases in recycling rates:

Figure 1. Recycling rates for London and England 2000/01 – 20012/13[4].

10. These figures suggest that improving recycling rates is getting harder year after year and that a hypothetical glass ceiling may have been reached. To continue to improve recycling rates and reach the 50% EU target, local authorities need to overcome challenging barriers such as recycling contamination, low recycling rates in flats and the general public ‘scepticism’ on the value of recycling.

11. As Defra ‘steps-back’ from waste policy, existing recycling policy measures at local level will not have the support needed to address these more challenging barriers. National policies currently being steered by other Departments may also have the potential to inhibit or reduce recycling rates:

• In 2012, the Department for Communities and Local Government (DCLG) set up a £250 million to support weekly collections of residual waste. This policy is not specifically aimed at improving recycling rates and undermines the capacity of local authorities to implement recycling policies that are most appropriate for their local circumstances.  In seven London boroughs[5] fortnightly refuse waste collections combined with the introduction of separated food collections have helped to reduce the amount of waste generated and improved recycling rates. Government should leave local authorities to make decisions about waste collection services to ensure they best serve local needs.  

• Clause 29 of the Deregulation Bill currently being debated in the House of Commons will limit local authorities’ enforcement powers in relation to recycling. At the moment, London boroughs and other local authorities in England have the option to issue fines to those residents who persistently do not facilitate waste collection or refuse to recycle correctly. If passed, Clause 29 will limit councils’ enforcement powers to issuing fines only when there is evidence of harm to local amenity (e.g. reducing the quality of their neighbours’ surroundings), reducing their capacity to incentivise residents of the benefits of recycling.

• The requirements of the Waste Regulations (England and Wales) 2011 (amended 2012) may have a negative impact on tonnages of household recycling in relation to what is technically, environmentally and economically practicable (TEEP).  TEEP will impose an additional burden on local authorities who will have to demonstrate that their waste management policies meet this requirement. What constitutes TEEP may change depending on factors such as processing costs, material prices, etc.

• The limitation of including organic material which has not achieved Publicly Available Specification (PAS) 100 for composted materials and 110 for quality digestate (biofertiliser) as part of a local authority’s recycled/composed material may reduce recycling tonnages and therefore reduce recycling rates reported by local authorities.

12. Finally, metals recovered for recycling from incinerated residual waste can legitimately be counted for the purpose of monitoring progress towards achievement of recycling targets; however the figures published by Defra exclude it.  In 2012, Defra announced that these metals would be counted, but to date Defra reporting channels continue to exclude them.

Whether England’s national recycling targets should be higher than those stipulated by the EU; and the pros and cons of compulsory household waste recycling;

13. The difficulties involved in achieving the current target do not seem to be recognised by government. As stated above, incrementally improving recycling rates is getting more difficult. In addition, densely populated areas such as many London boroughs face specific challenges compared to other suburban or rural areas.

14. London has the lowest household recycling rate amongst English regions (34% compared to the 43.2% national average[6]). Causality can be attributed to London’s urban geography where, the housing stock, with a high percentage of high rise properties and flats, adds complexity to recycling. London also produces less green waste which contributes significantly to the higher recycling rates in other English regions. However, it is important to acknowledge that overall London produces 11.2% less household waste compared to England’s average and over 15% less than the Eastern region which is the highest performing region for recycling[7].

15. Devolved administrations in Scotland and Wales have higher targets, but also appear to have more ambitious strategies sustained by the funds necessary to improve infrastructure for both collection and re-processing. In contrast  the government is limiting its own activities on waste in England and funding cuts to local authorities and support agencies (e.g. Environment Agency, WRAP, LWARB) will impact on local authorities' ability to optimise performance in waste management. 

16. LWARB, in particular, has been supporting recycling projects in London boroughs through different initiatives such as Recycle for London, the Flats Recycling programme and the Driving Up Performance fund. LWARB’s grant from government is finishing in 2015, however, the returns from their investments in commercial waste infrastructure will enable LWARB to continue to offer a comprehensive London local authority support programme for 2015 – 2020.

17. Introducing a higher recycling target without coherent national policy and appropriate funding at national or regional level would set local authorities up to fail. There is also need for a more balanced focus between prevention, re-use and recycling. Government should place greater emphasis on waste minimisation as reducing waste in the first place is the best environmental and cost-effective option, rather than recycling.

The role of businesses and households in municipal waste recycling and recovery;

18. Recycling at home affects every resident. Hence the establishment of locally-designed, efficient and fit-for-purpose recycling services for households can potentially provide a template for what can be achieved when householders are out of their homes – at work, school or travelling.

19. Businesses play a key role in facilitating waste recycling and recovery, particularly activities around sustainable product design, reduction in packaging and the provision of consumer information. Large businesses seem to be taking the lead in promoting waste reduction and recycling however small to medium enterprises (SMEs) and the third sector may face difficulties due to budget/cash flow constraints, lack of expertise or ability to access funding. The reduction in government funding for WRAP has particularly impacted on support for SMEs. Government should develop a support package for SMEs and the third sector to make their products  easier to re-use or recycle and could introduce tax breaks for SMEs and the third sector working on waste prevention, reuse and recycling.

Whether England has the right balance of waste treatment technologies between anaerobic digestion, incineration with energy recovery and gasification to produce fuel/heat/power;

20. There is a need to make the correct strategic decisions at both national and sub-national level to provide the right mix of treatment infrastructure and therefore avoid future overcapacity. It should be noted that currently there is a gap on material reprocessing capacity in London and in England, which in turn hinders progress towards improving recycling.

21. London currently exports 54% of the waste generated[8] to other regions of the UK and other countries.

Table 2 Estimated Geographical Destinations of Waste Generated in London – 20012/13[9].

22. The majority of waste exported by London goes to the home counties in East of England and the South East. The waste being treated or disposed further away decreases in value due to the costs associated with transportation. However, sometimes these costs of bulk transport by rail or water can offset higher land costs and planning processes in London treatment facilities. 

23. London also imports a considerable amount of waste from other regions in the UK, mainly to transfer stations and recycling facilities. The following table summarises estimates of London’s waste exports and imports by facility type:

Table 3. Estimated Waste Exports and Imports Inferred using the Waste Data Interrogator (2012)[10].

24. A regional approach to waste facilities such as the one suggested in the Mayor’s Municipal and Business Waste Strategies[11] and delivered by LWARB’s Investment Committee[12] has the potential to provide a higher degree of coordination on waste infrastructure and achieve an optimal mix of treatment and reprocessing sites.

25. Since it was established, LWARB has committed just over £48.5m to various waste infrastructure projects to improve waste management in the Capital[13]. These projects include PlasRecycle, the UK’s first recycling facility for plastic films, an anaerobic digestion and in-vessel composting plant, re-use infrastructure and material recovery facilities. London’s local authorities have also been instrumental in driving the additional alternative treatment capacity that is needed.

26. The LWARB model which enables it to re-invest the income generated by its investments into new infrastructure and recycling initiatives could be replicated in other regions in England. Such an approach would decrease local authorities’ reliance on central funds. This could be easily facilitated where appropriate existing governance arrangements already exist such as Joint Waste Disposal Authorities (JWDAs), combined authorities, city regions and other local partnerships.

27. Localism-based approaches to dealing with waste generate benefits (jobs, income, and energy recovery) to the local community which can lead to a sense of ownership and result in greater recycling. However, investment in waste infrastructure is significantly dependant on guaranteed input tonnages, and this will be difficult to achieve without a coherent national or regional strategy.

28. In order to support London’s continued economic and population growth, the London Finance Commission[14] has made the case for more financial and fiscal control for London. One of its recommendations suggests the possibility of devolving the landfill tax to London in a similar way to the new Scottish landfill tax[15]. The tax revenue could then be re-invested in waste treatment infrastructure as well as waste minimisation and recycling initiatives. From April 2018, the Welsh government will also control landfill tax. London currently generates £63m pa in Landfill Tax[16]. The devolution of this tax to London would be a huge boost for the much needed investment for waste infrastructure in the Capital.

The extent to which increasing the capacity of thermal treatment plants could impact England’s municipal waste recycling rates;

29. Without an overview of the number and location of the various processing options (in operation, in construction and in planning process) and a coordinated approach at regional and national level, there is a risk of creating over-capacity in some technologies, which in turn threaten the viability of others. However, as most thermal treatment plants are anchored by local authority municipal contracts any over-capacity could provide opportunity to treat C&I waste of a similar composition that currently goes to landfill.

Whether anaerobic digestion (AD) is the best option available to deal with food and other biowaste;

30. AD should be part of a mix of treatment infrastructure to deal with food and other biowaste, which also includes in-vessel composting and initiatives to support home composting. However, as mentioned above, it is important to follow a localism-based approach and adapt treatment infrastructure to local needs and established collection systems.

31. Separate organic collections are necessary for the use of AD and in-vessel composting technology, however, some local authorities are facing difficulties in introducing or expanding separate organic waste collections due to budget constraints. In some cases, the take-up of food waste recycling services is very low amongst residents. This is partly due to public perception of food waste (smells, flies and vermin). The government should focus on supporting separate organic waste collections to increase recycling and develop national policies aimed at reducing food waste in households and businesses.

Whether the Government’s Anaerobic Digestion Strategy and Action Plan has substantially increased the use of AD

32. Increasing the number of AD plants is possible when there is guaranteed feedstock derived from the introduction of local authorities’ food waste collection services. As stated above, government’s support for food/organic waste collection services would be of benefit and could complement the measures introduced by the AD Strategy and Action Plan.

The feasibility of the introduction of a ban on landfill and/or incineration in England

33. Any potential ban on landfill and/or incineration would have to specify what waste streams would be affected and ensure that alternative waste treatment capacity is in place. Any such bans would also need to be carefully considered to ensure that they are practical and enforceable including an impact assessment on local authority waste services.

34. A ban on landfill and/or incineration, in relation to food waste for example, could potentially assist in encouraging households/businesses to separate their waste streams. However, a total ban on landfill in England would be impracticable as there is waste produced[17] for which landfill is actually the most suitable option.

35. Without enforcement powers, it would be nearly impossible for local authorities to comply with such legislation. Councils have the statutory duty to collect household waste, but as a result of the Deregulation Bill, soon will have no power to specify what goes in each bin/container.

36. The Government’s announcement in the Budget 2014 on future landfill tax escalation has proved helpful in the short term. This is an established and accepted methodology for controlling the quantity of waste landfilled avoiding the need for complicated new legislation that would be associated with banning specific materials. However, the extent to which Landfill Tax is being used to invest in waste infrastructure needs to be reviewed.