Written Evidence submitted by the Suffolk Waste Partnership
[WME 0039]
Who we are:
The Suffolk Waste Partnership (SWP) is a local authority partnership of the Waste Collection Authorities and the Waste Disposal Authority in Suffolk. This includes Babergh District Council, Forest Heath District Council, Ipswich Borough Council, Mid Suffolk District St Edmundsbury Borough Council, Suffolk Coastal District Council, Waveney District Council and Suffolk County Council.
As a partnership we work collaborately to develop and implement plans and actions for the strategic management of municipal wastes, including:
Reason for our response:
The SWP considers the following important as part of our approach to delivering services locally:
1.1. DEFRA or the lead national policy authority for waste and recycling should have a clear framework to meet the EU recycling target, encompassing a range of measures similar to those DEFRA has already evaluated as part of the approach to the Waste Prevention Programme 2013. Moreover this should also encompass how the waste hierarchy will be delivered and identify where the market has failed to resolve particular issues e.g. where there is limited access to convenient and affordable waste reprocessing infrastructure.
1.2. Clarity is required in terms of the key policy drivers for waste management in light of the close relationship with carbon management and future fuel strategy and soil strategy, particularly in the adoption of Energy from Waste (EfW) and other energy producing technologies such as Anaerobic Digestion (AD).
1.3. The investment attractiveness of a particular waste management solution is not geographically homogenous and it is important that DEFRA and DECC is clear and coordinated in the approach how the market operates to deliver this, particularly where incentive programmes exist.
1.4. DEFRA audited data for 2012/13 indicated that the national household waste recycling rate reached 43.2% in England with wide variation in local authorities performance with only 73 out of 352 local authorities in England achieving a 50% or more recycling rate, based on amounts sent for recycling. Whilst this has increased from 11% in 2000/2001 with rapid increases in recent years due to local authorities introducing and expanding their recycling collection schemes, the rate achieved has plateaued in recent years. This slowing of performance would suggest that the existing policy measures may be insufficient in their own right.
1.5. Coupled with this is any potential impact resulting from the increasing focus on improving the quality of material recycled, which may effect a reduction in material recycling in the short term. Moreover, any changes in waste definitions have an impact and the requirement for "separate collection” and TEEP will need monitoring to assess any impact of waste recycling rate. Equally the change of including compost which hasn’t achieved PAS 100/110 will reduce the tonnages which can be included in reported recycling tonnages. Nationally, minor changes can have an influencing impact on the percentage of waste recycled and it is important to review waste data to provide an insight into progress and projected recycling levels.
1.6. The current economic environment is focusing councils on options to reduce the costs of delivering services. Affordability is key criteria in the adoption, expansion and maintaining of household waste recycling services. Improving the performance of currently well performing waste recycling services may not be considered important when compared with other local priorities. Under such circumstances, further recycling may be inhibited. This is also coupled with the degree to which recycling can be financially incentivised locally.
1.7. Councils who previously introduced free collection services for garden waste, in order to boost their combined recycling and composting performance, are reviewing this approach as the availability of public funding for waste services reduces, which may improve service affordability and enable further investment but may also reduce overall tonnages diverted.
1.8. As part of DEFRA strategy they need to consider the impact of other measures on recycling performance such as producer responsibility, packaging reduction measures etc. Whilst this is positive, it will influence the ability of exceeding the target.
1.9. Various government departments should also seek to promote a uniform waste policy(s) which supports the localism agenda and local authorities’ ability to choose the method of collection and disposal which best supports the needs of their communities. For example, DCLGs push to encourage weekly bin collections could have a negative impact on public perception of the need to recycle, and if DCLGs policy were further pushed onto councils such as Suffolk it would negatively impact on recycling rates as more residual waste would be collected.
2.1. The focus of future policy should be on an integrated approach to waste management utilising a range of treatment options, rather than being driven by an arbitrary target. In reality, if waste minimisation and reuse are considered more important in the waste hierarchy, it could be argued that the target needs to focus more on this for specific waste streams. Moreover, the use of the most appropriate metrics is essential to ensure that the overall best environmental option is targeted.
2.2. Targets may be useful to incentivise further recycling but this is subject to having an affordable, realistic and deliverable strategy to meet them. Moreover, the type of target needs further thought so as it supports wider policy objectives and the waste hierarchy. The Suffolk Waste Partnership sees no benefit in setting targets higher than those in the EU unless it is the output of planned actions i.e. DEFRA have a delivery strategy and this will achieve a certain recycling level. However in the current economic environment, it is difficult to see how this would be achievable.
2.3. DEFRA need to recognise the difficulties involved in achieving the current target. The devolved administrations have higher targets, but also have coherent strategies and appear to be willing to fund necessary improvements to infrastructure for both collection and processing facilities.
2.4. Compulsory recycling will be difficult to monitor and enforce and following the recent review of local authority enforcement powers, appears contrary to the current policy approach that favours incentivising behaviours. Furthermore, it is not easily or immediately evident in collections system operations if the resident has made every effort to recycle. Furthermore, if recycling has not been undertaken, what form of “punishment” would be applied?
2.5. In addition, our experience demonstrates that the majority of householders are generally well engaged with recycling where it is clear what materials can be recycled and the services are convenient and easy to use. In some cases householders feel limited by what can be recycled, are confused by the difference between local scheme acceptable materials versus product packaging claims of recyclability, composite materials and unhelpful and exaggerated media claims that can undermine recycling schemes.
2.6. Obviously whilst compulsory recycling would support an increase in recycling rates, the practical delivery and enforcement of it would be difficult in addition to the perception of recycling as an imposition rather than a consciously accepted activity.
3.1. Households have always played a key role as their collective behaviours influence two key factors; (1) the quantity and (2) the type of waste generated, albeit their purchasing decisions are influenced by the products available to them and their relative purchase costs.
3.2. Behaviours are important to influence these positively and effectively and are a significant factor to deliver the waste hierarchy and rely upon ongoing investment in consumer education and awareness alongside access to appropriate facilities and collection regimes.
3.3. The recent focus on the circular economy illustrates the connection of consumers to their waste and their ability to:
3.4. In Suffolk, households are in the main very supportive of waste recycling and have:
3.5. The approach for businesses is similar to households, albeit the cost of waste management tends to be the significant driver to influence the choice of waste management option.
4.1. It is important that access to the right type of facility is available locally to support the proximity principle and reduce waste haulage distances.
4.2. In order to assess the right balance of treatment technologies it would be useful if DEFRA could produce carbon data (emission factors) for each of the treatment options for each waste material type to enable us to compare the relative impact of treatment options.
5.1. This is dependent upon the approach adopted for the operation of the plant and whether the plant is part of an integrated system to deliver a waste management strategy based upon the waste hierarchy that initially favours and focuses on waste reduction, reuse and recycling. In Suffolk, the new EfW facility will compliment other waste treatment approaches and support the waste hierarchy, in particular reduce reliance on landfilling.
5.2. In terms of the focus of reducing landfill reliance combined with the rising cost of fuel, there has been a focus on the development of thermal treatment plants. Local Authority managed waste going for incineration with energy recovery rose 13% to 5.5 million tonnes in 2012/13 and has more than doubled in the last ten years. It is important that this increase does not have the detrimental effect of creating over-capacity or compete with recycling in the long term.
5.3. Landfill tax continues to be the main driver for local authorities to reduce waste to landfill, with thermal treatment also supporting the energy recovery option. It is important that decision makers have the information available to determine the most appropriate option to manage waste based on the circular economy. Recycling should never be pursued for the sake of recycling or the achievement of arbitrary recycling targets and must be part of a wider costed appraisal of options.
6.1. Anaerobic digestion is a well-proven renewable energy and waste management technology. It can reduce greenhouse gas emissions by capturing methane from the decomposition of a wide variety of organic material including manure, slurry, sewage sludge and food wastes. A biogas is produced which can be used to generate heat and power and the digestate can be used as a fertiliser and soil conditioner.
6.2. The best approach to be used for waste management should be devised locally. Delivering sustainable food waste collection systems must be affordable and must be part of a local strategy to guarantee a constant supply of feedstock for facilities. In terms of stimulating food waste, DEFRA needs to review its strategy to determine the extent to which this has influenced AD or whether market forces are at work, particularly linked to energy policy and incentives. Whilst the number of AD facilities is increasing, I assume the drivers for this are numerous and variable.
6.3. The relative economic growth opportunities of different recovery options such as methane capture, incineration, anaerobic digestion etc. is complex but important to inform local decision making.
6.4. Establishing food waste diversion schemes is dependent upon many factors but ultimately it must be cost effective and utilise technology that is proven and free from significant risk.
7.1. Whilst such bans would be almost impossible to fully comply with, they would provide a useful tool to assist in encouraging householders/businesses to separate their waste streams. However, without enforcement powers, it would be impossible for LAs to comply with such legislation, since we have a duty to collect household waste.
7.2. In terms of greenhouse gas (GHG) savings and resource efficiency there is a case for banning and/or restricting certain waste from landfill. However, the introduction and phasing of any ban should not disadvantage public sector finance, collection affordability or operational efficiency. Whilst we support the strategic objective, this needs to be part of a wider policy approach. DEFRA research (Household Waste Prevention Evidence Review) suggested that the experience of other countries that had made a significant impact on municipal waste growth had in place a wide range of instruments and initiatives aimed (directly or indirectly) at waste prevention. In terms of policy instruments these generally included a significant number of the following: product eco-taxes; eco-labels; container reuse/deposit-refund schemes; variable- rate waste charging or rebates; high landfill taxes; and disposal bans on certain materials.
7.3. Sustaining communication and enforcement of landfill bans also requires further consideration, both in terms of the responsibility and the affordability. A range of regulatory and policy instruments are already in place to encourage diversion of waste from landfill. These include landfill tax and economic drivers to maximise savings on landfill gate fees. Many local authorities are developing alternative infrastructure to divert waste from landfill. Suffolk has developed a Private Finance Initiative (PFI) funded residual waste treatment plant which is planned to be operational by 2015. This will mean that only a small amount of waste collected by the local authorities in Suffolk (EfW rejects and residues) will be landfilled in 2015 and therefore landfill bans/restrictions would not influence the activities in Suffolk. However an incineration ban, if we are including EfW facilities, will have an impact and it may have a detrimental effect by impacting on the economic foundations on which the facility was originally justified and the ongoing projected revenue streams and operational efficiency, particularly if the ban includes waste with a high calorific value.
7.4. A key consideration for household waste is public acceptability; waste collection authorities are not only required to identify the most appropriate means to effect waste recovery, but this is also dependant on securing and sustaining public support for the collection scheme in order to maximise participation and overall scheme performance. A ban would suggest that both participation and material capture at the kerbside would need to operate at 100% efficiency for the respective banned wastes.
7.5. Waste Collection Authorities are mainly involved in ‘end of pipe’ solutions for the household waste stream and have some but limited influence on behaviours and decisions at the front of the ‘closed loop’ approach. In must therefore be appreciated that the ability to meet the requirements of the bans locally is dependant on a range of factors, many of which are beyond the scope and influence of local authorities.
7.6. Rather than a ban, the focus should be on recycling more and addressing the issues preventing us from recycling more e.g. collection costs, infrastructure, manufacturing processes, influencing consumer and resident behaviour, public acceptability of recycling systems. As local authorities we would always rather recycle than to landfill or incinerate waste, but a ban for the sake of a ban would not be useful without a focus on addressing the recycling system. In particular, a disposal ban would be difficult alongside the recent push for greater material quality. We could see a position nationally where good quality recyclate is cherry picked, leaving the lower quality recycling being pushed back to disposal (in contradiction to a disposal ban). Therefore it is important that the government support a strong system of recycling for all grades of recyclate before a ban could be introduced.