Written evidence submitted by FCC Environment
[WME 0056]
Waste management in England
1.1 FCC Environment is one of the UK’s leading waste and resource management companies and as a result is uniquely positioned to respond to the Efra Committee call for evidence on waste management in England.
1.2 FCC Environment considers that waste management policy to date has been valuable and achieved its aim. Further legislation or targets, including a ban on incineration or landfill, would add to the red-tape burden in an already fragile economy and as such, is not recommended. The Government needs to focus instead on promoting the economic benefits of recycling and the circular economy.
1.3 FCC Environment is confident that England can reach the EU target of recycling 50% of household waste, provided there is sufficient stability in the materials market to provide the sector with the confidence to invest in the additional recycling facilities required. It is recommended that stability of the materials market is achieved through Government intervention.
1.4 Additionally, achieving the 50% recycling rate will require the Government to continue to fund local authorities for the collection ‘at source’ of recyclable materials.
1.5 There is a need for policy-makers to work together across the planning, waste management and energy sectors to ensure continued progress in achieving recycling rates.
1.6 FCC Environment recommends best practice guidance to encourage a more consistent approach to waste collections across local authorities. A more consistent approach is also required from Environment Agency enforcement.
1.7 FCC Environment has concerns over subsidies that favour one waste management technology over another and takes the view that all forms of energy from waste (EfW) technology should be subject to the same subsidies.
FCC Environment:
2.1 Is one of the UK’s leading waste and resource management companies helping thousands of businesses and communities waste less and recycle more and as a result is uniquely positioned to respond to the Committee’s call for evidence.
2.2 Is part of the FCC group, one of the world’s largest environmental services companies. This multi-national expertise and experience, working in markets with different legislation and policies further adds to its ability to provide a response.
2.3 Operates from more than 200 locations across the UK including landfills, EfW plants, household waste recycling centres, materials recycling facilities, and compost plants, all operated to ISO 14001 environment standards.
2.4 Provides waste processing services for residual and contaminated waste. Its infrastructure includes industrial waste treatment plants, asbestos disposal sites and a dedicated hazardous waste landfill site.
2.5 Offers municipal and business waste solutions including local collections and skip hire.
2.6 Believes every waste collection is an opportunity to reclaim valuable resources and improve the environment we all share. The company employs the latest recycling and green energy technology to ensure we recover as much resource as possible, minimise the use of landfill and drive the circular economy.
3.1 FCC Environment welcomes the opportunity to offer its perspective to the Efra Select Committee inquiry on waste management in England.
3.2 As a result of its extensive experience in waste management in England the company is acutely aware of the opportunities and challenges the sector faces in helping to achieve recycling targets and is able to offer unique insight into the possible impact of Defra ‘stepping back’ in areas of waste management.
3.3 FCC Environment is at the ‘coal-face’ of waste management in England and as such, is witness to the economic drivers of waste management, the impact of an unstable recycled materials market, the contribution of EfW to the energy mix, and the impact of policy.
3.4 For this reason, FCC Environment feels it is able to provide the Committee with evidence and comment that can help inform Defra’s future work and Government policy to ensure a robust and efficient waste management industry that contributes to a reduction in waste and the circular economy.
4.1 FCC Environment is confident that England can reach the EU target of recycling 50% of household waste by 2020, with many local authorities already ahead of, or close to that now, provided there is sufficient stability in the recycled and recovered materials market to provide the sector with confidence to invest in the additional recycling facilities required.
4.2 Local government responded well in the first instance to the financial penalties put in place to encourage recycling and diversion of waste from landfill, however it is FCC Environment’s view that clear economic drivers for recycling now far outweigh the need to penalise.
4.3 Local authorities can realise financial efficiencies through effective waste management and participation in the materials market as a supplier of recovered and recycled materials. However, continued Government funding to maintain a high level of kerbside sort collection regime to feed such markets is deemed essential.
4.4 However, the economic drivers for recycling only remain whilst there is a market for recycled and recovered materials which local authorities can utilise. The materials market is notoriously unstable and FCC Environment has seen the impact of this instability on the confidence of the waste management sector to invest in new recycling facilities.
4.5 Materials market rates are a key factor in the determination of costs for proposed new facilities. Due to the instability of the market these costs can drop dramatically and make proposals economically unviable, often despite heavy investment already having been made in the project. Local authorities require the waste management industry to take this risk, making it one of a few industries expected to take commodity risks.
4.6 FCC Environment considers that this risk would be better shared between the producer (i.e. local authority) and the waste management service provider through an accepted Government position. This could be a simple indexation system similar to the RPI mechanism.
4.7 There is an assumption that the private sector is profiteering, however there is no business advantage to alienating its current and potential clients. It is FCC Environment’s view that local authorities would get better value from their waste services contracts if the risk were shared, because the waste management industry would not need to be as cautious with its pricing.
4.8 There will always be some residual waste which cannot be recycled. The treatment of this residual waste is largely dependent on what facilities are available in the locality e.g. landfill, EfW.
4.9 The EfW process produces by-products including Bottom Ash and Fly Ashes. Landfill diversion measures ensure that the best possible thought is given to the use of these by-products.
4.10 Bottom Ash is removed, and processed into a secondary aggregate and used in road sub base, a bulk filler for construction and other materials. Large objects such as stones, bricks and metals are recovered to be recycled or reused where possible.
4.11 At present recycled Bottom Ash and other recovered materials from EfW are not counted towards England’s recycling targets, whereas they are in Scotland and Wales. FCC Environment is of the view these figures could be included in England’s, although care should be taken to avoid the danger of double-counting of recycled and recovered tonnes.
4.12 It is FCC Environment’s view that the Government should consider more incentives through recycling policy to encourage better recovery of materials.
4.13 FCC Environment considers it important to recognise the contribution of EfW to the country’s energy mix and in helping to reduce reliance on oil and gas imports, as well as the role it could play in helping to reduce increases to household energy bills.
4.14 Given the need for the country to be producing less waste, FCC Environment would like to see further action from Government to encourage product and packaging designers to design and build goods that are easier to recycle and reuse.
4.15 A particular concern for FCC Environment is the limited availability of facilities in the UK for waste fuel. At present, a significant amount of waste fuel is transported to the EU for processing.
4.16 FCC Environment is concerned that if changes are made to trans-frontier shipment of waste policies, England will be left with waste fuel to dispose of without the appropriate facilities to do so.
4.17 The Government needs to be alive to the potential of such policy changes and any implication on waste fuel disposal in England. In light of this FCC Environment considers further efforts should be taken to see an increase in the number of waste fuel facilities in England.
4.18 In order for continued progress towards recycling targets the right waste management infrastructure needs to be in place. The current planning system does not always make this easy.
4.19 FCC Environment is keen to see continued investment in local planning authority resources. Without sufficient resources in place, there is a danger new waste management facilities will be delayed in the planning system, with an inevitable impact on recycling and landfill diversion targets.
4.20 FCC Environment recommends that the Government considers applying General Development Rights to the waste management industry in a similar way to the quarrying industry. This would make small, low-impact developments such as a site office at a landfill easier to manage, both for local planning authorities and the waste management industry and free up staff to concentrate on the larger, more complex applications.
4.21 Waste management facility proposals are subject to planning application fees. FCC Environment has experienced first-hand the impact and added cost of local authorities not determining planning applications within the statutory timeframe. FCC Environment would like the Government to consider rebates to companies from local authorities where determination has not been made after six months.
4.22 An additional blocker to new waste treatment facilities is community opposition. Waste treatment facilities generally need to be located in areas of large load i.e. large numbers of waste producing businesses or households to ensure logistical costs are economical and use of outputs maximised. This does mean that facilities are almost always in someone’s ‘backyard’. The Government and industry needs to work together to ensure the planning system, whilst open to the views of local people, is not strangled by the very vocal views of a few.
4.23 FCC Environment recommends that the Government provides expertise to local authorities on best practice waste collection.
4.24 At present, local authorities determine their own methods of municipal waste collection, leading to inevitable inconsistencies across the country.
4.25 FCC Environment considers it important to provide a simple system that the average person can understand to ensure take up at a household level.
4.26 FCC Environment would like to see the Government produce a best practice guide for local authorities to maximise efficiencies in the waste collection system and for those that operate them.
5.1 FCC Environment does not believe that varying England’s national recycling targets from those stipulated by the EU makes economic sense. Environmental reasons for the recycling targets have now been met and as such it is the turn of economic drivers and the circular economy, rather than enforced targets, to take over.
5.2 As England is now operating at over 43% recycling rates, the remaining waste is more difficult to recycle due to contamination and quality issues and there is not necessarily the market for the recycled materials. Above 50% this would become even more of a challenge.
6.1 In most areas compulsory household recycling already exists. However, any further legislation would require additional administration and policing, putting added pressure on local authorities at a time when many are coming to terms with difficult budget measures.
6.2 Many households share bin facilities and in such situations compulsory recycling is not always practical and can lead to contamination of the end product e.g. plastic in food waste.
6.3 If the materials market becomes more stable, there is an opportunity for fiscal rebates to be given to local authorities or householders from the waste management industry for clean, well sorted waste; passing some economic benefit back to the community. However, the practicalities of this are likely to be difficult to define and administer as the contract for waste management services sits between the service provider and the local authority, rather than with individual households.
7.1 There is a community and social responsibility on businesses and households to recycle, a notion that is becoming better embedded in the psyche of the nation compared to 10 or 20 years ago.
7.2 FCC Environment considers the Government has a continued role to play in keeping that responsibility in people’s minds through education and campaigning.
7.3 Businesses have a responsibility to not pass on their problems to the consumer, but the Government needs to be careful of placing any extra burden on businesses; as a whole it is doing well with the regulation already in place.
7.4 It is FCC Environment’s view that there is a continued role for the Government in assisting small and medium sized businesses with recycling by providing information on the financial benefits.
8.1 FCC Environment believes that England broadly has the right balance of waste treatment technologies between anaerobic digestion, incineration with energy recovery and gasification to produce fuel, heat or power. However, the balance varies regionally.
8.2 FCC Environment has concerns over subsidies that favour one technology over another as it can lead to losing sight of what needs to be achieved. Are subsidies there to propose a waste management solution or the technology? If the primary driver is to reduce reliance on fossil fuels, it is FCC Environment’s view that all forms of energy from waste should be subject to the same subsidies as currently in place for gasification.
9.1 It could be argued that the more waste processed by thermal treatment plants the less recycled. However, FCC Environment believes that when operating at a 50% recycling rate, the remaining waste would be residual and uneconomic to recycle. Therefore, increasing the capacity of thermal treatment plants would have no impact on recycling rates above 50%.
9.2 It is FCC Environment’s view that after the 50% recycling rate targets is achieved it is more economical to process residual waste through energy recovery facilities, thereby maximising its energy potential and contributing to energy supplies.
10.1 Separate sorting and collection of food waste at a household level can be expensive, however FCC Environment considers anaerobic digestion an appropriate part of the waste management mix, where there are economic drivers to a facilities inclusion in a locality.
10.2 The Government’s Anaerobic Digestion Strategy and Action Plan has increased the use of anaerobic digestion predominantly due to the financial incentives offered. This inevitably creates an artificial market that may not be sustainable once the incentives are withdrawn, particularly due to the availability of feedstock.
10.3 FCC Environment feels that the driver for anaerobic digestion has been one of public perception. There has been significant public opposition to new EfW schemes, whereas anaerobic digestion is seen as the greener option.
10.4 FCC Environment feels that the market should be left to determine how waste is treated in a locality. If an EfW facility already exists, there is little economic sense in introducing an additional anaerobic digestion facility especially if the main driver is waste as fuel to produce non-fossil fuel energy.
11.1 FCC Environment supports some limits on waste to landfill through the waste hierarchy but does not believe that the introduction of an outright ban on either landfill or incineration is feasible.
11.2 Even with an effective recycling system there will always be some residual waste that needs to be processed at an EfW facility or in landfill.
11.3 Incineration with energy recovery should be encouraged as it maximises the energy potential of the residual waste. However, not all waste is suitable for incineration which means limited use of landfill for waste such as poor quality material.
Clarification of terminology
12.1 FCC Environment considers there is a role for both Government and the industry to clarify the terminology used relating to incineration and Energy from Waste. It is often unclear what is meant by the term ‘incinerator’ - does it include all thermal treatment including those with energy recovery, or only those without energy recovery? This can lead to difficulties with communication and understanding amongst the public.
Consistent approach to enforcement
12.2 FCC Environment has experienced inconsistent interpretation of policy and enforcement by the Environment Agency. FCC Environment would welcome a more consistent approach, both between Environment Agency regions and as applied to different waste management companies. Often large companies such as FCC Environment are an easier target for enforcement than the smaller waste management companies and illegal operators.