Written evidence submitted by the Chartered Institution of Wastes Management (CIWM)
[WME 0073]
Waste Management in England
1. The Chartered Institution of Wastes Management (CIWM) welcomes the opportunity to provide written evidence to the Environment, Food and Rural Affairs Committee’s inquiry into Waste Management in England.
2. CIWM is the professional body which represents around 6,300 waste management professionals, predominantly in the UK but also overseas. The CIWM sets the professional standards for individuals working in the waste management industry and has various grades of membership determined by education, qualification and experience.
Executive Summary
3. The key messages that CIWM wishes to highlight to this Committee are:
4. This inquiry is strongly focussed on recycling of municipal solid waste (MSW) in England. CIWM members recognise the importance of both MSW and recycling but would rather see this and future inquiries look at the management of resources – involving wastes from all sources including industrial & commercial and construction & demolition wastes as well as MSW; and taking account of all elements of the waste hierarchy from the revised Waste Framework Directive, namely: waste prevention, re-use, recycling, recovery and disposal. CIWM has, however, addressed the inquiries specific questions in detail below.
5. The EU Commission estimates that better waste and resources management in Europe could contribute an additional 3% to GDP. In CIWM’s evidence to the current Environment Audit Committee inquiry into development of a circular economy, the Institution has estimated this would be worth at least £60 billion in this country, possibly more. Effective resource management should be seen as a vital contribution to this country in business, environmental and social terms and increasingly, sustainable waste and resource management is seen as an issue that spans the interests of many, if not most, Government departments. CIWM members would like to see a ground-breaking step in select committee impact through a joint inquiry spanning the remits of several departments given the importance of the issues and the clear lack of a co-ordinated cross-government response to them.
6. Many EU Member States do not differentiate between municipal wastes and those from commerce and industry as we do in this country. Variable definitions and recording standards across Europe make direct comparison between Member States’ performance either, difficult or misleading, exacerbated by poor quality, partial and sporadic collection of commercial & industrial waste data in particular. CIWM published a report in October 2013 exploring the issues surrounding industrial and commercial waste data, forecasting and infrastructure provision [http://www.ciwm.co.uk/web/FILES/Technical/21st_oct_FINAL_CIWM_2013_President's_report.pdf] CIWM concluded that there is likely to be a shortfall in industrial and commercial waste treatment capacity in this country developing between now and 2020, even when only considering the current EU Directive targets (e.g. under the Landfill Directive). The Institution believes this will further drive exports of recyclates and waste derived fuels which in turn will undermine further infrastructure investment.
7. In the face of poor data and forecasting of wastes produced and how they are managed, UK governments need to co-operate in development of the Waste Duty of Care and the data collected through it. CIWM advises that Governments should seriously consider making the use of the electronic (web-based) Duty of Care data system (edoc) mandatory. CIWM also believes that Government need to argue for common and effective data gathering and reporting for this industry across Europe. Without this, policy development and delivery of services and infrastructure outside of MSW (possibly only 10% of all wastes) is seriously hampered.
8. CIWM members warn that the EU Waste Framework Directive recycling target of MSW (50% by 2020) will be difficult to meet in England. A number of factors combine to make this conclusion including: resource constraints on local authorities; poorly co-ordinated and sometimes antagonistic departmental policies and interventions; and a lack of sustained and co-ordinated communications to develop public and business engagement. MSW recycling in England has reached just over 43% but is flat-lining. CIWM is exploring the reasons why with its members but also warns that changes to regulations later this year regarding material recovery facilities and the separated collection of wastes, coupled with tight biowaste recycling standards and other exclusions from the definition of recycling may drive reported English recycling for MSW backwards for the first time since before the turn of the century.
9. If reported recycling performance deteriorates there will be a much greater need for intervention, proper resources for local authorities and a strong and sustained communication campaign if the very significant public support won in this area in recent years is not to be lost.
10. The EU Directives driving waste and resource management, especially diversion from landfill and increased recycling are currently being reviewed. Early indications from the EU Commissioner for the Environment are that recycling targets could be increased to 70% or even 80%. This inquiry and government policy and intervention must look beyond short term targets and must look beyond concentrating only on MSW and recycling.
11. The inquiry asks if England should aim to reach recycling beyond EU targets. CIWM members advise that with current resources, policy and infrastructure/services, the 50% target in 2020 is already hard to hit. However, England should be capable of hitting EU targets – for 2020 and beyond – without excuses. Wales and Scotland (and shortly Northern Ireland) have recycling targets beyond the current 50% and in line with possible new EU targets. However, at a UK level the weaker England performance (assuming continued recycling improvement in both Scotland and N Ireland) will probably bring down the whole UK average. Businesses also tend to recycle more successfully than households but England focuses on MSW as household wastes, excluding industrial and commercial wastes.
12. England should aim to at least meet EU targets – but only with the proper focus and resourcing, and with clearer definitions and reporting by all Member States.
13. Changes in waste and resources services, and infrastructure in particular, have long lead times. If objectives such as extended recycling targets, increasing domestic (i.e. in UK) markets for secondary materials and landfill or other waste management bans are to be set, we need long-term plans allowing the industry to adjust. Short term or poorly planned targets, bans, etc may lead to increased waste and resources exports, more waste crime or poor strategies and solutions.
14. Many areas of government policy need to be co-ordinated to make that happen and CIWM members want to see cross-departmental co-operation regardless of whether wastes and resources are seen as:
15. There is no ‘perfect’ Government department to take this lead but the issues need to be led, championed and co-ordinated across departments and at cabinet level. CIWM does not see this at the current time.
16. Despite the lack of Government leadership in waste and resources management, good progress is being made within the waste industry itself as well as around the circular economy. New technologies and better product design make more materials or energy recoverable from waste, and many local authorities - especially in less urban areas - already have excellent recycling performance.
17. This industry can play a vital role, one which is substantially larger and more important than municipal solid waste (MSW) recycling, in a resource efficient circular economy and Governments have a key role in making that happen.
18. Turning to the specific areas of inquiry for this Committee, CIWM would respond as follows:
The ability of existing recycling policy measures to ensure that England reaches the EU target of recycling 50% of household waste by 2020
19. There are a number of factors that impact the level of recycling in England, as with any other country:
20. Population growth – as the population grows, the more waste is produced. Currently, UK population growth is strong and if no steps are taken to promote the drivers (see below); the proportion of waste recycled will decrease.
21. Demographic churn – To maintain the habit of recycling, engagement with and information and support for the public is required. With a movement of the population in terms of their location and ageing, all education programmes have a finite life and must be repeated, especially in areas with transient populations and to take account of natural ageing and movement.
22. Economic drivers – At the domestic level there are few if any economic drivers to move waste management up the hierarchy. However, the landfill tax has played a major role in diverting waste away from landfill by encouraging local authorities to implement source segregated collections, and build facilities that enable the separated waste to be sorted and recycled (in the case of the recyclate stream) and the residual waste sent for energy recovery. Landfill tax, however, is a blunt tool and whilst it will divert waste away from landfill, it will not necessarily direct it towards recycling.
23. Policy drivers – Policy has played a major role in establishing recycling. Without it the revolution in waste management practice that has taken place in the last 20 years would not have occurred. It has been policy, through the use of the Landfill Allowance Trading Scheme and carbon footprint considerations that have encouraged the implementation of source-separated collection and the MRF infrastructure that now exists. Removal of, or lack of enforcement of policy will facilitate a shift towards the lowest economic cost option, which may well not be recycling.
24. CIWM is concerned the EFRA Committee is not looking at the waste management hierarchy in total, but concentrating on recycling, to the detriment of waste prevention and re-use. As noted in the recent Environment Audit Committee call for evidence, the circular economy is key to England achieving resource efficiency.
25. Over the last three years there has been a perceptible dilution of policy on waste management in England. It is the CIWM’s view that if the recycling target for England is to be achieved in 2020, it is vital for Government to maintain strong policy in this area. Without that, and with continuing constraint on spending by local authorities, considering the factors stated above, it is our view that with a current recycling level of 43.2% and the slowing of the increase in recycling rates, as highlighted in recent statistics, the 2020 target may not be met.
26. CIWM notes that EU derived targets apply to the whole of the UK including Wales, Scotland, and Northern Ireland, but England cannot rely on the devolved administrations to ensure that – on average - the target is reached. In light of present trends Wales is likely to meet the target, Scotland and Northern Ireland need to maintain or improve recycling performance, while England’s recycling appears to have plateau’d and may fall in the near future. Tighter standards for what can and cannot be counted as ‘recycling’ include new reporting requirements for the recycling performance of materials recovery facilities and the exclusion of composts or digestates from non quality controlled sources including street sweeping leaves. Even within the UK different reporting standards exist e.g. the inclusion of incinerator bottom ash in Wales as ‘recycling’ but not in England and the exclusion of composts and digestates that do not meet rigorous quality standards (PAS 100 and PAS 110) in Scotland and Wales. CIWM members consistently call for common standards and reporting to make comparisons between countries possible.
27. Aspects of DCLG policy – such as the drive for weekly waste collections - are making an already hard role for local authorities more difficult. Alternate weekly (fortnightly) collection is a demonstrably effective system for encouraging recycling and raising participation in recycling activity, and it enjoys a high level of public satisfaction and support especially where it is complemented by separate collection arrangements for food and disposable nappy wastes for example. Some local authorities in Wales and Scotland where collection regimes have successfully minimised residual wastes are actively considering 3-weekly or even 4-weekly residual waste collections. CIWM is not aware of any English Waste Collection Authority considering such a step.
28. Other changes in policy have weakened or removed local authority recycling enforcement powers designed to tackle reluctant or disruptive residents. These powers were only used as a tool of last resort but were an important option for authorities to use where all other approaches failed.
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
29. The EU MSW recycling target of 50% by 2020 is currently under review. Further information on the new targets, which could be up to 70% or 80% according to the EU Environment Commissioner, is expected as early as June or July this year. The 50% target is reflected in the current (2007) national Waste Strategy for England. This also includes targets for total recovery from MSW (including energy recovery) of 67% by 2015 and 75% by 2020.
30. CIWM Members already warn that given current resources and Government policy and other support, the 50% 2020 target is increasingly unlikely to be met in England. However, given adequate resources and support, this country should be capable of matching EU targets just as well as any other EU15 State. If the EU targets are increased – and especially if they are increased as suggested then England should aspire to meet those new targets. To aim to exceed those targets would be over-ambitious, but just to meet them will require a step change in services, public engagement and government support.
31. CIWM also advises against over-reliance on waste recycling and MSW recycling targets in particular. First, the whole life cycle costs of high resource consumption in affluent societies cannot be fully off-set by high recycling. The aim should be to reduce overall resource use, not just maximise secondary resource use through recycling. Secondly, as municipal and industrial / commercial recycling targets rise so will competition for waste materials e.g. between major retailer producer responsibilities and local authority recycling targets. And thirdly, weight based % recycling targets often incentivise recycling of relatively low impact high weight materials rather than more environmentally costly materials e.g. favouring green waste composting over plastics recycling.
32. CIWM wants complementary targets for all wastes and preferably measures of overall waste production per head and residual waste production per head. These measures have gradually reduced in recent years in England but it is not clear yet whether this is due to:
33. Adoption of better measures of resource use and efficiency needs to be championed by Government in Europe. CIWM also accepts that some EU Member States will find even existing targets impossible to meet. Government should press for common standards throughout the EU but accept that in exceptional cases individual Member State targets and improvement plans may be needed for laggard Member States.
34. England should therefore strive to meet the EU 2020 50% target as it should strive to meet post 2020 targets, but should not seek to go beyond them. Government support to meet those targets will be needed as will their support to pursue more meaningful targets in future which better measure resource efficiency and whole life cycle costs.
35. With regard to compulsory recycling there is little practical evidence available in England. The London Borough of Barnet introduced compulsory recycling backed with penalties for non-participation with some success in terms of increased recycling performance. However, it is clear that Government does not favour compulsion or the use of fines or even direct charging of households for residual wastes. This leaves local authorities and their contractors with little other than communication and encouragement to drive recycling upwards. Government should also beware: over-simplistic compulsion or charge-based schemes (even incentive schemes) can lead to difficult to eradicate contamination of otherwise potentially valuable recyclable materials as householders are in effect rewarded for putting contaminated or contaminating materials in with their recycling collection. CIWM would like to see well designed and monitored pilot schemes to assess which charges, incentives or compulsions are effective and under what circumstances, such that best practise can be identified and spread.
36. The introduction of separate collection requirements for glass, metals paper and plastic – where necessary to meet the needs of high quality recycling and where technically, environmentally and economically practicable (TEEP) will be an additional pressure on local authorities and private sector waste operators, but it will not represent a compulsion so far as householders are concerned.
37. Government must also consider markets for recyclates rather than the activity of recycling itself, as source separation of household waste and its sorting into material streams for resale is not an end in itself. Those recovered material streams must be converted into new materials for manufacture and if we are to derive real growth in GVA (gross value added) from it within the British economy, that conversion and subsequent manufacture should take place in the UK wherever possible. Excellent work has been and is being done through organisations such as WRAP and this needs to be supported in the future.
The role of businesses and households in municipal waste recycling and recovery
38. It is clear that elsewhere in Europe the differentiation between household and commercial & industrial waste does not exist in the same way that it does within the UK. Waste policy in France, Germany etc takes into account both private and public sector arisings and as a result policy applies much more across the two than is the case in England or the UK.
39. Businesses have historically been more effective in recycling than households with up to 70% recycling reported by some surveys. Businesses have a much clearer financial incentive to prevent waste and to recycle more – even if only to avoid rapidly increasing landfill costs driven by the Landfill Tax escalator. They also have the incentives of corporate social responsibility, supply chain pressures and future resource security to consider and these all contribute to successful recycling by businesses.
40. CIWM believes that industrial and commercial wastes should be managed alongside municipal wastes - especially where it is similar in nature and composition. Government policy and intervention regarding infrastructure planning and provision has had a tight focus on municipal wastes in England and CIWM believes that poor data and this undue focus has contributed to poor advice and decisions by Government over the need for waste treatment infrastructure. The Institution estimates that there will be a shortfall of at least 5 Million tonnes per year treatment capacity by 2020 and possibly greater – estimates supported by parallel assessments elsewhere in the sector. Waste strategies and plans for industrial and commercial wastes in England have been almost non-existent; there are no targets or specific policies for most of these wastes (hazardous wastes and waste tyres excepted) and Government has signalled its intention to step back from these important wastes. This discourages investment in the sector and will encourage continued exports.
41. The paucity of industrial and commercial waste data exacerbates this situation and it is unlikely that UK Governments will undertake future surveys (limited in value as they are). CIWM has supported development of the electronic duty of care data system (edoc) and believes that all 4 UK Governments should consider making its use mandatory in future to deliver strategically important waste flow information complementary to the WasteDataFlow system for municipal wastes. Edoc also supports legal compliance for waste transfers and should drive better resource management through all sectors through access to waste and resource information. If the Committee is not aware of the edoc system CIWM would be pleased to provide further information.
Whether England has the right balance of waste treatment technologies between anaerobic digestion, incineration with energy recovery and gasification to produce fuel/heat/power
42. Each of these technologies target different waste feedstocks and different parts of the hierarchy. The mix of technologies and the number / distribution of the treatment plants must reflect the waste composition and availability.
43. Access to appropriate waste feedstock over the economic life of a treatment plant is vital to its commercial viability. For AD, for example, that includes separation of sufficient food wastes from the general waste stream – without undue contamination. Data on food waste potentially available for AD is usually very different from the amount actually available either because of lack of separate collection, or poor participation rates or – increasingly often – through high levels of contamination. The mix of technologies used will therefore continue to evolve as waste composition and separation practices continue to evolve.
44. Waste gasification is relatively under-developed in England as it is throughout the UK. The Energy Technology Institute has identified gasification as the technology that is furthest from widespread take-up in the market and has commissioned a demonstration project to explore the future role of this technology.
45. CIWM remains concerned that the different treatment technologies remain under-developed, capacity-wise, for industrial and commercial wastes. The vast majority of infrastructure built to date deals with only municipal waste – household and some commercial waste collected by the local authorities. If private sector commercial & industrial waste is accepted at these facilities, the quantity is marginal at best.
46. The PFI programme has done an excellent job in developing facilities in most of the large conurbations for the treatment of municipal waste, but, for example, even now there are only two energy from waste plants treating commercial & industrial waste.
47. For more commercial & industrial waste plants to be developed it is essential that investors can predict the future revenues and be assured that their investment will be re-paid. In the case of recycling plants, this relies on a stable market place for the sale of recovered materials. In the case of energy recovery plants, it relies on a predictable energy (especially electricity) market. In the latter case, the Renewables Obligation and the contract for difference under Electricity Market Reform perform this function. For recycling, the best prospect for a stable market place is the development of a strong domestic market for the use of recovered materials along with re-manufacture – namely a circular economy. Government needs to support the development of such a market. As stated above, the thrust of future waste management lies in maximising its utilisation through business, not in treating it exclusively as an environmental issue.
48. The most under-developed technology in England is heat recovery and the use of CHP. There are a number of reasons for this, the prime one being the risk associated with building a heat delivery network on a speculative basis with no guarantee that potential users will take and pay for the heat. For this reason, if distributed heat networks are to be developed/supplied by waste plants (ADs and EFWs), it is essential that the public sector securitises the heat off-take to enable the network to be developed. In the absence of this, nothing will happen. Leaving heat network development to the free market is fraught with problems. For example, if one business takes heat but goes out of business or moves premises, the incoming business’s requirements may not be the same and decline to take it. Key heat users are hospitals, leisure centres, care homes etc – all of which can be supported by public sector intervention.
49. Heat networks need to be planned into new developments, and waste treatments should be viewed as just one of the possible inputs. Retro-fitting heat networks is usually expensive.
The extent to which increasing the capacity of thermal treatment plants could impact England’s municipal waste recycling rates
50. CIWM believes there is a need for more energy-from-waste capacity in England. Ultimately, over-provision could detract from other waste management options further up the hierarchy, but CIWM does not believe we are there yet. Additional capacity is needed for energy recovery from all wastes, not just municipal wastes, and this needs to be planned for, and planned at a larger-than-local scale.
51. From Environment Agency records, there is approximately 18.5 million tonnes of waste still being disposed of to landfill in England each year. There is a clear requirement for further diversion from landfill through all options further up the hierarchy including energy recovery in all of its forms. However, CIWM believes that with the exception of hazardous substances, waste treated by EFW should only be residual waste where the recovery of materials for recycling is no longer economically viable or practicable.
52. It is now likely that other than those currently under development, no more thermal treatment plants will be developed in England paid for solely by the public purse. This being the case, future development will occur from within the private sector and the number of plants developed will be a function of feedstock availability and market pricing – including the availability and cost of export of part-processed waste for energy recovery elsewhere e.g. in the Netherlands or Denmark. The rapid development of the energy from waste export market from England suggests that inadequate energy recovery capacity exists and CIWM strongly advocates government support in developing commercial and industrial waste data collection and forecasting to allow planning at a regional scale for all wastes. Long term reliance on exports of waste for energy recovery open up the risks of that capacity not being available to English markets – possibly at short notice - and denies the use of waste derived fuels in England as part of a diverse and secure energy supply mix. Meanwhile, infrastructure provision predominantly for municipal wastes is the norm and leads to sub-optimal provision and exploitation of our wastes in England.
Whether anaerobic digestion is the best option available to deal with food and other biowaste
53. Anaerobic digestion deals effectively with food waste and other wet biowaste – manures, slurries and sludges. As a technology it does not deal efficiently with higher lignin containing materials – trees, bushes, garden waste etc. AD can deal with other biowastes but the biochemistry of methanisation is very complex and it is not a simple technology as sometimes portrayed.
54. Despite the complexities, CIWM believes that AD is currently the best option for dealing with food and other biowastes. Research into the use of enzymes with food waste may lead to the development of potential for ‘waste to chemicals’ to produce chemicals such as n-butynol and racemic lactic acid and liquid fuels from food waste. Support should be given to these emerging technologies as in addition to producing valuable by-products, they have potential for working alongside anaerobic digestion in a synergistic way to enhance the valued obtained from the waste stream. But, for now, anaerobic digestion is the ‘best’ option for food waste provided suitable uncontaminated feedstock and a market for the digestate is available.
55. Anaerobic digestion is used primarily for producing biogas, which is then burned to generate electricity – encouraged by the DECC incentives. This detracts from it being injected into the gas grid (although a RHI payment can be claimed) and / or the use of biogas as a transport fuel. The subsidies available for these three applications need to be balanced and to be maintained as constant as possible to allow stable business plans and investment to be secured for development of services and infrastructure.
Whether the Government’s Anaerobic Digestion Strategy and Action Plan has substantially increased the use of AD
56. The Strategy and Action Plan did much to raise the issue of AD and encouraged better management of manures and slurries. It also highlighted the need to address some regulation and policy issues.
57. Much work has been done on the science and technology of AD. The process is more complex than many believed and much of the technology and expertise to develop AD has had to be imported. Important issues remain however, especially:
58. Whilst CIWM believes that waste management technologies must be viable without subsidies, it has been a fact that in many cases they have been the only reason the development has gone ahead. Government uncertainty and policy changes over subsidies have, without doubt, unsettled the investment community, making funding more difficult to achieve than otherwise would have been the case.
The feasibility of the introduction of a ban on landfill and/or incineration in England
59. CIWM would support the gradual phasing out of landfill, but before it could support a ban would need to see clarity in the regulations that will apply in the event landfill becomes prohibited. CIWM believes that the detail behind a ban on landfill must be spelt out and carefully examined. In particular, CIWM believes it will be important for Government to consult on and agree where responsibility lies for enforcement of a ban, particularly if there are insufficient facilities to deal with the waste arising.
60. The significant lead-times involved in providing non-landfill alternatives, especially where extensive planning delays are possible, means that any landfill bans will have to be announced many years (many suggest up to 7 years) in advance and planned for. CIWM gave this advice in response to the recent Defra consultation on a possible wood waste landfill ban. CIWM also agreed with the Defra conclusion that a ban was not necessary. The Institution would want to see a thorough assessment of the likely impacts of other interventions and therefore the NEED for a landfill ban to be clearly demonstrated before consideration of HOW a landfill ban could be operated.
61. CIWM sees no rationale for a ban on incineration at this stage, nor does it believe that such a ban could be implemented without major negative impact on investment confidence in the UK.
May 2014