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waste not, want not a collection of responses to the Government

“green alliance...

Waste Not, Want Not a collection of responses to the Government Published April 2003. Design by Carruthers and Hobbs. Edited by Ben Shaw.

Green Alliance is one of the UK’s foremost environmental organisations. An independent charity, its mission is to promote sustainable development by ensuring that the environment is at the heart of decision-making. It works with senior people in government, parliament, business and the environmental movement to encourage new ideas, dialogue and constructive solutions. Green Alliance 40 Buckingham Palace Road London SW1W 0RE tel: 020 7233 7433 fax: 020 7233 9033 email: web: The Green Alliance Trust is a registered charity number 1045395. Company limited by guarantee, registered number 3037633.

contents dear prime minister Introduction by Ben Shaw and Julie Hill, Green Alliance


a bridge half built? Robin Murray highlights the significant progress that the Strategy Unit report represents but also some important omissions


deeds not words Mike Averill calls for clear leadership and action from government


level the playing field Dominic Hogg calls for greater consistency in waste policy signals


pulling together Barbara Young on the regulator’s roles and relationships


information, incentives, initiative Jane Birchenough on what government needs to do to motivate the public


an equal partner? Kay Twitchen says local authorities are key to fulfilling the Government’s waste objectives


which way from here? Mike Coe highlights the need for a clear and staged action plan from government


two sides of the same coin Peter Jones calls for a true integration across government of waste and resources policy


Dear Prime Minister Last November your Strategy Unit published Waste Not,Want Not, the result of its investigation into the challenges facing the UK if we are to achieve the much-needed transformation of our waste management practices. At the same time the Chancellor made announcements in the Pre Budget Report (PBR) that gave effect to some of the key recommendations of the Strategy Unit report. The broad response from outside government has been positive. The Strategy Unit report, along with the PBR, made some significant steps forward in terms of articulating the principles underlying UK waste policy as well as understanding the policy instruments required to deliver change. However, full judgement has been reserved. While the Strategy Unit’s words are encouraging, what counts is their translation into adopted government policy backed up with the measures capable of turning aspiration into reality. The PBR indicated that the Government would make its initial response to the Strategy Unit report by Budget 2003, so this is a pivotal moment.

“your Government must build on the Strategy Unit’s analysis and make change happen”

If the UK is to be put on course to meeting its statutory objectives and to move towards being a world leader in waste and resource management, now is the time to act. We are urging your Government to be bold. As an environmental NGO you would of course expect this from us. However, to demonstrate that the support for the Strategy Unit’s recommendations goes beyond the usual suspects we have commissioned this set of open letters to you and your Government. The letters reflect the views of all the key players in the waste and resources debate: the waste management industry, waste producers, local government, consultants, NGOs, academics, householders and the regulators.

These letters do not necessarily reflect Green Alliance’s views – those are set out comprehensively in our 2002 report Creative Policy Packages for Waste: Lessons for the UK and subsequent representations to the Treasury. What they do reflect is the strength of feeling, among diverse institutions and individuals, that your Government must build on the Strategy Unit’s analysis and make change happen. And while the letters do not themselves agree on all points there are some clear common messages: the time to act is now, and the action must be bold; the need for vigorous political leadership alongside clear policy direction; the need to provide strong incentives for change; the importance of getting price signals right; the appeal of shifting more responsibility to producers and consumers; the need to integrate waste policy into a fledgling resource productivity agenda. We hope you find them an illuminating read. Ben Shaw and Julie Hill Green Alliance


A bridge half built? Robin Murray highlights the significant progress that the Strategy Unit report represents but also some important omissions The Strategy Unit’s waste report, and the Chancellor’s parallel Pre Budget Report together mark a major step forward in English waste policy. Many of the ambiguities and problematic assumptions that have clouded policy over the last five years have been clarified. A strategy for increasing recycling has been set out and a move made to redress the economic imbalance between waste disposal and waste diversion. The Report also identifies sources of funds that can finance the costs of transition from a disposal centred waste regime, to one geared to reduction, re-use and recycling. There are major gaps, some of which threaten to undermine the impact and even the direction of the strategy. They have prompted well-founded criticism by those who see the Report as a glass half empty. But it is now a question of acknowledging the progress that has been made, and pressing on to develop the Strategy so that its goals can be realised. First the achievements. The Strategy Unit removes many of the ambiguities that have been used to delay the introduction of a new diversion-centred strategy:

Its rationale is not based on the bureaucratic foundations of the requirements of the Landfill Directive but on the need for a new waste system as a means of cutting pollution, reducing global warming, and increasing resource productivity.

Diversion is clearly distinguished from disposal and sits unambiguously at the top of the waste hierarchy. It will no longer be possible to argue that energy recovery is somehow on a par with recycling and composting. Incineration is classified as a pre-treatment/disposal option, a point re-enforced by the European Court of Justice ruling on 13 February 2003. The goal of the waste strategy can thus be clearly stated as maximising diversion and minimising disposal.

The Strategy Unit sets a reduction target of one per cent in the growth rate of waste and a recycling target of 45 per cent by 2015. It even holds out the possibility of 60 per cent recycling by 2020.

At long last the outdated household waste composition figures, on which earlier strategies have been based, are swept aside. This is significant because it recognises that garden and kitchen waste alone make up 37 per cent of the household waste stream, and thus moves the diversion of organic waste to the forefront of the strategy.

Waste minimisation and recycling are, as the Report says, the centrepieces of the strategy. Waste growth will be the major component of increasing waste costs over the next twenty years, and therefore from an economic, let alone environmental, point of view its reduction must be paramount. The strategies on reduction need further development and the targets could have been more ambitious. But the approach is right.

After waste minimisation, the next priority, which is quite new in the UK context, is composting. The Report has been clearly influenced by the Italian success in organics diversion and by the forthcoming Bio Waste Directive, the drafts for which underline the importance of high levels of bio waste capture through source separated doorstep collection, and of the use of compost to restore the quality of soil.

The Report calls for the widespread adoption of a three-stream system for the collection of dustbin waste (organics, dry recyclables and residuals) plus bulky waste diversion, similar to those used in the high diversion authorities abroad and in the UK. 4

On disposal, the Report is less forthright. Many of those who have campaigned against incineration because of the poor level of performance of existing incinerators will be disappointed by the Report’s acceptance of incinerators as an option. On the other hand, the Report marks the first serious discussion of Mechanical and Biological Treatment as a means of ‘neutralising’ residual waste prior to landfill.

The Waste Summit in November 2001 called for the Government to provide leadership for change in the waste economy. The Strategy Unit’s report has done this through the strategy and target set out. Equally important are the two main fiscal changes that are recommended in the Report and announced in the “The Report as PBR; that the landfill tax is to be raised from £15 to £35, and the reform a whole provides of the Landfill Tax Credit Scheme to free up funds to support diversion. In the longer term, the Report’s attempt to shift responsibility for the financing of household waste away from municipal budgets to producers and consumers is equally important. While the Report may be overoptimistic in its support for voluntary producer responsibility, it has underlined its importance and placed responsibility for effective implementation squarely with the producers themselves.

real grounds for hope. Yet in many ways it represents a bridge half built”

The Report as a whole provides real grounds for hope.Yet in many ways it represents a bridge half built. There are three main omissions that mean that the goals of the strategy may not be reached: 1) the increased landfill tax threatens to lead to a shift from one means of disposal (landfill) to another (incineration), by increasing the cost of landfill relative to incineration. PFI contracts reduce energy from waste costs still further. Recycling and composting on the other hand face higher costs in the short run. There is no financial incentive to maximise recycling, and unless this continuing disparity is addressed, the Strategy Unit’s report risks becoming a Charter for Incineration. 2) The Report does little to make reduction and recycling more attractive to the two main institutions taking decisions on disposal - disposal authorities and waste disposal companies. 3) Nor are there strong enough incentives for collection authorities - who should be the spearheads for municipal recycling - to abandon the simplicity of mixed waste collection for the greater complexity of three-stream systems and the uncertainties of recyclate markets. The cash to fund the transition is now likely to be there - in the form of increased recycling credits, re-wiring of landfill tax proceeds, and material sales revenues. But of these only the recycling credits are fixed in a way that counts in the drawing up of budgets. The Strategy Unit rightly have sought to restructure producer and householder incentives to encourage waste minimisation. But they have not adequately addressed the incentives needed by those taking the service level decisions. What now needs to be resolved is how the system of financial incentives and regulatory requirements can be structured so that those responsible for waste services have an interest in promoting reduction and recycling rather than disposal. That is the central issue.


Four measures should be considered: 1) Replacing recycling targets by disposal reduction targets with fixed penalties per tonne of under performance. If each tonne disposed of in excess of the target carried a penalty of say £50, every disposal authority would have an interest in co-operating with collection authorities to deliver an effective reduction/recycling policy. 2) Changing the incentives for collection authorities so that (i) they bear the costs of disposal and receive the savings from reduction; (ii) they pay penalties per tonne, say £50, for shortfalls from the statutory recycling targets; (iii) they receive a fixed sum per additional tonne recycled or composted. 3) Introducing a composting offset payment which would fund any premium costs that would result from restrictive regulations arising from the Animal Bi-products Order. These regulations are in danger of severely restricting the composting of household organic waste which has a pole position in the Strategy Unit’s plans. 4) Shifting the £355 million allocated for PFI funding of waste projects to knowledge economy programmes related to waste, e.g. social marketing, training, management information systems, low cost distributed processing technologies. PFI schemes encourage capital intensive, disposal-oriented programmes. Incentives should be geared to small and medium firms who have been the pioneers of new recycling and composting systems. Incentives remain the key. The test of policy should be whether the main parties involved in waste have an interest in promoting reduction and recycling. When they do, many of the administrative, economic and political barriers which have held Britain back will fall away. The Strategy Unit’s report has already changed the economic contours of waste, but it needs to be taken further if it is to have the desired effect. That is now the responsibility of DEFRA and the Inter-Ministerial Committee. Theirs is the bridge to complete. Robin Murray is a visiting research associate at the Centre for the Study of Global Governance, London School of Economics.


Deeds not words Mike Averill calls for clear leadership and action from government Whilst the initiative to launch such a detailed study, along with the vast majority of the many recommendations to come out of the Strategy Unit’s report on waste, have been warmly and widely welcomed, the overriding consensus remains that we are still stranded near the starting blocks rather than setting off towards the finishing line. The Report’s recommendations are extensive and generally point the way to ensuring that the UK meets its statutory obligations in achieving timely compliance with EU law. But although the race has long since started we are seriously lagging behind. The time for words is done. Only deeds will count from here on in. And only continued political will together with adequate resources - in the form of government leadership and action – can achieve the necessary and vital transformation. Whether we can now actually succeed in meeting our obligations within the required timescales is a moot point, but if we are to have any chance at all of even coming close the Government must pick up the baton, now without delay, and lead the charge for the line. early, high

“an rate landfill tax, will inevitably be required”

Here at Shanks we need look no further than the examples of Belgium and the Netherlands, where we also conduct our business, to help identify some of the key areas for action. The upfront combined use of clear and consistent regulation and appropriate fiscal measures have been at the core of much earlier waste management changes in these two countries and elsewhere. A mixture of regulatory instruments, such as landfill bans, and financial incentives, e.g. an early, high rate landfill tax, will inevitably be required to make real and timely changes here in the UK. In simple terms, a fiscal approach may be identified as the most appropriate driver in relation to ‘lower disposal cost’ municipal solid waste (MSW). The ultimate higher landfill tax levels proposed in the Strategy Unit report and by the Chancellor need to be introduced sooner rather than later to boost recycling and help achieve the landfill diversion targets set out in the Landfill Directive. Regulation can be regarded as the most appropriate primary mechanism to drive change in the management of ‘higher disposalcost’ hazardous waste. Simultaneously, though, and across waste types, there must be commitment to, and resourcing of, strong and uniform enforcement as part of the regulatory regime. Also required, particularly in the case of the local authorities, is clarification and agreement on what the ultimate aims and success criteria are. Councils need to be given clear direction for purchasing decisions on waste management services. Any move away from landfill will inevitably incur higher costs. However, waste strategies face running into a brick wall when actual planning permissions are sought. Much more effort is needed to turn (local) waste plans into meaningful waste strategy documents and further planning reform is vital if the waste management industry is expected to be able to deliver the raft and range of new facilities necessary for the required change.


Environment Agency Chief Executive Baroness Young recently criticised the public’s attitude to waste. They were aware it was a hot issue, were facing increases in waste of their own generation, yet generally remained opposed to new forms of disposal. Communities needed to be more involved, she was reported as saying, but above all she called for the Government to take the lead in waste management. “We need some overarching leadership to take us forward, there is no overall group with this responsibility. Let’s look to Government to fill this gap.” Leading from the front in this way is the only route to making significant progress in other areas, like producer responsibility. This can be further utilised to promote the avoidance of waste, at both a personal and a manufacturing level, and to address waste which is produced further up the production chain through good design and, perhaps, the increased use of take-back schemes. The recommendations contained within the Strategy Unit report are many and wideranging. They contain options for action covering all the key areas discussed above, which need to be recognised as crucial elements and prioritised as such as part of an urgent and co-ordinated national action plan. But the keyword is action, bold and sustained. It would be churlish not to recognise that some progress has been made in promoting the waste hierarchy in the UK – but much too little and much too slowly. Where the waste management industry has been at the heart of those pockets of improvement it has more often been despite, rather than because of, existing policy and market drivers. Without doubt, though, where conditions are appropriate, the Shanks Group and other waste management leaders are ready and willing to provide the necessary investment and innovation to deliver change. In fact, many of the ‘innovative’ waste solutions much discussed in the UK are already in operation in mainland Europe and can readily be replicated here given the required elements of action, certainty and understanding. We, and all those others who welcomed the production of the Strategy Unit report as the sound of the starter’s pistol, need the Government to really grasp this opportunity and seriously begin to set the pace for home. Michael Averill is chief executive of Shanks Group plc


Level the playing field Dominic Hogg calls for greater consistency in waste policy signals ‘Waste disposal in the UK is too cheap’ seems to be, rather like waste minimisation, one of the things all analysts agree upon. The low cost of waste disposal is one of the main reasons for the lack of progress in source separation of municipal solid waste. In the absence, until recently, of statutory targets requiring source separation systems to be in place, the duty of local authorities to collect waste, allied to the fact that disposal is so cheap, led to a situation in which the vast majority of waste is simply collected for disposal to landfill. Why is waste disposal too cheap and what can be done about it? What amounts to sustainable waste management? In the case of landfill, the clarion call has been for increases in the landfill tax. The strength of these calls is enough to make one think that by itself, this will lead to a radical change in UK waste management.Yet a tax is not the only way to discourage landfill. For example, consideration might have been given to requiring pre-treatment of waste prior to landfilling - to stabilise it prior to final disposal. This would have been consistent with the Landfill Directive requirements. Instead, however, one finds some measures that enable operators to offset, albeit marginally, the effects of a tax. Revenues can be generated from the sale of Renewables Obligation Certificates arising from the energy generated from landfill gas. This ‘renewable energy’ generation is deemed worthy of support despite the fact that the Landfill Directive will anyway require the capture of landfill gas and its recovery for energy as far as possible as a condition of operation of sites which accept biodegradable waste. If landfill gate fees were to rise to £100 per tonne, what would happen? It’s not the case that all material would suddenly be recycled or composted since other options are less expensive. So, under a financial constraint, the next cheapest option might be the most appealing. There are good arguments for suggesting that for paper and card, and for biowaste, source separation may well be the best option. But for some other materials, the next cheapest option is likely to be incineration or mechanical biological treatment. For a given scale of incineration facility, the costs are driven by a number of factors including the requirements for flue gas treatment, the costs of dealing with ash and air pollution control residues and the revenues received for energy generation. The Renewables Obligation determined that incineration would no longer benefit from enhanced revenues for electricity delivered, arguing that to do so would be inconsistent with UK waste policy. Oddly, this logic was not extended to other residual waste treatments, including landfill, but also, pyrolysis and gasification. On air pollution control residues, the requirement for significant pre-treatment prior to landfilling does not seem to have been given adequate consideration. But most important of all is the way in which EU Directives on Incineration and Integrated Pollution Prevention and Control seem likely to be implemented in the UK, without obviously requiring Best Available Techniques (BAT), which they should. Were they to do so, it seems unlikely that incineration gate fees would be so low. By way of illustration, recent work by Enviros, based on operational data at UK incinerators, suggested that a best estimate of NOx emissions from UK incinerators exceeded best practice in Europe by a factor of ten. The failure to introduce effective technological standards for incinerators does much to keep non-landfill residual waste management cheaper. It does so at the


expense of higher levels of air emissions which are damaging to human health. Whilst no residual waste treatment is free of some form of impact, the rationale for establishing BAT standards is to reduce these at acceptable cost. Given that many EU Member States require better flue gas treatment as a matter of course than occurs in the UK, it would seem extremely difficult indeed to refute the fact that current UK incinerators are not operating using BAT. All of this would not be quite so worrying were it the case that suitable incentives existed for the options higher in the hierarchy.Yet here, instead of treatments being made cheaper, the UK is proposing to introduce standards for composting and anaerobic digestion processes where the feedstock may contain kitchen wastes which are tighter than anywhere else in the world. Indeed, whereas the UK has tended to interpret EU legislation creatively so as to make residual waste treatment cheap, in the case of composting and digestion of catering wastes, the UK has decided to ‘over-interpret’ the EU Animal By-products Regulation. The testing requirements initially proposed in the amendment to the Regulation alone would make it more or less impossible for any system below 500 tonnes or so to operate economically. More generally, even larger scale facilities may face cost increases in the order of £10 per tonne of input.

“it would seem extremely difficult indeed to refute the fact that current UK incinerators are not operating using Best Available Techniques”

This follows hot on the heels of guidance from the Environment Agency on acceptable distances from compost plants to sensitive receptors such as housing or businesses. This guidance was developed from two studies concerning bioaerosols, which were based on measurement from only five open windrow schemes and one in-vessel scheme. By the standards of waste management interventions, the guidance was issued with almost indecent haste. Local Authorities are being given targets (in England) for recycling and composting. Yet residual waste treatments are being ‘kept cheap’, while composting and anaerobic digestion of catering wastes are being made more expensive. Our incinerators are poorly regulated by the standards of some of our EU neighbours, but our compost sites will be so tightly regulated that many will find it difficult, perhaps impossible, to operate. There is much emphasis on discussion around the public acceptability of incineration facilities. One senses a desire on the part of regulators and government to ensure greater acceptability of incinerators, even when they are performing poorly relative to what is possible. At the same time, composting is being stigmatised by regulators and government. In short, it appears that regulators and government are arguing that there is too much scare-mongering around the incineration issue, despite the fact that these operate some distance from best practice, whilst they themselves play the role of principal scare-monger in the case of composting. This is but one more way in which the UK manages to keep turning the waste management hierarchy on its head. Local authorities will rightly be scratching their heads thinking why the economic effects of regulatory instruments seem to be designed to encourage them to do exactly the opposite of what they are being told to do! The unevenness in regulation across facilities, notably between those for dealing with source separated kitchen wastes, and those for mass burn incineration of residual wastes, is to say the least, counterproductive. It needs attention from the very top of the Government. Dominic Hogg is director of Eunomia Research and Consulting


pulling together Barbara Young on the regulator’s roles and relationships Tackling waste remains a key priority for government. Municipal waste is one of the failing indicators of sustainability. There are more testing times ahead to meet the Landfill Directive targets, never mind our ambitions for sustainable “world class” waste and materials management. Waste Strategy 2000 was barely one year old before the Government called their Waste Summit and commissioned the Strategy Unit report – they knew they had to do something to make the strategy happen. Strategic planning for waste does not have a thrilling track record, so we read with interest the Strategy Unit’s report. Crucially it’s a report ‘to’ government and not ‘by’ government, so the real work has yet to be done. Most of the 34 recommendations in it depend on decisions yet to be taken by the Government, particularly the Ministerial group set up to take it forward. One of the targets for announcement is the April Budget. The deadlines for many of the targets (EU or self-imposed) are too close to allow any delay. It’s already action time and we need clear government policy, funding decisions, responsibilities and co-ordination. We need strong and sustained leadership. Turning to the Strategy Unit report itself – it’s got some potentially powerful proposals, and is obviously backed by much more analysis and supporting information than was published. Hopefully that increases the chances of early announcements on its implementation. However, the Agency raised questions about two features of the report:

Firstly, it focuses almost totally on municipal waste – less than 10 per cent (about 30 million tonnes per year) of the total waste (about 400 million per year) which needs to be planned for. Of all this, it’s the hazardous waste, currently about 5 million tonnes per year, that the Agency is most concerned about. Half of it goes to landfill and in the middle of next year (July 2004) that option could stop almost dead. Where will it go? Who can and will continue to manage it? And how? We need answers and we need them quickly. The market is not responding on its own; stronger signals on Hazardous Waste Strategy are needed.

Secondly, there’s no provision for a Strategic Waste Authority – the impartial coordinating body that many thought was essential to deliver the strategy. Clearly several bodies are expected to develop their existing roles and somehow glue-together in an informal but seamless network. We think that is possible, but not without a strong sense of leadership from government to get us all to that point.

There still needs to be a debate about what role the Agency should have. The Government’s guidance on our sustainable development role was published in December. The guidance requires us to regulate, to provide data and to assist regional and local government in waste strategy development. We need to get down to brass tacks on the data and strategy roles. We must get a clear understanding of where we stop and WRAP or Envirowise or local government starts. We must know what’s expected of us and how it will be funded.


At the same time as the Strategy Unit work and report, the Agency’s waste regulation activities have been audited by the National Audit Office. We appeared in front of the Public Accounts Committee in January and are waiting for their final report and recommendation. Piecing together the two processes, we can see the Agency needs to develop its waste role in five ways: 1) Waste data, research and development, including the means to turn data into information and tools to turn information into costed strategies. We need to get away from slow and costly sample surveys for data – we need 21st century solutions. 2) Support to regional and local authorities in the development of their waste plans and strategies. It isn’t reasonable to expect many authorities to afford their own expertise to develop and test Best Practicable Environmental Option (BPEO) based strategies. Some will need help, most will need training.

“We’ve got to coordinate, co-operate, collaborate if we’re going to get that “world class” waste management system”

3) Technical advice on the capabilities and costs/benefits of in-market and near-to-market waste management technologies. Local Authorities need it for strategy development; we need it to be able to regulate. 4) Illegal waste management enforcement. Fly tipping and other illegal waste management is going to grow as the cost of responsible waste management goes up. We have to tackle it in close cooperation with local authorities, the Police, Customs and Excise. We all need from government better powers, clearer responsibilities, resources and tougher penalties.

5) We have to continue to drive for efficient regulation. Otherwise we can’t deliver on a whole string of new expectations like fly tipping, or end of life vehicles or WEEE. We are working hard with DEFRA on the review of waste permitting and hope that will complement the streamlining we’re already going through. New styles of regulation must be risk based and they must be both efficient and effective in protecting people and the environment. The five areas of development won’t happen overnight, but we’ve made clear what we need – policy, legislation, resources – to do it. We’re just as clear that none of these things involve the Agency acting on its own. None of us can. We’ve got to co-ordinate, co-operate, collaborate if we’re going to get that “world class” waste management system. And that needs leadership. And that’s not something that only the Government can deliver. Barbara Young is chief executive of the Environment Agency


Information, incentives, initiative Jane Birchenough on what government needs to do to motivate the public I read with interest the Strategy Unit’s report, Waste Not,Want Not. I approached the Report on the basis of my own knowledge about waste, knowledge that I thought was more than basic, but is very much about how waste is handled locally. What really came home to me from the Report was how much central government needs to get a grip on this issue. It is clearly a national as much as a local problem. The other thing that struck me very forcefully was the long-term costs of getting it wrong. I was shocked by the figures on how much waste we all produce. I can see why waste production and wealth creation would be linked, but surely rising wealth should mean increased education and awareness about the consequences of our actions, and that should translate into less wastage. I thought the 12 per cent household waste recycling figure was very low, because I judge it by what I recycle personally, which has to be more than 12 per cent of my rubbish, and what I do seems so straightforward that I can’t understand why it is not the norm. Presumably it’s because people don’t have sufficient motivation or incentive. The waste hierarchy was not a familiar concept to me, but it makes sense. Personally, I bracket landfill and incineration together, since I think they are both dangerously polluting and we should move away from them in the long term. On landfill, I had assumed that at some point we would simply run out of space and the Report confirms that in some places that is likely to happen. Although replacing all of landfill with the alternatives of recycling and reduction seems such a huge step change, in the longer term it shouldn’t be beyond the wit of man to achieve. I agree with the idea of pricing landfill so that it becomes the least desirable option and pricing incineration should also be an option.

“I am much more in favour of incentives than penalties or regulations”

I’m sure I could be recycling more myself, but that fact that I don’t is down to ignorance – I don’t feel that anyone has made any effort to inform me about what can and should be recycled. My sister-in-law, who is 15, knows far more about it than I do, which may reflect the fact that more information is given in schools now. But my generation needs to be better informed. It is also important to get feedback on progress – my local recycling centre has a thermometer-style indicator of how much waste has been recycled, and that really makes me feel that I’ve contributed.

The Report did inspire me to think about what is in my rubbish bin and how it gets there. Most of the waste comes from supermarket packaging, so surely it must be tackled at that level, by giving shops incentives to reduce packaging. I agree with the emphasis the Report places on getting those who produce products to take responsibility for the waste. In general I am much more in favour of incentives than penalties or regulations – I don’t think that penalising people stimulates the will to change. There have to be benefits for businesses as well as costs. I thought the document could have had more examples of how supermarkets, for instance, could assist. In terms of what I buy, I do try to think about how to reduce waste while I’m shopping – paper bags rather than plastic, for example. I think people need incentives to develop that kind of consideration and discrimination in their purchasing decisions, and to get away from the idea that we can consume without any thought for the consequences.


I am entirely prepared to take responsibility for my waste – I don’t view it as someone else’s problem – but at the same time I want everyone to do their bit. Again, there should be incentives rather than penalties, and they must be applied fairly. However, if there were to be financial incentives for householders to do more recycling, I would be concerned about fraud – what’s to stop people putting rubbish in the wrong bags or disposing of it somewhere else? It is not so much the exact mechanism that’s important, as the level of monitoring and enforcement that goes with it. I think I would also like to be rewarded for recycling and reducing my waste with a good environmental conscience rather than just for financial reward – I suppose it’s because it means that I will try to do it consistently and will pass on those values to my children and neighbours wherever I can. I want that level of motivation to be recognised and reinforced in some way. Perhaps rewards could be in kind as well as in terms of cash – getting compost back according to the amount of green waste taken for recycling, for instance. I thought the Report was a very user-friendly, interesting, practical document but needs to be better publicised, since I wouldn’t have known about it if it hadn’t been brought to my attention. I am doubtful that it has very high priority inside the Government. The Secretary of State for Environment is named as a figure-head for the strategy, which is good, but is it really being driven forward politically? I don’t see much sign of that at the moment. Jane Birchenough is a householder from Oxfordshire


An equal partner? Kay Twitchen says local authorities are key to fulfilling the Government’s waste objectives The Local Government Association (LGA) recognises that the Strategy Unit’s Report represents a serious and considered attempt to really get to grips with the country’s waste problems. It is clearly intended to provide much-needed strategic direction to the Government’s Waste Strategy – and that is very much to be welcomed. If the strategy set out in the Report is to be translated into practical and achievable actions, a firm and early commitment from the Government is going to be crucial. There is much in Waste Not,Want Not to be welcomed – particularly the proposal to set waste reduction, re-use and recycling at the forefront of a new government strategy. This is essential if truly sustainable waste management is to be achieved. It will also require vision, commitment and resources for it to be realised. The LGA is firmly of the view that, if the recommendations are to be carried forward effectively, there is a clear need for a significant local government input to be incorporated in this process. The LGA recognises that the Strategy Unit Report calls for significant changes in overall local authority performance if waste management practices are successfully to move up the waste hierarchy. This is a challenge which local government can, and must, rise to. However, whether and to what extent it will be able to, will depend to a considerable extent on other changes occurring at the right pace. Obvious examples are market expansion for recycled products, investment in new technologies, resolution of current uncertainties affecting composting, and a review of the construction of local authority recycling targets. “We cannot Every local authority I know is keen to develop recycling, and where they lag behind the leaders it is not a lack of will that is the reason, but lack of resources. The £140m recycling fund promised in July 2000 has only just been fully distributed. The community sector has to rely on lottery funding to develop recycling schemes. We cannot go on expecting to deliver good, sustainable waste management on the cheap.

go on expecting to deliver good, sustainable waste management on the cheap”

On the issue of variable charging for collection of household waste, the LGA has been entirely consistent. We fully support the principle of councils being given the freedom to incentivise, whether through charging or through reward, as a means of controlling the increase in volumes of household waste. What we have never supported is any suggestion that the Government should require us to charge householders, or impose upon us any system of doing so. In practice, I think that if the power to charge is allowed within the legislation, what will happen is that a number of local authorities will run pilot schemes of various types. These are likely to range from a free allowance of residual waste with additional amounts being charged for, right through to a system of weighing the amount of waste put out for recycling, and rewarding householders with a reduction in their council tax.


As far as local authorities are concerned, the main issue here is freedom. Our responsibility is to our electorate, as well as to comply with government targets, and we need to be free to set in motion schemes that we think will suit the people we serve. I entirely support the Strategy Unit’s report towards higher standards. Local government is determined to achieve more sustainable waste management, in the interests of the environment and the communities we serve. But none of it can be done without proper investment in infrastructure. Aside from the Strategy Unit’s report, local authorities are having to come to terms with new duties under the End of Life Vehicles Directive, the Waste Electrical and Electronic Equipment Directive, and more immediately the Waste and Emissions Trading Bill. This latter bill seeks to impose stringent financial penalties on local authorities which exceed statutory landfill targets. It does occur to me that on the one hand we are being asked to spend more and more of our scarce resources on improving our waste management methods and making them more sustainable, the need for which we do, of course recognise.Yet, on the other hand, we face the imposition of fines and penalties if we fail to comply with statutory targets, which will take away the very money we need to develop the services. I would hope that the Government could begin to regard Local Authorities as true and equal partners. Then I think we will start to make real progress. Councillor Kay Twitchen is chairman of the Local Government Association’s Waste and Environmental Management Executive


Which way from here? Mike Coe highlights the need for a clear and staged action plan from government Reading Waste Not,Want Not brings on a rather depressing feeling of déjà vu. Several investigations and reports into the UK’s waste policy over the past decade have produced many valid conclusions but very little action. The Report points out correctly that the UK might not respond fast enough to European Union objectives, such as those in the Landfill Directive. This could be both costly and damaging. A failure by the UK to achieve its waste targets is likely to impose additional costs on industry and lead to restrictions on consumer choice. Unilever makes products that meet everyday consumer needs. Demographic changes are leading to a growing number of smaller households, with the resulting rise in demand for smaller packs. This trend contributes to an increase in the amount of domestic waste and heightens the challenge we face in reducing packaging to a minimum. Sustainability considerations are integral to our business. It is clearly in the interests of everyone, ourselves included, to encourage quick, concrete action on effective waste policy. Below we outline our view of the main obstacles to change, and suggested solutions. Current waste policy lacks an overall management structure. Measures taken by each party – local government, regulators, producers, waste managers – need to be implemented in an integrated way. Somebody needs to be in charge. The Report recommends a steering group and a task force. This is good, but these bodies will need skills, influence and authority if they are to manage such a multi-faceted issue. We need to know where we are going. This demands a long-term roadmap with milestones and deadlines to encourage long term investment. WRAP, or another body, should be charged with defining the goals. This blueprint will focus attention on action and also provide information needed by potential investors. Local government has too much of the responsibility to deliver combined with the added difficulties they face in developing regional solutions. The Report lacks a clear plan on how to help local government create regional solutions. One approach is to give this task to regional government offices, working with other regionally organised bodies, such as the Environment Agency. Another more radical solution would be to apply the utility industry model to waste collection and disposal. There is a lack of willingness to make energy recovery part of the solution. It is clear to us that energy-from-waste must be part of the solution but nothing is being done to ameliorate the public’s dislike of incinerators. If government fails to act to enable the building of these facilities, the UK will fail to meet Landfill Directive targets. The Report lacks incentives to encourage people to accept incinerators and other resource-recovery facilities in their backyard. The Government should consider how to reward local communities that host such facilities. This could be done through the community tax assessment or other incentives. An increase in landfill tax – as proposed by the Report - will certainly help but it will only be part of the solution and will not lead to the recovery of very large volumes of materials. Financial incentives, such as preferential pricing, are needed to boost recovery programmes.


Minimisation of waste is fundamental to success. It is in our interests to minimise packaging because it cuts costs. But packaging cannot be eliminated because it performs a range of vital roles, including protecting the product and preventing wastage. The Report supports voluntary measures to encourage minimisation. We strongly agree that government policy should avoid over-prescriptive regulation. For example, it has been suggested that defining the essential requirements of packaging in regulation would prevent over-packaging. We think this could be cumbersome and costly. We accept that industry must justify the packaging it uses and continually improve its design. But it is inefficient to apply a bureaucratic regime to all packaging when the majority is responsibly designed and used.

“Minimisation of waste is fundamental to success�

We favour the Packaging Standards Council model. This provides stakeholders with an ombudsman who can adjudicate on complaints. While voluntary agreements are our preferred approach, we accept that they do not suit all circumstances and regulation certainly has a role to play.

The Report suggests the formation of an Industry Forum. This could be helpful, but its membership must not be confined to waste management companies, who will be the main beneficiaries of the changes in waste handling. Supply chain companies must be well represented on any forum. We realise that we play a part in the problem and we want to contribute to solutions. Mike Coe is packaging regulations advisor at Unilever


Two sides of the same coin Peter Jones calls for a true integration across government of waste and resources policy Ministerial attention spans with regard to waste, resource efficiency and the environment are beginning to lengthen. That is very much a basis for optimism. The interconnectivity between resource efficiency, energy, waste and agricultural policies are beginning to dawn in the minds of those who control the levers of progress. Product and service supply chains, the waste industry, technology providers, local government and NGOs can only exhort – but they all await clear, demonstrable signals from Westminster backed by bold and decisive action. Such initiatives would not exactly constitute a giant leap in the dark – the technologies are available and exemplars already operate in mainland Europe, Canada, the US and elsewhere. Unfortunately that final ounce of confidence appears to be missing so we are not yet at the tipping point. Messages continue to be confused by narrowly based perspectives. The Cabinet Office team appear to have been circumscribed in considering a National Waste Strategy principally around 30 million tonnes of domestic refuse. The reality is that our developed economy is absorbing around 600 million tonnes of physical raw materials and busily converting them into 85 million tonnes of materials which are buried, 45 million tonnes which are reused, 160 million tonnes which ends up in the built stock of the nation, 200 million tonnes which ends up on the land (in agriculture or spoil tips) and 170 million tonnes which we shoot into the atmosphere. The 8 per cent which passes through people’s dustbins is the product of systemic failures in the broader economy. Trying to sort the latter by addressing domestic flows is looking through the binoculars from the wrong end. Mrs Beckett’s decision to focus on resource efficiency and resource flow measurement, however, is welcome news indeed – it is a hobby horse I have tried to ride for the last five years! What is perverse is the separation of waste strategy, which government seems to confine to local authorities, from resource efficiency, which government confines to industry. Surely the two are one and the same? The waste economy does not distinguish waste from consumption and “The ills of the waste from production. The technologies, regulation and economic resource economy signals for both act in much the same way. Acceptance of such a premise is blurred by a top-level failure to integrate the financial/monetary can only be economy into the resource flow economy. In the financial economy health addressed through is maintained by detailed monitoring that tracks € 1.3 trillion of wealth to maximise employment, minimise inflation and achieve modest integration into the controllable growth. In the resource economy, however, 600 million financial economy” tonnes of input is squandered with substantial unemployment (resource inefficiency) and hyper-inflation (pollution). Sooner or later governments are going to have to realise that the ills of the resource economy can only be addressed through integration into the financial economy. The nub lies in re-valuing and pricing inputs and outputs from the resource economy which are currently ‘free’. If ever there was a true role for governments in grappling with how this transitional valuation process moves forward, this is it.


Still, at least we should be starting that journey at home, aware of the impacts on our international competitiveness if we become over enthusiastic. The irony is that when we work out the numbers, the sums involved are pretty trifling. £55 per household per year has been mooted as the cost of moving to 20 per cent of energy from renewables with the attendant substantive reduction in CO 2 levels. A not dissimilar financial sum would deliver all the Government’s domestic household waste objectives as well. The old public/private split between Waste and Resource Efficiency strategies seems to carry forward in terms of economic instruments applied to each. On the one hand the waste/public sector/local authority strategy box is dominated by Keynesian fiscal approaches involving around £700m per annum of subsidies, bid funds, regulatory bans, special allocations under local authority funding formulae and similar efforts to beat the market. The market is set by cheap landfill that – with tax levels of £14 per tonne – can sell at £26 while all the other more resource efficient technologies need £45-£50 per tonne to compete. So the response from central government is to pay local government the difference to get them to shift and, for added measure, top up with a further £30m or so for end market creation via the WRAP. Money moves round with different labels, allocated over different time periods by different departments like a game of ‘Spot the Lady’. On the other hand when we look at economic instruments in the context of resource efficiency and industry we are much closer to Milton Friedman and the Chicago School – traded pollution permits, taxes, pollution permit rationing, allocation by scarcity, punitive fines and producer responsibility. The problem is not that one is right and the other wrong – simply that such a split approach is sending confused signals and integration is needed. The two halves of this policy approach need to be mixed through mechanisms underpinned by open dialogue between industry, NGOs and government. The Keynesians in DfT, ODPM and DEFRA seem to tough it out against the Friedmanites in the Treasury with the DTI and Environment Agency holding the ring. The Treasury liability for waste management of public sector flows now runs at around £2bn including the hidden subsidies. It would take another £1bn to fund the aspirations targeted for 2015. The cost could reduce by £1bn if around half the waste were managed by private sector supply chains through producer responsibility. The real debate should be around how that £1bn can be transferred into supply chain prices without prejudicing inflation pressures, competitiveness, market share and profitability for a private sector dependent for its survival on the whims of shareholders oblivious to these issues. Consumers should see these externality costs priced in at the point of sale – not lost in the general tax take to be fed back as subsidies. However, at a time when FTSE 100 companies face pension fund shortfalls equivalent to 12 months total profitability, the prospect of taking on board another £1bn-£5bn liability to internalise environmental externalities is not exactly mouth-watering. We therefore need to consider these issues on a top-down basis and develop scenarios in terms of transition costs, quick gains and sectoral impacts. Nations like Austria and Canada realised years ago that such approaches were not just about pollution abatement – they also produce conditions in which nations can create opportunities to supply an emerging global market which is likely to form the basis of the next industrial revolution. The first industrial revolution (since 1780) taught us how to organise and allocate inputs of goods and services to meet peoples’ needs. The next one will focus on taming the pollution outputs of that process.


The problem is that we have only 20 years to do it, not 200. In the UK we have the academic, financial and educational capacity to compete for those markets, but we must tackle our bout of policy schizophrenia first. Peter Jones is director for external affairs at Biffa Waste Services.


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Waste not, want not: a collection of responses to the Government  

In November 2002 the government's strategy unit published Waste Not, Want Not, the result of its investigation into the challenges facing th...

Waste not, want not: a collection of responses to the Government  

In November 2002 the government's strategy unit published Waste Not, Want Not, the result of its investigation into the challenges facing th...