A year late it may be, but England’s new waste strategy has turned out to be a lot meatier than early signs suggested.1
The review was initially intended to be a modest exercise. DEFRA was happy simply to examine whether England was on course to meet the EU landfill Directive’s landfill diversion targets for biodegradable municipal waste, and felt the measures introduced after the Strategy Unit’s waste review in 2002, such as the landfill allowance trading scheme, would be enough (ENDS Report 362, p 47).
But despite recent increases in household waste recycling, it became clear to DEFRA over the past two years that to meet the landfill diversion targets, local authorities needed more help to boost recycling, and waste treatment and recycling facilities needed to be more economically viable.
At the same time, climate change shot up the political agenda and cutting greenhouse gas emissions - especially carbon dioxide - became the government’s overriding environmental goal.
Tony Blair travelled the globe exhorting countries to sign up to new greenhouse gas emissions targets, but at home CO2 emissions - which account for the lion’s share of emissions - refused to fall.
Armed with renewed purpose, relaxed about the public’s acceptance of new measures and driven by an ambitious new Environment Secretary trying to counter the ‘Cameron effect’, the government has produced a waste strategy dominated by the need to reduce methane emissions through landfill diversion; boost renewable technologies that burn waste as fuel; and cut carbon emissions from virgin material production by increasing recycling. As much emphasis is placed on commercial and industrial waste as municipal waste.
The government’s greater ambition was clear in this year’s Budget which doubled landfill tax for active wastes over the next three years to £48 per tonne (ENDS Report 387, p 4). The hike is clearly designed to encourage investment in waste treatment and recycling facilities, but the government would not have imposed such a cost on municipal waste landfilling unless it was confident local authorities would have the powers and funding needed to increase recycling significantly.
Environmental groups welcomed the strategy as a step forward. Friends of the Earth and Green Alliance singled out a promise to legislate early to allow authorities to introduce ‘save as you throw’ charging schemes for households (see box, pp 36-37), the promotion of anaerobic digestion for treating kitchen and food industry waste and the plan to set targets for authorities to reduce residual waste left over after recycling, composting or recovery.
Green groups were disappointed that the household waste recycling targets were not higher (see box).
Landfill methane emissions have fallen since the 1990s but still account for 3% of all UK greenhouse gas emissions. Waste sent to landfill has dropped slightly over the past six years but the UK still landfills more municipal waste per capita than any other EU15 country except Ireland and Greece.
Key objectives, says the strategy, are to "meet and exceed" the landfill Directive’s diversion targets, to divert more non-municipal waste and secure better integration of treatment for municipal and non-municipal waste. Another is to "secure the investment in infrastructure needed to divert waste from landfill and for the management of hazardous waste".
Gold-plating argument loses ground
A potentially radical proposal is to consult on whether further restrictions on landfilling biodegradable waste and recyclable materials would reduce greenhouse gas emissions and increase resource efficiency.
It is too early to guess whether such restrictions would be outright bans, but they would go beyond the EU landfill Directive’s requirements and would symbolise the government’s willingness to drop its opposition to ‘gold-plating’ - the overly prescriptive implementation of EU directives.
Other EU countries have found such restrictions "have encouraged higher rates of recycling and recovery". These, the strategy adds reassuringly, "have sometimes been introduced… with significant lead-times between proposals and their implementation".
The consultation will be linked to a raft of further measures on priority waste materials.
The strategy will also assess whether voluntary agreements could increase the separate collection, recycling and recovery of decorative paints and garden chemicals.
DEFRA and the Environment Agency will shortly publish draft updated guidance on interpreting the definition of waste. This will build on guidance issued by the European Commission earlier this year on the distinction between non-waste by-products and waste residues (ENDS Report 386, p 53).
DEFRA is also reviewing inert waste regulations. The review covers issues such as use of inert waste exemptions, inconsistencies with the landfill tax regime, and quality of guidance. A consultation paper is due by the end of the year.
The government will also work with the Agency, local authorities, the police and businesses to develop and implement an action plan to tackle illegal waste activity.
Recent studies by consultants
ERM for DEFRA and by WRAP, the government’s Waste and Resources Action Programme, "suggest significant potential savings in greenhouse gas emissions (in the UK and elsewhere) from greater diversion of certain materials from landfill, through recycling and energy recovery, over and above current efforts."
In terms of CO2 saved per tonne of waste recycled or recovered, by far the greatest savings can be made by aluminium (see pp 30-33). Textiles, wood, paper and card, ferrous metal and dense plastics also offer significant savings.
But in terms of reducing the tonnages of materials entering the waste stream, the greatest savings are offered by paper and card, followed by wood, kitchen waste, aluminium and dense plastics.
Both recycling and energy recovery of paper and card show significant benefits over landfill, but the benefits of recycling versus energy recovery depend on material quality and whether energy recovery also recovers heat as well as generating power.
DEFRA will establish with the paper industry an agreement to reduce paper waste and increase recycling that incorporates and develops existing agreements on newspapers, magazines and direct mail.
It will also consider whether to establish similar agreements for office paper, free newspapers, catalogues and directories, or include them in the new agreement.
Buried in one of the strategy’s annexes is the fact that the Direct Marketing Association (DMA) failed to meet its target to recycle 30% of junk mail by 2005 by two percentage points.
Since the agreement was signed in 2003, the amount of addressed junk mail has fallen 5%, partly because of the mailing preference service, which allows households to opt out of receiving such mail. But volumes of unaddressed junk mail are rising by 1-2% per year and the DMA will develop an opt-out service for this. The government will also explore whether an opt-in system for junk mail is needed.
The agreement with the Newspaper Publishers Association will be reviewed after a final report later this year. The average recycled content of newsprint in 2006 was 80.6%, well above the target to achieve 70% by the end of that year.
The Confederation of Paper Industries welcomed the strategy’s emphasis on greater recycling but warned that the UK uses a lot of imported paper and "engagement further along the supply chain will be required". It also says that measures to increase waste paper collections need to minimise contamination of paper with other waste and that "in the short to medium term" most of the extra waste paper collected will have to be exported.
Subject to further analysis, packaging recycling targets will be set for aluminium and plastics that go beyond the 2008 targets in the packaging Directive. Like the proposal to examine restrictions on landfilling certain materials, this shows the government’s willingness to drop its opposition to gold-plating in certain cases.
The British Plastics Federation, which wants more plastics to be burned as fuel because of the economic, logistical and technical barriers to recycling many plastic waste streams, says it supports measures to increase recycling but is "wary of going beyond European targets… because there are limits to viable recycling."
Measures are also proposed to stem the continuing rise in packaging waste and the fact "there is still a problem of excess packaging around many products".
In a tacit and long-overdue admission that the "essential requirements" regulations have failed to ensure packaging is made with the least material possible, the government will "amend producer responsibility regulations to achieve packaging minimisation while keeping in mind businesses’ commercial objectives."
The regulations will set optimal packaging standards for a product class, building on existing WRAP standards, so that packaging specifiers would be expected to require the lightest packaging available. WRAP estimates that if just 10% more imported wine was bulk imported and bottled here in lighter bottles, 138,000 tonnes of CO2-equivalent per year could be saved.
It is not clear if this will be done by amending the producer responsibility regulations, drafted by DEFRA, or the essential requirements regulations, drafted by the Department of Trade and Industry. If the DTI is given the task - assuming it survives after Gordon Brown succeeds Tony Blair as Prime Minister - there is a danger that the enforcement regime could remain weak.
DEFRA’s Waste Implementation Programme will develop energy markets for wood "by addressing informational and practical barriers to expansion". Relatively little energy is used to produce wood products, but they have high calorific value. While 16% of waste wood arisings are reused or recycled, just 0.3% is burned as fuel.
Environmental groups will support moves to reduce wood landfilling but they may be concerned that DEFRA’s preference for burning wood for fuel over reuse and recycling to reduce CO2 emissions will do little to reduce timber imports, and that the climate agenda is overriding the need to preserve forests that can be biodiversity havens and carbon sinks.
DEFRA is also gathering evidence about products’ life-cycle impacts and will publish a progress report on its efforts to identify policy measures in spring 2008.
The strategy singles out the retail sector because the rapid growth in the waste it generates has largely been responsible for the slight increase in commercial waste arisings in recent years (ENDS Report 370, pp 4-5). Nearly half of household waste going to landfill originates from supermarkets and convenience stores.
But the strategy merely suggests building on WRAP’s voluntary programme, the Courtauld Commitment. WRAP hopes to extend the agreement to non-food retailers and will develop guidance for retailers on which plastics to use as packaging materials.
The food and drink sector, which sends more than four million tonnes of waste to landfill each year, has been identified as a key sector with scope to improve performance. DEFRA is currently in talks with the sector over how to implement the target included in its sustainability strategy to cut waste by 15-20% by 2010 (ENDS Report 376, p 8).
Several new targets have been proposed for construction and demolition waste, which accounts for a third of the 272 million tonnes of waste produced in England each year. As WRAP and the sector’s Sustainability Forum announced last November, the construction industry will halve the amount of construction, demolition and excavation waste sent to landfill - excluding site restoration, landfill engineering and quarry backfilling - by 2012. The base date has not yet been agreed, but 2005 is a possibility.
Another target would be for construction clients to include, by 2009, requirements for measurement and improvement of material resource efficiency for half of all construction projects in England worth over £1 million. A third target requires government projects to achieve "waste-neutral construction" by 2012.
Other targets are likely to appear in the government’s sustainable construction strategy, due later this year. They could include objectives of zero net waste at construction level by 2015 and zero waste to landfill by 2020. The recent agreement with manufacturers on the recycling of plasterboard will be extended to other parts of the supply chain.
The Environment Agency plans to publish an annual resource efficiency inventory covering processes regulated by the pollution prevention and control regime. It will compare performance using league tables covering sectors, companies and sites.
Anaerobic digestion wins favour
For the first time, the strategy includes a clear preference by the government for a particular waste treatment technology. Anaerobic digestion (AD) has "significant environmental benefits over other options for food waste" and therefore "the government wishes to encourage local authorities and businesses to consider using anaerobic digestion."
Research by consultants Eunomia for WRAP found that separate collection of garden and food waste makes "economically and environmentally friendly decisions more easily obtainable".
Collecting green waste separately allows it to be windrow composted in open air. This is the cheapest treatment for such waste, provides a valuable service to households unable to use home composting bins and may reduce the carbon emissions associated with householders taking green waste to civic amenity sites.
The study also found that collecting kitchen waste separately minimises processing costs and increases waste capture. Food waste can be processed by in-vessel composting facilities, but these need an equal amount of green waste which could be composted more cheaply by windrow facilities.
But AD plants can treat kitchen and other food waste without green waste. They also produce carbon savings greater than composting units, according to research for DEFRA by ERM.
Routing 5.5 million tonnes of food waste through AD instead of composting would save at least 250,000 tonnes of CO2e per year if the electricity produced displaces gas-fired generation, says DEFRA. Diverting kitchen waste to AD plants would also complement measures to promote anaerobic digestion of manure and slurry from farms.
The digestate could be used as a fertiliser or soil improver. WRAP and the Environment Agency are developing a standard and a protocol for the digestate to build market confidence; this is due by spring 2008.
Kitchen waste collection
Only a few authorities collect kitchen waste separately, all on a weekly basis, and WRAP is supporting several local trials.
The strategy acknowledges public concern about the impacts of alternate weekly collections, in which kitchen waste is collected fortnightly, but says such schemes "can work well" and there is "no evidence of increased health risks". But the choice of collection system is a matter for local authorities.
The landfill allowance trading scheme was "successful" in 2005/06, its first year, and all authorities reported validated waste data to the Agency. As part of a review this year, DEFRA will consider the development of a reporting and monitoring system that would allow authorities to fully account for diversion of biowastes from landfill by supported home composting schemes.
The government is also considering a greenhouse gas emissions performance indicator for local authority performance on waste.
To implement the strategy across Whitehall, the government will establish a Waste Strategy Board, chaired by the lead DEFRA director for waste and sustainable consumption and production. It will also set up a Waste Stakeholder Group to provide advice on future delivery of the strategy and future policy development.
But successful implementation will depend on increasing levels of local authority expertise, improvement in the investment climate and fewer planning delays for waste treatment facilities.