The 140-page report produced for WRAP by Eunomia Research & Consulting highlights how focussing on landfill diversion could result in material that should be reduced, reused, recycled or composted being incinerated instead, and how any requirement to pre-sort waste should be applied to all forms of residual waste treatment, including incineration, and not just landfill. The report also suggest that such requirements should be applied to businesses as well as to local authorities.

The report, entitled Landfill Bans: Feasibility Research – The environmental, economic and practical impacts of landfill bans or restrictions: research to determine feasibility, is available from http://www.wrap.org.uk/content/updated-report-feasibility-landfill-bans

According to section 3.0 of the report: “Climate change benefits and resource efficiency gains are likely to be greatest where landfill bans are coupled with a requirement to sort materials (defined here as a ‘ban on unsorted waste’;…In all cases, the biodegradable waste ban leads to net costs to society. This is due to the increased costs of residual waste treatment options (such as incineration, or mechanical biological treatment) which would be used more widely under such a ban and the fact that the environmental benefits of switching away from landfill are lower than the additional costs of using these treatments”.

And from Section 6.1: “If the intention is to move materials further up the waste hierarchy and into recycling / composting / digestion, it is likely that other instruments will be required to drive this. In discussing how this might be achieved, we have suggested that an appropriate measure would be a ‘requirement to sort’ in support of a ban on unsorted wastes from landfill and other residual waste treatments. The ‘requirement to sort’, and the extension of such a requirement beyond waste that is destined for landfill only, are the measures which we concentrate upon here (though as hinted at above, other instruments could also be considered appropriate for the purpose)…”

Section 6.4 states: “If the intention of a landfill ban (and complementary measures) is to increase recycling of materials which are currently not captured from the waste stream, then it makes sense to apply any ‘requirement to sort’ across the board rather than simply to material that would otherwise have been landfilled. For example, if, in an area where incinerators already deal with the majority of residual household waste, there is little by way of glass recycling, then a ban on landfilling unsorted waste will change nothing (because the unsorted waste is not being landfilled). We are also aware of some two-tier areas in England where Districts’ wishes to collect food waste separately are effectively constrained by the existing residual waste treatment contract. As the proportion of residual waste being sent to landfill declines, the potency of a measure aimed at ensuring that material is sorted for recycling or composting / digestion prior to landfilling is significantly diminished (since a growing proportion of residual waste will not be destined for landfill anyway).”

“Consequently, all facilities intending to deal with ‘residual waste’ should be treated in the same way as landfills for the purpose of the measure where the express intention is to encourage recycling of materials. In essence, therefore, the ban on unsorted waste would amount to a requirement to sort the designated materials and products irrespective of the choice of residual waste treatment. As such, a logical counterpart to the ‘requirement to sort’ is the extension of the measure to all other residual waste treatment facilities (such as incineration, MBT, MHT, autoclaving, pyrolysis / gasification, etc.).”

“There are other reasons why it may be more beneficial and more productive to apply the requirement to sort to all businesses. The requirement to sort, particularly in the case of commercial wastes, should help to increase ‘economies of density’ in collection, whilst the approach would give greater certainty to the market in terms of collection (the certainty would be reduced if, for example, requirements to sort could be side-stepped through switching residual waste from landfill to an alternative residual waste treatment).”

Section 6.5: “If the intention is to encourage recycling of specific materials irrespective of the destination of residual waste (as the environmental analysis suggests it should be), then the restriction on landfilling of unsorted waste logically needs to be extended to a restriction on sending unsorted wastes to any form of residual waste treatment.”

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