The recently released Confederation of Paper Industries (CPI) 2012-13 review raises concerns regarding the detrimental impact on recycling of incineration overcapacity and long-term waste contracts. Alongside this, CIWEM have raised concerns that existing economic drivers give rise to the incineration of material that could be dealt with in the top tiers of the waste management hierarchy.

The CPI’s 2012-13 Review states that:

“We [the CPI] have lobbied against…the indiscriminate development of Energy from Waste plants which are a potential threat to supplies of recyclable fibres…CPI will highlight to both local and central Government the potential risks to the future availability of quality recyclate posed by thermal waste treatment…For UK local authorities (LAs) entering into long-term residual treatment contracts underpinned by guaranteed minimum tonnages (GMT) there is a genuine risk that residual treatment over-capacity could act as a disincentive to increasing recycling rates…The implications of waste treatment over-capacity for recovered paper are significant and CPI will be engaging with local and central Government on this issue”.

In October 2012 CPI Director General David Workman stated that: “As a part of any future manufacturing strategy we must also have a clear action plan aimed at creating a ‘circular economy’, where all materials that are capable of being recycled are banned from landfill or incineration.”

Similarly, the Chartered Institution of Water and Environmental Management (CIWEM) recently made representations relating to their consultation response on the Waste Prevention Programme based on their March 2012 Less is More report. CIWEM make the arguments that the waste management incentives are out of step with the waste hierarchy in a way that promotes incineration over recycling.

In response to Question 14 (“Do you have any evidence that incentives help to drive waste prevention and/or reuse behaviours?”) CIWEM state:

…There is a lack of clear policy on waste planning and this has led to inappropriate investment in handling and treatment technologies. Public funding from the EU budget needs to be prioritised to activities higher up the waste hierarchy (for example to re-use centres over waste disposal facilities). Currently most investment is directed to energy from waste because of the potential for the Renewable Obligation, feed-in-tariffs and Renewable Heat Incentive and this conflicts with the Waste Hierarchy. A higher and stable carbon floor price could help drive measures up the hierarchy as it would account for the carbon saved further up the hierarchy and not just subsidise energy production that is not in-line with the overall carbon price. A carbon framework is needed to plan fiscal incentives and ensure that they do not cancel each other out…

In response to Question 15 (Do you have any evidence of where targets have driven waste prevention and/ or reuse behaviours?) CIWEM states:

“…Landfill tax has been a major driver and has helped halve the amount of UK waste going to landfill since 2000, but the current proportion of UK municipal waste going to landfill is still 49 percent, compared to an EU-27 average of 37 percent. There are a number of incentive mechanisms to drive recovery, but this is largely that of energy rather than materials. Defra claim that landfill tax indirectly drives waste prevention. It may, but it does not drive measures up the hierarchy. There is a lack of real regulations or incentives tasked with driving waste minimisation and prevention at the top of the hierarchy and it is largely left to voluntary agreements. This may explain why action has stalled in the middle and recycling has become a focus of many waste minimisation and prevention strategies. Extended producer responsibility needs to be used to drive more measures up the waste hierarchy…”

In response to Question 17 (“Which barriers do you consider should be priority areas for action? Why?”) CIWEM state:

“The main barrier to waste prevention is that fundamentally our economy does not encourage sustainable behaviour. Our neo-liberal economy is based on the need for year on year growth to support monetary expansion and lending. Continuous growth is not possible in a finite system. We need to move away from economic models which are based on perpetual growth and consumption of resources. An economic model built around sharing ownership and increasing well-being, rather than material wealth, would be able to support the population in a more sustainable way. The work of the Ellen MacArthur Foundation has shown the magnificent potential of moving to a circular economy. What we now need is for our political leaders to take brave, ambitious and innovative decisions to keep our resource priorities down and not be afraid to ask more from business.”

Previous expresses of concern regarding incineration from the CPI and other businesses and trade bodies reported by UKWIN include:

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