UKWIN has provided written evidence to the Environment, Food and Rural Affairs Committee’s inquiry into Waste Management in England.

UKWIN’s submission makes the following recommendation:

  • a) England should introduce waste reduction targets as part of a move to One Planet Living by 2050, embracing waste reduction targets that are no less ambitious than those already in place in Wales, i.e. between 1.2% and 1.5% each year, and those proposed by the EEB (in their ‘Ambitious scenario’), i.e. reducing MSW per capita to 400kg by 2025 and 350kg by 2030;
  • b) Adopt recycling targets or measures that are no less ambitious than the Scottish and Welsh recycling targets of 70% by 2025;
  • c) Adopt a recycling target (and/or other measures that will result in the equivalent) of exceeding 75% recycling, composting and anaerobic digestion (AD) by 2030, as a pathway towards ~100% recycling by 2050 (in line with the Welsh zero waste goal;
  • d) Require the removal of dry recyclables from mixed waste prior to incineration;
  • e) Require separate collection of food waste;
  • f) Ensure that the use of incinerator bottom ash (IBA) and air pollution control residues (APCr) do not count towards recycling targets;
  • g) End government subsidies and financial support for waste incineration;
  • h) Impose a moratorium on new incineration capacity, including pyrolysis and gasification;
  • i) Introduce a tax on waste incineration;
  • j) If there are to be landfill restrictions, they should be designed to ensure waste is not simply incinerated;
  • k) Design out materials / products that cannot be readily recycled, e.g. plastic products either need to be recyclable by all Local Authorities or they need to not be produced at all;
  • l) Ensure goods are long-lasting, e.g. through Extended Producer Responsibility;
  • m) Ensure goods are re-used where possible, e.g. bulky waste collection services should not send re-usable goods to landfill or incineration, and HWRCs should operate re-use schemes); and
  • n) Provide support for Local Authorities who want to get out of being locked-in to paying for unwanted incineration capacity.

Evidence submitted by others is also well worth a read. Many  respondents promote higher recycling rates and highlight the importance of reducing waste arisings, and phasing out material that cannot be recycled.

A number of organisations have said some interesting things in relation to incineration and residual waste treatment capacity as part of their evidence, including:

    • DS Smith: “Processing materials through thermal treatment plants is not recycling and therefore should not count towards the country’ recycling rates. It has a negative impact on recycling and does not follow the principles of the waste hierarchy.
    • The Chartered Institution of Water and Environmental Management (CIWEM): “Energy incentives must not be allowed to distort re-use and recycling markets for waste. Too much thermal capacity is highly likely to have an adverse impact on recycling rates; this can be seen with the current competition for feedstock from underutilised European plant. An approach similar to that taken in Scotland may be appropriate, ensuing that recyclable materials are as far as possible recovered for recycling prior to waste being incinerated…there is a need to ensure that only truly residual waste is used [for incineration]…
    • Confederation of Paper Industries:
      • In the absence of strategic planning, new regional EfW facilities generate substantial risk [England’s municipal recycling rates]”
      • For those English Unitary and Waste Disposal Authorities entering into long-term residual treatment contracts, underpinned by guaranteed minimum tonnages (GMT), residual treatment overcapacity may well act as a disincentive to increasing recycling rates. Whilst investment in infrastructure to achieve landfill diversion and recycling improvements is an imperative, the business case for exceeding the recycling performance is questionable; not only does the cost of delivering additional recycling typically increase as the ‘higher hanging fruit’ is sought, but also an increase in recycling may also bring with it a greater risk that future residual feedstock falls below minimum contractual thresholds.
      • Councils operating co-mingled collection systems therefore risk facing the starkest choices down the line. At face value, for example, finance officers weighing up the benefits of incurring either a Materials Recycling Facility (MRF) gate fee of around £7 per tonne, or bolstering EfW feedstock in order to avoid defaulting on GMT payments in the region of £90 per tonne, are unlikely to place waste hierarchy considerations high upon their own priority lists.”
      • Any introduction of a ban on landfill and/or incineration in England ban should include a requirement to pre-sort recyclable materials.”
    • Cornwall Waste Forum – St. Dennis Branch: “The best idea would be to work slowly along the path to Zero Waste (sent to landfill and incineration) and to do so in a controlled and scientific process, undertaking R & D into those items that resisted treatment. These could then either be removed from the waste stream by providing substitutes, banning their manufacture (as in Norway), or investigating alternative methods for their treatment.
    • Eunomia Research & Consulting Ltd:
      • We believe that there is a danger that England invests too heavily in residual waste treatment. If higher recycling rates are delivered, then this may become problematic. There is already evidence locally of residual waste treatment contracts having the effect of constraining recycling increases.“The main causes of this are as follows: Authorities and their advisers have tended to overstate the rate at which waste would grow; Authorities and their advisers have underestimated the potential for recycling; and Incinerator contracts often include a guarantee from the waste disposal authority to supply a minimum tonnage of waste to the facility. Some contracts seek to ‘weaken’ the strength of this bind by placing a requirement on the contractor to make endeavours to cover any shortfall in the guaranteed minimum tonnage, but in practice, it might be expected that local authorities would still lose money under such arrangements as a result of the underpinning ‘put-or-pay’ nature of the contract.”
      • “We have clear evidence that, locally, this is already a problem for many local authorities….Authorities already incinerating more than 50% of their waste may, it seems reasonable to argue, have to consider scaling back quantities being incinerated in order to improve recycling. Some of these may be under no major contractual constraint, but equally, it seems reasonable to say…that few  of these would feel compelled to seek to recycle more waste: affordability does not appear to be their problem.”
      • “[Regarding the extent to which increasing the capacity of thermal treatment plants could impact England’s municipal waste recycling rates] Generally, this is an issue that arises in a local context. The more widely it does so, then the more it tends to inhibit recycling rates for a nation at large. The best of example of this at the national level is to be found in Denmark, where a recently revised waste plan makes clear that for Denmark, if waste is to be managed in a sustainable way, there has to be less incineration and more recycling. The household waste recycling rate is around 27% in Denmark, though there is virtually no household waste landfilled: the management of waste has been ossified by virtue of the fact that there is no incentive to recycle more if there are no financial savings to be made from doing so (because fixed investments have already been made).”
      • At the local level, there are a number of local authorities in England who are already in a situation where the options for additional recycling are constrained by contracts they have entered into with companies regarding incineration of residual waste”
      • The case for an incineration ban is no stronger than for landfill: until 100% recycling is achieved, then there will be residual waste, and this needs to be managed. If the intention is to consider material specific bans on landfill and incineration, then the same applies to incineration as to landfill: enforcement would be all but impossible for materials widely found in mixed waste. We do believe, on the other hand, that there is a case for a tax on incineration.“More generally, Government would do rather better to consider the measures it can take to encourage recycling rather than unjustified and infeasible measures to ban the flow of materials into landfill and incineration. Meaningful approaches might be (for example) charging households for waste (to incentivise prevention); fostering reuse networks, and embedding reuse targets in producer responsibility schemes; implementing producer responsibility schemes with high recycling targets; deposit refund schemes for beverage packaging, and potentially, in future, for (small) WEEE items; and requirements to sort materials such as food wastes. It might also be worth considering setting standards for reprocessors of some materials to ensure that such processes do not destroy components of high potential value which could be recycled.”
    • Green Alliance: “Landfill bans are not a silver bullet however and to avoid landfill bans simply leading to an increase in incineration of residual waste, it is important to introduce them with supporting policies that develop collection and recycling systems. The Waste (Scotland) Regulations provide an instructive example of a well-targeted package of measures that includes landfill and incineration bans.
    • Institution Of Civil Engineers: “In the waste hierarchy, recovery through thermal treatment is below recycling. This suggests waste should only be recovered where it is not possible to recycle. As such, efforts to decrease the amount of waste produced and to increase the amount of recycling could be affected by the drive to develop EfW….”
    • Keep Britain Tidy: “…Defra needs to set a policy framework to get recycling moving again whilst ensuring that increasing capacity for residual waste treatment does not undermine this….Whilst energy is produced from thermal treatment and incineration of waste, these treatments are still an inefficient way of producing energy and are at best a stepping-stone to a sustainable economy…We would welcome an incineration tax that supports recycling alongside the existing landfill tax. Furthermore we need to review and implement fiscal measures that support the waste hierarchy and focus on prevention and reuse where possible.
    • Leicestershire Waste Partnership:
      • “It is likely that the current regulatory framework and fiscal pressures will drive England towards greater use of large scale incineration…”
      • “…[incineration] undermines the concept of waste being a resource….”
      • “[Regarding the extent to which increasing the capacity of thermal treatment plants could impact England’s municipal waste recycling rates] Anecdotally we would expect to see an impact on a regional basis, where a high capacity of thermal treatment may undermine recycling efforts. There is already a perception that there are a number of regions with high thermal treatment capacity that have lower recycling levels than would otherwise be expected.”
    • London Councils: “In order to keep these costs down, councils need to reduce the amount of waste sent to landfill and incineration (the two most expensive options) and invest in waste prevention, re-use and recycling.”
    • National Association Of Waste Disposal Officers (Nawdo):
    • “[Regarding the extent to which increasing the capacity of thermal treatment plants could impact England’s municipal waste recycling rates] A variety of comments were received from NAWDO members, including:”
  • “…Without an overview of the number and location of the various processing options, the risk of creating overcapacity in some methodologies, which would in turn threaten the viability of others, will be a risk….
      • The current lack of drivers will be encouraging Energy from Waste ahead of other technologies. This could create an imbalance in the future as we may find we have an over-supply of that kind of technology if we wish to further our ambitions to view and use waste as a resource. Some Authorities in areas where there has been a longer standing adoption of EfW as the preferred treatment method have lower recycling rates whilst having high landfill diversion rates. This is in no way a criticism of any LA adopting this approach but does illustrate that locally barriers may exist either contractually or through planning constraints.
    • Novamont SpA: “Experiences from Scandinavia, the Netherlands and Germany where today recycling has plateaued and excess incineration capacity exists leading to significant cross border transfer of residual waste at low costs show that high levels of incineration not only hinders recycling at a local level but in other countries as well.
    • Sita: “high recycling targets automatically constrain the role of incineration”
    • Wood Panel Industries Federation: “Current biomass energy generation policies are undermining this principle by subsidising energy generators to burn not only waste wood that could be reused by wood processors but also virgin timber that could been processed and recycled numerous times before being burned. Unfortunately the subsidies provided to biomass energy generators offer a very significant market advantage in purchasing this wood, damaging efforts to encourage wood recycling and reuse by acting as a disincentive for segregation and sorting….It is essential that only waste wood which could not have been reused or recycled should be incinerated. Energy plants will naturally gravitate towards the cheapest and easiest material to use – namely, uncontaminated wood – unless specific measures are put in place to focus incentives (and restrictions) around the use of contaminated wood…A ban on sending wood to landfill alongside a ban on burning uncontaminated waste wood would ensure that the best use is made of our valuable and finite timber resource.”
    • Wyre Forest Friends of the Earth: “A phased closing down of incineration is feasible and would lead to higher levels of recycling and reuse…There is good evidence that incineration puts a cap on recycling levels…”
    • Zero Waste England:
    • Incineration is second to bottom in the Waste Hierarchy, above landfill. The majority of the ‘residual’ waste can be reused, recycled, composted/AD and we should aim to design out the remainder…By 2020 the planned increase in incinerator capacity threatens to lock us into recycling rates of between 50-60%. We must not build any more incinerators…Landfill and incineration are remnants of the old linear mind-set and hold back progress. They should be phased out in favour of more resource efficient techniques by means of escalating disposal taxes. Recommendations for action:  

      A moratorium on incinerators in the procurement pipeline to ensure there is no ‘crowding out’ of

future recycling of at least 70% by 2025 and moving towards zero waste by 2050…”

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