Defra’s Stage One Consultation on the transposition of the revised Waste Framework Directive (Directive 2008/98/EC) in England and Wales closed on 9th October 2009.
Submissions from Friends of the Earth (FoE) and the Campaign for Real Recycling (CRR) are now available from the UKWIN website, and these are well worth a read!
Highlights include:
Friends of the Earth (FoE)‘
Friends of the Earth welcomes this opportunity to comment on the Government’s proposals to transpose the revised Waste Framework Directive.
We believe that waste policy should be aiming to improve the UK?s resource efficiency, and minimise our climate impacts, by maximising prevention, reuse, recycling and composting, and by gradually phasing out residual waste.
With the UK needing to realise every option available in the battle to minimise the impact of climate change, the further contribution of recycling and sustainable waste management to winning that battle should not be underestimated. Furthermore, it is economic madness for the UK to be importing expensive materials such as aluminium and then dumping them in landfill or incineration, when they could be recycled.
If the UK limits itself to only reaching the recycling targets set out in the WFD, and not improving upon them (like some Member States are already able to do), then we will continue to see the scandal of significant wasted resources being buried or burned that could be sensibly recycled.In planning for residual waste management, waste planning authorities should ensure that:
• Firstly, any remaining recyclable waste should be removed (e.g. metals, plastics, some paper).
• Secondly the small amount of waste remaining after this should be composted or anaerobically digested and, unless sufficiently clean to be used as compost, should be disposed of to landfill (as the disposal route with lowest environmental impacts for this waste).
• These processes should occur in small, localised treatment plants.The waste management priority order enshrined in the waste hierarchy should be incorporated in paragraph 7 of the Planning Policy Statement 10 – Planning for sustainable waste management. This would help to ensure that facilities offering the most environmentally sustainable waste management options are built.
We are still sending huge amounts of material for disposal that could be better recycled or composted. Friends of the Earth want to see recycling targets set for commercial and industrial (C&I) waste in order to help ensure that the materials diverted are moving up the hierarchy as far as possible rather than just being diverted from landfill to waste incineration (and speedy collection of up to date data).
To ensure that MSW and C&I waste is diverted from landfill to recycling and not incineration, we would like a ban on the landfill and incineration of recyclable materials to be introduced.
Download the FoE submission [PDF]
Campaign for Real Recycling (CRR)
The Campaign for Real Recycling sees the EUWFD transposition as a substantial opportunity to achieve quality recycling in the UK and could be a driver for substantial growth in the UK secondary materials economy. It could make contributions to local authority efficiency, green jobs, lower carbon impacts of recycling and long term material security for our industries.
The best figures in England in terms of high diversion from landfill at the best value for money are those of Somerset Waste Partnership. We note that Defra does not wish to be prescriptive to local authorities as to what collection method to deploy in pursuit of domestic recycling collections; however, we can see no reason why Defra should not advocate clearly source separation at the kerbside, not least since, as paragraph 2.63 in the consultation document says: There are particularly strong arguments for encouraging more separate collection of food waste.
This can provide the greatest environmental benefits most cost effectively… The experience of CRR stakeholder Bryson Recycling, which runs kerbside sort and commingled collections side by side in Northern Ireland, makes it clear beyond any doubt whatsoever that kerbside sort is both the most cost effective and most environmentally sound method of collecting domestic recyclate.
Evidence amassed last year shows that over time it produces greater diversion from landfill. This echoes findings of recent WRAP guidance to local authorities.
6. CRR has been clear for some time that as kerbside sorted diversion of dry recyclables rises, the cost per tonne falls. Although collection of food waste introduces new costs and occasions a price per tonne rise overall, the cost per tonne starts to fall again thereafter.
The experience of Somerset Waste Partnership and their contractors May Gurney is now that it is more cost effective to recycle 65 to 70% than it is to remain at 35 or 40%. This is in part due to the success of the Landfill Tax, which has occasioned not just higher landfill cost but high gate fees for treatment and other end-of-pipe alternatives. Whilst these are issues about the environment and related matters, anyone in government with the latitude to indulge in joined-up thinking will see that this also goes to the heart of local authority financial issues. Government has more than one reason to urge local authorities to invest in quality.
Kerbside sort collection, relative to co-mingled/MRF collection:
• costs less per tonne to collect in whole system terms
• produces better quality material
• diverts more material from landfill as schemes mature
• feeds UK based reprocessors more than export
• has a lower carbon footprint
• meets comfortably the EUWFD separation specifications
• is a demonstrably better manifestation of the proximity principle
• contributes more to local job and wealth creation
We cannot see why Defra should want to encourage continued co-mingling. Equivocation around this being a matter for individual local authority decision is pointless. As with many other public sector services, an element of choice is generally a good thing, but it is never a substitute for quality.
Question 16: Do you agree that the UK is currently self-sufficient in installations for the recovery of mixed municipal waste from private households etc? If not, please (i) explain your reasons and (ii) the steps you consider need to be taken by the UK to achieve self-sufficiency in relation to such installations.
Investment in waste disposal facilities could well work against recycling. In order to plan that this does not occur, it seems important to know the maximum possible percentage of material recovery and what is in fact likely. It seems strange to CRR that so few officials and politicians appear at all curious about such projections before multi-million pound waste facilities are built that we may not even need.
If, for example, local authorities were to follow closely the lead set by Somerset Waste Partnership, indicative figures suggest that the UK would have treatment and other disposal facilities standing idle within ten years. CRR believes that it is time to stop investing in waste disposal infrastructure and invest heavily in waste reduction and high quality recycling, and to consider how strategic investment could assist those working further up the hierarchy.
Commingled collections, minus glass, allow a bigger range of materials collected than the limited source segregated type, which was the previous system locally. It seems reasonable to assume that this will lead to a much bigger weight of recyclate due also to the ease of use for newcomers to recycling (only 50% recycle at present, locally).
Performance at mrfs has to improve to reduce failure rates. That is the challenge ahead since commingled looks like the way forward for householders and businesses.
I have to agree with the two key points John Costigane raises. Our research leads to the same trade off benefits of Comingled recyclate, minus glass; to quality MFRs only..ie those extracting PET/HDPE by scanners. Comingled is certainly the easiest and most saleable collection system for residents and businesses. Total segragation confuses folks and does account well that folk are different.
The next biggest direction will be when every WCA is obliged to collect separated food waste to anarobic digestion, via separate kitchen caddy. Other than the obvious landfill and soil benefits; it should mean cleaner residual and easier resource separation,