In its response to the government's consultation on potential restrictions, which closed last week (June 10), the Local Authority Recycling Advisory Committee (LARAC) also called for a lead-in time of up to 10 years for any bans – echoing the conclusions of research published by WRAP to accompany the consultation (see letsrecycle.com story).
However, despite its reservations, LARAC also said that it could – if evidence was found in a second consultation to support such a proposal – support bans for paper, card, green waste and food, while also claiming that there was a “stronger argument” than the one made in the March 2010 consultation for banning WEEE from landfill, due to the resource depletion of precious and semi-precious metals.
Its response comes as the new coalition government is yet to outline its position on the potential for landfill bans to be introduced – despite former environment secretary Hilary Benn, who launched the consultation in March 2010 (see letsrecycle.com story), urging his successor Caroline Spelman to take action on the proposals.
Incentives
In its response, LARAC outlined exactly why it believed that incentives to make resources derived from waste attractive to the market were a preferential option to introducing landfill bans or restrictions.
It said: “We would encourage the Government fully to evaluate and consider the effectiveness of other instruments, with landfill restrictions or bans to be used only where they can be shown to add value to incentives and contribute significantly to more sustainable wastes management.
“We believe that attempts simply to “push” material out of landfill will not be effective without measures that will also “pull” resources into the economy,” it added.
In particular, the body pointed towards the market incentives such as the ROCs green electricity subsidy and the proposed Renewable Heat Incentive as examples of “strong” market incentives which would pull paper, card, green waste and food from the waste stream and, as such, should be evaluated before any ban was introduced.
Landfill Tax
The body also stressed the importance of Landfill Tax as a means of driving waste out of landfill, claiming that it had “superseded” drivers such as LATS and statutory recycling targets by creating the financial conditions to make alternative waste collection and treatment options financially “viable”.
As a result, it said: “LARAC is of the opinion that the effects of the landfill escalator should be fully evaluated alongside the implementation of the current generation of municipal waste management strategies before further legislation and drivers are introduced.”
Other key points raised by LARAC in its response include:
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Support for the two-stage consultation process proposed by Defra, with the second consultation examining proposals in “more detail”;
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A lack of support for banning glass, wood and plastics from landfill, with the body claiming the argument for banning plastics from landfill is “particularly weak” because it would drive the material to mass burn incineration which would result in greenhouse gas emissions;
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A need to look closely at any pre-treatment requirements for waste that is diverted from landfill via Energy-from-Waste;
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Introducing some kind of ‘last resort' to allow material to be sent to landfill, both in the event of markets for recyclables and/or secondary materials collapsing and in the case of non-landfill treatment technologies breaking down or requiring maintenance;
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Considering other options for diverting material from landfill, such as using producer responsibility to target junk mail;
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Questioning the “fairly narrow criteria” used by the government for landfill bans, with particular doubts raised over the decision to model outcomes based on greenhouse gases and the ‘net benefit to society', with LARAC stating that: “We remain to be convinced about some of the evidence based on notional ‘cost of carbon' as the margins for error are potentially significant and could alter the report conclusions.
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