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Waste management revolution

Gev Eduljee examines the impact of changes to the definition of municpal waste and potential landfill bans

The UK might well be on the cusp of another revolution in waste management, with one recent (the change to the definition of municipal waste) and one heavily trailed policy announcement (landfill bans). While not in themselves out of line with long-established European practice, they nevertheless could induce some deeper policy thinking from Defra.

The change in definition would bring the UK in line with the Northern European Member States – in other words, a definition of municipal waste that is based on its compositional likeness to household waste, regardless of its source.

 
Recycling and waste expert, Gev Eduljee, is director of external affairs at SITA UK

Since this change will draw additional biodegradable waste into the UK's Landfill Directive diversion targets, Defra will have to think very hard about the delivery of alternative treatment infrastructure, to handle the much larger volumes of waste that will be coming out of our landfills.

The National Audit Office stated recently that even for current 'municipal' wastes the prognosis for meeting 2013 and 2020 landfill diversion targets was touch-and-go, primarily because of the slowness of the planning process.

Add to those volumes the far greater volumes of C&I waste that will now have to be diverted, and the scale of the challenge for treatment infrastructure delivery is magnified. How much additional capacity will the UK need, and of what treatment types? Is the current rate of planning approvals in each category sufficiency responsive to our needs? If not, how can be planning process be speeded up? These are some of the questions Defra needs to address.

In administrative terms, Defra will need to look carefully at how the overall national diversion target can be met without unravelling (at least for the time being) existing structures such as LATS. The most sensible solution would seem to be to set up two parallel systems such that local authorities get on with their existing municipal (mainly household) waste diversion from landfill under LATS, while measures reported in the recent C&I Waste in England – Statement of Aims and Actions 2009 would deal with the C&I wastes that the change in definition will now bring into play.

An interesting conundrum would arise if the revised consolidated diversion target was not achieved in a target year. Defra would have to assign the financial penalties stipulated under LATS between the private and public sectors, and for the former, decide on which companies to penalise – impossible if the waste cannot be tracked.

Restricting or banning particular waste streams from landfill impacts on alternative infrastructure requirements, but also poses other issues. For example, how could a ban on aluminium or food waste be enforced? It is clearly impractical to search each waste consignment for the possible presence of a sandwich or a foil wrapper!

Looking to the Continent, typically three policy strategies are invoked:

  • 1- mandating source separation of the target waste streams, and banning the landfill of all separately collected materials

  • 2 – introducing additional landfill acceptance criteria, for example stipulating a de minimis level of biological activity in any wastes accepted for landfill

  • 3 – concurrently, minimising the inevitable leakage into landfills by ensuring that alternative infrastructure is available on time, when the bans come into force.

This latter point is of particular importance in relation to a potential landfill ban on food waste. While Government has an ambitious aspiration to divert such wastes to anaerobic digestion, our focus to date has been on technological issues – pilot schemes, demonstration projects and the like. The reality is that the key blockage affecting speedy plant delivery in the UK is not technical, but structural.

Most AD plants on the continent co-digest food waste with farm waste. The latter being the dominant waste stream, where are the policy levers and incentives directed towards the agricultural sector? Should food waste come to a farm-based AD plant or vice versa? Is the strategic waste management planning in place, linking the agricultural waste sector with the food waste sector, so that planning permission can be assessed on a plan-led basis?

Are farm-based plants able to connect readily to the gas or electricity grid? What about the effluent discharge typical of AD plants, adding to the pollution load in our rivers? How can we ensure the digestate is of sufficient quality to spread on land, so that we do not end up with a residual sludge problem?

These are some of the issues Defra need to think through before committing the UK to landfill bans. The lack of adequate infrastructure at the right time will force Government to water down the ban by offering derogations, while costs would inexorably rise as the banned waste continues to be landfilled at ever-increasing landfill tax rates.

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