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Waste Review – in-depth analysis

Waste Review – in-depth analysis

By Nick Mann

Waste collections, potential landfill bans and a lighter touch to enforcement for both businesses and households all feature heavily in last months Waste Review, but already the document is drawing criticism for a perceived lack of concrete policy proposals.

As the dust settles on a frantic couple of days that reportedly saw parts of the Review being re-written at the 11th hour to reflect last minute changes in the governments approach to collection frequency, the task of digesting the content of the document can begin in earnest.

The absence of any funding for a return to weekly residual waste collections was one of the headline-grabbing tenets of the Waste Review
The absence of any funding for a return to weekly residual waste collections was one of the headline-grabbing tenets of the Waste Review

And, regardless of whether you believe the Review is light on policy but heavy on ambition and narrative as some leading industry figures have said it does address all the major areas of waste management in England.

From council fines to small business bring banks and from recycling on the go to energy-from-waste incineration, the Review touches on a wide range of issues, even if some are given little more than two paragraphs mention in the 80-page tome.

Below, letsrecycle.com analyses the review, breaking it down into specific sections to address what it says for each sector of the industry and what the impact of those words might be.

Councils

– Collection frequency: The absence of any financial incentive for local authorities to return to weekly residual or food waste collections was one of the headline-grabbing points of the review, although it does include a commitment to work with councils to increase the frequency and quality of rubbish collections and make it easier to recycle. Rather than focusing on a blanket call for weekly collections, the focus is on smelly waste, which the Review says the public has a reasonable expectation to expect to be collected quickly;

– Collection code: Building on the WRAP Waste Collection Commitment, the Recycling and Waste Services Commitment will be published shortly and is described in the Review as a stronger statement by local authorities of a willingness to consult fully, to listen to and work with householders; to provide information about recycling and re-use and to make it easier for householders to do the right thing. According to the Review, householders will be able to able to hold councils to the principles of the Commitment and also raised the potential for them to challenge councils if they dont sign up to it;

Defra acknowledged in the review that some householders have an issue with separating out food waste for collection
Defra acknowledged in the review that some householders have an issue with separating out food waste for collection

– Food waste: Despite claims in the national press that the Review commits to a slop bucket for every home, there is no explicit advocacy of separate food waste collections as the only option for capturing the waste stream. Indeed, Defra states we know that some consumers do not like separating out their food waste and notes that local circumstances will dictate collection methods. But, given the Reviews strong support for AD, separate food waste collections look set to have a key role to play in securing the feedstock needed for the roll-out of that particular treatment technology;

– Fines and enforcement: The Review addresses the governments concerns over bin snooping and bin spies with a range of measures such as stopping councils from inspecting household waste and from fining households up to 1,000 for presenting their waste for collection incorrectly. Instead, it states that: Enforcement must be targeted at the small minority who harm the local environment and local amenity due to their irresponsible behaviour. As well as removing criminal sanctions for these offences, the Review proposes the introduction of harm to local amenity as a test to be applied before councils apply any civil penalty;

– Incentives: The government has made no secret of its preference for the carrot not the stick and the Review reiterates its support for schemes such as US-devised recycling rewards scheme RecycleBank. It also details a 500,000 fund to support innovative reward and recognition schemes and reveals government has commissioned research to find the most effective methods of rewarding people;

– Reporting requirements: As revealed by letsrecycle.com two months ago (see letsrecycle.com story), the Landfill Allowance Trading Schemes, or LATS, will be scrapped at the end of 2012/13, with the landfill tax escalator now seen as the main driver for keeping waste out of landfill. This is one of a number of steps outlined in the Review which Defra claims will remove some of the bureaucracy and burdens which have hindered local authorities delivery of front line services for too long. These also include: no new council recycling targets to replace the old National Indicators; the replacement of the Controlled Waste Regulations (1992) to end the Schedule 2 situation; further changes to the data required for the WasteDataFlow database with a carbon metric reporting tool being promoted which could possibly tie in with WDF; and, consulting on a potential end to the need for Joint Municipal Waste Management Strategies.

Businesses

Defras approach to business waste in the Review pays particularly close attention to small and medium enterprises, or SMEs. The department says that it wants to make it easier and more cost effective for SMEs to recycle, with the abolition of LATS detailed above seen as removing an important perceived barrier to councils running SME waste services.

Other measures outlined in the Review include:

The review outlines plans to encourage councils to make HWRCs available to small and medium-sized businesses, or SMEs
The review outlines plans to encourage councils to make HWRCs available to small and medium-sized businesses, or SMEs

– HWRCs: Defra says it will encourage councils to consider whether they can adapt their household waste recycling centres and bring banks for use by businesses, so firms can access recycling and waste management facilities at an affordable cost. The department claimed the revenue raised from this move could keep HWRCs threatened by closure open. This move is likely to be welcomed by the Federation of Small Businesses which had identified HWRC access as a key way to make it easier for SMEs to recycle more;

– Bring banks: Defra says it will work through WRAP to develop similar initiatives to the trade waste bring banks rolled out on a trial basis on Merseyside and in Bristol;

– Developing a Business Waste and Recycling Collection Commitment: To be published this summer, councils will be encouraged to sign up to principles setting out how they can help businesses to meet their waste responsibilities and recycle more;

– SME waste voluntary responsibility deals: In the review, Defra said it would work with the waste management industry to cover issues such as raising SME take up of recycling services, improving data on commercial and industrial (C&I) waste and raising awareness of waste prevention and sustainable waste management. Defra says it has been working with the ESA, FSB, LG Group and EA on this agreement, which will also promote quality to tie in with the new MRF Code of Practice The responsibility deal was announced in late June 2011 (see letsrecycle.com story);

– Sector-specific voluntary responsibility deals: The government made no secret of its support for voluntary producer responsibility ahead of new regulation in the lead-up to the Review and this is borne out in the final document. Among the sectors where deals will be considered are the hospitality sector, the paper industry, direct mail and textiles. A working group will also be established to discuss toy packaging, similar to that set up to address Easter egg packaging.

– Packaging: Continuing this voluntary approach, Defra said in the Review that it will work with businesses to encourage greater use of recycled content in packaging and to make packaging more recyclables. It also outlined plans to consult on new packaging recycling targets for 2013 to 2017 (see separate section below).

Waste management industry

Waste companies will have a key role to play in many of the measures outlined above to tackle household and business waste, but there are also a number of aspects of the Review that more specifically impact on the waste management industry.

These include:

The review includes a commitment to explore regulatory issues around areas of the industry such as composting
The review includes a commitment to explore regulatory issues around areas of the industry such as composting

Lighter touch to enforcement: It emerged in January 2011 that Defra was exploring the role that standards and accreditation could play in reducing the regulatory burden on businesses as part of the Review (see letsrecycle.com story) and the final document confirms this, with work on the provision of standards one of the main areas to be addressed under the banner of allowing businesses to fulfil their obligations more easily. The document also outlines measures to better integrate regulatory controls in the best interests of people and the environment, such as closing gaps in the evidence base to ensure regulatory requirements are based on the best available information the potential risks to health from bioaerosols produced during composting are given as an example in the review. This is balanced against tough talking on those who do break the rules, with a commitment to rebalance the approach taken to regulation to more markedly enforce against non-compliance.

Responsibility deal: As detailed above in the business section, this is a voluntary commitment by waste companies to improve the experience and access of SMEs to recycling services. The deal was formally launched on June 23 (see letsrecycle.com story).

MRF Code of Practice: Described by Defra in the Review as an industry-led initiative, the Code is expected to include requirements to measure the quality of input and output materials at materials recovery facilities (MRFs). Defra says this is key to maintaining the credibility of commingled collections under the revised Waste Framework Directive as well as future market for recyclable materials, in the UK and abroad. In the Review, it raises the potential for the Code to be mandatory. Further detail of the code proposals was revealed last week (see letsrecycle.com story);

Export controls: There is no promise of new action to tackle the issue of illegal waste exports, but Defra says it will continue to encourage the Environment Agency to prioritise the issue using pioneering techniques and an intelligence-led approach.

Key areas

There are several other key areas of the Review which have already attracted considerable attention. These include:

A consultation on restricting landfilling of wood waste is expected next year
A consultation on restricting landfilling of wood waste is expected next year

Landfill bans: Reviving a policy idea previously explored by the last government and later discounted, in the short-term at least, by the current one the Review commits to a consultation in 2012 on restricting landfilling of wood waste, in a bid to push it up the waste hierarchy. Defra also says it will review the case for landfill restrictions for other materials between now and 2015, including textiles and biodegradable waste.

Energy from waste: Despite industry pressure for the Review to explicitly support energy-from-waste incineration, the document takes a more cautious stance, stating that our aim is to get the most energy out of genuinely residual waste, not to get the most waste into energy recovery. Instead, Defra says it will make information is available to communicate the full range of recovery technologies and their relative merits.

Anaerobic digestion: The energy from waste technology to receive the most specific attention in the document is, as expected in the lead up to its publication, anaerobic digestion, with Defra claiming that, for food waste, AD is considered to deliver a better overall environmental outcome than recycling the waste, taking into account the local economic and environmental considerations. The Review claims that AD could reach 3-5 terawatt hours of installed electricity generating capacity by 2020, as well as highlighting its landfill diversion and emissions saving potential. And, in light of this, and AD Strategy and Action plan was published alongside the Review to set out how the government aims to overcome the barriers to achieve these aims, including a 10 million loan fund (see letsrecycle.com story).

Planning: Often identified as one of the main barriers to developing new waste infrastructure, planning is given relatively short shrift in the Review itself, with Defra confirming it will maintain the current threshold for only large scale (over 50MW) energy-from-waste plants to be decided centrally, with smaller infrastructure decisions still sitting at a lower level. However, it does pledge to explore whether a system of industry protocols for community benefits similar to that used in the wind sector could be used in waste.

Infrastructure: The Review confirmed a detailed breakdown of government policy on waste infrastructure will be included in the revised National Infrastructure Plan, which is due to be published in November 2011.

Future packaging targets are yet to be set, although the review did reveal they would be consulted on next year
Future packaging targets are yet to be set, although the review did reveal they would be consulted on next year

Packaging targets: The government used the Review to commit to a consultation on increasing packaging recycling targets for the period 2013 to 2017, but stressed that any final decision will have to take into account the review of the EU Packaging Recycling Directive which is due in 2014. Defra stressed that it would make a final decision on targets in the 2012 Budget (see letsrecycle.com story).

Waste prevention: With prevention the top priority under the rWFDs waste hierarchy, the Review states that, as required under the Directive, a comprehensive Waste Prevention Programme is to be developed by the end of 2013. It also reveals that a Waste Prevention Fund will be set up, to allow businesses, social enterprises and councils to carry out waste prevention activities. The WRAP-managed fund is expected to be worth 1 million.

Deposit schemes: While acknowledging the potential a deposit scheme for beverage containers could offer in terms of increasing recycling rates and saving councils money, the Review concludes that concerns over the very high cost of running a system mean it is not taking forward the option of introducing a deposit system for the time being.

Recycling on the go: The commitments made in the Review to encourage recycling in public places focus on improving communications, with WRAP and Keep Britain Tidy bringing their recycling and anti-littering messages together and councils trialling recycling as part of their Big Tidy-Up events in 2011/12.

Civil society: Short-term measures outlined in the Review to increase civil society involvement in waste and recycling include making it easier for civil society groups to deliver waste services, and examining how they can become involved in work delivered by WRAP and the EA, as well as encouraging partnership working and engaging them in policy development.

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