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 Target: to recycle 40% of household waste by 2005 CONSULTATION DOCUMENTS |
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Target: to recycle 40% of household waste by 2005 CONSULTATION DOCUMENTS |
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| Covering letter re consultation on the waste treatment requirements of article 6(A) of the landfill directive. Richard
Silver 18 January 2002 Dear Mr. Silver Consultation on the waste treatment requirements of article 6(A) of the landfill directive. Attached are comments on the above consultation document made on behalf of Project Integra, a working partnership of Hampshire County Council, its constituent district councils and the unitary authorities of Portsmouth and Southampton cities. Thank you for the opportunity to make these comments. If you require any further comment or clarification, please contact Ian Fielding on the above telephone number or e-mail address. Yours sincerely, Ian Fielding PI response to consultation on waste treatment The following is a response to the consultation on waste treatment requirements of Article 6(A) of the landfill directive published by the Environment Agency in October 2001. This response is made on behalf of the local authority and private sector partners of Project Integra, namely:
Any enquiries about this consultation should addressed to:
Consultation on draft guidance on the waste treatment requirements of article 6(A) of the landfill directive. Response by Project Integra Project Integra is grateful for the opportunity to comment on the draft guidance and welcomes the Agencies attempts to provide authoritative advice to industry, operators and local authorities on how to comply with the requirements of the Landfill Directive regarding the treatment of waste. However, we have three fundamental concerns:
These points are expanded on below: The draft guidance is based on a stated Government view that treatment must fulfil three basic criteria. The criteria reflect the drafting of the Directive and draft UK regulations except that "volume" in the draft Regulation is substituted for "mass" in the consultation document. We are unclear where the stated criteria originate from, and are concerned that the substitution of the word volume indicates that the Agencies’ guidance is based on a pre-conceived assumption that compaction of waste should not constitute treatment. Also, the guidance states on several occasions that treatment should take place prior to landfill, but the Directive and draft regulation require only that measures be taken to ensure "waste that has been subject to treatment is landfilled". This does not preclude the landfill operation itself constituting the treatment although this is not considered at any length within the guidance. It is further argued within the guidance (para 2.2.2.) that consideration of transport impact may not be used to avoid treatment. Given that the Directive specifically identifies that treatment may be in order to facilitate handling of waste, we do not accept, as stated in the guidance, that consideration of transport impacts is contrary to the Directive and we conversely argue that ignoring the transport benefits associated with compaction is counter to the principle of the Directive. Transport implications must be part of the overall assessment of the BPEO of the waste stream being considered and compaction is a vital element of reducing the net environmental impact. There is further contradiction in the draft of the assessment criteria between paras 3.2 and 3.3. The suggested characteristics of waste that need to be changed to constitute treatment are set out in table 3.1. Included in the table are hazardousness, volatility and combustibility which directly relate to the ‘in order to’ examples given within Article 2 of the Directive. However, there is no reference to waste density which is a key characteristic of any material, and one which similarly relates directly to the other examples given within Article 2; reducing volume and facilitation of handling. It is easy to argue that the intention of the Directive is to reduce reliance on landfill, and compaction does not, in itself, do this. However, the arguments in the draft guidance to support this assumption are weak, and do not take into account the fact that high levels of compaction within a landfill site fulfils the underlying principle of the Directive, in that it reduces the number of operational landfill sites as effectively as reducing the amount of waste requiring landfilling. Such an argument also fails to take into account the other legislative requirement that will deliver the principles of the Directive. Local authorities are required to meet minimum recycling performance standards as well as reduce the reliance on landfill for biodegradable waste to minimal levels by 2020. These measures alone will deliver the principles of the Directive for municipal waste without the further need to demonstrate ‘treatment’. We therefore do not believe that the arguments against counting compaction (either to facilitate transport or within the landfill operation) as treatment are proven. Project Integra are concerned as to how the guidance will be applied and enforced. It is suggested that separation at source will constitute treatment for municipal waste, which is welcomed as a practical response, However, the guidance clarifies this as meaning where such separation is designed to meet statutory recycling targets. This doesn’t take into account the whether such targets are actually being met, and the significant variations between authority targets. It introduces inconsistency in application for identical wastes, and creates confusion as to how compliance will be monitored and enforced. Why for instance, would an authority meeting its recycling target of only 20% be considered as having treated its waste whilst another recycling 30% but failing to meet its target of 33% be considered as not having treated its waste? What action would the Agencies take in such circumstances? If the onus is on the operator to monitor and control deliveries of treated waste then an authority effectively becomes accountable to its contractor who may refuse to accept waste rather than risk prosecution? Including separation at source as adequate treatment for municipal waste also fails to take into account the separate obligation to reduce biodegradable municipal waste to landfill, which in itself will require treatment. It is also unclear under what conditions further treatment of the residual element of the segregated waste stream would be required under this provision, and what tests would apply? For example, what level of recovery of what materials would be adequate so as not to require further treatment? The lack of clarity within the consultation document on these issues is preventing a full assessment of the practicality and workability of the guidance but, in our view, inclusion of municipal waste within the requirement for treatment adds no value, is unlikely to bring about any change in itself, and is therefore un-necessary. It is likely only to lead to increased administration, without contributing in itself to the landfill directive objectives. The objectives of the Directive will be delivered for municipal waste in other ways. If a definition of treatment for municipal waste needs to be developed, then the proposals to include source separation are welcomed, although this gives rise to significant concerns about fairness and consistency, and enforcement. Karl Nsiah Dear Mr. Judson Government consultation on distribution of the £140 Million waste minimisation and recycling fundAttached are comments on the above consultation document made on behalf of Project Integra, a working partnership of Hampshire County Council, its constituent district councils and the unitary authorities of Portsmouth and Southampton cities. Thank you for the opportunity to make these comments. If you require any further comment or clarification, please contact Ian Fielding on the above telephone number or e-mail address. Yours sincerely, Ian Fielding
PI response to consultation on £140 Million fund The following is a response to the Government consultation on the distribution of the £140 Million waste minimisation and recycling fund published by the Department for Environment, Food and Rural Affairs in November 2001. This response is made on behalf of the local authority and private sector partners of Project Integra, namely:
Any enquiries about this consultation should addressed to:
CONSULTATION ON ADDITIONAL FUNDING FOR WASTE MINIMISATION AND RECYCLING RESPONSE BY PROJECT INTEGRA Project Integra is grateful for the opportunity to comment on the DEFRA proposals for the operation and distribution of the new £140 million waste minimisation and recycling fund in England. Project Integra was awarded Beacon Council status for Sustainable Waste Management and has been successful in implementing an integrated strategy that is delivering around 25% recycling over a population of 1.6 million and is set to achieve recovery levels in excess of the Landfill Directive requirements when three new energy recovery incinerators are commissioned over the next three years. This achievement has involved a very substantial financial commitment on the part of the partner authorities and further substantial funding is needed to maintain the momentum to achieve our longer-term 40% recycling objective and meet our Best Value Performance Indicator (BVPI) targets. Thus funding recycling is a very important issue in Hampshire as well as nationally. Whilst the £140 million support is to be welcomed, the ‘one-off’ nature of the allocation will not address the core issue of ensuring that adequate on-going revenue funding is available to support intensive recycling. Local authority budgets are under extreme pressure and a long-term national plan to adequately fund recycling and waste management generally is urgently needed. Our current problems are exacerbated by the fact that we currently pay £8.5 million each year in landfill tax, which is effectively lost from the system. If Project Integra had the benefit of this amount to support expansion of recycling (which becomes more difficult and expensive as success raises the threshold) we would resolve at a stroke the funding of the further expansion of recycling and composting to meet our target and BVPIs. Turning to specifics, it is unfortunate that the consultation has been left so late in the day that the timescale for formulating bids and allocating monies for 2002 / 03 is so tight. Hopefully, there are lessons that should be learnt for the future from this situation. Our responses to the questions set out in the consultation document are detailed below.
Do you agree that applications should be supported by a strategic framework on what needs to be achieved? Do you agree that the quality of a strategy should be a factor in determining grants? Our experience in Hampshire over the past eight years has demonstrated the benefits of adopting a strategic approach to waste management in terms of adding value, effectiveness and efficiency. We therefore believe that a strategic approach is vital and that it is absolutely right that the quality of the strategy should be a factor in determining grants.
Whilst waste minimisation is a laudable aim, our experience suggests that achieving a measurable impact in reducing waste volumes is very complex issue that cannot be achieved overnight. A long term strategy and plan to effect lifestyle change is needed and initiatives such as the National Waste Awareness Campaign are crucial to making progress. Given this background, and the short - term nature of the fund, we cannot see that the funding could make a measurable impact on waste minimisation (other than in purely public relations terms). It is therefore right that the majority of the Fund should be focussed on recycling and composting. Analysis of recent growth in household waste shows it to be a complex issue that is not yet fully understood, although it is highly probable that the major influences are outside local authority control. In truth, the actions open to local authorities in tackling growth in household waste are limited and further likely to have little effect compared to other national interventions such as increases in landfill tax. For example, it is probable that the recent failures of industry take-back schemes for fridges will give rise to a 0.5% increase in household waste within Project Integra next year (an increase in growth of some 15%). It is however important to ensure actions aimed at increasing recycling do not attract waste that otherwise would have been disposed of (and often recycled) through means other than the municipal waste stream. Actions need to have regard to the best environmental option for waste, such as home composting as opposed to collection of garden waste, and should take into account the effect on total waste within the municipal waste stream, but grant funding should not be dependant on specific actions aimed at reducing waste growth.
In general terms, do you agree that the funds should be used selectively rather than distributed on a formulae basis? If you think it should be on a formula basis, what formula should be used? The first point is to reiterate that the Fund offers the prospect of ‘one - off’ funding’ which will not address the fundamental problem of a shortfall in revenue funding to support recycling. This is holding back many authorities and is one that the Government needs to address as a matter of urgency. Given the Fund as constituted, it is difficult to see how distribution on a formulae basis would represent best value in terms of kick starting recycling when the blockage may well be in revenue funding. A relatively small one off sum would therefore be of very limited benefit to many authorities in terms of investing for the future and we therefore support the selective allocation of the Fund.
In broad terms we support the approach adopted but would make the following comments about the priorities as proposed. The distribution mechanism finally adopted needs to send out clear messages about the responsibility individual local authorities have for improving recycling in a strategic, cost effective and sustainable way. The mechanism should therefore recognise those authorities who have invested in recycling and improved performance as well as those who have hitherto given recycling a low priority. Also it should be recognised that reaching a lower recycling performance threshold is relatively easy and proven, but that costs increase when moving to higher levels. It can therefore be argued that the problem of poor performance should be addressed through the Best Value regime and that support from the Fund should be conditional on poor performing authorities demonstrating that they have already done all that is reasonably possible to improve. It is also questionable whether the Fund should be supporting community initiatives when there is substantial funding for this area available through the New Opportunities Fund (we do however recognise that the proposed Fund allocations to community initiatives are quite modest). Having regard to the above points, we would propose that the key priorities for the Fund should be:
The lack of a distribution structure at regional level and the tight timescale would seem to mitigate against allocation on a regional basis in the short term. Research is needed on the regional variations in recycling achievement and the associated reasons to inform whether a longer term shift to this approach would be beneficial.
We would prefer to see the Fund distributed equally between the three priority areas set out above. However, on the basis of the priorities and indicative allocations set out in the consultation, we would prefer to see the sums allocated to turning round low performance and general projects reversed, i.e. £35m to low performance and £50ml to general projects. There should also be flexibility in allocation grants to projects that meet the criteria of more than one type of project, so as not to frustrate the ability of an appropriate project to receive adequate funding merely because it can only be counted against one type of project. We would prefer to see the funding allocations for partnerships, innovation and general projects increased in 2002 / 2003. Given the one off nature of the allocations, there is very little difference in practical terms to local authorities in the division between capital and revenue support. It will also be more challenging to spend a full years revenue allocation within the year when grants will only be confirmed at the end of April.
Agreed.
It needs to be stressed that PSA funding supports the achievement of enhanced recycling targets not the achievement of BVPIs for recycling. On this basis it would be very unfair if authorities were to be excluded from Fund support to achieve their BVPIs on the basis of existing PSA support which is only intended to reward achievement of an enhanced target over and above BVPIs. It is also important to draw a clear distinction between PSA support for traditional recycling initiatives and new resource management approaches that seek to address the issue upstream in terms of production, consumption and reprocessing. There is currently no Government support other than the PSA route and the possibility of WRAP support for local authority work in this area.
Do you agree that partnership working between authorities should be supported by the Fund? Do you agree with the type of projects and the criteria we propose to use in assessing applications under this heading? We support the inclusion of partnership working and propose that the fundamental objective should be to demonstrate added value to the community (e.g. in terms of cost efficiencies, achievements that would otherwise be impossible) through partnership working. We agree that the criteria in selecting projects should be the tonnage to be recycled and / or additional materials to be diverted as a result of the initiative. It is important that the Fund supports the development and expansion of existing partnerships a well as facilitating the creation of new ones. The transfer of expertise and best practice between groups of authorities is as important.
Project Integra fully supports the principle of pooling targets but we have difficulty in understanding the benefits of doing so as outlined in Annex D. Pooling targets is a natural extension to the process of collaborative working and implementation of joint strategies. However, to be effective, any pooling of targets must remove the divisive elements of individual ones. The proposals in Annex D appear to require each authority to retain an individual target and do not therefore remove individual accountability for their achievement. Project Integra does not believe the proposals outlined in Annex D will be attractive to local authorities for the simple reason that, by definition, at least one authority within each pooling arrangement will be required to replace its performance target with a higher one. The proposals will need to be changed to enable pooling authorities to be jointly accountable for a single pooled target if they are to be attractive and therefore effective. Individual targets would then cease to have relevance for those pooling authorities.
Do you agree that we should support projects that seek to deliver innovation and help achieve high performance? Do you agree with the type of projects and the criteria we propose to use in assessing applications under this heading? A number of local authorities have BVPIs for 2005 /06 of 40%. Performance at this level challenges best practice in the UK and it is vital that funding is given to develop large scale systems to achieve these levels. We therefore support the proposals under the section.
Do you agree that we should support projects that focus on turning-around low performance? Do you agree with the proposed approach? There needs to a clearer definition of what constitutes low performance and clarity between low performance as a result of real practical barriers and that simply as a result of failure to give due priority to recycling. It is questionable whether or not the Fund should support the latter when many other authorities have struggled to improve performance in very difficult circumstances.
Do you agree that some ‘general projects’ should be supported by the Fund? Do you agree with the criteria we propose to use in assessing applications under this heading? The concept of the challenge fund, including the concept of improving the cost – effectiveness of recycling, is welcomed.
Do you agree that we should support projects that focus on developing community initiatives? Do you agree with the type and of projects we are looking to support under this heading? Do you agree with the proposed criteria? As noted above, it is questionable whether or not the Fund should focus on this area given the substantial funding available for community initiatives under the New Opportunities Fund. There should be sufficient flexibility to allow local authorities to bid for relevant support services to the voluntary sector under the NOF. More co-ordination and targeting of the various funding sources to support strategic cross - sector recycling plans is needed.
Do you agree with these proposed timetables? This would appear a reasonable way forward given the circumstances
We are very concerned that the funding will be granted on a single year basis, to the detriment of projects, which form part of a strategic plan with implementation lead - in period or are to be implemented over more than one year. Getting funding for year one does not solve the problem of getting such projects off the ground and we would request that account taken of linkages between the two funding rounds for such continuation projects and that this be a factor in establishing priorities for allocating funds. This type of arrangement used to apply to the former SCA allocations for capital expenditure on recycling. Whilst we appreciate your wish to understand how any future cost commitment will be met, this raises again the need for additional on-going additional revenue funding for recycling. This is hopefully something that the Government has recognised and is addressing. Whilst it is reasonable to ask for information about future funding, the Government needs to be realistic is recognising the difficulty that many authorities will face in making on - going revenue commitments at this time. The key point therefore is to ensure that funding is directed towards strategic sustainable proposals that will deliver in an effective and cost - efficient way rather than focussing too much on whether future funding is covered at this stage. We support local authorities and / or groups of authorities being able to bid for support under a number of categories, particularly where this is part of an overall plan to increase recycling in the area. It would be sensible for such bids to be prioritised so as to receive partial funding if appropriate.
Our main concern about adopting the expert panel approach for 2003 2004 is to ensure that it does not result in a change in approach to the allocation of funding, particularly continuation of support to on-going plans. As noted above, the urgent need is for certainty in funding strategic plans to achieve what are in Project Integra’s case very challenging recycling targets. It would not be helpful to change tack in mid course of a two year cycle.
We welcome the developing idea that the various funding sources need to be co-ordinated
to the extent that the various programmes support integrated strategic recycling plans.
This was a key message put over by the New Opportunities Fund speaker at the consultation
road shows. Monitoring, Review and Reporting Do you agree with the proposed approach to monitoring, review and reporting. Agreed, although it needs to be recognised that the development timescales for capital infrastructure (such as MRFs) may be too great to enable full expenditure of allocated funds by the end of 2003/04. It would be useful to have the ability to draw down funds at the start of a project, or roll them over into subsequent years, and therefore provide commitment to the full funding of development works spanning more than one financial year.
Response to the SEERA Regional Waste Management Strategy Consultation Draft "No Time to Waste" Introduction The response is in two parts – General comments and specific responses to each of the Policy Proposals. The latter follow the numbering of the proposals (W1-W26) as set out in chapter 7 of the document. 1. General Comments
Fig 1.
The SEERA strategy embraces Integrated Waste Management as a concept and in some respects goes beyond, pointing towards IRM. It may be considered to be at point S1 on the continuum. The strategy could jump to point S2. Project Integra along with its partners in the Hampshire Resources Initiative are willing to assist SEERA in the consideration of how this could change the focus of the strategy. The IRM approach might also help join up thinking in relation to SEERA policy in a number of other key areas. These might include:
IRM will also involve closer engagement with the whole process chain from raw material extraction or cultivation through processing, manufacture, distribution and retailing of products as well as post consumer. Financial Considerations The most striking gap in the draft strategy is how the new infrastructure and collection systems will be paid for. Ultimately the consumer will pay in one form or another. Ideally the externalities (the environmental/social costs) covering the whole of any product’s life cycle would be reflected in the purchase price of any item. Economic instruments or market forces would then channel the appropriate costs to the appropriate part of the resource recovery system. Even if this is completely possible in practice, it will not happen in the short term. In the meantime the environmental/social costs of waste disposal will continue to be passed on to society as whole. To tackle these issues will require significant investment of public money over a long period of investment. There is little indication that the Government is prepared to embrace this.
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