"Working for our members to be the voice of government on waste minimization and recycling issues"
Policy Positions:
LARAC's Advocacy Role has become more important as the rate of environmental policy-making has increased and Europe has become more prominent in this area.
As an officer-led organization within local government, LARAC has as its main Raison d' Etre to provide an information and networking service and develop and disseminate good practice among our members. However, we are also advocates - making the voice of waste practitioners heard and ensuring that our views are taken into account when decisions are taken, regulations made and laws passed by the Government. This role has become more important as the rate of environmental policy making has increased and Europe has become more prominent in our area. It has become increasingly obvious that, even though we put our trust in the professional judgment and good common sense of our leading Executive Committee members, common and understood positions on matters of waste policy are needed to ensure that our message continues to be consistent, environmentally sound and representative of our membership.
Some of these policy positions are uncontentious - we use the waste hierarchy as a guide. Some are more debatable: What is LARAC's position on Energy from Waste? Do we prefer energy generation or compost from residual waste? What about Alternate Weekly Collections (AWCs)? What about Recycling Credits? We have developed very general positions in areas in which we don't have special expertise but which nonetheless have a bearing on the job in hand, which is to deliver high quality and environmentally responsible waste management services to the communities we serve - funding and investment, joint working and local authority structures.
The string of statements is not comprehensive and will, we hope, be alive to debate and further development as our legislative and technical world evolves. I hope members will feel free to continue to contribute insights, knowledge and suggestions of further areas in which LARAC's policy needs to be clarified, debated and better understood.
WASTE MINIMISATION
Waste Hierarchy:
LARAC upholds as a basic principle. Measures to reduce waste and promote re-use or re-manufacture have the highest priority because generally information from Life Cycle Analysis (LCA) shows that closed loop recycling & composting are better for the environment than energy recovery and energy recovery is better than landfilling. Variations from this principle may be accepted if LCA demonstrates a benefit.
End of Waste:
Materials should be designed to remain in economic circulation for as long as possible, only being discarded when this is no longer possible. All means should be sought for making materials that have to be disposed of at the moment available as secondary materials or fuels. This means giving priority to developing standards for what is "fit for purpose" for applications and markets where primary products may be displaced - where there isn't a significant environmental disbenefit. Examples are:
- compost, where (contrary to the position of the Composting Association) materials that may be separated from Municipal Solid Waste MSW) through Mechanical & Biological Treatment (MBT) could be certified as suitable for certain applications, so long gas they met standard criteria. This would have the additional benefit of encouraging the development of MBT processes that produce stabilised biomaterials suitable for use on land and not landfilling.
- waste mineral oil, where the use as secondary fuel replacing oil or coal is supported, provided that it is burnt in plant where harmful emissions are not increased relative to the primary fuel (this would improve the economics of waste oil recovery for local authorities) - Secondary Recovered Fuel (SRF), where, again, the development of standards should be used to promote the use of materials produced from municipal wastes as secondary fuels.
Waste Minimisation & targets:
This is a complex area in which whole product lifecycles, durability, remanufacture and international trade and energy policy all have a significant bearing. As better LCA information becomes available, LARAC's policy is to work with producer organizations, retailers and Government to develop systems that will avoid waste, reduce unsustainable consumption and reduce harmful emissions. Local Authorities should have power to set their own targets for minimizing waste as much as achieving national targets will allow.
Residual Waste Management:
LARAC supports measures that reduce residual waste to the lowest practicable level. Where possible, responsible organizations are to be encouraged to design out waste, for instance by avoiding excessive or unnecessary packaging, light-weighting single-use packaging, and improving designs to extend useful life and avoid obsolescence. LARAC supports measures and activities that prevent, reduce, re-use and recycle wastes. LARAC also broadly supports measures that actively encourage householders to think about and reduce the waste they throw away, for example specifying bin sizes, charging for certain waste types, alternate weekly collections and compulsory recycling schemes.
Direct charging for household waste:
LARAC broadly supports measures that will provide local authorities with the power to implement direct charging mechanisms in order to reduce residual waste quantities and increase recycling rates. Such mechanisms should be fit for purpose, cost effective and administratively proportionate to the desired outcome.
RE-USE
Third sector:
LARAC wishes to promote the involvement of the third sector but acknowledges that in some parts of the countries the potential benefit for established systems may be limited. Where third sector organizations can deliver true community involvement and/or services of the required quality they are to be encouraged.
COMPOST
Composting:
in all its forms is preferred to energy recovery where returning biodegradable material beneficially to land is technically feasible. Home composting is the best and preferred means of achieving this. Although emissions of carbon dioxide are only slightly reduced, the quality of soil is also an important environmental consideration. Compost is also a means of sequestering carbon in soil.
LATS/LAS (England & Scotland):
LARAC strongly supports the inclusion of material diverted through home composting in landfill returns, although this needs to be introduced as a long term measure and not in a way that would add further uncertainty or unfairness to the market in the short term. It is very important that local authorities are given strong incentives to promote home composting. Assessments of the biodegradability of residual waste should be conducted regularly instead of counting in biodegradable wastes that are diverted through composting when calculating local authority obligations. LARAC supports further investigation of additional measures that will reduce the biodegradability of residual waste, such as sink macerators. The Government should find means of taking non-household waste out of LATS altogether, because this inhibits the development of local authority trade services. A level playing field is needed between local authority and private sector management of commercial wastes.
RECYCLING
Quality:
LARAC acknowledges that the wider market acceptance of secondary materials in place of primary depends on paying attention to the quality of materials coming out of local authority schemes. "Quality" and its close relative "Fit for Purpose" are a high priority issue. Although LARAC does not seek to prescribe what systems or processes should be used to achieve quality, LARAC will work with its members, contractors, specifiers, recyclers and WRAP to develop appropriate specifications and promote good practice.
Trade recycling:
LARAC encourages its members to offer and promote trade recycling (as opposed to collection & disposal) services, and more sustainable waste management practices in non-household waste streams generally. Management of trade wastes (as well as of some waste streams that may be defined as household waste – see under Controlled Waste Regulations - 7 below) should not be subsidized from local authority budgets. Trade wastes, as well as household waste, should be subject to treatment through provision of separate recycling facilities, although the Environment Agency's position of treating all municipal waste as though it were treated prior to landfill is not challenged. LARAC does not support withdrawal from provision of trade services. Local authorities should, however, have powers to require their trade waste customers to separate wastes for recycling in containers specified by the local authority. However, note also LARAC's position on LATS - 8 above.
Producer responsibility and packaging:
LARAC will press the Government to review fundamentally the application of producer responsibility to packaging, and in the mean time work with ICER and retailers to reduce the numbers of over-packaged products that are sold. Local authorities still pay for the separate collection of most packaging for recycling. Full costs of collection and management of "producer responsibility" waste streams should be borne by producer organizations, in partnership with local authorities, that would be expected to retain a co-ordinating role. Producer organizations should also contribute significantly to the costs of waste awareness and promotion campaigns and provision of information, not the public purse.
Recycling Credits:
LARAC favours local authorities making payments to partner organizations based on avoided residual waste disposal costs for new projects where recycling will be increased. However, local authorities should not be forced to pay "discretionary" recycling credits for activities that private sector or third sector organizations would be carrying out anyway or which compete for material already collected under an existing scheme. In particular LARAC opposes any initiatives whereby the payment of recycling credits is demanded in exchange for information, or local authorities are required to pay recycling credits to private sector organizations to help fund collections of packaging waste.
Export of recyclables:
LARAC hasn't a fundamental objection to recyclable materials being exported outside of the EU (assuming that trans-frontier shipment (TFS) regulations are observed), but LARAC promotes and supports the development of local and indigenous industries and organizations that recycle, and use, secondary material streams.
Deposit and Return Systems
LARAC acknowledges that deposit and return systems for non-refillable, recyclable beverage containers can encourage householders to recycle and may reduce litter. It welcomes producer's efforts to introduce such systems, provided that collection tonnage figures are reported to Local Authorities.
LARAC does however consider that
• separate kerbside collections for the same packaging materials will remain necessary as a result of legislation and to capture non-drinks containers of the same materials
• running a deposit and return system will mainly divert materials away from kerbside recycling collections (where available)
• running deposit and return systems concurrently with kerbside collections may confuse householders
• with appropriate funding there is still scope for significant expansion, improvement and promotion of kerbside recycling collections
and that therefore further investment in Local Authorities’ kerbside collections is preferable to investment in deposit and return systems for non-refillable beverage containers.
LARAC would like to see the Producer Responsibility principle applied to household packaging waste and would strongly support a PRN system with separate targets for household and commercial waste or with separate targets for primary, secondary and tertiary waste as a means of implementing this principle.
LARAC deems that refillable packaging systems can contribute to waste prevention and resource efficiency. In the Waste Hierarchy, waste prevention features above recycling, and provided the environmental cost of collecting, cleaning and refilling containers does not outweigh the beneficial effects mentioned and the economic cost is reasonable, it supports such systems. Where systems exist for using re-fillable packaging, LARAC unreservedly supports re-use over other methods of treatment or disposal.
LARAC would suggest that waste prevention targets, impacting on producers of household packaging waste, may act as an appropriate incentive for the introduction of refillable systems, but, in the light of other options open to the industry (such as lightweighting), and the logistical challenges of operating deposit and return schemes, LARAC does not suggest that they should be made mandatory”.
Standardisation:
LARAC supports a long term drive to standardization of two aspects of recycling collections, namely the colour of containers and the range of materials collected. It would however not wish to see a standard system be made mandatory for Local Authorities, and recognise that local circumstances may determine non-standard systems, particularly in the short term. Standardisation would aid clarity for householders, and facilitate national communication, including labelling on packaging (which should be funded by packaging producers); however any national communications must make it clear that details may vary locally. Standardisation would also benefit MRFs and reprocessors. Any standard system must remain flexible enough to allow adaptations to technological improvements.
RESIDUAL WASTE TREATMENT AND ENERGY RECOVERY
Energy from Waste:
Highly efficient conversion of waste materials into energy is promoted, including Anaerobic Decomposition and mass burn incineration with Combined Heat & Power (CHP). LARAC supports the WFD proposals to classify the most efficient processes as "recovery" and not "disposal". LARAC would not support an incineration tax now, but would support long-term policies that will have the effect of continuing to move waste management up the waste hierarchy.
Renewable Energy from Waste:
LARAC considers that, as the Renewable Energy content of mixed waste is the energy contained in the biowaste fraction of that waste, the most efficient process for extracting the renewable energy depends on the nature of the biowaste fraction and Renewable Energy policies should be designed to encourage the most efficient methods. Source-separating waste, so that the various fractions may be recycled, digested or incinerated to achieve optimal environmental benefit, is encouraged. LARAC deems incineration of biomass (including woody biomass) that could contribute to the sequestration of carbon in soil via compost should not be generously banded relative to renewable technologies that do not emit significant tonnages of carbon dioxide.
LARAC would like to see clear definitions with distinctions made between wet biomass waste, woody biomass waste, and energy crops. It proposes that the term biowaste (defined by the European Commision to exclude the paper and card fraction) may be useful in energy policy; although in certain circumstances (such as long term absence of markets for recyclate) it may be expedient to use paper and card waste for energy generation, this should not be awarded with high ROCs. It would also like to see further efforts to develop standard conversion methods between energy content and gas generating potential of biomass, taking into account moisture content.
LARAC suggests that the ROC band for ‘Energy from Waste with CHP’ should be clarified as several technologies in other bands also generate energy from waste with CHP.
As with generating plant from non-renewable sources, LARAC strongly supports CHP installations and welcomes measures to identify and develop heat markets.
FUNDING AND INVESTMENT INCLUDING DISPOSAL
Funding:
LARAC would ring-fence public and private sector funding needed for the development of more sustainable waste management systems as far as practicable. Income streams from direct charging schemes (see 5 above) and increased landfill tax revenues should be included in ring fenced funding streams.
Disposal of household waste streams:
The Government should conduct an early fundamental review of the Environmental Protection Act 1990 and the Controlled Waste Regulations 1992, specifically the lists in Schedules 1 and 2 (defining types of household waste for which a charge for collection may be made), in the light of current practices and expectations, in order to ensure that local authorities are not required to fund the disposal of waste from universities, colleges, schools, hospitals, prisons, caravan sites and commercial organizations such as care homes and camping sites, and that organizations that will not separate wastes for recycling into containers specified by the council are not entitled to receive free or subsidized services.
Investment:
Government should invest sufficiently and early enough to ensure that waste treatment and recycling infrastructure is developed in time for European targets for reducing reliance on landfill and increasing recycling are achieved. PFI is one model among many that the Government should use to promote investment in infrastructure for residual waste. The Government shouldn't rely on PFI as its only significant vehicle for investing in local authority waste management. The resourcing and development of partnerships involving building merchant plants that are shared with local authorities is not sufficiently encouraged.
JOINT WORKING AND LOCAL AUTHORITY STRUCTURE
Joint working and Local Authority structure:
LARAC is aligned with the LGA, which promotes autonomy for individual local authorities. The development of joint waste authorities and partnerships is a matter for democratic processes in the areas affected to determine. However, where joint procurement exercises and sharing services enable services to be improved whilst retaining effective democratic accountability, this is supported. In the longer term, LARAC will work closely with national and regional authorities (using and developing its own devolved and regional structure) where authority is devolved downwards by the central Government, to promote more sustainable municipal waste management practices
Andrew Craig, updated: 27.04.09