Local Authority Recycling Advisory Committee Conference 2011
"Working for our members to be the voice of government on waste minimization and recycling issues"
"Working for our members to be the voice of government on waste minimization and recycling issues"
As an officer-led organization within local government, LARAC has as its main raison d' être 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 and change 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.
Direct Charging
LARAC broadly supports measures that would 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.
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
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.
Residual Waste Management
LARAC supports measures that reduce residual waste to the lowest practicable level. Where possible, responsible organisations are to be encouraged to design out waste, for instance by avoiding excessive or unnecessary packaging, light-weighting single-use packaging and by using resource efficient product design and manufacture to extend useful life and avoid obsolescence. LARAC supports measures and activities that prevent, reduce, re-use and recycle wastes.
LARAC 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 where these measures fit with local circumstance.
Producer Responsibility (Waste Minimisation)
LARAC strongly supports the use of producer responsibility initiatives. With respect to waste minimisation initiatives that promote reduction of packaging materials, LARAC continues to work with IncPen, British Retail Consortium and other retailers to reduce the numbers of over-packaged products that are sold and where possible promote reusable products (see Deposit & Return).
However, LARAC recognises that some forms of packaging do indeed lengthen the shelf life (and therefore prevent unnecessary wastage) of some products, for example shrink wrapped fresh fruit and vegetables. Furthermore, some such essential packaging requirements oftentimes lead to confusion of material types and thereby effectively reducing the recyclability. LARAC supports as far as possible, options that harmonise protection and recyclability
Waste Minimisation & Targets
This is a complex area in which whole product lifecycles, durability, remanufacture and international trade, as well as energy policy all have a significant bearing. As better LCA information becomes available, LARAC's policy is to work with producer organisations, 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 minimising waste.
Single Use Carrier Bags
Whilst LARAC supports the promotion of re-useable carrier bags; the provision of single use carrier bags is not automatically opposed. Instead their general or restricted use should be considered in as wider context as possible, ensuring full account is taken of the environmental, economic and social implications.
3rd Sector
LARAC wishes to promote the involvement of the third sector but acknowledges that in some parts of the country the potential benefit for established systems may be limited. Where third sector organisations can deliver community involvement and/or services of the required quality they are to be encouraged.
Reuse Credits
LARAC are fully supportive of DEFRA’s position on Reuse Credits available here
Deposit & Return
Non Refillable Containers
LARAC acknowledges that deposit and return systems for non-refillable, recyclable beverage containers can encourage householders to recycle both at home and “on the go” and may reduce litter. LARAC acknowledge that this has been documented in schemes throughout Europe.
It welcomes producer's efforts to introduce such systems, provided that collection tonnage figures can be included in Local Authorities recycling figures.
LARAC does however consider that
Refillable Containers
LARAC deems that refillable packaging systems can contribute to waste prevention and resource efficiency. Waste prevention features above recycling; 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 for these types of containers. In this respect emphasis should be given to materials which add the greatest overall value. Where systems exist for using re-fillable packaging, LARAC supports re-use over less sustainable methods of waste treatment or disposal.
LARAC would suggest that waste prevention targets for producers of household packaging waste, may act as an appropriate incentive for the introduction of deposit return systems on refillable containers, but, in the light of other options currently open to the industry (such as lightweighting and concentrating), and the logistical challenges already identified in other countries, of operating deposit and return schemes, LARAC suggests that introduction of deposit return schemes should in the first instance be undertaken on a voluntary basis.
Large Scale and On farm Composting
LARAC support the use of composting in all its forms and it is preferred to energy recovery. However the continued development of suitable standards and protocols that facilitate use of waste derived materials on land is of great importance to ensure material returned to land is suitable. Furthermore, this should encompass additional research into the risks and benefits associated with such activity and development of protocols and standards for compost in different applications. Standards should be “fit for purpose” for particular uses of compost.
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.
LARAC would support a phasing out of “compost like output” (CLO) as a substitute for daily landfill cover. This is in line with support for an overall reduction in the use of landfill.
Where biodegradable material is heavily contaminated/mixed with plastics, then valorisation as energy may be a better option. What do we say about the development of MBT processes?
Home Composting
LARAC strongly supports the inclusion of material diverted through home composting in landfill returns, although this needs to be undertaken as a long term measure and not in a way that would add further uncertainty or unfairness to the market. It is very important that local authorities (and householders) 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.
Sink Macerators
Whilst LARAC supports the use of existing facilities to manage waste particularly where greater efficiencies can be gained, the large scale use of sink macerators appears both impractical within the current infrastructure and cost prohibitive when compared with local authority food waste collection schemes. However it may be the most appropriate means of managing food waste in certain circumstances, for example in new developments for multiple occupancy where separate food waste collections would be relatively expensive. LARAC believes dialogue with the water industry and, possibly, sharing of facilities, may bring about synergies and benefits to all parties.
Standardisation
LARAC supports a long term drive to standardisation of two aspects of recycling collections, namely the colour of containers and the introduction of a minimum range of materials collected. Whilst LARAC recognises the need for a degree of standardisation at a sub regional level to enable support policies that promote this, it would not wish to see a standard system be made mandatory for Local Authorities, and recognises that local circumstances may indicate 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.
Recycling Credits
LARAC favours local authorities making payments to partner organisations 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.
Producer Responsibility (Recycling)
Overall LARAC strongly supports the use of producer responsibility initiatives including the use of higher packaging recovery targets in both the short and longer term. LARAC upholds that challenging packaging recycling targets are an essential element of not only increasing recycling and reducing carbon, but also in helping user organizations to develop new supply chains out of plastics, cardboard and composite packaging. To this end, LARAC would also welcome further initiatives with respect to tyres and textiles for example.
With regard to recycling in particular, schemes that promote the recycling of goods at the end of their life such as WEEE are further encouraged by LARAC . However LARAC also supports the view that current application of producer responsibility in respect of recycled packaging is not as transparent as it could be in relation to how funds are used to support recycling infrastructure development and collections schemes
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 organisations, in partnership with local authorities, which 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.
LARAC would like to see a fundamental review of the PRN system. In particular those areas of PRN/PERN revenue spend to produce a system that targets investment in the UK’s ability to meet future targets and is transparent enough to give the confidence that it in fact what it is doing.
In addition, LARAC would also like to see the introduction of more challenging recycling targets for producers in both the short and long term as part of encouraging producer responsibility to fund collection systems. Whilst high targets mean more focus will be placed on obtaining waste from the municipal waste stream, LARAC would not wish to see any extra burden be placed on Local Authorities as a result.
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.
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. Local Authorities should not be obligated to manage trade wastes (as well as of some waste streams that may be defined as household waste) thereby subsidising these through public sector budgets, instead Local Authorities should be given choice through the power to subsidise such service should they wish to.
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. In providing a collection service to local businesses, local authorities should have powers to require their customers to separate wastes for recycling in containers specified by the local authority. Section 47 of the EPA allows Local Authorities to specify how householders must present their waste, i.e. in the container provided. LARAC would support a similar approach to Trade Waste through the extension of this provision.
LARAC supports fully WRAP’s Business Waste and Recycling Collection Commitment aimed at providing clarity on the standard aspects businesses can expect should they choose to use local authority refuse and recycling collections.
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. Furthermore a move away from reliance on export markets requires investment in the UK economy which only seeks to underline the importance of the Quality Chain in the development of recycling/resources-based industry within the UK.
Although LARAC does not seek to prescribe what systems or processes should be used to achieve quality, LARAC advocates the need for quality materials and will work with its members, contractors, specifiers, recyclers and WRAP to develop appropriate specifications and promote good practice.
Export
LARAC hasn't a fundamental objection to recyclable materials being exported outside of the EU (assuming that trans-frontier shipment (TFS) regulations are observed) where it is most environmentally and economically advantageous, but LARAC promotes and supports the development of local and indigenous industries and organisations that recycle, and use, secondary material streams.
Landfill
LARAC acknowledges that Landfill sits within the waste hierarchy as an option for waste disposal. However where landfill is considered, this should be a last resort. Where landfill is used, priority should be given to maximising the capture of landfill gas for use as a renewable energy source wherever feasible.
LARAC supports the principle of increasing targets for diversion of all types of waste from landfill alongside alternative treatment/recovery measures.
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.
Investment
LARAC acknowledge the reduction in Government supported PFI as a key funding model for waste infrastructure, however would also like to see greater resourcing and development of partnerships involving building merchant plants that are shared with local authorities to be encouraged more. In addition, providing local authorities with the resources to manage a number of different contracts with smaller firms (local SMEs, community enterprises) would assist in encouraging investment to be directed towards appropriate treatment facilities, not necessarily large service providers. This could better encourage more innovative processes that are being developed by a wider range of companies as well as being part of the wider “localism” agenda.
Energy from Waste (including AD)
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.
In order to achieve the high EfW efficiencies (>70%) reached in other European countries, it is vital to use direct heat from EfW plant. LARAC would urge Government to take a more proactive role in the planning of EfW plant and the development of district heating systems to ensure that the need for a heat load is identified early on...
LARAC would also urge Government to facilitate for upgrading the gas grid in order to enable the injection of biogas from AD plant directly into it. This would allow the gas to be used domestically for heat, rather than for centralised electricity generation, leading to greater efficiencies.
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 Commission 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.
allow the gas to be used domestically for heat, rather than for centralised electricity generation, leading to greater efficiencies.
Landfill Bans
LARAC has no objection to the principle of introducing landfill bans provided that these take into consideration the following:
In conjunction with the introduction of any landfill bans, LARAC would generally support the use of market interventions in order to ensure materials are used where they deliver most environmental benefits, e.g. by the development and stimulation of markets for recyclates.
Prior to the introduction of a ban on landfilling recyclate, LARAC would urge that contingency arrangements are put in place for situations where market failure could lead to a less optimal use of the recyclate material.
Notwithstanding the above, LARAC would question the added value that a ban (“push” measure) might bring alongside other incentives for the use of secondary materials/energy. LARAC’s view is that the increasing levels of Landfill Tax, another “push measure” already constitute a very effective mechanism in encouraging Landfill Diversion.
LARAC would recommend the Government to pay attention to “pull” measures such as the RTFO, and to consider a separate incentive or subsidy to pull plastics out of waste. We would generally support measures that incentivise the use of secondary resources against primary resources.
Biowaste comprises park, garden and food waste; biodegradable waste includes all other biodegradable materials such as paper, card and wood. Biodegradable waste fractions with varying moisture content and carbon/nitrogen ratios will have different optimal treatments. However as with other wastes, LARAC believes a balance needs to be struck between the practicalities of the degree of separation and the benefits of optimal treatment.
In general, but depending on specific circumstances:
In detail, different biowaste can be categorised in different ways:
Food Waste
Whilst LARAC fully supports the prevention of food waste in the first instance as much energy goes into food production and distribution, the preferred route of treating, vegetable and fruit waste is via home composting and for cooked food waste a home digester. For catering wastes and large amounts of domestic kitchen waste Anaerobic Digestion is considered the best route followed by invessel composting
Park & Garden Waste
In situ composting or natural degradation is preferred. Where these are not practicable, the optimal treatment method depends on the nature of the garden waste with composting preferred where practicable.
Furthermore, different biodegradable waste can be categorised as:
Forestry & Agricultrual Waste
Whilst these categories do not concern Local Authorities directly, LARAC would promote partnerships with organisations in these sectors where appropriate to meet technical standards and achieve economies of scale.
Sludges
The co-treatment of sludges with other biowastes may be problematical owing to the risk of chemical pollutants contained within them, which would restrict the markets for the resulting digestate or composts.
Paper & Card
For paper and card, recycling is generally the preferred option.
For all EfW, including AD,
CHP processes are strongly supported and for AD. The direct use of gas may be environmentally preferable to CHP.
Wood
For waste wood, the waste hierarchy is adhered to, and reuse & recycling options should be explored. Efficient EfW is supported where reuse and recycling are not possible or not practicable. Where wood is contaminated with preservatives and paints, appropriate environmental safeguards must be in place.
Biodegradable Bags
The use of biodegradable bags both for the separate collection of food wastes and by Supermarkets for consumers is not supported. However LARAC understands that the use of separate bags for the collection of food waste provides a convenient method for householders to separate food waste for collection for AD or in-vessel composting.
LARAC supports the LGA in relation to various specific policy issues, for example, resisting imposed measures & targets especially if they increase costs, local independence, landfill tax revenues to be fed back into waste management and making resources management more democratically accountable on a scale that is appropriate.
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 sub-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.
LARAC supports the Government’s review of Local Authority requirements under Schedule 2 of the Controlled Waste Regulations 1992 and supports the general principle that those who produce waste should be fully responsible for the costs it creates, allowing local authorities to charge Schedule 2 premises for disposal as well as collection. In any case, LARAC would not wish to see any additional burdens placed upon LAs without additional resource.
Municipal Waste
LARAC supports the view that the UK’s existing approach to Municipal Waste is focused too narrowly on waste collected by local authorities and this waste stream is too small in proportion to the total produced to enable the environmental objectives of the EU Landfill Directive and the aims of the Waste Strategy for England 2007 to be met. As such LARAC supports a broader definition of municipal waste for purposes of reporting against the targets set out in the EU Landfill Directive. This will mean, regardless of the source of waste, its environmental impacts can be monitored and managed in a consistent manner. However this must enable a robust and credible monitoring methodology to be determined
LARAC agrees that biodegradable municipal waste should be measured at the point of disposal. Further analysis of commercial waste tonnages and composition is urgently required.
Updated by Sally Sheward, LARAC Policy Support Officer on 8th November 2011