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Agricultural Waste Briefing
Meeting the agricultural waste challenge
Mike Walker, Director of Policy, Environmental Services Association
3 December 2002
ESA is pleased to convene today's event - bringing together policy makers, regulators, waste producers and waste managers to meet the challenge of managing agricultural waste.
We hope today will be an opportunity to assess the current state of affairs, and provide us with an opportunity to have a full and open debate about some of the ways in which we will meet this challenge.
The planned extension of waste management controls to agricultural waste will pose significant challenges. wastes are managed according to the requirements of the Waste Framework Directive.
In 1998 there were over 400,000 tonnes of non-natural agricultural wastes.
Some could be covered by take back schemes operated by suppliers.
But over 300,000 tonnes might require transport and management.
These include 32,000 tonnes of packaging materials, 76,000 tonnes of agrochemicals, machinery wastes, 22,000 tonnes of tyres, and 21,000 tonnes demolition waste.
The Waste Framework Directive has set the broad principles around which all subsequent waste legislation in the EU has been crafted. These principles have been in place since 1975, and they have applied to agricultural waste since 1991.
European Union law remains the most important driver for improving UK environmental performance. EU waste management controls are the tightest in the world.
Regulation
Regulation - 80% coming from the EU and originating with the Waste Framework Directive - is the primary driver in the UK for managing waste in a more sustainable way.
ESA represents the UK's waste managers. We understand the central role played by regulation. Regulation will drive environmental improvements and higher standards for waste management.
Without regulation there would be no waste management industry. But we can't have regulation for regulation's sake.
It has to be smart regulation.
To be effective it must be proportional and even-handed.
The right sort of regulation will encourage growth in the waste management industry. The turnover of the regulated industry represented by ESA should double over the next decade as the UK achieves higher standards for managing waste and the various EU and UK targets.
But complying with these higher standards and meeting these targets will require substantial investment. ESA's members are willing to invest. Our leading Members have indicated that they would be willing to invest up to £1 billion per year for the foreseeable future in new waste and secondary resources management infrastructure.
But no-one invests in a vacuum. In order for this investment to be forthcoming, the UK Government must show leadership. It must put in place a framework which will provide the certainty our Members need.
The framework needs to define a clear role for the Environment Agency as regulator, and allow waste producers to plan for the costs they will face to meet the higher standards required.
The first step in getting certainty is to ensure that the requirements of EU legislation are implemented into UK law in a timely and transparent way.
It benefits no-one - not waste producers, or waste managers, the Government or the regulators - when we continue to have delays in implementing the laws that will achieve the standards in waste management and environmental protection that are required of us, and which we all want to achieve.
Following transposition, strict and consistent regulation must then direct waste towards the licensed and regulated facilities of responsible operators. In doing so, it must also encourage the management of waste by processes as high up the waste hierarchy as the UK can afford.
We have seen the problems that delay and uncertainty can bring. The fridges debacle shows how without certainty, industry is unable to invest - even it did, it is unlikely that the capital could be raised.
Better environmental quality, higher standards come at a cost. The UK needs to make a choice - internalise the cost within the UK economy and support a strong home-grown environmental services industry. Or pay the cost and let the money flow to Germany.
Regulating agricultural need not cost the earth - but it will require huge changes. Whilst exemptions are likely to apply to large volumes of wastes arising, managing the remainder may not be a simple task. Not huge volumes perhaps, but quite probably hazardous, and scattered across a wide geographical area.
These challenges, will require a fundamental shift in behaviour by farmers and other waste producers within the sector.
New legislation must take account of existing obligations, such as the pre-treatment requirements and the standards relating to the management of hazardous waste under the Landfill Directive.
And many suppliers to the agricultural sector will be bound by the recovery and recycling obligations of the evolving producer responsibility regime.
Of course these new obligations will compound the effects on a sector recovering from the aftermath of BSE and Foot and Mouth, poor economic conditions within the agricultural sector and ongoing uncertainties relating to the CAP.
It is therefore even more essential that the framework should make compliance as simple as possible - for waste producers, waste managers and regulator.
Data
ESA has long-advocated science-based policy.
To manage wastes effectively, we need reliable and robust information.
We need information on the quantities. What they are. And where they occur.
Information on waste management in general has been poor. We welcome the fact that the Environment Agency has recognised this and is taking steps to remedy the situation.
But while progress is being made with quantifying the commercial, industrial and municipal waste streams, we still need more accurate data on agricultural waste arisings.
In the light of the Government's decision effectively to abolish the Landfill Tax Credit Scheme in its current form last week, it is ironic that much of the recent work which has been undertaken to collect and analyse information on agricultural wastes, and to assess the feasibility of some of the options for managing this waste in accordance with the new regulatory regime, has been funded through Object C of the Scheme using credits made available by ESA's Members.
We will be hearing the results of some of this work from Sara Bragg of Marcus Hodges Environment later.
Along with BDB Associates and the West Country Rivers Trust, Marcus Hodges Environment, has undertaken a substantial amount of work to determine the scale and nature of agricultural waste streams.
The majority of this work has been funded through contributions via the Landfill Tax Credit Scheme made by ESA's Members.
And an ESA Member has donated credits from the scheme to fund a farm waste liaison officer in Berkshire.
This work is extremely useful.
We now have a clearer picture of how much waste is actually on farms, waiting to be managed, and more importantly in terms of planning for final management, the individual components of that waste.
Second, alongside a recently published study funded by the Environment Agency, this work has also given us an understanding of how the challenge of managing agricultural waste has been met in other European Union Member States.
Learning from abroad
Schemes operating abroad have shown that a one-size-fits-all approach doesn't work.
We need a menu of the different ways to meet the challenge.
Management systems need to respond to the type of farm, geography, economic factors.
The role played by the private sector in other Members States has been shown to be an important component of the overall strategy. For example in product and materials take-back schemes.
In this context, ESA has consistently championed the use of Producer Responsibility as a forward thinking driver and a feasible practical tool in the move towards environmental and economic sustainability.
ESA facilities
But municipal waste management facilities might also have an important role in managing agricultural waste.
More and more of these facilities in the UK are operated by ESA's Members.
We recognise there may be limitations on how these sites could be used, but the potential exists.
And the provision of collection services by ESA's Members, may also remain a viable option.
I mentioned that some agricultural waste will be hazardous.
Hazardous wastes need to be managed according to existing - and soon to be introduced - legislation. They need to be managed in strictly regulated and responsibly operated facilities. Overwhelmingly these facilities are operated within the private sector by ESA's Members.
ESA has responded to this important part of the challenge.
Already we have held preliminary talks with the Crop Protection Association, who are represented here today. We are exploring ways of managing spent crop protection residues and out-of-date products.
These hazardous materials will be governed by strict treatment standards as a result of the Landfill Directive and will require management using those hazardous waste management facilities capable of meeting these standards and operated by ESA's Members.
Partnership
ESA and its Members want a partnership to manage the UK's waste streams.
We have already worked with Government and regulators to manage the disposal of animal carcasses arising from the Livestock Welfare Disposal Scheme during the Foot and Mouth outbreak last year.
ESA welcomed the opportunity to participate in the Agricultural Waste Stakeholders Forum announced by the Secretary of State in March of this year. The cross-sectoral group has already started to address some of the challenges posed by the need to introduce new legislation. And I hope that this event provides some input to the work of the forum.
Earlier this year ESA commissioned Marcus Hodges Environment to explore the legal, technical, economic and practical feasibility of using of existing licensed waste management facilities to manage agricultural wastes.
ESA believes that compliance should be simple, effective and flexible.
The UK has an already developed network of sites that are licensed and regulated and which might play an important role in helping the UK manage agricultural waste.
ESA has for some time proposed that these might be used as a simple way to help manage some of the UK's agricultural waste.
Encouraging farmers to bring waste to these sites, perhaps by having a national brand, and by providing the necessary supporting information, might be a straightforward and cost effective route to compliance. Certainly there examples of similar "bring" schemes in other parts of Europe.
We shall have to wait to see what Sarah Bragg has to say about this and other ways of dealing with farm wastes.
The Stakeholders Forum is an important first step. Bringing together people is important.
But the challenge for Government - and for all of us- is to ensure that the experience and expertise of the various groups and individuals are put to good use.
And I hope that the rest of today will be another step on that road. 
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