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A Partnership for Compliance
Dirk Hazell, Chief Executive ESA
London, 1 July 2004
Today’s focus is the UK but perhaps we should cast our net a little wider for a moment.
The Dutch Presidency of the EU starts today.
Holland is even more densely populated than Britain, with even more pressure on land.
However, unlike the UK, Holland achieves one of Europe’s highest levels of recovery and recycling. One of ESA’s Members operating in Holland has for years recycled all the construction and demolition waste it collects.
Holland already complies with Landfill Directive’s the 2016 biodegradable municipal waste diversion targets.
Here in Britain, we’re nowhere near achieving these targets. Based on current performance, future governments will find it challenging to secure compliance even with four year extensions running to 2020.
The UK is facing a task of massive proportions:
We need to divert 25% of biodegradable municipal waste by 2010, and 50% by 2013. The targets are set against 1995 volumes.
If waste grows at current rates this will mean diverting more than half of waste arisings in 2010, and nearly ¾ in 2013.
By 2020 we will need to divert 83% of BMW. This is over 30 million tonnes.
The Government does not even measure the new waste management capacity that is granted and that which is lost. Even so, ESA is pretty sure that instead of getting increased capacity, Britain’s total permitted waste capacity is currently falling.
The planning process is not consenting anywhere near enough waste treatment and processing infrastructure sufficient to enable the UK to comply with EU law.
To divert waste from landfill, the UK will need a different collection, transport and management infrastructure.
The Environment Agency has estimated more than 2,000 new facilities will be required to comply with the Landfill Directive alone in the next ten years and this is also the mid-range estimate of the Institution of Civil Engineers.
On top of this, sufficient landfill capacity will still be needed to manage residual waste following treatment and processing.
Getting these new facilities will be a huge task.
It shouldn’t be: after all, we constantly reminded that people want to recycle, that “it’s easier than you think”. Also, new facilities will improve the UK’s resource efficiency, create new jobs and help to stimulate environmental enterprise.
Instead of presenting a huge task, the planning process should facilitate this revolution in waste management.
The planning system needs to provide certainty, minimise investment risk and deliver decisions more quickly.
It’s rather worrying that the Government claims the planning system already does this.
The Government recently told the Environment Select Committee that the planning process is “doing a good job”.
This is simply not the experience of ESA’s Members.
If the planning process was “doing a good job” and there were not significant problems, none of us would be here today. In the event this is a sell-out conference where ESA had to turn people away.
Our Members’ typical experience of the planning process is of delay and ever rising costs. For example, in 2002-2003, half the “major” waste management applications took more than 17 weeks to be determined.
Obtaining planning permission for a MRF can cost £40,000.
Adding an environmental assessment can cost up to £100,000. An application for an integrated waste management facility can cost more than £1 million.
If there is a public inquiry, the cost goes up a few million.
Given the scale of what our industry needs to achieve, this is an insupportable level of cost.
There is a ray of hope.
The Government has two key opportunities to ensure that the planning process points towards achieving compliance with EU Law on waste.
First, there is the review of Planning Policy Guidance Note 10 expected later this year.
Second, next year the Government will review its own waste strategy.
ESA and our Members will make the best of these opportunities.
If the UK is to comply with the Landfill Directive targets, the Government will also have to do the same.
ESA published our Land-use Planning report a couple of months ago and copies of the report are in your delegate packs.
Rather than run through the report, I simply highlight some of the more important recommendations.
Planning for waste management occurs at national, regional and local levels.
The report makes the obvious point that with so many different players, successful delivery of new infrastructure needs partnership.
As partnership is the only route to success, our report suggests how each partner can best add value.
ESA’s Members are ready to invest thousands of millions of pounds in a new generation of waste and secondary resource management infrastructure.
Our contribution goes wider.
Our Members understand the need to engage with local communities when submitting major planning applications.
Consultation can facilitate a solution but it is not the solution. Companies and authorities need to know when to stop and when the useful level of consultation has been provided.
As an industry, we are still on a learning curve but we are clearly committed to effective consultation.
Our Members will also contribute fully to the preparation of Waste Development Frameworks.
One area where we can demonstrate our commitment is in the design of facilities.
Instead of focussing on disposal, new facilities will recover value contained in waste and stabilise residues.
Compared to existing waste management infrastructure, the new generation of facilities will look different and be differently sited.
There is a real opportunity for planners and industry in partnership to design facilities in ways that promote public acceptance and permitting.
We are an industry offering to help the UK meet its international obligations, to be fully involved in the planning system at strategic as well as with individual applications, and to promote good design for facilities.
What would we like in return?
We would like clear, consistent and relevant political leadership.
The Government has made some useful contributions.
The recent review of health and environmental effects of waste management facilities should help to counter disinformation that has dogged planning applications for far too long.
The review effectively confirms that the UK’s private sector regulated waste management infrastructure presents minimal risk to the environment and health as well as being exceptionally cost-effective.
And standards will go even higher with the implementation of the Landfill and Waste Incineration Directives.
We need more from the Government.
For example, we need the Government to define the environmental outcomes that need to be achieved and the waste management capacity that will be needed.
Regional and local planning bodies need to know the scale of the change that is required in their areas.
With the resources of local authorities stretched to manage the requirements of the Planning and Compulsory Purchase Act and the Strategic Environmental Assessment Directives, the Government could offer practical assistance by preparing model policies for Waste Development Frameworks.
More fundamentally, the Government must work with its partners urgently to review the principle and application of Best Practicable Environmental Option. This morning Richard Read and David Harper identified some the problems BPEO is creating and ESA of course shares their concerns.
Emerging EU environmental policy indicates increased emphasis on life-cycle analysis.
Developing life cycle analysis might achieve more than preoccupation with BPEO.
The Environment Impact Assessment, Strategic Environmental Assessment and Pollution Prevention Control Regulations will all affect waste management: if BPEO is found to add no more value, it should be scrapped.
We would welcome environmental business planning zones where recycling, recovery and other environmental businesses could take advantage of a local supply chain.
Such zones could help to regenerate areas of the UK, reduce traffic movements and provide opportunities for wealth creation within a framework of greater planning certainty.
Environmental business planning zones could provide a welcome boost to environmental enterprise in the UK:
the UK has a 4% share of the global environmental goods and services market. Achieving the Government’s target of increasing this to 7% would be worth an additional £15 billion to the UK’s economy.
Decisions are best taken at a local level and local planning authorities can play a crucial role in enabling higher levels of resource efficiency.
There are significant pressures on local authority resources. In addition, action groups are becoming more vociferous and sophisticated in their opposition to facilities.
We understand the difficulties but our industry-and the UK as a whole-needs local authorities to take decisions promptly.
As the Institution of Civil Engineers reported last month, waste planning authorities cannot afford to defer decisions on new waste management capacity. Waste management infrastructure can take considerable time to develop and commission. And there is no miracle cure new technology.
As well as a planning process that delivers, the UK needs other changes to comply with the Landfill Directive.
First, management of the municipal waste stream remains chronically under-funded.
On average, each household pays about £65 a year for their waste to be collected, transported and safely managed. This is less than half as much as households in European countries achieving much higher levels of recycling and recovery.
For £1 per person per week our Members, in partnership local authorities, could transform levels of recycling and recovery.
ESA has consistently encouraged the Government to modernise the funding arrangements for local authorities and introduce flat-rate direct charging for municipal waste. This would reflect the polluter pays principle and increase resources available for waste management without any additional burden on the public purse.
The second change we need to comply with EU law, to provide certainty for businesses to invest, is for regulation to provide a framework that is consistent, transparent and enforced. The ineffectiveness of the current regulatory framework can be summarised in two words: hazardous waste.
In two weeks the co-disposal of hazardous and non-hazardous waste will be banned.
The Government has known about this since before it signed the Directive in 1999.
For over 5 years it has known that the UK would require a greatly enlarged hazardous waste treatment infrastructure by 2004.
And yet the standards to which hazardous waste will have to be treated, the basis for investment by ESA’s Members, only became law two weeks ago. So, obviously, new infrastructure has not been provided.
The Government must get waste right and the planning system is an essential ingredient.
The imminent reviews of PPG10 and the Waste Strategy are probably Britain’s last chance to get on track to comply with standards of waste management other European countries have been managing for years.
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