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West Midlands Waste Management: Responding to the Challenge
A Perspective from the Waste Management Industry
Wayne Laramee, Head of Parliamentary Affairs
10 November 2004
Slide 1: Opening
I am delighted to be asked to speak as a representative of the waste management industry.
For the past decade there has been a debate between the European Commission, Governments and the regulators on the future of waste management. This debate has resulted in new legislation that will transform waste management in the West Midlands.
I have got a lot of information and views that I want to share with you so I will push on.
Slide 2: Introduction to ESA
ESA is the trade association for the UK’s waste and secondary resource management industry. Our Members provide a range of waste management services to both the public and private sectors in the UK.
Ours is a sector that contributes more than £5 billion annually to the United Kingdom’s economy, about 0.5% of GDP. To put this into context, and to demonstrate the fantastic value that waste producers receive from our Members, Tescos has an annual turnover more than four times larger than that of the entire industry represented by ESA.
As a proportion of GDP, the UK spends far less on waste management services than its European competitors. However, this is going to change. Cheap exit routes will disappear and EU law will bring the UK much more into the line with other northern European Member States.
Slide 3: The State of the Region
We have heard this morning from Barbara and Ed about current waste management capacity in the West Midlands. They have concluded that there is spare albeit marginal capacity in all categories.
Measuring existing capacity is incredibly difficult and it is in recognition of this, the resources required and the problems encountered that I make the following observations.
First, spare capacity is not the same as surplus capacity. For example, in relation to chemical treatment capacity may be needed to build up sufficient stocks of the right materials.
Second, available capacity does not always match waste types. Chemical waste can’t simply be mixed into one tank at a chemical treatment plant as this may cause adverse chemical reactions.
Third, there is no data on the amount of waste sent to exempt sites. We simply don’t know how much waste is going there.
These are constraints on our knowledge of existing capacity. But what we can say for certain is that as a consequence of legal and other drivers the waste management infrastructure available in the West Midlands in 2020 will be markedly different to that in place today.
Slide 4: Legislative Drivers
I have tried here to encapsulate some-but not all-of the regulatory drivers affecting a range of waste streams. Of these, the Landfill Directive is perhaps the single most important legal driver.
And do not believe that enlargement of the EU means the pace of environmental reform will slow. The emerging thematic strategies will set the framework for EU environmental policy for the next decade.
I believe that there are three main themes to the regulatory framework that has emerged over the past few years.
1) Better use of resources: less emphasis on landfill and more on maximising the life of products
2) Tighter regulatory controls: on how waste should be managed
3) Tighter definitions: like reclassifying hazardous waste as non-hazardous.
And to this must be added the implications resulting from rulings of the European Court - Texaco, Mayer Parry.
But these aren’t the only drivers affecting the region
Slide 5: The State of the Region
There are drivers relating to the region’s economic and social development.
The West Midlands is a region contributing annually £63 billion to the UK economy and which over the next decade is predicted to create 100,000 new jobs and 200,00 new households. True some decline in the region’s industrial base is predicted but overall I would suggest that there is an upward pressure on waste growth.
The process and location of the development is as important as meeting the regional target for the development of brownfield land will produce hazardous waste.
Slide 6: Waste Management in 2020
We have heard from Adrian this morning about how waste management could look in the West Midlands in 2020.
This type of work is incredibly difficult and I pay tribute to Adrian’s commitment and dedication. I really do believe that more resources need to be made available for such an important and technically complex
I would like to make the following comments on the conclusions he has reached.
Slide 7: ESA’s Observations
First, I entirely agree with Adrian that the report is indicative rather than a statement of fact. It provides a benchmark but I would warn against any local authority from following it slavishly.
Second, all reports like this should be seen as setting minimum rather than maximum requirements. Market forces will protect against over-supply.
Third, the infrastructure required will flow from the type of collection system used.
Fourth, all predictions on future waste arisings should, as the European Commission says, be based on sound science and rigorous assessment. ESA supports waste prevention but we must never lose sight of how difficult it is to achieve.
Fifth, we shouldn’t underestimate our need for capacity to manage residual waste. Landfill will be needed to mange large volumes of non-biodegradable and non-municipal waste as well as treated hazardous waste.
Specifically, for some of the reasons I have already outlined, the region will need additional capacity to treat hazardous waste which will be driven by the application next year of waste acceptance criteria.
I will come onto hazardous waste later but in assessing the need for new capacity the region may not want to lose sight of the benefits that can arise from adapting existing treatments.
Slide 8: Developing a Market
Our Members want to invest in a new generation of waste management facilities to meet the needs of the county.
To invest ESA’s Members require
- An effective regulatory framework
- The right economic conditions
- An efficient and effective planning
Currently, none of these levers yet points towards the UK’s compliance with EU Law. This is bad news for managers and producers of waste in the West Midlands.
Slide 9: An Effective Regulatory Climate
Regulation is the building block for our industry and creates a market for our Members. Without a clear legal framework ESA’s Members cannot invest.
I need only mention two words hear to make my point: hazardous waste. Here was an industry eager to invest and yet the standards to which hazardous waste will have to be treated, the basis for investment by ESA’s Members, only became law four months ago. As Select Committees have argued, we have to get better in transposing EU Directives into national law.
UK Law needs to be enforced assiduously so that waste is driven to regulated infrastructure. Implementation of higher environmental standards should not automatically result in an increase in criminal activity. However, it needs what we don’t currently have, an adequately resourced regulator.
There also needs to be a concerted effort to make waste producers aware of their new obligations resulting from new laws on waste. Organisations like ESA and ICE can and do help. However, it is the Government which signs up to EU Directives and so it should be the body which leads. Alarmingly a survey carried out last year by the Environment Agency revealed that three quarters of businesses were unaware of their legal duty of care.
Solutions
We list here some of the solutions we believe could help to improve the regulatory climate like an implementation plan for each new EU Directive as soon as it appears in the Official Journal.
We would like to see an adequately resourced Environment Agency including funding sufficient to enable it to set up an online data management system for waste flows and capacity. We welcome the formation by DEFRA of a waste data advisory group and hope this will lead to a material improvement in the quality of data on waste.
Regulation must create a level playing field by ensuring that technologies operate according to common environmental standards.
Above all we need a Government that acts promptly to provide the clear legal framework necessary for investment.
Slide 10: Economic Framework
As you would expect, the economics also need to be right:
Management of the municipal waste stream remains under-funded: currently each household is paying half as much as much as households in European countries achieving much higher levels of recycling and recovery.
We need to end the waste of valuable resources for public and private sectors currently resulting from the procurement process.
As solutions, ESA strongly supports the introduction of direct charging as a means to raise additional investment without any demands on the public purse. We also support a greater standardisation of waste contracts based on the engagement of both public and private sectors.
Slide 11: Barriers to Efficient Planning
The planning process is absolutely crucial to achieving compliance with EU Law: ESA shares the view of the ICE that the performance of the planning process needs to improve.
Our Members regularly encounter delay and in 2002-2003 half the “major” waste management applications took more than 17 weeks to be determined.
Costs are also increasing. 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.
BPEO has become a millstone around the neck of the planning process and duplication continues to occur between the land-use planning and environmental protection regimes.
Awareness of the scale of the change ahead and the time available to make decisions can be low. And finally, and I think many here will share this view, resources available to national, regional and local planning bodies are inadequate. I am very worried about how local authorities are going to meet all of the new challenges which face them over the next few years.
It is these concerns and the forthcoming review of PPG10 which led ESA to set out action that national, regional and local planning bodies should take now.
Slide 12: Picture of ESA Statement
This report can be located on ESA’s website and makes a series of recommendations.
Slide 13: Solutions
These include a national statement on the need for additional waste management capacity for all waste streams and support for apportionment.
Our statement also notes that Strategic Environmental Assessment, Sustainability Appraisal, EIA and IPPC will deliver the objectives of BPEO and provide the necessary levels of environmental control. With so much expected of the planning process duplication is something that simply cannot be afforded.
To help local authorities and spread best practice we call for the Government to prepare model policies and believe that introducing permitted development rights for minor, non-controversial applications would enable resources to be focussed on larger applications. And we want a clearer statement from the Government on the boundaries of the planning and environmental protection regimes
Above all the statement makes it clear that only an approach based on partnership will work and we recognise that the waste management industry also has a key role to play.
Slide 14: ESA’s Commitment
Our Members contribution will go beyond the investment of billions of pounds in new facilities to include continuing proactively to engage communities when submitting applications and encouraging good and innovative design of facilities.
If the three ingredients of regulation, funding and planning are in place there will be significant changes to the waste management landscape in the west midlands region.
Slide 15: Hazardous Waste Pre-16 July 2004
Co-disposal landfill has been the workhorse for the management of hazardous waste in the region.
According to the Hazardous Waste Forum, 40% of the hazardous waste generated in the West Midlands, equivalent to 206,000 tonnes was sent to co-disposal landfill sites. The region’s co-disposal landfill sites also managed over 300,000 tonnes of hazardous waste generated in other regions.
Following the banning of co-disposal and the application of waste acceptance criteria in July of next year, there will be a much greater role for treatment. The profile of the region’s hazardous waste management infrastructure will become much more like that of the Netherlands and Germany.
For example, the Hazardous Waste Forum reports that the total hazardous waste landfill capacity available in the region, including separate cells, will fall to just over 50,000 tonnes per annum.
It is not ESA’s purpose to advise on which treatment solution are the best that is the job of our Members. However, a series of hazardous waste treatment solutions are available to make up this shortfall, all of which will be driven by the standards set by the Waste Acceptance Criteria.
Slide 16: Post 16 July 2004
Stabilisation
Stabilisation is a treatment common in France and can manage a large proportion of hazardous wastes. Cement is added to the waste which is then allowed to solidify under closely controlled conditions. The stabilised material is then landfilled. A typical plant size is anything from 20,000 – 100,000 tonnes per annum
Soil Treatment
I will talk about this option in more detail in a moment.
Solvent Recovery
A typical plant size can be from 20,000 to 70,000 tonnes per annum although the Volatile Organic Compounds Directive is reducing solvent use.
Adapting Existing Treatments
Some of ESA’s Members are likely to look at expanding and/or adapting existing technologies like physico-chemical plants. This may have advantages in terms of cost and planning.
High Temperature Incineration
There are 13 high temperature incinerators In France compared to 2 in the UK and the process involves the burning of hazardous wastes under carefully controlled conditions. Hazardous wastes can also be burnt in cement kilns and according to the British Cement industry there may be potential for the co-incineration of 300,000 tonnes depending on the nature of the waste.
Waste Minimisation: Of course waste minimisation is not a treatment but I believe that the increase in cost for managing hazardous waste will place a downward pressure on hazardous waste arisings. Similarly, the incentive to ensure that non-hazardous waste is consigned as such will be stronger.
And landfill will continue to play an important role in managing pre-treated hazardous waste. According to the Environment Agency there have been 10 applications in the West Midlands for single cells accepting stable non-reactive waste.
Slide 17: A Case Study: Soil Remediation
I want briefly to talk about soil remediation.
In 2002/03, 565,000 tonnes of soil from building development was sent to landfill as hazardous waste. With the end of co-disposal, remediation is one method available for managing contaminated soil.
The process decontaminates and stabilises the soil to a state where it can be used to help restore landfill sites or in restoration projects. Treatment can take place either on site or at a dedicated soil treatment centres.
One ESA Member has applied for planning permission for a site in the north of England capable to accepting 50,000 tonnes of soil a year. Three other remediation centres may follow.
However, planners take note: the process is space hungry and compared to treatment solutions like high temperature incineration is a slower process.
Slide 18: Non-Hazardous Wastes
Changes to the region’s infrastructure for managing non-hazardous waste will be equally as dramatic.
Public policy will determine the exact number and type of facilities that will be delivered over the next decade. However, we do know for certain that much more waste will be processed by a range of biological, thermal and physical systems that neutralise the material not in 30 years but in 30 days, or less.
Technologies like these:
Slide 19:
This is a Ball Mill operated by an ESA Member as part of their contract with Leicester City Council. Can you guess which Member it is?
Slide 20:
And this is a picture of an aerobic digestion plant just north of the city.
Slide 21: ESA’s Observations
There is no technological blockage to achieving compliance with the requirements of EU Law. All of the UK’s largest waste management companies operate in at least one other EU Member State and already gained experience from operating these technologies in their other markets.
Second, one size doesn’t fit all. What works in one part of the region might not work in another. There is no one solution and decision-makers need to encourage a framework that allows for a range of technologies.
The experience of other EU Member States like Austria, the Netherlands and France, Member States which are further down the road to compliance with the EU Law on waste, emphatically demonstrates that high levels of recycling/composting can co-exist with high levels of energy recovery.
Given the scale of the challenges ahead, local authorities may need to allow a higher proportion of non-hazardous commercial and industrial waste to be managed in facilities based on a municipal waste contract. This can help to deliver economies of scale delivering benefit for public and private sectors.
Finally, we really are a critical juncture where decisions cannot be delayed. There really is no all singing and dancing technology that can make waste disappear. View with suspicion those tell you about alchemy. Waste is waste and will need to be managed. The laws of physics will remain in place.
Slide 22: Inert Waste
I want briefly to talk about inert waste.
Nearly three million tonnes of inert waste and soils were sent to landfill in the West Midlands in 2000/01. I believe that over the next few years the incentive to recycle this waste stream will become stronger.
For example, WRAP has a specific work programme to address aggregates, the Environment Agency has recently proposed that all landfill sites should be lined which will increase costs and the Government is tightening the rules for exemptions.
ESA’s Members are already responding to this changing framework.
Slide 23: Case Studies: Recycling Opportunities
For example, one ESA Member has recently begun a trial to crush concrete and asphalt to produce a secondary aggregate which can be re-used in the building trade. If it is successful I am sure the Member will explore further opportunities.
Slide 24: Conclusions
My conclusions:
Reports on capacity requirements must be treated as indicative rather than as tablets of stone. The reports are important and they do add value but I the region could make a mistake by binding itself to its predictions.
Providing the legal and economic framework is in place and the planning process is performing effectively and efficiently, ESA’s Members will deliver the facilities to achieve the UK’s compliance with EU Law. There is, as I have already, said no technological block.
Importantly, we are only at the beginning of the revolution in waste: there are many more changes ahead. The end of co-disposal was only the first step in transforming hazardous waste management and the introduction of waste acceptance criteria in July 2005 is equally as important.
And finally, we need action now. Done in the right way, meeting these challenges can present the west midlands region with opportunities for economic growth over and above the avoidance of fines resulting from failure to comply with the Landfill Directive and the Landfill Allowance Trading Scheme.
Slide 25: Opportunities and Responsibilities
For example, the right framework can help to improve the region’s access to the global market in environmental goods and services. This market is growing by 10% a year and is set to rise to an annual turnover of $700 billion by 2010.
Improving resource efficiency also increasingly make economic sense in a context where we are almost certainly looking at large long term increases in commodity prices. Rising commodity prices hit the bottom line as relentlessly as climate change hits the environmental headlines. A year ago, oil cost $30 a barrel. It now stands at over hit $55 a barrel.
There needs to be a better alignment of economic and environmental sustainability to address the growing and increasingly insupportable pressures on our environment. Atmospheric CO2 has now risen to the highest level for perhaps 65,000,000 years and the cost, adjusted for inflation, of extreme weather events was 1000% higher in the 1990s than in the 1950s, averaging US $40 billion each year in 1990s. We must act before the damage done to the environment becomes irreversible.
Slide 26: Website
Finally, ESA’s website is packed with information and so please do log onto it.
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