|
CIWM Waste Data Seminar
Waste Data - An Industry Perspective
Dirk Hazell, Chief Executive, ESA
24 November 2004, London
So many people have so much to say about waste management.
But, to misquote Winston Churchill, “never before in the field of human debate was so much said by so many with such little knowledge”.
Even our regulator does not know what it is regulating.
This has always mattered, as waste by definition needs to be managed within a regulatory system to ensure the protection of human health and the environment. A regulator knowing what it is doing is the foundation of our sector’s business.
It matters even more now as we move from emphasis on final management in landfill towards more emphasis on closed loop systems, with the European Union trying to lead the World in sustainable use of resources.
ESA has therefore for years advocated a better understanding of waste flows in the economy.
Our Members and the regulator need to be able to track materials from when they become waste to when they cease to be waste.
Knowledge of relevant material flows is a key element of better resource management. Cost-effective on-line reporting to the regulator could at a stroke stop fraudsters and improve prospects of investment in state of the art regulated waste management infrastructure.
DEFRA’s Strategy
The springboard for today’s event was the publication last month of DEFRA’s draft waste data strategy which ESA welcomes.
To start to discuss how to measure and chart waste flows at the half way house between defining the National Waste Strategy and the first deadline for diverting BMW from landfill is rather quaint but…better late than never!
If it was not so wearing for everyone involved, it could almost be an Ealing Comedy with a purposefully hatted Margaret Rutherford determinedly setting out to drive from London to Bristol before reluctantly deciding, having reached Grimsby and encountered several adventures, to consult a map.
But at least a map would have been available. In this industry, the maps available to the industry are sometimes about as informative and useful as ancient maps of the World with unknown areas marked as “there be dragons”.
As I am sure you discussed this morning, if you can’t measure it you can’t manage it. And measurement of relevant data is only the first step. The purpose is the knowledge that arises from processing data.
As you know DEFRA’s data strategy will:-
cover all waste streams; be based on detailed information; use common definitions; gather data t through regulatory returns; and, most important, be underpinned by a regulatory obligation to provide data.
These principles are welcome to ESA. Our concern is whether the strategy can be delivered, and whether it is sufficiently focussed.
Turning first to need, data can obviously help our Members to manage their businesses. Aggregated data can become knowledge about current waste flows and, over time, can provide predictive models of trends. For politicians and regulators, relevant knowledge is the power to define necessary environmental outcomes and to catch crooks. For ESA’s Members, relevant knowledge is the means to add value.
Real-time reporting of relevant waste and material flows could help the authorities to catch criminals. Annual aggregation of data might be enough to develop public policy and to enable ESA’s Members to plan investment in infrastructure.
While detailed management data is essential for ESA’s Members’ prudent management of their businesses, it is not what is relevant to regulators and should certainly not be broadcast. Not everyone needs access to everything. However, we all have an interest in much more reliable indicators of the composition of the waste stream and in changing trends.
Turning from the need for data to priorities, ESA always recognised the importance of the EU Waste Statistics Regulation. We’re already in the first reporting year. By 2006 the UK must submit its report and thereafter submit regular reports. So we need the right data strategy.
Management and diversion of biodegradable municipal waste is the priority for local authorities and the benefit of WasteDataFlow seems to be appreciated. We need to build on this success with other data sets.
If we are to develop better markets in recycled materials, better analysis of industrial and commercial waste would be helpful. It is in any case necessary for sectors subject to producer responsibility.
Other waste streams have been identified by DEFRA, including waste streams which are not yet regulated. While we need a system flexible enough to add new streams in the future-for example, agricultural, forestry and mining wastes-at the moment we should focus on the priorities set by EU law.
From the industry’s perspective, a data strategy must have three key characteristics:
the data must be fit for purpose;
it must be capable of being collected in a cost-effective way; and
commercial confidentiality must be respected.
We need to know why we are collecting and manipulating data, we need a shared understanding of what the data is for, and we need to be confident the data is up to the job it is meant to do.
The foundation of a successful strategy can only be a clear and shared understanding of why data is needed. Data is a means to the end of knowledge.
Once we understand what we want to know, and why, we can determine how much data is needed and whether it is feasible to collect such data and whether the value of the data is greater than the cost incurred in gathering it.
We need to avoid the situation described in a UNIX programmer’s manual: “Now that we have all this useful information, it would be nice to be able to do something with it…it can be emotionally fulfilling just to get information for its own sake but this is usually only true if you have the social life of a kumquat.”
Data collection must be cost effective. The system should be straightforward: a lot of different people will be inputting data and accessing reports and the system needs to ensure all involved in the waste management chain-small and large operators, the community sector and exempt sites-input data.
The objective should not be complex and costly systems to collect detailed but irrelevant data but reliable but fairly basic data on waste flows.
While the draft strategy glosses over the external costs of data provision, there should be a proper assessment of the costs to private companies, particularly if data provision is to become a regulatory requirement.
Disraeli said “As a general rule, the most successful man in life is the man who has the best information”. ‘Twas ever thus.
A system of data that breaches commercial confidences is doomed to failure. It would tend to damage the best companies.
To publish site specific data, for example, would normally disclose too much to its competitors about a particular operator’s business strategy.
So we need common sense and proper engagement with our sector from the outset in determining what data is and is not collected and what is then done with the data.
It ought to be possible from the outset to get broad agreement of data that should be aggregated to avoid the publishing of disaggregated data damaging companies’ legitimate commercial interests.
While data can have useful applications for private sector operators, data is not on its own useful.
The draft strategy shows little evidence of Defra talking to companies about the type of data they would find useful and valuable for the operation of their businesses. Although this may be in part what the current consultation is about, the central thrust of the strategy examines “how” it will be done rather than “why” it is useful to do it.
We are entitled to draw attention to this because ESA’s Members already provide vast amounts of data to the Agency and to local authorities.
If it is indeed the case that most of this does not simply disappear into a data black hole, the Agency and Defra should be doing more to illustrate the benefits to businesses who spend money to provide data.
It’s not mentioned explicitly, but a waste strategy should not be simply be owned within the machinery of government by DEFRA and the Agency.
Government Departments need to work closer in the preparation and operation of the data strategy.
For example, integration of ODPM data on capacity could indicate whether planning authorities were granting enough new treatment capacity in their areas and identify geographical areas or material streams where intervention might be justified.
Given emphasis on resource efficiency, on tackling waste further up the “chain” and on producer responsibility initiatives, DTI too must play a full and transparent role.
There is even scope for integration with HMCE data on landfill tax.
We are not advocating unnecessary complication. It’s just better to try to get the system right now rather than having to reconsider and redesign the system in a few years’ time.
In conclusion, ESA supports the data strategy: it is crucial that we have better knowledge of waste flows in the economy, of how they are managed and of their environmental impact.
We want the strategy to ensure that data is cost-effectively identified and collected to add to relevant knowledge so we can help to improve the UK’s resource efficiency.
Much thought and effort has gone into the practicalities, the “how”, of the strategy. I hope your meeting today will help to put more focus on the “why”.
|
