Eunomia has been publicly warning for four years now that the UK’s “dash for trash” will leave us – like Sweden, the Netherlands and some of our other Northern European neighbours – with more residual waste infrastructure than we really need.
While it has been widely read, the message of our Residual Waste Infrastructure Review (RWIR) hasn’t been rapturously received, especially amongst those for whom the planning, construction and operation of incinerators and advanced thermal treatment is a major source of income. Indeed, it has spawned several imitations, perhaps intended to cast doubt on our conclusions and buoy up the market. However, we’ve found serious problems with the capacity reviews produced by Suez, CIWM and others, whilst so far as we are aware, no-one has taken issue with our methodology – except us, as we’ve refined it over time.
With Issue 8 of the RWIR currently approaching completion, it was somewhat gratifying to see the Local Government Association quoting November’s Issue 7 as a key source in its EU Circular Economy position paper last month. The position paper contains much that is laudable, including greater emphasis on producer responsibility, designing out waste, and stimulating the market for secondary materials. However, it warns the EU against a hike in recycling targets with the following argument:
“English local authorities have committed many hundreds of millions of pounds to underpin the delivery of waste treatment infrastructure to radically reduce landfill by 2020. This treatment capacity will process a volume of waste that will make meeting a suggested 70 per cent recycling target unachievable. Unless Member States’ committed investments are taken into account in target setting there is a risk that these expensive and long term facilities are made redundant leaving public authorities with large liabilities.”
Local government has been one of the key investors in residual waste treatment. The (now defunct) Landfill Allowance Trading Scheme (LATS) and Landfill Tax escalator provided the push, with Defra PFI credits providing the pull towards more predictably priced solutions for councils to tackle their expected tonnage of residual waste.
Of course, the LGA is right in its diagnosis. If the EU were to agree on a 70% recycling target for its Member States, for England to have any chance of achieving it local authorities would need to be in the vanguard. Yet if all of the facilities currently being constructed are completed, our numbers show that UK and local authority recycling will be limited to below this target level. If a higher recycling rate is demanded, it risks leaving some of England’s expensively obtained residual waste treatment capacity short of domestic feedstock.
Part of the aim of producing the RWIR was to alert investors in residual waste treatment to the growing likelihood that treatment capacity would exceed the supply of waste, as we have no wish to see facilities built only to be left idle – potentially at great cost to investors, whether public or private sector. However, little purpose would be served by simply telling local government “Well, we warned you”, and leaving them to pick up the tab.
Another motivation was to try to head off the all too foreseeable scenario in which recycling and incineration come into direct competition. Eunomia has warned that, as the role of landfill rapidly declines, recycling and incineration are – at the margin – competing for the same material. On both environmental and economic grounds, we would prefer to see resources devoted to increasing recycling rather than propping up incineration.
Change of prescription
In this context, the interesting issue is whether the LGA is right in its prescription – should the EU moderate its recycling ambitions to take account of “Member States’ committed investments”? Or are there alternatives that councils, which are already committed to significant pieces of infrastructure, should be exploring? Here are a few alternatives to what we would see as the councils’ representative body’s counsel of despair:
- Targets are typically set at member state level, and have much wider scope than just local authority collected waste. Instead of calling for less ambition on recycling, the LGA could ask government to support business to improve the recycling rate for other waste streams such as commercial, industrial, construction and demolition waste, to make up for the potential local authority shortfall.
- Equally, the LGA could reflect on the difficulties that councils are facing when it comes to increasing – or even maintaining – their recycling performance in the context of deep funding cuts and weak material markets. It could call on government and the GIB to support the much smaller investments needed to support the collection and reprocessing of recyclable material in the UK, making alternatives to incineration more attractive.
- The UK government has rightly been reticent about passing targets on directly to individual local authorities. Demographics have always played a role in recycling performance: numerous rural councils already achieve recycling rates in excess of 60%, while others (especially in inner cities) barely achieve half that. The fact that some councils have heavily constrained their recycling rate through a commitment to incineration is just one more factor to take into consideration. So, LGA could call on government to recognise these constraints when considering UK targets; and to support authorities that aren’t constrained by existing infrastructure to maximise their recycling, thereby taking the pressure off those that are.
- Eunomia’s capacity projections take account of treatment facilities that are at various stages of development. To ensure that England’s local authorities can play their full role in meeting a higher recycling target, the LGA could:
- Call on government to help some councils renegotiate their incinerator contracts to enable exit from any requirements that commit them to supplying a guaranteed minimum tonnage; and/or
- By supporting collaboration or trading between councils to allow waste to be matched with capacity.
- The waste a council sends to an incinerator does not have to come from households. The LGA could encourage councils to step up their commercial waste operations, or to actively encourage local commercial waste operators to supply waste to their incinerator to replace any shortfall in the council’s own material.
While it is encouraging to see the LGA at last taking note of the RWIR’s concerns, the lessons it draws from the study are certainly not those we would wish to encourage. Calling for less ambitious recycling targets may seem like the obvious solution, but many cheaper and more creative ways of dealing with the challenge of local authority incinerator overcapacity are available. We hope that the LGA and the councils they represent will be keen to explore them, preferably before the likelihood of a 65% or 70% recycling target becomes a reality.