Zero Waste England Circular Economy Response

Transcription

1 Zero Waste England Circular Economy Response This is a response by Zero Waste England to the EU Commission Public Consultation on the Circular Economy at Introduction and some Conclusions Zero Waste England is an open source, not-for-profit think tank focussed on researching the path towards zero waste and a circular economy in England. At present, we are concentrating on issues relating to household and municipal waste ( MSW ), and secondarily we are looking at commercial and industrial waste ( C&I ). We agree with the widening of the scope of the concept of the Circular Economy in the latest Roadmap, however we will restrict our comments to the areas which are within the current scope and expertise of our organisation. Overall, we applaud and welcome the content of the Circular Economy documents which we expand upon below, and our overall conclusions can be summarised as follows: 1. We welcome the proposal to prohibit the landfill or incineration of recyclable materials wherever this is practicably and economically feasible, target inception This is entirely in line with the Waste Hierarchy which, in theory but often not in practice, is a legal requirement in member states consequent upon the Waste Framework Directive 2008/98/EC 2. There are inconsistencies in the documents regarding recycling targets and inception dates. We believe 70% recycling by 2020 is ambitious but entirely feasible, and already being achieved in some places. As change takes hold, we believe at least 80% by 2030 should be binding. Again, some places are achieving this already. 3. But we feel that recycling rate by itself is not a very good indicator as waste growth can still be occurring. We therefore suggest the additional metric of residual waste per capita per annum or per week expressed in grams or kilograms, together with reduction targets. 500 grams per person per week in our view and experience is easily achievable, and 250 grams is achievable. 4. We wish to see a clear commitment to a level playing field of taxation of landfill and incineration in order to encourage circularity. Both disposal methods are equally undesirable although we accept that very limited landfill of mostly inerts will continue. 5. We wish to see an immediate moratorium on the building of more incinerators both because there is existing or impending capacity excess in most of the Union and because incineration is a contributor to climate change. This does not imply not continuing research: for example true pyrolysis has the potential to sequester carbon. We would point to the twin problems of inertia and vested interests within both local authorities and the waste industry as we highlight in the content of appendix 5 which includes our related comments concerning roadblocks. 6. We wish to see substantial Commission support for and investment in publicity and education regarding waste, and the active encouragement of simple community level waste management such as and the Zero Waste Communities at 1

2 Appendices In the appendices below, we make comments within the various Commission documents which apply to these concepts as, understandably due to their format; measures are often somewhat buried within the texts. We have extracted what we see as the relevant parts of the documents to our agenda. Where appropriate we have made comments and recommendations, identified under yellow highlight. Appendix 1 Roadmap to a Resource Efficient Europe COM/2011/0572final This document can be found at This was really the first Commission document where the term Circular Economy is mentioned albeit within the text, and where the concepts are clearly looking forward to a circular economy in practice. We refer to section 3.2 Turning Waste into a Resource as being within our remit. In particular, we highlight the following extracts: In some Member States more than 80% of waste is recycled, indicating the possibilities of using waste as one of the EU s key resources. Improving waste management makes better use of resources and can open up new markets and jobs, as well as encourage less dependence on imports of raw materials and lower impacts on the environment. We agree that 80% recycling is entirely practicable and we have seen it in operation Zero Waste Communities as cited in summary Point 4 above. If waste is to become a resource to be fed back into the economy as a raw material, then much higher priority needs to be given to re-use and recycling Agreed. There is far too much emphasis on disposal rather than working as high up the waste hierarchy as possible due to inertia and vested interests. Despite its legal status within the Waste Framework Directive, the waste hierarchy is not enforced by Member States. Milestone: By 2020, waste is managed as a resource.. More materials, including materials having a significant impact on the environment and critical raw materials, are recycled.. Energy recovery is limited to non recyclable materials, landfilling is virtually eliminated and high quality recycling is ensured. The Commission will:. - Ensure that public funding from the EU budget gives priority to activities higher up the waste hierarchy as defined in the Waste Framework Directive (e.g. priority to recycling plants over waste disposal) (in 2012/2013); Facilitate the exchange of best practice on collection and treatment of waste among Member States And it is the Commission that will have to make this happen, if necessary by forcing change by Directives to overcome inertia and vested interests. 2

3 Appendix 2 Roadmap Circular Economy Strategy dated 04/2015 This document can be found at This is the document which is the subject of this present consultation, and is commonly assumed to be the replacement for the original Potocnik Circular Economy Package com/2014/0398final (which we comment upon below); however we see it more as a broadening of the scope of the original proposals rather than making any new proposals in and of itself. The document is very general and non-specific in its approach, generally looking forward to further work and citing a long list of related initiatives and previous consultations. Appendix 3 Towards a Circular Economy: A zero waste programme for Europe COM/2014/0398final2 This document can be found at and is the original Potocnik proposal, in turn cited by the new Roadmap above. In general we agree and applaud this whole document. In particular, we highlight the following extracts: From section 1: Existing infrastructure, business models and technology, together with established behaviour keep economies locked-in to the linear model. 2.1 incentivising and supporting waste reduction and high-quality separation by consumers; The waste hierarchy that underlies our waste legislation is leading progressively to adoption of the preferred options of waste prevention, preparation for reuse and recycling, and discourages landfilling. Add: and incineration In 3, The European Union has set out its political commitment [24] to reduce waste generation, to recycle waste into a major, reliable source of raw materials for the Union, to recover energy only from non-recyclable materials and to virtually eliminate landfilling. In 3.1, Defining waste targets, Six [Member States] [are] reaching recycling rates of 85 % in certain regions Note this for discussions elsewhere. Separate collection at source along with sound methodologies to calculate recycling rates will ensure high quality recycling and contribute to the development of markets for the supply of high quality secondary raw materials. Member States should endeavour to virtually eliminate landfill by Energy recovery, including waste-to-energy recovery and use of bio-fuels, will have a role to play with respect to non-reusable and non-recyclable waste. This will require more efficient use of the unevenly spread energy recovery capacity currently available in the EU, together with measures to avoid overcapacity. This should perhaps be existing energy recovery and energy recovery meaning full heat use as well as electricity generation. As we argue elsewhere, there is already an incineration overcapacity in many member states. Where the heat use is essential, such as for district heating, RDF can be 3

4 shipped from other Member States. Measures to avoid overcapacity we suggest could simply mean a moratorium on new build incineration capacity - boost reuse and recycling of municipal waste to a minimum of 70% by 2030; We think 80% by 2030 is entirely feasible as you agree in 3.1 above that 85% is already being achieved in places, and indeed we have seen it. - ban the landfilling [Add: and/or incineration ] of recyclable plastics, metals, glass, paper and cardboard, and biodegradable waste by 2025, while Member States should endeavour to virtually eliminate landfill by 2030[26]; For 2025, change to This simply requires effective kerbside sort followed by good MBT pretreatment before disposal. The techniques exist and are well proven. Economic measures have proved instrumental in improving national waste management, in particular through landfill and incineration taxes, pay-as-you-throw and extended producer responsibility schemes, or incentives for local authorities to promote prevention, reuse and recycling. Agreed. There should also be a level playing field in taxation between landfill and incineration. European funds can support Member States efforts focusing on integrated waste management including separate collection, reuse and recycling infrastructure. Landfilling or stand-alone incineration should not be supported in future. Agreed. This concurs with our comments above on the waste hierarchy and district heating. Making the best use of available waste management capacity in the EU would require better planning and information-sharing and may involve tolerating more shipments of waste within the EU towards the most modern and efficient installations, at least as a transitional measure. Absolutely. Municipalities are not surrounded by brick walls. The Silo culture is a problem. - promote direct investment in waste management options at the top of the waste hierarchy (prevention, re-use, recycling). Agreed. There has been too much investment at the bottom of the waste hierarchy and too little at the top. In fact the Waste Hierarchy has been widely ignored in investment decisions despite its legal status in the WFD due to inertia and vested interests. Member States performance will be monitored against the target of 70 % recycling by

5 Appendix 4 Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Directives 2008/98/EC on waste, 94/62/EC on packaging and packaging waste, 1999/31/EC on the landfill of waste, 2000/53/EC on end-of-life vehicles, 2006/66/EC on batteries and accumulators and waste batteries and accumulators, and 2012/19/EU on waste electrical and electronic equipment COM/2014/0397 final This is a Directive cited by some of the documents above, and would appear to have been overlooked by many, whereas we feel that, as a directive, it should receive more attention as it has the force of EU law unlike text put forward as proposals. We have: (4) Many Member States have not yet completely developed the necessary waste management infrastructure and are planning investments now. It is therefore essential to set clear policy objectives in order to avoid locking secondary raw materials at the bottom of the waste hierarchy. Absolutely. Investments are still being made in incineration at the bottom of the waste hierarchy when to achieve change to circularity AND simply obey the waste hierarchy, investment is needed at the top of the hierarchy including in public relations and education. (8) Through a progressive increase of the existing targets on preparing for re-use and recycling of municipal waste and the elimination of recyclable waste from landfilling [Add: or incineration ] corresponding to a maximum of 25% landfilling [Add: or incineration ] by 2025, it should be ensured that economically valuable waste materials are progressively and effectively recovered through proper waste management and in line with the waste hierarchy Implementation of clause (8) will clarify the legally binding requirement to comply with the waste hierarchy as far as is technically and economically practicable and which currently is being effectively ignored by continued investment in disposal by incineration at the bottom of the hierarchy (9) Clear environmental, economic and social benefits would be derived from further increasing the targets laid down in Directives 2008/98/EC, 94/62/EC and 1999/31/EC for reuse and recycling of municipal and packaging waste, starting with waste streams which can be easily recycled (e.g. plastics, metals, glass, paper, wood, bio-waste). 12) It follows from the targets included in this proposal that Member States should support the use of recovered materials, such as recovered paper and wood, in line with the waste hierarchy, with the aim of securing the supply of raw materials and moving the Union closer to a "recycling society", and, whenever possible, should not support the landfilling or incineration of such materials. Member States should not support the incineration of waste that can be recycled in a technically and economically feasible way and under environmentally safe conditions. Recital 29 of Directive 2008/98/EC should be interpreted in this context. We applaud this clause for making really clear the policy regarding avoiding incineration of recyclable materials and this is also an important clause in relation to the effects of incineration overcapacity and the need to avoid its consequences on achieving circularity, and we suggest a moratorium on building any further capacity Article 9 Prevention of waste (i) point (a) is replaced by the following:'(a) by 1st January 2020 at the latest, recycling and preparing for re-use of municipal waste shall be increased to a minimum of 50% by weight; NO! This is inconsistent with 70% by 2020 elsewhere. 50% is going backwards! (ii) the following point (c) is added: 5

6 (c) by 1st January 2030 at the latest, recycling and preparing for re-use of municipal waste shall be increased to a minimum of 70% by weight. NO! Again, this is inconsistent with targets elsewhere. This should be at least 80%. Appendix 5 Local Government Association EU Circular Economy position paper April 2015 This paper is the response to the Circular Economy consultation by the UK Local Government Association which can be found at ular+economy+position+paper+april+2015/8b87f4f5-a80e afef c and we use it as an example of the practical difficulty of achieving change. What follows is mostly our commentary with quotes from the document in parentheses. This paper seemingly starts well with: We welcome the review of the original EU circular economy package and offer a range of suggestions to inform the revised proposals. Our suggestions seek a more rounded approach that includes all waste produced across the economy, a greater focus on waste prevention that builds on councils commitment to the principles of the waste hierarchy and avoiding the disposal of waste to landfill. However we would have liked to have seen and incineration at the end of this paragraph. Why was incineration omitted? We think this is fully explained by the last paragraph in section 2.1 which says: There are also practical limitations on what can be realistically achieved. English local authorities have committed many hundreds of millions of pounds to underpin the delivery of waste treatment infrastructure to radically reduce landfill by This treatment capacity will process a volume of waste that will make meeting a suggested 70 per cent recycling target unachievable.8 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. For treatment capacity read Incineration capacity! We think the effective preference for large incinerators has been considerably exacerbated by both the big business approach implicit in the EU and OJEU contract rules, together with seeming member state preference for this approach, for example coming out of the DEFRA Waste Infrastructure Delivery Programme PFI (private finance initiative) awards in the UK and to date this approach has largely been continued by the UK Green Investment Bank with some 85% of its waste infrastructure project funding going to new incineration. There is also an almost complete lack of top level coordination by the governments of many member states. In practice these approaches mitigate against local, community based, not-for-profit solutions which can deliver better results at significantly lower cost through their better understanding of local circumstances including effective involvement and communication with the communities they serve. For a true circular economy to succeed, implicit within this should be the creation of industries that will perform the essential processes of repair, re-manufacturing and manufacturing with locally sourced recycled resources. 6

7 There is ample evidence that the UK, and we would presume some other member states, that we will see an increasing oversupply of incineration capacity in relation to even current waste arisings trends. The overcapacity will be even greater if the targets proposed by the Circular Economy Roadmap become Directives. Set against this the fact that, unlike other waste processes, incinerators have to receive waste volumes approaching their design throughput in order to maintain the temperatures required to meet the Waste Incineration Directive. So there are arguments that recycling cannot reach the levels the Roadmap requires because the incinerators that will exist will have to be fed with waste, which of necessity will include recyclable materials. Quite simply, this cannot be allowed to happen and would simply be a continuation of the outdated linear paradigm. So some, many even, incinerators may indeed become redundant and may have to be shut down well before the end of their binding contracts with local authorities. At least seven years ago, the evidence and trends on waste arisings were clear well before the original 2011 Roadmap. It was widely reported in the waste press, such as this article from 2012, see We quote: Frans Beckers, a director of Dutch waste services company the Van Gansewinkel Group explained that his company imports RDF from the UK and Italy but had recently closed one incinerator due to overcapacity and urged others to follow suit. He said: We closed one of our incineration plants in the Rotterdam area. There is overcapacity in Germany and we hope some of our colleagues will follow suit. We hope more capacity will be taken out of the market. In the end we could harm recycling performance. Even seven years ago, recycling was increasing, and residual waste remained generally static (at least in the UK). And yet incinerators were built predicated on 50% recycling and residual waste rising with GDP on 25 years + contracts. And they are still being planned, funded and built despite substantial local opposition. As we say above again and again, circularity will be resisted because of inertia and because of vested interests, and this is why we also suggest a moratorium on all new or planned incineration capacity, including those projects which have planning consent. So it will require clear, strong, binding directives and real commitment to change from the Commission and from Member States in order to force through the essential changes such that some sectors loosen their grip on the seeming certainty of the old linear paradigm. Compiled by Chris Harmer, a director of Zero Waste England and on their behalf. Zero Waste England is Company Number and registered in England. Its registered address is 69 Church Lane, Coventry, West Midlands CV2 4AL, UK. Correspondence in this matter should be addresses to the author at: Spring Corner, Rockness Hill, Nailsworth, Gloucestershire GL6 0PJ, UK Or to chrisharmer[at symbol]zerowaste-england[dot]org[dot]uk. The Zero Waste England logo is in process of revision so is not displayed. 7