A New Recycling Policy Comments by Northern Ireland Environment Link 10 th June 2011 Northern Ireland Environment Link (NIEL) is the networking and forum body for non-statutory organisations concerned with the environment of Northern Ireland. Its 56Full Members represent over 90,000 individuals, 262 subsidiary groups, have an annual turnover of 70 million and manage over 314,000 acres of land. Members are involved in environmental issues of all types and at all levels from the local community to the global environment. NIEL brings together a wide range of knowledge, experience and expertise which can be used to help develop policy, practice and implementation across a wide range of environmental fields. These comments are agreed by Members, but some members may be providing independent comments as well. If you would like to discuss these comments further we would be delighted to do so. Prof Sue Christie, Director Northern Ireland Environment Link 89 Loopland Drive Belfast, BT6 9DW P: 028 9045 5770 E: Sue@nienvironmentlink.org W: www.nienvironmentlink.org Northern Ireland Environment Link is a Company limited by guarantee No NI034988 and a Charity registered with Inland Revenue No XR19598 1
Introduction We thank you for the opportunity to comment on the above consultation. We hope that the information below will be useful forthe decision making process. We invite you to contact us if you have any further questions regarding our comments. Northern Ireland Environment Link annually publishes a summary of the policy priorities agreed by members, entitled The Way Ahead. This document strongly supports our priorities to adhere to sustainable development principles and to achieve environmental protection via enhance waste management practices in line with the waste hierarchy. It is clear that the generation of waste from all sectors needs to be urgently addressed. We strongly support the new recycling policy which aims to actively encourage an increased recycling rate and take a more positive approach to waste prevention. This policy will also address targets in previous legislation such as the revised Waste Framework (2008/92/EC) and Landfill Directives (99/31/EC). In the current economic climate which is facing severe spending cuts, waste must be viewed as a resource that can reduce costs and create additional revenue. For too long waste has had an image that it needs to be discarded to a landfill. We strongly support the application of the waste hierarchy as we believe that it will help prioritise resource efficiency and enable us to reach future targets for recycling waste. We particularly welcome the life cycle approach and the emphasis on preventing waste rather than dealing with material produced by disposal options. We agree with introducing sustainable measures which will support this policy in meeting the targets. We are concerned with protecting our natural and built environment as Northern Ireland boasts a landscape rich and diverse with many sites of international importance. Waste reduction will help to protect the environment and also assist in the reduction of Green House Gas emissions. Consultation Questions 1. Do you think that an inspirational regional target municipal recycling rate of 60% by 2020 is appropriate? Recycling rates have increased significantly to over 30% over the last decade. Contributing factors such as increased services provided by councils to include garden, food, dry recyclable and black bin services affect recycling rates of households, and more can be done in increasing the services available and encouraging people to use them. We strongly support the aspirational regional target of at least 60% by 2020. While we are in favour of this new recycling rate, we are concerned with how we are going to meet this target. The correct infrastructure and services need to be provided and incentives offered to encourage their use. This must be supported by an integrated approach to waste streams and provision of a range of processing options for different materials. It requires a major initiative with retailers and producers to decrease packaging and increase the recyclability of the packaging that cannot be reduced. Research estimates that an average household is throwing away 50 worth of edible food and drink each month. Food and other biodegradable waste must be a prime target for provision of 2
separate collection as it comprises nearly one quarter of waste collected as well as being a major contributor to GHG emissions and potential pollution. For these reasons we strongly urge a focus on addressing food waste with attendant social and economic benefits for consumers as well as councils. Focusing on recycling rates can obscure the overall drive for waste reduction which is the prime goal. It is vital that mechanisms for measurement and reporting of recycling do not undermine or counteract drives for waste reduction. The inclusion of different waste streams, different materials, different collection methods and provision of facilities to recycle different items all impact on measurement and make comparison of reporting difficult and this needs to be borne in mind when establishing reporting and monitoring arrangements. 2. How can this target be achieved? The ultimate goal is to reduce the amount of waste produced and to recycle the maximum proportion of that which is produced. To fulfill this we support the following principles: A strong and buoyant local reprocessing industry that adds significant value to the NI economy through the availability of materials suitable for reprocessing. Encourage closed loop recycling so that the economic and carbon benefits of recycling are maximised (for example glass recycled into glass bottles rather than aggregates). Build public confidence in recycling through openness and transparency about the end destinations and landfill rejection rates of recyclables. Encourage recycling systems that are easy to use and are not too demanding on the public. Establish targets and indicators that are most likely to result in objectives being met. Inclusion of all sectors This target can be achieved by the involving all sectors (private, central government, local government, community & voluntary) in integrated approaches targeted at the areas where they are each most appropriate. Households need to be engaged about the issue of waste disposal through improved information, facilities and education. Manufacturers need to improve products and packaging with end of life options clearly prioritised. Central and local government need to ensure the clarity and consistency of the message and support through appropriate incentivisation and disincentivisation packages. NGOS can play an important role It is important to target certain information to the different consumers within a household. Educating the younger generation should be creative and inspire behaviour that cares for our natural environment. Presently there are programmes being run by environmental NGOS which are educating and advertising the importance of recycling in schools. Therefore we want to see the investment to keep these services. There are many other areas where NGOs can contribute to achieving waste-related government environmental objectives and actively exploring these offers significant opportunities for effective and efficient progress. The willingness of people to act on messages is often closely related to the organisation giving the 3
message and their perceived motivation; working with NGOs can provide more effective messaging than government working alone. Effective and convenient services In order for consumers to be active in recycling, it has to be easy for them. We recommend that waste disposal services should be reviewed to ensure that they fulfil this criterion; the problem of different councils recycling different materials must be addressed to allow uniform messaging, and the issue of recyclable materials not being recycled causes much confusion and frustration to the public. Initiatives and incentives to recycle should also be considered as way to encourage households. We should look to other countries for effective examples. Focus on quality of recyclate It is vital that the materials collected can be effectively recycled into new products; this requires a focus on obtaining high quality products with a minimum of contamination. This maximises the economic return and thus minimises the cost to citizens. 3. Do you think that, subject to more accurate data becoming available on commercial and industrial waste, similar targets should be set for this form of waste? Targets for commercial and industrial waste are required, but the lack of data is concerning. There are huge opportunities for integration across waste streams to deliver more efficient and effective solutions (different technologies, local delivery of energy/waste management benefits) and integration across waste streams will make this much easier to achieve. Targets for C&W waste should be at least as high as municipal. 4. How can these targets be achieved? These targets can be achieved by providing the sector with the appropriate clear, concise information and support to meet any targets. We recommend further that the Department takes advice from and work with organisations that help businesses and authorities to reduce their waste and recycle more. The Waste& Resource Action Programme (WRAP) provides detailed research and case studies which prove resource efficiency and recycling can occur in all sectors. Involvement of design solutions for packaging, effective promotion of re-use, provision of uniform and universal recycling facilities which householders find easy to use and integration of commercial recycling provision are required. Financial incentives/disincentives are required as support, as is full information on the actual costs to society as a whole of inappropriate waste management. 5. How can the 70% recycling target for construction, demolition and excavation waste be achieved? We encourage the introduction of legalisation with a recycling target to gain compliance. Therefore regulating this process is the best option. NIEL has already strongly supported the introduction of the Site Waste Management Plans (SWMP) in a consultation earlier this year, as 4
it is estimated that 13% of materials delivered to a site will be unused and considered as waste. We believe that the production of this type of plan could be a tool to scrutinise over the use and provision of resources. 6. Do you think that targets should be developed at individual council level and as well as for Northern Ireland as a whole? While we recognise that each council is faced with slightly different factors that can affect how services are run, there must be integration even beyond the three Waste Management Groups given the overall small size of Northern Ireland and the need for a consistent message to consumers. We support the introduction of a target system for the individual councils recognising the constraints and opportunities within their particular system. Full commitment of all councils to delivering on overall NI targets is required. Consideration needs to be given to the ability of smaller councils with low per capita production, as it may be more difficult to achieve further major reductions so a consideration for councils with low waste arisings may be needed. Consideration needs to be given as to how targets are applied; per capita is the most obvious but there may need to be consideration applied to urban vs rural as well as progress to date. 7. What are your views on the need for a comprehensive regime of measures, including incentives and sanctions, across all sectors of waste management to encourage the best outcomes? We support the introduction of comprehensive measures that will include incentives and sanctions. We believe that fiscal incentives and disincentives for those in the waste management sector will provide significant motivation to participate. Sanctions therefore need to be sufficiently enforced and infractions published. While it will be beneficial to have measures across all the sectors which deal with waste management, the Department should consider having specific measures for particular sectors that will act as appropriate drivers to action by that sector. 8. What are your views on the Department s intention to consider giving the targets in this paper a statutory basis as part of a wider landscape of legislative provisions to promote the appropriate management of waste? If the targets are to become statutory, consideration would have to be given to the governance of any measures. Penalties, checks and administrative requirements would need to be fair and penalties large enough to act as effective deterrents. 9. What interventions- if any- by local and central government do you think could help contribute to further growth in the recycling and reprocessing sector? We suggest that both local and central government need to work together to deliver improved recycling rates.government in all its forms must set an example in the implementation of this policy. Incentives and sanctions, support by central to local government to develop integrated approaches and clear delivery and messages are required. Ultimately a single Waste Management Authority which looks at the needs of Northern Ireland as a whole would lead to improved delivery. 5
10. Are there other ways through which the Department could encourage the construction, demolition and excavation sector to recycle more of the waste produced and ensure the targets are met? Information, sharing of best practice, incentives and sanctions and clear statement of policy and requirements (e.g. to obtain government contracts) are all required.recycling should be seen as essential aspects of saving money/ reducing costs of doing business. Perverse barriers to recycling must be identified and addressed urgently. 11. Are there other ways through which the Department could encourage the commercial and industrial sector to recycle more of the waste produced and ensure targets are met? Information, sharing of best practice, incentives and sanctions and clear statement of policy and requirements (e.g. to obtain government contracts) are all required. Recycling should be seen as essential aspects of saving money/ reducing costs of doing business. Perverse barriers to recycling must be identified and addressed urgently. SUMMARY POINTS Government should take the lead in this policy and be an example. We strongly support the use of the waste hierarchy with the aim to shift as much of the waste as possible to the prevention level and the minimum to the landfill/disposal level. Recycling should be encouraged not only to protect our natural environment but also human health and reduce green house gases emissions. Households should be educated about reducing, reusing and recycling of waste. Through different type of media, programmes and activities. All sectors- private/public and community & voluntary should get involved. Local councils should provide a service that suits the needs of their local community; however there should be a balance struck with providing a uniform service to allow everyone to recycle the same materials and facilitate unified messaging. We support the introduction of council targets as Northern Ireland council population, demographics are diverse, however it should not be seen as opting out of the 60% target. Incentives and sanctions should be introduced across all sectors involved in waste management in order to achieve full compliance. We believe that more data needs to be collected about commercial and industrial waste in order to address the problems of the sector and devise appropriate incentive schemes. 6