Freepost                                                                          
Defra Waste Strategy Review
Freepost SEA 12430
Thornton Heath
CR7 7XT

May 6 2006

 

Dear Sir or Madam

 

Please treat this letter as my response to the consultation on England’s Waste Strategy.

 

Q1  I call on Defra to:

-          give more weight to waste separation,

-          to base all parts of the waste strategy on a sound understanding of waste composition so that facilities are matched to waste materials,

-          to show leadership in setting waste reduction targets for all sectors and

-          to ensure that incinerator-free options are made available to communities.  Anaerobic Digestion, which fared well in assessments, and generates energy, is being ignored.

The way incineration and fuel for incinerators are being favoured and promoted troubles me.    

 

Q2   I consider that the new national recycling and composting targets should be at least 60% by 2025.  

Q3   I believe very strongly that municipal waste recovery targets should be scrapped.  If a) recycling and composting targets and b) targets for diverting biodegradable waste from landfill are met, recovery rates will have to be high.  To set an arbitrary recovery target will simply serve to restrict options as to how these other more important targets are met.  For example, the draft recovery target for the South East of 84% recovery would rule out technologies such as Anaerobic Digestion that the South East Plan itself advocates as good environmental options!

 

Q5   I am worried by the suggestion that you might encourage some waste recovery by exempting it from needing a licence.  Public confidence in regulation in the waste sector is already low.

 

Q10  Yes, there should be a lot more effort to encourage waste prevention as well as promotion of recycling.  There needs to be a high profile advertising campaign, on a scale with that used to encourage wearing of seat belts, to promote waste prevention and recycling.  The importance of separating food waste, which cleans up the bin, should not be underestimated in changing attitudes to recycling.

Figure 9 is missing a key motivation.  Many people are changing their behaviour when it comes to waste because they want to avoid incineration.  Avoiding undesired consequences is a key driver that can be harnessed to change attitudes.

 

Q13  A major information gap is ignorance about waste composition.  For example, the composition of waste remaining after 60% recycling has been achieved is needed to determine the most appropriate treatment facilities.  There is also a need for research into MBT configurations that avoid incineration.   Best options should be established for various waste compositions.  This will offer an effective alternative to incineration that also meets targets.

 

Q15-18  Reducing the built-in obsolescence of goods should be encouraged, as should the potential to upgrade rather than replace products.

Companies such as supermarkets should be given compulsory targets for reducing the amount of waste they produce, particularly waste which cannot be recycled or composted.

 

Q22  An effective way to engage consumers to reduce waste would be to offer incinerator-free waste management options if they play their part.

 

 

Chapter 5:  I disagree with the following from the “summary” and consider that:

-          incineration should not be encouraged as part of energy recovery

-          while unclean, unsorted landfill is bad, landfill of clean, biostabilized material could be a good environmental option

-          composting, including home composting, should not be overlooked given that 68% of waste is biodegradable.

“Challenges” listed should include “failure to develop environmentally sound options that respect the strong public aspiration in some communities to avoid incineration

It is notable that while incinerator industry concerns are acknowledged, legitimate public concerns about incineration are dismissed as misguided.  Community partnership based on an incinerator-free approach could be a very strong motivator in meeting targets.

 

Q24  I believe strongly that Local Authorities should have waste separation targets to promote this vital stage in managing waste to recover resources.  Communities should also have waste prevention targets.

Q25  All communities should be expected to play an equal part in achieving national waste prevention and recycling targets.                              

 

Q26  I am shocked by the section on recovering energy from waste.  This completely disregards Anaerobic Digestion (alone or as part of MBT) even though it comes out very well in assessments, produces energy (gas) and heat and it would prevent methane- generating landfill.  The fact that Austria has already met its landfill avoidance targets with no more incinerators than the current UK level, and that Spain is opting for AD, should be explored.  The fact that with a recycling rate of 31% Hampshire no longer generates enough black bags for its incinerators is a recent reminder that flexibility in waste treatment capacity s required rather than relying on large facilities.

 

I am deeply unhappy that the Government is suggesting incineration (EfW) should be expanded from about 10% to 25% of waste treatment capacity and will be considering financial and other support to deliver these facilities.

 

Q28  A place for well-managed landfill of clean, bio-stabilized or separated material should be recognized.  This place would be after maximum recycling, composting and biological treatment have been achieved.              

 

Q29  Delivery of waste facilities could be speeded up if technologies with greater public acceptability, and that make better neighbours, were used.  Defra-funded research and assessments have shown that incineration is not necessarily the best option.  This finding needs to be fed through into policy.  EG Entec study for Surrey Local Government Association.

 

Q38  I strongly support moves to improve facilities for taking hazardous materials out of household waste and wish to see public education about the consequences of putting hazardous materials such as batteries in mixed waste.  

 

Yours Faithfully   

 

 

 

 

 

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