Does less landfill equal more incineration?

1. Burying the evidence

Almost 80% of domestic waste in the UK ends up in holes in the ground: and most of that it not pre-sorted to extract recyclable or compostable materials. In this respect the UK is the country by far the most addicted to burying in Europe. We know we are going to have to change, if only because burying undifferentiated waste is literally a waste of recoverable resources, and because there are simply no more holes left to bury things in. But we are also now enjoined to change by tough new EU regulations on landfill which set targets for reduction that require radical action on the culture of burying in the UK if they are to be met. The problem is that the easiest way to do this is to divert waste from holes to incinerators - barely up the scale of 'goods' and 'bads' as far as waste management is concerned. We may well be set to replace the problems of burying with new problems of increased CO2 emissions from waste, and the long term commitment for incinerator feedstock of materials that can and should be sorted and diverted from the waste stream. The government, in planning its response to the EU directive, is confident that this will not happen, but a number of theoretical arguments, and the evidence from Local authority plans suggest otherwise.

2. The Government's waste strategy.

The Government set out its strategy on managing the increasing tide of waste in the 'Waste Strategy 2000' published in May 2000.1 This identified why progress had to be made on the waste mountain - no action would mean waste increasing at 3% per year, and in any event environmental considerations made separation, reuse and recovery of waste a priority. This in itself suggested that the profile of waste disposal had to change radically - we could no longer countenance practices of simply gathering the waste up and dumping it in landfill. Landfill sites are becoming scarce, and in any event, the emergence of the EU waste directive meant that the UK was required to put into law measures for achieving a radical reduction of waste going to landfill. Using a baseline of 1995, the EU targets would require a reduction of biodegradable municipal waste going to landfill by 25% by 2010, 50% by 2013, and by 65% by 2020.

The Government has moved to put these targets into UK law by means of a sophisticated waste trading mechanism: waste disposal authorities will be able to trade surpluses of landfill reduction over their targets with other authorities failing to reach their targets in an agreed year: a 'cap' on the total tradable level of landfill will ensure that the target overall is met.

At the same time, the Landfill directive has spawned targets adopted by Government for the recovery of value from municipal waste in general: by 2005 value should be recovered from 40% of waste, by 2010 45% and by 2015, value from 67% of the waste stream. 'Recovery of value' means that value from waste should be obtained by recycling, composting, digestion or by the production of energy from waste.

Within this target, the Government has set a sub-target of achieving value from waste by moving its treatment up the hierarchy, which is now a well established 'pyramid' of waste treatment. At the bottom is landfill, and at the top, waste reduction. In between lies, in ascending order, landfill with energy (capturing of methane), energy recovery, recycling and composting, and finally just blow minimisation, re-use.

The targets for recycling and composting are clearly designed, therefore to move waste forward in this pyramid, with a target set of recycling or composting at least 25% of household waste by 2005, 30% by 2010, and 33% by 2015.

Taken together, therefore the Governments intent is clear: ideally waste should be minimised, and the recent Strategy Unit report 'Waste not, want not'2 sets out a programme for initially slowing down and then stopping the annual increase in waste arisings. Within the waste stream, however, radical action is required to pull the treatment of waste up through the hierarchy. Far more waste must be 'captured' before it enters the disposal stream, and diverted for re-use or recycling. Where it is not diverted, it should be composted or digested. Some might still be incinerated especially if it is not possible to deal with it by other means, and certainly very little, by 2020, should be going into landfill.

3. Can we achieve our targets?

That is the grand plan, and to date, it has been the subject of some apparently founded criticism that it sets out tough targets and trajectories, all of which fail because of the essentially declamatory nature of the targets. The Strategy Unit report 'Waste not want not' indeed recorded a catalogue of target failures over more than a decade by governments of both parties.

However, the Waste and Emissions Trading Bill aims to break free of this cycle of failed targets: the enforceability of the local targets, the 'cap' and the trading mechanism will see to that. The overall EU targets of reducing waste going to landfill should, therefore be met on a guaranteed basis.

The question that arises, however, is whether the Bill also enables other sub targets to be met. Will waste move out of landfill and up through the hierarchy, via greatly improved levels of waste stream capture for recycling and re-use, and by compositing of the bulk of the biodegradable remainder? Clearly an upshot of the tough new regime that simply moved waste away from holes in the ground and into incinerators would not only be a poor environmental result from the point of view of greenhouse gas emission, but would entail a failure to break into the radical new treatments suggested by the 'hierarchy'.

Incineration as an alternative to landfill looks like the easy option. Establishing composting, recycling and re-use requires a much more extensive network of provision - of composting plant, of sorting and transit centres for recovered waste, and the development of markets for recovered or reused material. The Government, however, is confident that this option will be transcended. Incineration, despite plans for a number of new and relatively large incinerators 3 remains at a relatively low level as old and environmentally unacceptable municipal burners are phased out - some 9% only of municipal waste is treated in this way. The Governments case essentially is that this is about the level incineration will come to rest at: waste treatment will 'leapfrog' incineration and will settle into the higher reaches of the hierarchy over the timescale envisaged for the achievement of the targets.

4. Landfill to incineration?

But will it? The implementation of the strategy lies in the hands of the waste disposal authorities in England Wales and Scotland - Counties, Metropolitan Boroughs and Unitary authorities, working singly or in consortia. Strong arguments have been put4 that the rational response of waste collection authorities to the demands placed upon them by the enforceable nature of the landfill directive targets will be to downgrade other unenforceable targets and opt for incineration as a long term alternative.

The reasoning behind this argument is that waste disposal authorities have very few resources available to them to invest in the type of plant that would enable the 'leap through the hierarchy' to take place. It is true that they face a rapidly escalating charge for depositing their waste in landfill sites, but this is payable from revenue budgets. Indeed, a side effect of the increase in cost of landfill to WDAs is that the more they have to pay in gate fees, the less they have left from the same budget to pay the revenue consequences of schemes that might divert waste or compost it. It acts as a perverse incentive, in revenue terms for the establishment of the waste diversion schemes that are supposed to be incentivised by the rise in gate fees.

However, the type of plant necessary to 'leap the hierarchy' is expensive and extensive. It requires considerable battles with local planning permission, the importation of massive new capital plant, and some semi-commercial arrangements at the end of all of it to place the products thus recovered onto the market. All this is required as an alternative to the simple process of receiving the waste, putting it in a hole and paying for it.

Not only do many WDAs not have the capacity to do this, it is suggested, but they do not have the capital either, since the necessary plant will be a major call on the local authority's capital programme. Under these circumstances, the rational response is twofold: look for solutions that get the most 'bangs for bucks' (and which certainly do not inflate the council tax demand to service the debt) and try to obtain them off balance sheet - effectively by doing a deal with a private contractor to manage the service.

Private contractors, however, may solve the investment problem by putting up their capital rather than that of the local authority, but they will have other requirements that cause problems for managing the waste hierarchy. Firstly they will wish to co-operate with the 'bangs for bucks' requirement by proposing and operating waste management systems that process the most for the least cost - which is incineration. Secondly, they will expect some security for their investment. They will not expect to build a plant only to find in a few years time that the local authority has changed its mind, and they have a stranded asset to deal with. This will mean, it is alleged (and is demonstrated by various existing deals) that contracts will be for long periods - twenty five years perhaps - and guarantees will be sought about the waste stream to be supplied fro the incinerator. Both requirements, for example have been placed into the contract for Hampshire's waste: a similar arrangement is presently under way in East Sussex.

The result is that policy is frozen, and worse, frozen into incineration. The 'capturing' of the waste stream also means that, logically, programmes to divert waste for recovery or composting will have to stop once they succeed sufficiently to dry up the stream for incineration. The long term incineration option, therefore works directly against other targets.

This is, it must be stressed, an argument from logic, with some evidence of practice to underline it. But it is by no means established empirically, and indeed the Government strongly resists the notion that incineration will expand substantially from its present level. They point to a number of constraints on the permission regime for incineration plants, and the need for planned incineration plants to receive pollution prevention and control permits from the Environment Agency before they can proceed.

The Minister for the Environment, Michael Meacher, made this case in the committee stage of the Waste and Emissions Trading Bill. He said:

'It does not follow that waste disposal authorities will choose incineration over and above other forms of waste management if we do not provide legislative disincentives for it, because there are already disincentives in this country. Incinerators require considerable upfront capital investment. They are also very unpopular and I would judge, increasingly so, which leads to long delays in planning permission and to the rejection of applications. It can take up to ten years to introduce an incinerator…….Furthermore local planning authorities are required to have regard to national policies, including the waste strategy, when drawing up development plans that provide a framework for planning decisions'5.

5. A test for the arguments.

So are the concerns right in practice, as well as arguable in theory? It is very difficult to ascertain what might or might not happen, but one way of doing this is to assess what the waste disposal authorities present plans actually say. Do they, put together, present a picture that bears out the logic of the policy critique, or do they show a direction in practice, that comes into line with the Government's contention that incineration will not expand? It has to be said incidentally, that there are no Government statistics on this, since the relevant ministry does not collect information on local authority contractual plans.

I therefore wrote to all waste disposal authorities in England to ascertain their present practices, and their medium and long term plans for waste management. Specifically, I asked them 'whether your authority has entered into any form of contract to procure new incineration plant, is currently undertaking such a contract for current plant, or intends to do so in the future.' I also asked, in this context, for 'brief details of the size of the incineration plant, and the nature of any waste stream supply arrangements you have entered into, or will in the future'.

Whilst some waste disposal authorities required a follow up letter, I received a commendably prompt and detailed series of replies, most containing sufficient material to produce a reasonably reliable and comparative picture of present, near-term and long term plans involving incineration of waste.

The conclusions this exercise produces are, therefore based on direct or indirect information from all but five waste disposal authorities, representing a population of only a million out of the English population overall of about fifty million. Its findings are, therefore unlikely to be reversed should data on these authorities become available.

The picture is of course complex. The existence of a number of consortia representing the joint endeavours of a number of WDAs means that some authorities can be said to contribute to incineration whilst by no means sending the whole of their waste stream either now or in the future, to incineration. Those WDAs undertaking disposal without consortium arrangements and using incineration do so to varying degrees. Table one represents a distillation of the results.

The partial nature of the use of incineration by WDAs can be seen by comparing the percentage of England's population served by a WDA involved in incineration and the figures put forward by the Government about the percentage of municipal waste that actually goes to incineration. Expressed as a ratio, roughly one third of the waste arising in these authorities appears to go to incineration.

However, it can be seen from an analysis of the near future and longer term plans of WDAs that the percentage of the population covered by WDAs likely to be engaged in incineration over the next ten to fifteen years rises dramatically. Almost 20% of local authorities do not incinerate and have no plans to do so either in the near or far future. Cumulatively, the figure rises from 38.3% of the population living in incinerating authorities now to 45.1% of the population living in WDAs continuing with or likely to undertake incineration schemes in the near future. This takes into account the sole responding authority currently incinerating but indicating that it is not continuing to do so in the near future.

The cumulative figures rise more steeply over the medium and longer term. Within the next ten years, if plans are implemented, 67.4% of the population will be living in incinerating authorities, and in the long term, running towards the sustainability target date of 2020, 78.9% of the population will live in such authorities. If the proportion of actual incineration to population that is suggested by the current figures is extrapolated therefore, incineration, far from remaining static or dropping will consume over 20% of waste.

The programmes put forward by Local Waste authorities seem to gainsay the confidence of the Government that incineration, whether for its own sake or combined with energy recovery, will remain as a small part of the waste disposal mosaic. These programmes do, of course, reflect perceptions of current reality. A number of responses envisaged no feasible alternatives to incineration within the timescale during which a shift from landfill should take place. Reality may change. The Government is currently undertaking a review of the health and environmental impact of incineration. A report at the end of this review could herald new measures to discourage incineration as an alternative to landfill, , such as an incineration levy, or indeed positive incentives for local authorities to 'jump the hierarchy' in their future plans.

As matters stand today, however, and in the absence of such measures, the future of waste disposal looks to be far more incineration-led that is currently projected. This is not only a problem for climate change targets, and a loss for the benefit that might arise from diversion of waste from incinerators and towards other purposes, but a serious potential disruption of other measures that might push Britain's waste management up the hierarchy to which the Country is committed. One way or another, it seems that further measures to avoid that future for waste disposal are needed.

Notes.

1. DTLR 'Waste Strategy 2000 for England and Wales' Stationery Office May 2000
2. Government Strategy Unit 'Waste Not Want not - a strategy for tackling the waste problem in England' Stationery Office November 2002
3. See Written PQ Hansard 10 March 2003 col. 6W.
4. See Waste and Emissions Trading Bill Second Reading Hansard 20 March 2003. See also Environmental Audit committee fifth report session 2002-3 'Waste - an audit'.
5. Waste and Emissions Trading Bill Cttee Hansard 10.April 2003 col.193

Alan Whitehead MP House of Commons London SW1A OAA