Dr. Adam Read – Director
Waste Management & Resource Efficiency, AEA
Presentation to the Waste , Recycling Industry Association (QLD) inc
26th October 2012
Brisbane
A world leading energy and climate change consultancy
Presentation scope in 30 minutes …
+ Personal welcome
+ The legislative framework
+ Waste strategy development
+ Drivers for change:
Fiscal
Landfill tax
Regulatory
Permitting and exemption regime
Market Development
Quality Protocols
+ In summary – what can we learn?
+ Open Q&A….
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A personal welcome
+ Dr Adam Read
Practice Director @ AEA for Waste Management & Resource Efficiency
18 years of operational expertise
80 consultants (UK) plus 50 in the US
Former Local Authority Recycling Officer (RB Kensington & Chelsea)
Working with EA on new technologies and infrastructure delivery
Client Manager for WRAP (UK delivery agency)
Designed and rolled out innovative new collection schemes (15 years)
BUT I am not a regulator (this is important – watch this space)
+ Acknowledgements
AEA team (my co-authors)
Nia Owen and Maria Vinogradova
My clients for allowing me to ‘share’ their experiences (off record)
The organisers for the invite (thanks Rick & Georgina!)
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http://www.aeat.com
AEA delivers over £90 million annually of energy, environmental, resource efficiency, transportation, and climate policy support and program implementation services to:
UK Government
US Government
European Commission
International Institutions
…. waste management, carbon management, climate change strategies, transport, resource management, life cycle assessment, sustainability, energy efficiency, clean energy, GHG inventories, adaptation, behaviour change ….
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Our Scope of Services
Practice Areas:
+ Air and Environmental Quality
+ Chemical Emergency & Risk
Management
+ Energy & Climate Change
+ Enterprise Services
+ Information Management
+ Knowledge Management
+ Sustainable Transport
+ Resource Efficiency and Waste
Management
Expertise:
WRATE / Carbon Modeling
Audits
Procurement Support
Technologies / Cost / Barriers
Policy Development
Stakeholder Engagement /
Communications
Service Efficiencies
Knowledge Management &
Transfer
Training
…. experience at the interface of government, business, and academia 5
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EU Waste Framework Directive
+ Dates back to the 1970s
+ Enshrines the waste hierarchy within the WFD
+ Transferred to national law by each member state
Enacted through policy / strategy
+ Recent change to prioritise
‘reuse’
+ National Waste Management
Strategy
+ National Waste Minimisation
Strategy
+ Infraction if fail to comply….
Prevention
Preparing for reuse
Recycling
Other recovery
Dispo sal
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Landfill Directive - 2000
+ Scaling back of organic material to landfills compared to 1995 …
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The EU Landfill Directive
+ EU Landfill Directive – address landfill’s environmental impacts
BMW reductions required to mitigate fugitive CH4 emissions
Pre-treatment of landfilled materials
Landfill waste acceptance criteria (WACs)
Landfill design, operation, completion and closure requirements
+ BMW Landfill targets for the UK
75% of 1995 level by 2010
50% of 1995 level by 2013
35% of 1995 level by 2020
+ Required all stakeholders to work together
National legislation & policy
Support programmes
Engagement & Education
Collection and Treatment providers 9
Waste arisings – 2010/11
Waste Type Scotland Wales
Municipal
Household
C&I*
C&D*
3.14
2.82
6.5
7.6
+ Million tonnes per annum
1.63
1.39
3.6
12.2
Northern
Ireland
0.94
0.83
1.3
1.7
England
26.3
23.3
48.0
77.4
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The predicted ‘need for change’ …
60
50
40
30
20
10
0
Biodegradable Municipal
Waste Allowed to Landfill
Non-biodegradable
Municipal Waste
Biodegradable Municipal Waste
Requiring Diversion
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What does this mean?
+ This now includes C&I wastes….. GAME CHANGER!
A major shift in how the UK defines MSW!!!!
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UK Government
+ UK is responsible for reporting to EU on policy progress
+ National Administrations set policy and monitor performance
England
Scotland
Wales
Northern Ireland
+ Local Government set strategy, deliver services and respond to local
‘demands’
Funded by UK taxation
Funded by local Council Tax
Elected ‘members’ 14
Implementation … nationally …
+ Waste Strategy for England 2007
Waste Review 2011 (some minor revisions in priorities)
+ Scotland Zero Waste Plan 2010
+ Wales Towards Zero Waste strategy 2010
+ Northern Ireland Waste Strategy 2006 (now under review)
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“Strategy wars” – political objectives!
County
England
Scotland
Policy/
Strategy
Year
Government
Review of
Waste Policy in
England) Waste
Strategy for
England
(2011)
2007
Zero Waste
Plan
2010
Recycling
50% by 2020
70% by 2025
Wales
Northern
Ireland
Towards Zero
Waste
Towards
Resource
Management
2010 70% by 2025
Landfill
35% of 1995 levels by 2020
(biodegradable)
Incineration
Maximum 5% by
2025
Maximum 5% by
2025
Maximum 30% high efficiency
EfW by 2025
2006
50% by 2020
(HHW), 60% by
2020 (C&IW)
35% of 1995 levels by 2020
(biodegradable)
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Levels of ambition
England Scotland Wales
Targets beyond EU Landfill and Waste
Framework Directives
Restrictions on waste managed through incineration i.e. not just landfill substitution
Enforced source segregation of food waste
Landfill ban considerations
Individual authority targets and guidelines on collection systems
/ /
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Divergence?
+ Wales and Scotland are now clearly leading in terms of waste strategy
Clear centralised leadership
High priority issue
Ambitious targets beyond statutory EU limits
+ Wales and Scotland have fully embraced Zero Waste as a policy concept
Used as a philosophy to drive change
Zero waste to landfill initially
One Planet Living (Wales)
Carbon mitigation (Scotland)
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Does it make a difference???
120%
100%
80%
60%
40%
20%
0%
England
Scotland
Wales
+ Look at Scotland catching up after strategy…
+ The proof will come in a couple of years’ time…
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And the scores are………………………
Municipal Recycling Rates
1.
48% of household waste was recycled and composted in Wales during the financial year 2011-12, representing a
4% increase on the previous year
2.
Recycling rate for English councils was
42.5% between October 2010 and
September 2011
3.
Scotland reached a household waste recycling and composting rate of 40.7% for 2011
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Landfill tax escalator
£90
+ Landfill becomes unviable as tax increases
£80
£70
+ Tax is applied before gate fee
£60
£50
+ Gate fees at landfill
£40 c. £50-75/ tonne £30
+ Gate fees at EfW plants will be c.£70-£100 / tonne
£20
£10
£0
+ Landfill stopped making financial sense in 2009-10
Standard Inert
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Impacts!
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Solutions….. in England
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Waste Regulation
+ Enforcement:
Environment Agency in England & Wales*
SEPA in Scotland
EPA in Northern Ireland
*Wales is to have its own enforcement body from April 2013
+ EU is key driver for legislation:
Waste Framework Directive
Landfill Directive
Producer Responsibility (by material and sector)
+ Each member state is responsible for implementing legislation
significant differences in approach across the EU (voluntary vs. mandatory)
+ Within the UK each Country is also developing its own approach
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Increasing focus on C&I wastes …
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Private sector will invest!
+ Recognition that change wouldn’t happen without interference
+ Scotland have introduced the Waste (Scotland) Regulations 2012
+ Requirements:
Separate collection of metal, plastic, glass, paper and card from 1 st
2014 from all HHs and businesses
January
Food businesses (except in rural areas) which produce > 50 kg of food waste per week to present that food waste for separate collection from 1 st
January 2014
Food businesses (except in rural areas) which produce > 5 kg of food waste per week to present that food waste for separate collection from 1 st
January 2016
+ Regulations also ban the use of non-domestic food waste disposal units, i.e. macerators
avoid food waste being diverted to the sewers!
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Statutory (mandatory) Targets for MSW
+ Wales have introduced statutory recycling targets for MSW under the Waste (Wales) Measure 2010:
2012-13: 52% …… 2015-16: 58%
2019-20: 64% ….. 2024-25: 70%
+ Waste must have undergone a relevant recovery operation so that it has been reprocessed into a product, material or substance, whether for its original or other purpose to be counted in these targets
e.g. Compost must meet the requirements of Compost QP
+ Markets are critical to achieving recycling rates
+ Government are part funding quality collection systems
Influence what is happening without mandating solution
+ Failure to comply with statutory targets = financial penalties ££
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Environment Agency
+ Regulator for England and Wales
risk based approach to regulation
+ Executive non-departmental Public Body
+ Permits and licenses
+ Pollution control
+ Research activities
+ Data collection
+ Staff: 11,500
+ Budget: £1.1 billion
£750 million – from Central Government
£350 million – charged income
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Environmental Permitting Regime
+ Any waste operation will normally require an authorisation:
Bespoke
Permit
Standard
Permit
Exemption
+ Environmental permits issued by the Environment Agency
+ The waste operation must operate within the controls laid out in the environmental permit
+ Types of operation requiring a permit are:
Waste transfer stations
Materials recovery facilities
Incinerators
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Risk based regulation
+ The theory behind the Environment Agency approach
aim to reduce red tape and help businesses
+ Regulate poor performers and complex operations more rigorously!
+ Proportionate regulation and enforcement
+ Environment Agency offers a range of permits
Standard permits for low risk operations
Exemptions (no license, but on the radar)
Bespoke permits for complex / large operations
+ Operator Risk Appraisal: Opra
Charges and inspections are risk-based!
+ There is no operating outside the system
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Closing down the ‘worst’ offenders
Closure of most of the 8,000 licensed facilities
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Standard permit
+ Rules are set out in the Standard Rules document so that an applicant will know exactly what they have to comply with before they make an application
+ Conditions may include:
Proximity to housing
Nature conservation
Type and quantity of materials accepted
+ The application process is simpler and less time consuming as a risk assessment (generic for that type of facility) has already been prepared and the application requirements are reduced
+ Application fees for standard permits are cheaper than for bespoke permits, and are determined more quickly
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Exemptions
+ Lower risk activities can operate under an exemption from environmental permitting which must be registered with the
Environment Agency, and operated under the controls set
+ An exemption from a waste permit can be grated if:
Waste is recovered or disposed of without endangering human health and without using processes or methods which could harm the environment and in particular without
risk to water, air, soil, plants or animals; or
causing nuisance through noise or odours; or
adversely affecting the countryside or places of special interest
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Exemptions
+ Types of operations that can operate under a permit are:
Composting facilities which are processing waste generated on-site
Storage of waste in a secure place
Sorting of scrap metal
+ How are new waste operations managed?
New operations normally require an environmental permit
However, ‘low risk solutions’ will be considered by the EA where requiring a permit (no exemption exists) would be disproportionate to the risk posed
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Bespoke Permits
+ Bespoke permit needed if no exemption or standard rules permit is appropriate to your operation
+ Application must include detail on control of risk
+ Statutory consultation required & determination can take 13 wks
+ Charges - permitted sites pay a subsistence fee based on the
OPRA (operational risk appraisal) charging scheme, i.e. charges & inspection frequency are risk based
Complexity
Inputs & emissions
Location
Operator management systems & performance
+ Enables Environment Agency to regulate poor performers and complex operations more rigorously
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Enforcement
+ Environment Agency enforcement policy aims:
“To stop offending – aim to stop an illegal activity from continuing/occurring;
To restore and/or remediate – aim to put right environmental harm or damage.
To bring under regulatory control – aim to bring an illegal activity into compliance with the law.
Punish and/or deter – to punish an offender and/or deter future offending.”
Environment Agency
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Proceeds of Crime Act
+ Allows a Court to deprive convicted offenders of assets gained from crime. But can only be used following a guilty verdict
+ EA can:
Ensure environmental crime does not continue
Investigate finances to establish and find hidden profits
Stop the disposal of assets whilst investigations is underway
Present evidence to court for a confiscation order – i.e. how much the offender has to pay. Failure to pay – prison sentence
Remove profits, even if offender serves a jail sentence
+ Confiscations in 2011:
Number of on-going financial investigations: 132
Number of confiscation orders: 26
Total confiscated:
Highest confiscation:
£2.2m
£0.9m
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Driving up standards….
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Prosecutions
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Prosecutions
Types of illegal waste sites
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WRAP
+ Government funded organisation
+ Aims to help businesses, individuals and communities reap the benefits of reducing waste, developing sustainable products and using resources in an efficient way
+ Areas of action:
Preventing food and drink waste
Increasing the resource efficiency of products
Increasing the resource efficiency of construction and refurbishment projects
Improving the collection of materials for recycling and reuse
Helping SMEs to become more resource efficient
Increasing the reuse and recycling of priority products
Recycling organic waste and recovering energy
+ Market development is key!!
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Encouraging waste use as a resource
+ What is waste?
“All waste derived materials continue to be a waste until the point at which the beneficial properties are realised”
+ When has waste been fully recovered?
Distinct and marketable
Suitable for use
No greater risk to the environment or human health and than the virgin equivalent
+ By identifying more and more secondary materials as no longer waste, the industry and the regulator both maximise the value of resources – allowing them to compete with primary materials
+ This can only be achieved by the regulator, market developer and industry working together!
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Quality …
+ Is about consistently delivering materials to the marketplace that are
effectively separated to meet customer requirements
compliant with national regulations and policies….
at a cost that is acceptable
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Quality Supply Chain
Local
Authority
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Quality is a major problem ….
+ Increasing concerns about quality from the end markets
+ Less guarantees from Chinese & Indian reprocessors
+ Returned loads from Indonesia and Brazil
+ EA has clamped down on ‘waste’ exports
+ UK and EU reprocessors continually setting the ‘bar’ higher in terms of quality and consistency
+ Needs additional investment at MRF
+ Now looking at evolution of service provision …
+ Needs everyone to play their role …..
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Pushing up quality ….
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End of Waste – Evidence based ….
+ How can end of waste be demonstrated?
Meeting a Quality Protocol
Through an end of waste submission to the Environment Agency’s End of
Waste Panel
Compliance with EU ‘end of waste’ Regulations
+ End of waste submission (site specific approach)
Organisations can submit evidence to the EA to demonstrate that the product they manufacture has ceased to be waste
+ EU have started to develop end of waste regulations which define criteria for materials to achieve end of waste across all member states
Composts, digestates, RDF (fuels) etc.
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End of Waste definition
+ Operational: End of waste from scrap regulations
+ In the pipeline: paper, glass, plastics (recyclate)
+ In progress: biodegradable waste subject to biological treatment
+ Test:
“the waste has been converted into a distinct and marketable product”
“the processed substance can be used in exactly the same way as a nonwaste”, and
“the processed substance can be stored and used with no worse environmental effects when compared to the raw material it is intended to replace”
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UK Quality Protocols
+ Framework which allows user to demonstrate that the product(s) has ceased to be waste
Waste ceases to be waste
Quality
Protocol
QUALITY
PRODUCT
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Quality Protocols
+ Sets out the criteria which, if met, mean the product is no longer a waste …
+ QP compliant material is free of any further waste permitting
Aggregates from inert waste
Compost
Anaerobic digestate
Biodiesel
Processed fuel oil
+ Working well in the UK… stimulating new markets for materials
…. Drawing through more feedstock!
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Compost Quality Protocol
Source-segregated
Biowaste
Compost
Product
End Markets
Quality
Protocol
Waste ceases to be waste
Horticulture
(including domestic applications)
Soil-grown horticulture
Land restoration & soft landscaping operations
+ Process itself still requires permit / exemption regardless of whether the site is complying with the Compost QP
+ Material that doesn’t comply is a waste and so a permit or exemption is needed for its use, and it must be moved in accordance with Duty of Care requirements
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Aggregates Quality Protocol
Inert C&D waste
Quality
Protocol
Recycled aggregate
Waste ceases to be waste
+ Impact (year 1):
Landfill diversion
Landfill disposal savings
Virgin raw material saved
Increased sales
Cost savings to business
Carbon savings
21m tonnes
£158m
41m tonnes
£324m
£155m
105,000 tonnes/ £5.5m
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European Pathway to Zero Waste (EP0W)
+ Collaboration: WRAP and EA, funded by EU (Life+)
+ 8 Work Streams at all levels of the hierarchy – e.g. waste exchange for reuse and infrastructure delivery
+ AEA project: identifying barriers to infrastructure for business waste
Industry engagement workshops (300 specialists involved)
Bringing together a range of stakeholders – large operators, small operators, industry organisations, advisors, funders
Promoting partnership working
+ Critical piece of work @ present….
Identify solutions and potential ‘implementors’
Report reviewed by Defra to inform its infrastructure position
Good platform for operators to be heard and demonstrate their facilities
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Changing UK landscape
+ UK progresses has been driven by
EU Landfill Directive
Clear Strategy & policy
Sensible Regulation
Market Development
Infrastructure support
Increasing energy prices
Public demand
Reducing red tape
+ This has taken time….
+ All parties have to work together
+ We have had to learn some lessons and make some mistakes!
Govt
Regulator
WRAP - Market
Development
Industry
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You must develop effective delivery tools
+ EU Landfill Directive
+ Landfill Tax
+ Landfill Bans (Scotland)
+ Mandatory Recycling Targets (Scotland & Wales)
+ Voluntary Agreements e.g. hospitality sector food waste prevention
+ Incentives
Renewable Obligation Certificates (ROCs)
Renewable Heat Incentive (RHI)
Feed In Tariffs (FITs)
+ Business Engagement, Education & Support…
WRAP and ZWS BRE programmes ….
Supporting logistics of collection & reproceesing
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Joining up the dots ….
+ Landfill Directive could not deliver change in isolation…
+ Needed landfill tax to ‘wake things up’ @ all levels
LAs wanted to change & Businesses were feeling the pinch
+ Needed technology development to treat new food waste streams
New Technology Demonstrator programme
UK AD policy statement
+ Needed new markets for the products of composting / AD
WRAP market development work
R&D, and the Quality Protocols projects
RHI / ROCs for energy production from biogenic materials
+ Needs enforcement & regulation
Targeting bad sites, driving up the baseline 61
Next steps in the UK ….
+ More focused strategy and specific policy issues
Landfill bans on organics in Scotland
Mandatory collections (target materials)
+ More focused support
Green Investment Bank
Business engagement workshops
Waste business support programmes (diversification)
+ More market development
Closed loop policies
Green purchasing & Recycled content
Quality protocols
+ More appropriate regulation
Driving up quality
Focusing on performance
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Building blocks …. Sustainable WM!!!!!
What is the pathway for Queensland to consider?
+ Good strategy & leadership
+ Regulatory framework in tune with the policy agenda
+ Appropriate enforcement / compliance
+ Market development
+ Quality improvement – codes & protocols
+ Education & Empowerment of all stakeholders
+ Funding to ‘kick start’ initiatives
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1 message …..
+ Avoid on-going policy uncertainty ….
+ How can BUSINESS make fundamental investment decisions?
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The last slide … Questions ?
Dr Adam Read
Global Practice Director
Waste Management & Resource Efficiency
07968 707 239 adam.read@aeat.co.uk
www.aea.co.uk
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