Revisiting the waste hierarchy in European waste policy:

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1 Summary of the use of LCA in England

1.1

Approach

To illustrate the application of LCA in England, Heiskanen’s (1999) categorisation of the definitive, conceptual and facilitative application of LCA has been used. The definitive application of LCA is to find a definitive answer to a policy problem, to find an authoritative justification for a policy measure, to find the superior alternative, to identify environmental hot spots in the life cycle, and to identify product groups of high environmental impact (Dalhammer 2007; Heiskanen 1999). The conceptual application attempts to involve stakeholders by providing LCA to facilitate a greater understanding of environmental priorities. Thus, LCA helps to change the way actors view environmental problems. The

facilitative application of LCA looks to stimulate LCA activities, such as eco-design and life cycle management, in companies. This is done by the provision of life cycle data, methods and tools.

Through using LCA it is suggested companies may ultimately change business practices (Dalhammer,

2007).

1.2

Background

Among the European Member States, the UK has led the regulatory push for LCA to be used as a tool to inform waste management decisions and support waste policy. The definitive application of LCA is best illustrated through the statutory requirement to complete LCA as a part of the Best Practicable

Environmental Option 1 (BPEO) concept. The 1995 waste strategy for England and Wales announced the commencement of a research programme into LCA for waste management, where it would be integrated into the BPEO concept for waste management decisions. The BPEO became a core component of the Waste Strategy 2000 (DETR 2000a, 2000b). The strategy required LCA to be used as a part of the determining the BPEO: “to find an overall, optimal, environmental solution for managing waste, without the risk that our decision will result in a worsening of the overall impact, we need to adopt a life cycle approach” (DETR 200b:30). To facilitate the use of LCA, the WISARD 2 software tool was developed by the now defunct Wastes Technical Division of the Department of the Environment.

This facilitative application would enable competent authorities to conduct LCA studies in-house or via the engagement of external consultants. Competent authority waste management strategies developed during this period had a statutory requirement to conduct LCA as part of their justification of a BPEO (definitive application). A second LCA software tool, WRATE 3 , was developed by the

Environment Agency to replace WISARD due to intellectual property right issues related to the upgrade of WISARD (see Section 3).

1 A concept stemming from the 1976 Royal Commission into Environmental Pollution’s 5 th Report (RCEP 1976)

2 Waste Integrated Systems Assessment for Recovery and Disposal

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Waste and Resources Assessment Tool for the Environment

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A large portion of LCA work was and is subcontracted to consultants to undertake LCA, as many competent authorities lack the internal expertise or budget to justify development of such expertise.

However, some competent authorities do undertake in-house LCA work using the WISARD or WRATE models provided by the Environment Agency. In July 2005, DEFRA removed the requirement to determine the BPEO (see (DEFRA 2005)), following recommendations from a national review of waste management. This was replaced through plan led-strategies requiring local authorities developing municipal waste management strategies to undertake a Strategic Environmental Assessment (SEA).

1.3

Competent Authority level

Local authorities mentioned their use of the WRATE tool, either in–house or via the engagement of consultants, in the development of their waste management strategies. Additionally, there is a current obligation to utilise LCA in relation to obtaining Privately Financed Initiative (PFI) credits. WRATE is recommended by the Waste Infrastructure Delivery Programme as a tool to assess the environmental impacts of options at the Outline Business Case (OBC) stage of obtaining PFI credits (DEFRA 2008).

The Mayor of London and the Greater London Authority (GLA) have utilised LCT in the latest waste strategy for London, London’s wasted Resource: The mayor’s municipal waste management strategy

(GLA 2011), and the ‘Mayor’s preferred approach’. Whilst the strategy is technology neutral, LCT has been used to set the targets within the strategy, the objectives of the strategy, and it has been introduced as the metric for determining general conformity with the Mayor’s strategy with regards to energy from waste. The strategy introduces a carbon intensity floor (CIF) in order to determine whether a waste technology is in conformity with the strategy. The CIF compares energy-from-waste technologies with combined cycle gas turbine (CCGT), the UK’s marginal source 4 of electricity generation. The carbon intensity of CCGT by per megawatt hour of energy produced is approximately

400 grams of CO

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per megawatt hour. Any new energy-from-waste facilities must achieve a carbon intensity floor, better than 400 grams of CO

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per megawatt hour of energy produced (definitive use). A

Greenhouse Gas Calculator tool 5 , based on the WRATE tool, facilitates competent authorities assessing if their waste management strategies meet the requirements of the mayor’s municipal waste management strategy.

1.4

National level

At the national level, LCA is used with more emphasis on its conceptual capacity. Actors such as WRAP have identified the environmental impacts of various waste treatment options for the municipal waste stream or individual product/material waste streams, via the use of meta-studies drawing on existing life cycle studies (such as WRAP (2006) and WRAP (WRAP, 2010)) and their own LCA studies of individual waste streams (such as LCA of Management Options for Mixed Waste Plastic (Shonfield and

WRAP 2008)). In terms of plastic waste management, such studies have been used to identify the optimum markets for recycled materials and making technological improvements to improve virgin material substitution ratios.

The Waster Strategy 2007 shows a move from the definitive application of LCA (as implemented in the

Waste Strategy 2000) to the conceptual application of LCT. There has been a move in England to use

LCT to support the structure of waste policies; "Policies to reduce the environmental impacts of products, materials and sectors should be targeted at the most significant points in the life cycle.”

(DEFRA 2007:31). LCT has been used to inform policy in terms of identifying priority waste streams

(those waste streams with a high environmental impact during their end of life treatment). There has also been a shift toward a voluntary approach for the use of LCA, as opposed to the pervious stance

(evident in the Waste Strategy 2000) of mandating the use of LCA for waste planning decisions.

4 Any new energy-from-waste in London would effectively mean that there is less need for CCGT

5 http://www.london.gov.uk/priorities/environment/waste-resource/energy-recovery

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2 Historical account of the Role of LCA in the Best Practicable Environmental

Option

The Best Practicable Environmental Option (BPEO) originates from the Fifth Report of the Royal

Commission on Environmental Pollution, in 1976, extending the ‘Best Practicable Means’ concept which was used as a concept in air pollution control since the Alkali Act of 1874 (RCEP 1976). The concept, for a given waste stream, was defined as “...the optimum combination of available methods of disposal so as to limit damage to the environment to the greatest extent achievable for a reasonable and acceptable total combined cost to industry and the public purse.” The Twelfth Report

of the Royal Commission on Environmental Pollution (RCEP 1988), in 1988, entitled Best Practicable

Environmental Option, developed this concept which is commonly quoted as the outcome of a systematic, consultative and decision-making procedure which emphasises the protection and conservation of the environment across land, air and water. The BPEO procedure establishes, for a given set of objectives, the option that provides the most benefits or the least damage to the environment as a whole, at acceptable cost, in the long-term as well as the shortterm. (RCEP 1988:5)

The BPEO promoted the identification of options which provided the optimum balance of emissions to land, air and water, in order to minimise harm, ensure protection of the environment, whilst taking into consideration affordability and practicality.

The assessment of the BPEO stressed the need to involve the analysis of alternative options and also reflection of both long and short-term impacts. The RCEP placed strong emphasis that the BPEO be justifiable by a thorough and transparent assessment of the impacts of alternatives. The BPEO was introduced into UK legislation via Part I of the Environmental Protection Act 1990, relating to prescribed processes regulated under Integrated Pollution Control (IPC). The IPC applied the BPEO to pollution emissions from sites and was closely related to the concept of Best Available Techniques Not

Entailing Excessive Cost (BATNEEC):

The objectives shall… include the objective of ensuring that the best available techniques not entailing excessive cost will be used for minimising the pollution which may be caused to the environment taken as a whole by the releases having regard to the best practicable environmental option available as respects the substances which may be released.

(Environmental Protection Act 1990, p. 7)

Under IPC, the BPEO concept was not applied beyond the scope of specific sites. It did not apply to waste management strategies covering a range of sites and activities. However, the application of the

BPEO in this context was practical demonstration of the need to balance the consequence of different activities in order to identify those delivering the greatest benefit (ERM 2003).

The BPEO was first introduced to waste policy in the 1995 strategy Making Waste Work (DoE, 1995) as a way to determine the preference between the options of the waste hierarchy. Although several reverences were made to the BPEO it was never clearly placed in a clear context (Eunomia Research and The Open University 2004). This is the first instance where was introduced to life cycle assessment

(LCA) in English waste policy. The strategy notes that “The Department of the Environment has begun a programme of research into life cycle assessment, which is hoped will result in a systematic means of assessing the BPEO for many wastes”; its aim, to “result in a systematic means of assessing the BPEO for many wastes” (DoE 1995, p. 6).

Waste Strategy 2000 (DETR 2000a, 2000b) acknowledged that determining the ‘right way’ to treat particular waste streams was not a simple task and introduced the BPEO as a core aspect of the strategy; “Decisions on waste management, including decisions on suitable sites and installations for

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treatment and disposal, should be based on a local assessment of the Best Practicable Environmental

Option.” (DETR 2000a, p. 40).

When determining the BPEO consideration was given to the waste hierarchy, the proximity principle and the self-sufficiency principle, as well as international obligations (such as the Landfill Directive), national policy framework, and policy guidance at the regional and local levels. The Waste Strategy

2000 highlighted the waste hierarchy as a conceptual framework acting as a guide to the framework that should be considered when assessing the BPEO. The proximity principle is linked to the BPEO and the waste hierarchy, in that when considering options towards the lower end of the waste hierarchy, decision makers should consider both the financial and environment costs of transport. The BPEO relates to the self-sufficiency principle where waste planning authorities and the waste management industry are encouraged, where practicable, to aim for regional self-sufficiency in waste management.

A stepwise approach for assessing the BPEO was set out in the Waste Strategy 2000:

1) set the overall goals for making the waste management decision, subsidiary objectives and the criteria against which the performance of different options will be measured

2) identify all the viable options

3) assess the performance of these options against the criteria

4) value performance

5) balance the different objectives of criteria against one another

6) evaluate and rank the different options

7) analyse how sensitive the results are to variations in the assumptions made or the data used

In relation to the guidance on the assessment of the BPEO, the Waste Strategy 2000 recommends that

LCA be adopted as a methodology to provide a basis for strategic decision making through finding the overall, optimal, environmental solution for managing waste. The WISARD software tool (see Box

1), developed by the Environment Agency, was suggested as a way of assessing the environmental performance of waste management strategies (DETR 2000b).

In March 2001, the DETR published the Guidance on Municipal Waste management Strategies (DETR &

HMSO 2001) which provided guidance on the development on non-statutory strategies of waste management for all English authorities. In May 2001, the Office of the Deputy Prime Minister (ODPM) took over responsibility for planning.

In 2001, several criticisms were made of the use of LCA as a requirement of the BPEO. The House of

Commons Select Committee on Environment, Transport and Regional Affairs Fifth Report (House of

Commons 2001a) criticised several aspects related to the use of LCA. There was concern over the weighting of environmental impacts and the application of WISARD, noting that “it is particularly important that WISARD is not used as a dogmatic tool to 'prove' that one option is better than another but rather as a general guide for decision makers. This becomes particularly important when one considers the opening words in the definition of BPEO: "the outcome of a systematic and

consultative decision-making process...” (House of Commons 2001a).

There was a fear that the increasing use of tools such as LCA would lead to public consultation being overlooked. In 1998, the House of Commons Select Committee on Environment, Transport and

Regional Affairs recommended that WISARD be made available free of charge in order allow interested to probe the outcomes of the use of WISARD. However, the Environment Agency noted that the software was developed under contact and that WISARD was provided to local authorities, academia, the public and NGOS at a subsidised price of £1,000 + VAT, compared to the unsubsidised cost of £10,000 + VAT (House of Commons 2001b). Furthermore, Select Committee emphasised the fact that “no model can ever provide the solution to a complex and partly judgement-based process such as determining BPEO”. There was a concern that the BPEO would become a technocratic process

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used in isolation of interested parties that could be used to “steamroller a sceptical public into options which they dislike or distrust”, all in the name of a consultative decision-making process (House of

Commons 2001b).

In November 2002, the Waste and Emissions Trading Act was passed into law enshrined the obligation for most two-tier waste authority areas to produce a Municipal Waste Management Strategy, as expressed in the Waste Strategy 2000. In the same month the Prime Minister’s Strategy Unity publish the report Waste not, Want not: A Strategy for tackling the waste problem in England (ODPM 2002).

This highlighted barriers to the implementation of sustainable waste management, but reified “using the waste hierarchy as a guide to environmental benefits and applying the BPEO to make decisions”

(ODPM 2002, p. 43).

The application of the BPEO was not without further controversy, as exemplified in the well-publicised case of R v Derbyshire County Council ex parte Blewett. In 2003, a judicial review in the High Court quashed permission for a landfill development at Glapwell, north Derbyshire, on the grounds that the planning authority had not dealt with the BPEO concept appropriately (Brook 2005). The judge reasoned that waste authorities should refuse applications unless they were “in line with” the BPEO, a view which threatened to undermine the fundamental approach (Brook 2005). The judgement suggested that the BPEO is “more than” a material consideration in any application for planning permission for waste management facilities (Eunomia Research and The Open University 2004).

In May 2003, the Government responded to Waste not, Want not by committing resources to implement its recommendations; in part by the establishment of the Waste Implementation

Programme (WIP). In October 2003, the WIP commissioned a study Municipal Waste Management

Strategies and the Land Use Planning System for Waste in England (Eunomia Research and The Open

University 2004) to review English Local Authority Waste Management Strategies and looked at the development of potential options for ensuring the greater integration between municipal waste management and planning functions in various tiers of government.

In response to stakeholder consultation 6 the report noted that the value of the BPEO in the context of spatial planning was widely questioned, “especially since the advent of Strategic Environmental

Assessment, Sustainability Appraisal and Environmental Impact Assessment” (Eunomia Research and

The Open University 2004, p. 7). This report was particularly critical of the BPEO and LCA. The fundamental criteria in which the utility of the BPEO was assessed were the robust facilitation of

technical realistic options and achieving politically acceptable outcomes from decisions which took into

account how much waste needed to be managed at different points in time. Two weaknesses of LCA identified in this report were its inability to address “real world” operational realities (i.e., the consideration of logistics and therefore whole systems costs) and that modelling the full life cycles of complex waste management systems is practically impossible and diverges from the original scope of

LCA. It was also suggested that LCA represents a black box, at least for all those but the most technically knowledgeable, and that LCA is impenetrable for stakeholders seeking to assess the validity of the claims. The report concluded:

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that current policy and practice is unsatisfactory there should no longer be a direct role for the assessment of the BPEO within the land use planning system for waste.

The LCA based approach to the whole-system assessment, particularly in the context of spatial planning, is generally inappropriate.

6 Including actors such as: waste management and planning officers, waste management companies, waste industry and trade associations, Environment Agency, the Planning Officer’s Society, NAWDO,

LARAC, WRAP, representatives of the Regional Technical Advisory Bodies and Regional Planning

Bodies, other consultants working in the field and NGOs and campaigning organisations

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The role of LCA in BPEO assessment should also be revised and it should form one of a suite of methodologies to avoid more abstract analysis

The report recommended that “the application of the proximity principle and self-sufficiency should, when applied with common sense, provide a reasonable basis for Strategy decision making” (Eunomia

Research and The Open University 2004, p. 7). The waste hierarchy was suggested to be “at least” reasonable guide to the Best Environmental Option and the hierarchy should be used to determine what actions should be taken not in terms of an inflexible rule, but a way of targeting different waste streams or materials for minimisation, reuse, recycling or further recovery. Presumptions in favour of the hierarchy would not prevent well justified analysis from highlighting that specific material streams should not be targeted for recycling, but the onus would be on the strategy to demonstrate this through CBA or LCA. It was also recommended that the proximity principle should only be applied, in full, to waste disposal operations and not reuse or recovery, and that regional self-sufficiency should become more of a conceptual ‘aspirational’ objective than a specific requirement.

This review led to changes to the Waste Strategy 2000 concerning the decision making framework set out in the strategy and the obligation to apply the BPEO. “The evidence from a review of the working of existing policy in practice including stakeholder consultation, found that this process was a barrier to the development of new installations that are needed to fulfil the environmental objectives of the

WFD.” (DEFRA 2005, p. 3). The BPEO was “leading to confusion about how it should be applied, at what scale, what data should be included and at what cost… As it stands, it produces an outcome that is easy to criticise and hard to defend. This has led to significant delays in the planning process for waste management facilities” (DEFRA in Brook (2005)).

These conclusions resulted in the replacement of the BPEO and requirement for LCA and WISARD with:

… plan-led strategies that drive waste management up the waste hierarchy. … subject to

Sustainability Appraisal and set within the community engagement that is central to the reformed planning system. Similarly, local authorities developing municipal waste management strategies should undertake Strategic Environmental Assessment, combined with a thorough assessment of social and economic factors. (Environment Agency 2012)

One justification behind the move to Strategic Environmental Assessment (SEA) was that SEA is outlined in the SEA Directive (2001/42/EC), where waste management is one area in which environmental assessment is required to be carried out for plans and programmes. The Municipal

Waste Management Strategies and the Land Use Planning System for Waste in England (Eunomia

Research and The Open University 2004) report noted that due to the advent of SEA the implicit requirement for this assessment to be supported additionally by the BPEO was unnecessary and over burdensome, and risked not delivering plans to a timescale in line with delivery of the Landfill

Directive (1999/31/EC) targets.

It recommended that there should be “no longer a role for the assessment of the BPEO with the land use planning system for waste” (Eunomia Research and The

Open University 2004, p. 48).

The PPS10: Planning for Sustainable Waste Management (Department for Communities and Local

Government 2011) now requires a sustainability appraisal (incorporating SEA) to be applied to shape planning strategies that support the Government’s planning objectives.

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3 From the WISARD to WRATE

WISARD

The software tool WISARD (Waste Integrated Systems Assessment for Recovery and Disposal) was developed from Ecobilan’s (incorporated into Pricewaterhouse Coopers [PWC] in 1999) TEAM LCA software. Previous versions of the WISARD tool were used in French LCA studies dedicated to packaging waste management. This was done in the context of the introduction of Decree No 92-377, April 1 1992 on Municipal Packaging Waste and the Packaging and Packaging Waste Directive (94/62/EC) which the changed packaging waste management practices establishing extended producer responsibility and the creation of Eco-Emballages. The original application in France was to support decision makers at the local level, especially highlighting the need to move from the landfill of packaging waste to its recovery. The tool was gradually upgraded in terms of the processes and waste types included (paper, wood, plastics), allocation methods developed, etc.

The Wastes Technical Division of the Department of the Environment (now part of the Environment Agency) launched a Life Cycle Research programme in 1994 (McDougall and Hruska, 2000) to quantify the environmental burdens of management options for waste utilising a life cycle assessment framework. The aim of the programme was to provide an objective basis for the comparison of waste management strategies and of options for individual waste types (McDougall and Hruska, 2000). The programme consisted of five stages including: methodological guidelines for inventory analysis, data collection and inventory analysis, impact assessment and damage cost valuation, software development and decision tool applications.

WISARD was developed under contract for the Environment Agency, customising the existing commercially available Ecoblian software (Ecobilan retaining the Intellectual Property Rights). WISARD was launched in the

UK by the Environment Agency in December 1999. By March 2001 over 100 licences had been sold at a fee of

£1,000 + VAT.

WRATE

The Environment Agency noted that problems with WISARD included: contractual issues surrounding the intellectual property rights (owned by PWC), it included only existing UK waste technologies, it did not work as waste managers wanted and the results were designed for LCA practitioners (Environment Agency, n.d.). To address these concerns the Environment Agency commenced the development of the Waste and Resources

Assessment Tool for the Environment (WRATE) software tool in 2002.

WRATE comes in two versions: standard (£1500 for a 1 year licence) and expert (£5950 for a 1 year licence).

The standard version limits the user’s ability to access background data, limiting the foreground and background data to that included in the data base. If local authorities, technology or service providers want to differentiate their technologies or processes from those in the standard WRATE model, there was the ability to submit this information to the Environment Agency which would then go through several levels of validation to the verify the validity and robustness of the data. The expert version allows full access to background data, thus allowing a higher degree of flexibility for the user. Approximately more than half the budget of the

WRATE project was for the development of a database containing data, including site processes, collected by the EA’s Waste Technologies Data Centre.

The default impacts used by WRATE were chosen by the Environment Agency and include:

Abiotic Resource Depletion (kg of antimony equivalent)

Global Warming Potential (kg carbon dioxide equivalent)

Human Toxicity (kg 1,4-dichlorobenzene equivalent)

Freshwater Aquatic Ecotoxicity (kg 1,4-dichlorobenze equivalent)

Acidification (kg Sulphur Dioxide equivalent)

Eutrophication (kg Phosphate equivalent)

WRATE is no longer supported by the Environment Agency. Fig. S.1 shows the timelines for the development and launch and use of WISARD and WRATE.

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Fig. S.1. Timelines for WISARD and WRATE (reproduced from Gentil et al. (2010))

*“The grey area indicates the launch time of the models. The solid line represents the active development phase and launch of subsequent versions of the same model, while the dotted line indicates the research leading to the development phase or the subsequent research not necessarily leading to an active development (use of the model as a research tool)”

(Gentil et al. 2010:2638)

4 References

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Renewal, 25 Februar

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