City Hall
The Queen’s Walk
London SE1 2AA
Switchboard: 020 7983 4000
Minicom: 020 7983 4458
Web: www.london.gov.uk
Boris Johnson
Mayor of London
(Waste strategy response)
Our ref: MT/KR
Your ref:
Date: 12 March 2010
via email to: viewsonwaste@london.gov.uk
Dear Boris,
The Draft Municipal Waste Management Strategy, January 2010
I welcome the opportunity to comment on your consultation on a draft Municipal Waste
Strategy. I am responding on behalf of my colleagues Dee Doocey and Caroline Pidgeon
as the lead on Environment issues for the Liberal Democrat Assembly Members. The
response comments generally on the policy areas, rather than answering each of the
specific consultation questions. Overall the key points are that:
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Waste reduction should have its own target and incentives
The Strategy should set a date by when all boroughs should have introduced food
waste collections - we suggest 2012
Greater focus should be put on making recycling easy, notably by:
- Action by manufacturers and own-label retailers to simplify the materials
packaging is made from
- All boroughs collecting mixed plastics (e.g. tubs/pots)
- Producers investing in collection and recycling infrastructure
The Strategy should be more ambitious about:
- Improving recycling from flats
- Setting up on the go recycling across London
Whilst we recognise that the Mayor intends to make a business case to extend the London
Waste and Recycling Board’s funding beyond 2012, there is an over dependence on the
Board to help deliver the MMWMS.
Policy 1: Inform producers and consumers of the value of reducing, reusing and
recycling
We support the aim that there should be a zero percent increase in the overall amount of
household waste produced by 2031, despite an increase in population. However it should
be noted that household waste is already falling, and the next draft of the strategy should
make clear how this target differs from a ‘business of usual’ approach. If this reduction is
largely attributable to the recession, then initiatives should be developed by the Mayor
which can build on this reduction and ensure that when London’s economy recovers it is
based on more sustainable and less wasteful consumption patterns.
In terms of the strategy’s emphasis, waste reduction should be clearly separated from
recycling. The strategy acknowledges that waste reduction or prevention is by far the
most cost-effective and environmentally beneficial way to reduce the impact of waste; and
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this is exemplified through the sizable amount tonnes of CO2 avoided by preventing or
reducing waste shown in Table Two (p.41). Yet the London Waste and Recycling Board
has only funded waste reduction through £5.6m funding of campaigns which cover
encouraging reduction, reuse and recycling. The waste agenda in London, and nationally,
needs to change to give the same emphasis to waste reduction and reuse as has been given
to recycling.
Reuse is generally more sustainable than recycling. We welcome proposals to develop a
strategic reuse network across London. The London Community Reuse Network (LCRN)
has mapped the existing network and it is our view that the GLA should collaborate with
LCRN in the development of this network.
A major barrier to the development of a reuse network is funding. Whilst we welcome the
proposal for a £8.5 million investment in reuse infrastructure, we believe that you need to
consider how that investment can be used to support third sector reuse organisations in
becoming self-funding.
The Mayor should act to stimulate markets for recycled materials through the LWARB
and other channels.
We look forward to the Mayor’s plan of action to work with retailers to reduce packaging
and the setting up of a product design competition to design out waste. Such product
design competitions would also be an opportunity to work with secondary school pupils in
their design and technology classes. Overall I think that a polluter pays principle must
apply to manufacturers and retailers so that they have responsibility for the amount of
waste they produce. Specific instances of improvements which could be made include:
 Investigation of incentivising reuse through schemes such as returning bottles.
 Encourage the repairing of products through retailers offering repairs; or the
development of training schemes to repair goods.
 Design competition for simple, repairable design. (Not just for packaging
minimisation).
 Ending buy-one-get-one free offers on perishable goods. WRAP estimated in 2007
that the annual cost of avoidable household food waste is £10.2 billion nationally –
largely as a result of ‘overshopping’. (Also see Policy 4 response regarding food waste).
 Introduce a London-wide food waste minimisation campaign based on WRAP’s
“Love Food, Hate Waste” campaign
 Involving Business Improvement Districts in reuse schemes.
Policy 2: Setting a greenhouse gas standard (GHG) for municipal waste
management activities to reduce their impact on climate
We agree with the principle that the evaluation of how best to manage London’s waste
should be outcome based, and that a greenhouse gas performance standard is a sensible
measure.
This outcome based approach is likely to be complex to apply in practice. As the strategy
suggests, it must be supported by up-to-date figures on the composition of London’s waste
so that new waste infrastructure is accurately focused on the right material, as well as
potentially making waste collection more efficient. A standard designed to cut carbon
emissions should also take proximity into account (i.e. the distance materials travel to
waste facilities).
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If a GHG performance standard is used it is vital that the Mayor makes it clear how this
will be measured. We would support use of the Environment Agencies WRATE
modelling tool for this purpose.
We strongly support increasing the provision of anaerobic digestion facilities in London,
as the optimal treatment method for food waste (after waste reduction). This focus on
outcomes also needs to be matched by improvements in the collection of food waste to
divert it from landfill (see comments to Policy 4).
The next draft of the strategy should make clearer the impacts of waste treatment sites on
air quality. A link could be made to the draft London Plan policy that new developments
should aim to be ‘air quality neutral’ and give examples of how waste sites could
potentially use offsetting to ameliorate any negative impacts on air quality.
Policy 3: Capture the economic benefits of waste management
We support the move towards considering London’s waste as a resource. Currently a huge
opportunity to save CO2 via avoiding landfill, to generate energy and income is missed.
Ideally the findings of research into the economics and practicalities of co-mingled verses
kerbside sort recycling collections will also be made publicly accessible. This is because
the many benefits of better waste management, and why particular methods are chosen,
need to be made clearer to Londoners.
There may also be a role for the third sector in activities such as reuse of bulky waste,
Waste Electronic and Electrical Equipment and textiles reuse, waste awareness and
reusable nappies. The main barrier to the third sector’s involvement in the waste sector is
likely to be financial
Policy 4: London to achieve 50 per cent municipal waste recycling or composting
performance (including anaerobic digestion) by 2020 and 60 per cent by 2031
Boroughs will have modelled their infrastructure and expenditure on the requirements of
the EU Landfill Directive and UK Waste Strategy targets to date. The Mayor’s new
targets appear to be based on the national targets for ‘household waste’ which have been
translated into ‘municipal waste’ targets for London.
Recycling should be an everyday part of Londoners lives at home, in the workplace or out
and about. Therefore we agree with setting targets for the percentage of municipal waste
to be recycled or composted. However, there should be equal emphasis on the importance
of households reducing the total volume of waste produced – so the Mayor may need to
revisit the types of targets which are set to best reflect the priority of reducing the amount
of waste sent to landfill. We support challenging targets, such as a 60% recycling rate, and
would disagree with suggestions that London (particularly inner London) cannot reach
that level of recycling. (Although inner London will need more support with behaviour
change work than outer London).
We agree that the greatest opportunity for increasing recycling rates is through food
waste collections, recycling services to flats, on-street recycling and business waste
recycling:
 Food waste
As the strategy sets out, organic waste makes up 38% of municipal waste in London.
That’s 800,000 tonnes which could be composted or used in anaerobic digestion. Of that
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370,000 tonnes (19% of total) is estimated to be food waste. Yet, currently some 17
boroughs do not provide a borough wide food waste collection, and of those who do collect
food waste only a quarter have separate food waste collections. 1 This will become more
economically viable as Landfill Tax increases and we believe this an area where London
could lead the way, particularly with regard to converting food waste into compost or bio
fuels.
We would urge the Mayor to encourage boroughs to share best practice regarding
achieving good rates of food waste collection. For example, Islington collect food waste
from all street properties and collections have been introduced to 10,000 households on
estates and private blocks. Additionally an organic waste collection service is available for
all businesses in the borough.2 Much of Islington’s food waste is then converted into
compost used in the borough’s parks and green spaces.3 Camden have innovative plans to
convert food waste into fuel to power municipal vehicles in the borough (see policy 5
comments).4 Additionally the evidence from Camden’s trials is that dry recycling rates go
up when you introduce food waste collections.
 The Mayor should set a date (e.g. 2012) by when all boroughs should have
introduced
food waste collections.
 These collections should be linked to greater anaerobic digestion capacity.
The Mayor should support food bank schemes as a method of food waste reduction. Food
can be collected from supermarkets when it is at the end of shelf life to be redistributed.
 Flats
As stated in the strategy it is estimated that average recycling rates in flats and estates are
10% or less; a worryingly low figure given that half of London’s housing stock is flats.
Whilst nearly all boroughs provide some form of dry recycling collection available for
flats, with half of those providing co-mingled collections, these collections appear not to be
widespread given the poor recycling rates from flats.
However, there is evidence that some boroughs have made strides regarding recycling
from estates. Islington provides a weekly doorstep recycling service for 25,000 estate
properties (currently only around a quarter of boroughs provide this) as well as recycling
banks on estates for co-mingled collection.5 Islington have also piloted a very successful
scheme on eight estate blocks, including some larger tower blocks, to provide chute
recycling6, with dedicated recycling chutes. These chutes are clearly marked and
signposted and staff have visited flats to inform residents face-to-face about recycling
opportunities.
 We would urge the Mayor to encourage other boroughs, particularly inner
London boroughs, to share best practice with Islington in order to improve their
recycling rates from estates.
Other boroughs do not appear to have made such progress with recycling collections from
flats for a variety of reasons including: lack of facilities, lack of access to facilities and
This rate of food waste collection appears to be comparable to the rest of the UK
http://www.telegraph.co.uk/earth/earthnews/5110507/Households-could-be-forced-to-collect-food-waste-in-separatebins-under-EU-plans.html
2 http://www.islington.gov.uk/Environment/RubbishAndRecycling/recycling_new/home/kitchen.asp
3http://www.islington.gov.uk/Environment/RubbishAndRecycling/recycling_new/learningzone/food_waste.asp
4 https://www.camden.gov.uk/print/ccm/content/press/2008/october/first-biogas-fueling-station-in-london--turning-food-waste-into-vehicle-fuel.en
5http://www.islington.gov.uk/Environment/sustainability/RubbishAndRecycling/recycling_new/home/estates.asp
6http://www.islington.gov.uk/Environment/sustainability/RubbishAndRecycling/recycling_new/home/estates.asp
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ownership of estates. For example, Lambeth Council state they have where possible placed
green recycling banks on council-owned estates and that recycling banks are provided to a
number of non-council estates, but if residents in non council-owned estates wish to have
recycling banks the onus is on them to request these from the council rather than the
council providing them7
 We believe it would be prudent for Waste and Recycling Officers from all
boroughs to be encouraged to carry out site visits to estates where there are
currently no recycling collections in order to assess the facilities. This should be
done in consultation with tenants and residents associations and should focus on
all estates regardless of whether properties are owned by Housing Associations,
ALMOs or privately.
 The strategy should stress the importance of involving ALMOs in improving
recycling facilities, and suggest ways to engage with the caretakers, cleaners and
concierges of blocks who can often make the difference to recycling schemes
working or failing.
 On-the-go
We support the provision of more “on-the-go” recycling bins across London. Currently
there are only borough recycling facilities outside half of London’s Underground stations
(with LU providing newspaper recycling facilities in another six stations). The recent
refurbishment of London Overground is a good example of where contracts can be used to
improve recycling facilities (as newspapers can now be recycled at 35 of the 37 stations).8
With an estimated 1.7m free newspapers distributed in London daily it is imperative that
the producers of these papers take at least some responsibility for ensuring the recycling
of newspapers. We hope that the recent contract for the distribution of the morning free
newspaper on the underground network contains a strong commitment to improve
environmental performance. Consumers also need to take responsibility for their waste –
but recycling needs to be made easier.
 The Mayor should work with TfL to ensure that there are recycling facilities in or
outside each station.
 The Mayor should work with Network Rail to improve recycling at train stations
and of waste collected on trains (recent reports suggest that out of 29 train
operating companies, 22 of them lacked specific reports of passenger waste
amounts detailing the proportion that is recycled or sent to landfill).
 On-the-go facilities should be consistent across London (in terms of design/colour
coding of bins).
 The Olympics in 2012 would provide an opportunity to trial better on-the-go
recycling by: firstly making sure that all of the outlets within the Olympic
Park/venues use standardised and only recyclable packaging; and secondly link
this with the roll-out of standardised on-the-go recycling facilities and a big
information campaign.
We agree that there should be incentives to encourage people to recycle. However, these
should be clearly targeted and one type of scheme will not work London-wide. For
example, improving recycling in flats is a priority, but the example RecycleBank model
would be problematic as it is often difficult to apportion recycling - so may need to be
adapted to reward blocks/areas. Incentives should also be sustainable and offer benefits to
7
http://www.lambeth.gov.uk/Services/Environment/RubbishWasteRecycling/RecyclingCollections.htm
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http://mqt.london.gov.uk/mqt/public/question.do?id=29745
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the community as a whole. A voucher/reward-based scheme should be based around
encouraging further environmentally friendly behaviour.
 We have previously suggested the introduction of a sustainable reward card,
ideally linked to Oystercard technology, which goes beyond recycling. 9
Policy 5: Catalysing municipal waste infrastructure in London, particularly lowcarbon technologies
We support the principle of managing London’s waste in London and as locally as
possible to the source. In order to do this effectively, new facilities for reuse, recycling and
renewable energy generation will need to be developed. We would not oppose the use of
underused existing facilities that are close to London because this would avoid the GHG
impact of constructing new facilites.
The London Waste and Recycling Board has a crucial role in developing this new
infrastructure and now has an effective Brokerage service that acts as a match maker
between different organisations. But it has been slow to start investing in projects and we
are concerned that there need to be measurable outcomes by 2012 as the delivery of this
strategy relies on the LWaRB going forward.
In the current financial climate banks and other investors are unwilling to invest in new
thermal technologies such as pyrolysis and gasification. The Mayor must work with
LWARB to encourage banks and other investors to look again at these technologies by
offering to underwrite viable new projects. LWARB can also provide Letters of Comfort
to potential investors.
In particular we would welcome detail in the next draft of the strategy, or in an
investment plan from the Board on:
 The development of a mixed plastics closed-loop recycling facility in London.
Currently only some boroughs collect mixed plastics, and those that do have to
send them out of London for processing.
 The development of food waste collection schemes
 Links between the LWaRB, TfL and boroughs on the development of food waste
to fuel so that GLA and council fleets could be powered by biomethane.
Policy 6: Achieving a high level of street cleanliness
We agree that more needs to be done to tackle the problem of chewing gum on London’s
streets. Manufacturers do need to be involved, but an innovations fair may not be the right
forum as the technology for innovations such as biodegradable gum does exist (e.g.
Waitrose has been selling biodegradable chewing gum for a year; and Wrigley’s have had
a patent for an edible biodegradable chewing gum base since 1997).
There may well be a place however, for joint working across the boroughs. In a recent
survey we have conducted about chewing gum, 80% of boroughs have a policy of fining
people for dropping gum but enforcement action has been very limited. Responses for the
number of people given a Fixed Penalty Notice (FPN) last year varied from zero to three.
Joint approaches to FPNs and perhaps sharing clean up teams might help tackle the
problem.
Plastic bags littering our streets and verges in London are also a public nuisance. We
would wish to see a continued reduction in the number of plastic bags in use,
and encouragement given to see retailers charging for plastic bags supplied to their
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http://mqt.london.gov.uk/mqt/public/question.do?id=28058
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customers. The Mayor should talk with central government about the possibility of a
plastic bag tax, revenues from which could be used to support reduction, reuse and
recycling initiatives.
We look forward to your response.
Yours sincerely,
Mike Tuffrey AM
Leader, London Assembly Liberal Democrat Group
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