SC(3) CR-I&PB16

Sustainability Committee

Inquiry into Carbon Reduction in Wales: Carbon Reduction by Industry and Public Bodies

Response from Waste Network for SE Wales Friends of the Earth Groups

Public Bodies and the Waste Industry

This response concerns the greenhouse gas emissions consequent on Local Authority Waste policies and practices. Local Authority and Regional waste strategies are being prepared, as the basis for their own activities and for contracts with major companies and the voluntary/not-for-profit sector.  We argue that the 'shadow’ price of carbon should be factored into the economic appraisals of options. This would be in line with the recent UK Government decision that 'shadow' carbon costs are to be used in day-to-day policy and investment decisions by Westminster government Ministers.  We propose extending that policy to Environment Agency and Local Authority decision-making relating to waste management.  

We point out that the Landfill tax gives WAG a large revenue stream (£20-30 million/yr) for waste management purposes, but no proper policy exists on spending it.  Reducing CO2 associated with the waste industry should be recommended as an obvious, even priority, objective.

WAG divided Wales into three groupings for the purpose of writing Regional Waste Plans. The first versions were 2004 and all three groupings have to produce revised versions by August 2008.  All have had to use a waste options assessment written by Environment Agency Wales and to use Hyder to run public consultation completed in December (and was far sub-standard).  The EAW options assessment is based on their WRATE computerised "tool”.  Hyder is well-known (notorious) for running pro-incineration consultations for some English authorities and their presentations and their on-line questionnaire showed the same bias here.  

WAG has recently pressured local authorities to group in consortia to bid for grants for waste facilities.  Our experience is of the SE Regional Waste group and of the Prosiect Gwyrdd group (the SE Wales coastal subset).  Both are public bodies and acting on behalf of their constituent authorities, though with little openness or accountability.  Our argument is that all such bodies need to properly take CO2 into consideration in waste planning and procurement decisions.  There’s need for an explicit requirement on them to do so.  The context is that they are pursuing a large role for incineration - Prosiect Gwyrdd is after a large incinerator in Cardiff Bay - instead of maximising recycling and composting (as adopted policy - Annex B and further information below).

We submit supporting information and explanation on Friends of the Earth’s view, supported by studies, that the best waste management strategy in terms of greenhouse gases is to separate materials at the kerbside, to maximise recycling and to extract food waste for AD and other biodegradable wastes for composting.  For residual wastes the alternative to incineration technologies (including pyrolysis and gasification) are MBT technologies - which involve composting to reduce the biodegradability and then dispose the residue for land reclamation or to landfill [1-5].  We also draw on the Eunomia study of 2006 "Changing Climate for Energy from Waste” [6] which critically examines assessment of greenhouse gases in waste management (summary in Annex A).

We respond to selected questions:

Q3. What particular challenges does Wales face in reducing carbon dioxide emissions from industry and public bodies, and how can these challenges be overcome?

Public bodies are pursuing incineration projects for municipal wastes in the false belief that burning with energy recovery reduces overall greenhouse gases.  They wrongly claim that CO2 from wood and other partially biodegradable materials does not count.  These projects will consume resources that will be replaced by imports (and emissions overseas) and will lead to increased emissions in Wales.  To overcome this problem, we need a WAG waste strategy and waste management funding policy that take on board amounts and costs of carbon emissions and use properly reviewed assessments not biased to incineration.  The Regional waste groups have ignored CO2, which calls for specific guidance.  We look to the Minister to veto the inflexible and poorly-justified incinerator projects that are in train and to issue strong policy on recycling/composting targets of at least 70% and potentially 80-90%.

We propose adopting the shadow price of carbon in economic appraisal.  The shadow price was set to correspond to a real economic cost in global climate change (though higher levels could be argued) so in logic this must be used in decision-making.  The general policy requirement, adopted by central government in December 2007, has been developed over 2-3 years by an interdepartmental project and subjected to peer review.

www.defra.gov.uk/environment/climatechange/research/carboncost/index.htm

The shadow price for carbon is to cover all day-to-day policy and investment decisions of Westminster government departments.  We propose extending this to

• all regional Welsh public bodies, including the Regional Waste Groups and Transport groups
• to Local Authorities for deciding on waste policies (in LDPs) and setting waste contracts
• to the Environment Agency in assessing technology options in PPC permitting of incinerators and landfills.

We'd ask the Committee to recommend that these public bodies (and others) be instructed to use the shadow price for carbon in economic appraisals.  

Q4. Do the current Welsh Assembly Government economic development policies give sufficient emphasis to carbon reduction?

No. Incineration of waste obviously maximises CO2 from it; electricity generation is very inefficient (~15% net) so the CO2 emitted per kWh is much more (2-4 times) than from the power it displaces.  Yet WAG has given RCAF grants for large incineration projects, with no consideration to the CO2.  The issue of spending the large and increasing revenue stream (£20-30million) from landfill tax is not addressed in the Minister’s paper "Future Directions…” of October 2007, yet carbon reduction is an obvious objective.

Q5. To what extent has the Welsh Assembly Government been successful in utilising the powers available to it in order to reduce carbon dioxide emissions from industry and public bodies?

It has succeeded in increasing recycling/composting in Wales from abysmally low levels to ~30%, by policy exhortation backed by landfill tax and recycling facilities grants to.  We were supposed to meet 25% in year 2000!  WAG’s belated determination (after doing nothing to get Councils to implement their Recycling Plans from the 90s) is enabling Welsh businesses collecting and using recyclates to build up.  However, there is a long way to go and a danger that the big multinational waste companies will come in, squeezing out the small Welsh companies who cannot offer the full range of options that the Local Authority consortia require.  Squeezing out the local in favour of large scale operation will increase the CO2 associated with waste-miles.

Q6. Could alternative targeting of Welsh Assembly Government financial resources lead to greater emissions reduction from industry and public bodies than is currently being achieved? If so, where could additional resources lead to greatest impact? (Please provide detail to support your evidence).

Yes.  Revenue from the Landfill Tax is not being used under properly determined criteria.  It has so far have largely gone in refunds to local authorities, but WAG is telling them this is not guaranteed to continue, in order to pressurize them out of landfill.

It appears that the funds are being used on the basis of possible future policy (the pro-incineration strand of 'Future Directions’… ) and in response to pressure from pro-incineration officers (Annex D).           In June 2007 WAG awarded £400k 'Regional Capital Access Fund (RCAF’) to Prosiect Gwyrdd to draw up a business case and contract a huge incineration project that does not accord with existing policies (Policy in 'Wise About Waste’ is to minimise both landfill and incineration).  £200k was awarded similarly to RCT (with Merthyr and Torfaen).  In contrast, WAG refuses to fund appraisals of lower CO2 alternatives (MBT technologies) that are envisaged in the 2004 Regional Waste Plan (Annex B).

The Landfill tax is guaranteed to be revenue-neutral.  7% goes to landfill operators' community schemes.  With the tax at £24/tonne, increasing to £32 in April, WAG now has a £20-30 million revenue stream for funding waste management.  Yet they evidently lack an open and principled process for disbursing these funds.  

Welsh policy for spending this landfill tax revenue should in particular be linked to GHG performance.

We need fair and transparent mechanisms that might include:

• refunds and rewards to Councils that achieve targets
• funding waste reduction and recycling
• promoting local (Wales-based) recycling businesses (on the proximity principle).

GHG assessment and performance must be important in judging these.

Q7. What examples from other administrations (devolved, UK, and overseas), where other means have been used to achieve reductions in carbon dioxide emissions from industry and public bodies, could be adopted in Wales under current powers?

"Zero Waste” strategies have been adopted by cities, provinces and even countries [9].  They require a combination of reduce, recycle, composting and redesign.  Now that the inertia in recycling is being overcome and the public attitude much more positive and tax mechanisms available, and that the Minister is serious about high levels of recycling/composting, we should envisage adopting zero-waste in Wales within very few years.  

Q9. If specific carbon dioxide emissions targets are to be set for Wales, should those targets be subdivided into shares by sector?

We think it important that the waste management sector has separate monitoring and reporting.  Plans for incinerators have the potential for emitting 2 to 3 million tonnes of CO2 per year (based on 1.8 Mt/yr municipal waste) so this must not be hidden within the large industry sector.  CO2 reductions from this sector will be a matter of modelling based on carbon embodied in recyclate and the carbon returned to soils or sequestered in landfills.  Landfill methane emissions need also to be measured and modelled, which can be required by Environment Agency Wales PPC permits.

Further Information

Future Directions for Municipal Waste Management in Wales

The Minister Jane Davidson in October 2007 circulated Future Directions… as a 'discussion paper’, with aim of extending the time-horizon of the existing Wise About Waste: the National Waste Strategy for Wales 2002.  The 2007 paper proposed figures on recycling and composting for the longer term, of at least 70% and potentially 80-90%.  That makes Waste Plans focussing on 'residuals’ look silly and rules out the desired large incineration projects.  The Minister’s justification is that recycling materials is far better in GHG terms than reclaiming (part of) energy embodied in the materials.  This has long been known, but recent studies by WRAP [7] have demonstrated it conclusively for most waste streams, taking into account the energy used in collection and processing. [2, 8].

Maximising recycling and composting was an objective of the 2002 Wise About Waste and in the SE Regional 2004 plan.  Welsh LAs were slow in getting going but are now responding over recycling, because of the legal requirement for kerbside collections of at least three recyclable materials.    

They are slower to respond on composting, despite this being the principle way to meet the 2012/13 Landfill Directive limit on biodegradables.

Policy in Wales as in England has resolved that food waste has to be separately collected and processed via in-vessel anaerobic digestion (WAG grants for this).  Policy is also saying that source separation and kerbside collection is necessary to maximise recycling.  Recyclate from mixed refuse that is sorted mechanically is often too contaminated and has low or zero market value [2, 8]. Councils like Cardiff who have invested in mechanical sorters don’t like this message - rather than maximising recycling they are keen on incineration (funded by long term PFI contracts).

Incinerators generate the maximum carbon dioxide.  Incinerators convert to CO2 all the carbon in plastics, fabrics, paper as well organic material.  If the wastes are sent to landfill, the organic material and paper convert in part to carbon-gases, but the carbon in plastics most in wood/chipboard wastes is sequestered long-term.  Calculating the GHG benefit of incinerator energy and the methane emitted from landfills makes the overall greenhouse gas balance uncertain.  The Eunomia study of mid-2006 [6] challenged 'conventional wisdom’ - that energy from incineration of residual wastes is bound to 'generate climate change benefits’.   It showed that whether climate change impacts are positive or negative is dependent upon technologies and assumptions (Annex 1).  

The Eunomia challenge has stood up to critical review.  The conclusion is that - even if incineration technologies are affordable and their lorry waste-miles are limited, they can produce more greenhouse gases overall after taking into account any electricity generated.  WAG officials argue that they want high efficiency heat-delivering CHP incinerators.  Those in the UK are exceptional and  not high efficiency, and have not been shown to be commercial - we argue they are too uncertain as a base for revising the Wales Waste Strategy.

However, the Public Bodies have been persuaded (by the incineration lobby and interests within WAG) to exclude MBT technologies without considering the greenhouse gas argument.  They have funding from WAG for appraising major regional incineration facilities, whereas WAG refuses to fund appraisal of lower CO2 alternatives (MBT technologies).  The Regional Waste groups do make use of an Environment Agency assessment from WRATE, but we find that did not (or hardly) considered the bio-stabilisation potential of MBT (Annex C).

It’s true that if Regional Waste Plans include maximal recycling as officials argue (Annex D) and the Minister proposes, then the CO2 savings in the "recyclate” may outweigh that emitted in transport to Regional facilities and in incineration.  But that does not justify ignoring the low CO2 options for residual waste treatment - ie. composting, biostabilisation and use on land - and reducing transport CO2 on the proximity principle.

The Regional Waste groups’ strategy review documents do not explicitly consider the carbon reduction issue.  These documents are to be revised before adoption in final form (by end August on present schedule).  There is thus opportunity for them to address the carbon issue if the Committee advises the Minister to send them guidance on this.

Deficient Assessment via 'WRATE’

The EAW’s WRATE study dated 2006 'Life Cycle Analysis of Municipal Recycling Targets for Wales - Headline Results’ was used as supporting study for Future Directions… However, it is only a summary.  It promises "A more detailed report will follow detailing all of the assumptions used for this analysis”, but WAG says that does not exist.  We have to infer its inadequacies from other documents and from a copy of the restricted (non-specialist) software version purchased by central Friends of the Earth.  The Regional WRATE studies tabulate results for various options from which some assumptions can be inferred.  The EAW staff responsible for the Regional WRATE study have supplied some explanation.

Points of bias and inadequacy for greenhouse gas assessment have been submitted to Hyder (Annex C) and recently to WAG.

• Fails to include MBT stabilisation with return of materials to land, an established option in England (SITA/Northumberland; Biffa/Leicester; Global Renewables’ plan for Lancashire; New Earth Solutions/ Bournemouth).  
• Assumes AD followed by RDF production that involves energy-expensive drying - used in Germany but generally inappropriate in our context.
• Contaminated wood and wood derivatives assumed as 100% biodegradable, though ~10% is found.  The real figure gives advantage to landfilling because of sequestered carbon
• The WRATE electricity model wrongly assumes 25% generating efficiency (25.35% - Table 25) - EU protocols and the BREF standards give ~15% efficiency; new plant may reach 20%.
• Over-optimistic about CHP incinerators - the unusual Grimsby plant supplies an adjacent industrial user mainly taking heat.  The Coventry plant is given a fictitious heat load to pretend high efficiency.

When meeting with FoE representatives in December, WAG officials admitted that WRATE results are sensitive to assumptions.  But they are failing to try and make it work fairly, refusing to take on board our specific criticisms.  This means their policy has no basis in GHGs or BPEO (Best Practicable Environmental Option) for its bias against MBT technologies.  There is optimism in the Trade over the 'New Earth Solutions’ MBT system that reduces biodegradability to 10-20% or less, in trials in 2006 (validated by the EA in 2007).  But WAG officials remain wedded to their view (Annex D: "the thought of spreading MBT residue on any land frankly appals me”).

Need for Speedy Ministerial action in Waste Management

The revised waste policy deferred from autumn 2007 to mid-08 will come too late.  Waste Strategy for England 2007 came out last May.  Wales needs policy guidance quickly on the central thrust for over 70% recycling and to make carbon/CO2 a key driver.   Future Directions… has (unlike England)  only a weak reference to the need for flexibility with regard to developing technologies, to avoid lock-in on 25-30 year incinerator contracts.  We suggest the Minister should issue a MIPPS on Waste to give the recycling/composting target and carbon/CO2 importance the status of Planning Policy guidance.  It would follow that

• The Regional Waste Plans would need to be reviewed in the light of this guidance - they have in any case come too soon, because of deferral of the overall Wales Waste Strategy.
• This MIPPS would add to guidance for preparing LDPs (that contain County waste strategies) which is needed promptly at this stage;  it would mean LDPs would have to consider sites for recycling and MBT centres and landfill (shelved on the excuse of Prosiect Gwyrdd)  

The Minister should also inform Prosiect Gwyrdd that carbon minimisation should be an important factor in assessing rival bids for the waste management package (reportedly centering on incineration) that they are preparing to advertise, and ensure that the MIPPS and the mid-term RCAF review embody this policy.

The Minister should also issue guidance to EA Wales who have a big role in waste management

• that in their economic appraisals of cost-benefit, EAW should use the shadow cost of carbon.
• In their WRATE assessment they should include the benefit of sequestering carbon (soils and landfill) and a realistic assessment of MBT stabilisation of biodegradable wastes
• Make their WRATE assessment freely available to critics and develop a properly-reviewed version with contentious assumptions transparently laid out and subject to user-choice.

This guidance could be issued as "Statutory Guidance” to EAW or as a Direction under s.40 of the Environment Act 1995.  The Minister may need to consider if the overlap between her Waste Strategy branch officials and the EAW is appropriate (cf. Annex 4 - deficit in separation of existing policy and possible future policy).

Submission on behalf of SE Wales Friends of the Earth groups, Waste Working Party

Max Wallis     28 January 2008

References

[1] Recycling - why it’s important and how to do it www.foe.co.uk/resource/briefings/recycling.pdf

[2] Recycling collections - source separated or commingled? www.foe.co.uk/resource/briefings/recycling_collections.pdf

[3] Anaerobic Digestion, www.foe.co.uk/resource/briefings/anaerobic_digestion.pdf

[4] Stopping the waste - Maximising resource efficiency and minimising our climate impacts through the review of Europe’s main waste law www.foe.co.uk/resource/briefings/stopping_the_waste.pdf

[5]  Landfill Allowance Trading Scheme www.foe.co.uk/resource/briefings/lats.pdf

[6] A Changing Climate for Energy from Waste,.Eunomia report for Friends of the Earth www.foe.co.uk/resource/reports/changing_climate.pdf

[7] WRAP’s research on food waste is at: www.wrap.org.uk/local_authorities/biowaste.html.  

WRAP’s UK Recycling Stakes its Claim in Climate Change Debate of May 2006 and the back-up studies is at www.wrap.org.uk/wrap_corporate/news/uk_recycling_1.html

[8] The Campaign for Real Recycling (CRR) promotes high quality recycling; see www.realrecycling.org.uk/

[9] Zero Waste Alliance www.zerowaste.org/; Zero Waste New Zealand Trust  www.zerowaste.co.nz/; Zero Waste Alliance UK www.zwallianceuk.org/

Annex A   'A Changing Climate for Energy from Waste’ Eunomia Report, Dominic Hogg, May 2006 [6]

This report challenged 'conventional wisdom’ that energy from waste incineration is bound to 'generate climate change benefits’. Such benefits may be possible, but the report highlights the fact that whether climate change impacts are assessed to be positive or negative is dependent upon the assumptions used in the analysis and the performance of the relevant technologies, notably:

• the efficiency with which the incinerator generates energy (and in many UK-based studies, over-high efficiency is assumed);
• the assumption concerning which energy source might be considered to be displaced by the incinerator (this will always be controversial);
• the efficiency with which these 'displaced sources’ generate energy (these are tending to improve over time);
• whether or not one includes biogenic carbon in the analysis (most studies do not);
• the calorific value of the input waste;
• what percentage of carbon (biogenic and non-biogenic, depending upon the view of the study) is in the waste combusted.

Notably, the study highlights the fact that typical UK incinerators, generating electricity alone, emit a larger quantity of greenhouse gases (GHGs) per kWh than UK gas-fired power stations, and that incinerators emit more GHG/kWh than coal-fired power stations if biogenic carbon is included.   

This need not necessarily imply that energy from waste incineration is bad for climate change. It could, after all, be true that incinerating waste and generating energy from it is the best way of dealing with waste, as many life cycle assessment (LCA) studies have concluded. However, we argue that the use of conventional LCA-based approaches, and most notably, the largely unquestioned assumption that 'biogenic carbon can be ignored’ (or that only what is not liberated as CO2  after 100 years needs to be taken into consideration, which amounts to a similar assumption), is inappropriate for this type of analysis. The conventional analyses also do not cover the new treatments aimed at stabilising biodegradable mixed wastes.  Techniques for mechanical separation followed by composting treatments are showing they can produce stabilised 'compost’ that may be usable for land restoration or, if required to go to landfill, produce little methane and leachate that count against landfilling in LCA analyses.

Annex B   Current SE Regional Waste Strategy

Aim to achieve the 2020 Landfill Directive targets by 2013

• achieve this principally through maximising recycling and composting
• deal with residual waste by Mechanical Biological Treatment
• choose between either sending the residual waste from MBT to landfill or using
• it as Refuse Derived Fuel
• limit the amount of waste going to landfill to that which can not be dealt with
• acceptably in any other way.

Annex C   Criticisms of the use of WRATE

From Barry & Vale FoE’s response to the SE Regional Waste Plan, December 2007

(WRATE as in 'Sustainability Appraisal and Life Cycle Analysis of Strategic Waste Management Options’,

Summary report for the South East Wales Regional Waste Group, EA Wales 2006)

The use of WRATE to exclude MBT as incapable of giving sufficient reduction in biodegradability is of course unreliable.  Other authorities and consultants have shown MBT to be quite capable.  Though Global Renewables is said to be modelled (option 2D), that company has convinced Lancashire (whose waste is probably more industrial-contaminated than SE Wales) that it can be done.  Northumberland also has MBT up and running with EA approval for some re-use of the stabilite.

Points that are questionable or clearly in error

1. foodwaste, garden waste and "other organics” are all sent to MBT and then to landfill, with residuals or ~5% and mass reduction of only ~20%.  This is about the fraction of water, so the effectiveness of this MBT in biodegrading is minimal (thus S10 - 100%).

2. Including 19.25% garden waste in residual waste is wrong - collection authorities do not permit green waste in the residual bin and most are reasonably effective at enforcing this.

3. where Welsh authorities collect garden waste for composting, the residue is generally reused on land, so is already shown to meet EA standards (at least for woodland use, or land reclamation).  Only a small reject fraction would need to go to landfill

4. WAG is expecting, encouraging and funding Welsh authorities to collect food waste separately for in-vessel AD.  Depending on controls, and going through a second composting phase, this is generally found to produce good quality compost; rejects would also go to non-food producing land, so none to landfill.  

5. Col 16 expressing the amounts of water (3E, 3F) wrongly contributes to the total biodegradable fraction (1.16: 100%); it should of course only contribute to the total landfilled (col. 0).  It amounts to about 12% of the input to MBT pre-treatment, which is far less than normal for mixed residuals, partly because the paper is apparently presumed dry.

6. Other columns 4-7 have S4-7 of 50% (generic process data held in WRATE ) potentially including water.  Col 4 for textiles should allow also for synthetics, which normally make up more than 50%, so this figure should increase.

7. Paper is composed of some 30% non-biodegradable lignins, as well as some moisture, so the S1 of 100% should perhaps be 60%.

8. Option 3F has far more C&D fines which is an error (causes 3F to look worse than 3E).  

9. Options 3E and 3F use a generic MBT process from WRATE (composting and RDF production) which ignores biostabilisation.  EA Wales inform us that the established plant they observed in Europe treating residual waste always produced an RDF, so was not geared to stabilising wastes.  Indeed, producing RDF require a drying process that is energy-expensive, so is clearly inappropriate.  Thus total degradability of MBT in the stabilite is about 66% (final to initial cols) which is extremely high.  The Poole scheme gives 20% or less in trials of Bournemouth’s residual waste, as audited by the EA.

10.  MBT composting reduces solid (as dry) mass through conversion to CO2 and water.  The reduction found by SITA for black bag waste from Newcastle city (48 000t to 20 000t) appears to be about 60% including initial water.  This needs including.

11. Large contribution from C&D waste goes to landfill without treatment contributing ~25% of the biodegradables, presumably mainly wood.  Such an important waste stream merits particular treatment, introducing more source (or CA site) separation

12. MBT stabilite even from black bag waste from Newcastle city, may be spread on land - the EA has allowed SITA to use the product in land reclamation in Northumberland.

The EA document does not show the results are robust to assumptions.  It just says its outcomes "should be viewed with caution as a number of assumptions have been made about the composition of the waste, the types of material removed for recycling/composting and the amount of waste in the study year”.  This is quite inadequate as an assessment - but then it’s had no independent peer review.

The statement on biodegradability is also quite inadequate: "the actual reduction of biodegradability caused by a process also requires extensive monitoring and would be likely to vary depending on the input composition. The performance of the facilities in WRATE is based on actual measurement of plant performance”.

Biodegradability certainly varies - and can be very different from the EA’s assumptions.

Claiming "actual measurement” is also misleading, eg. not only are the biodegradability RDF figures inappropriate, but also the Coventry incinerator had a fictitious figure for heat uptake.

The conclusion from this sustainability assessment - "that the highest scoring options should form a technical basis for development of the Regional Waste Plan for South East Wales” - is therefore quite unsound.  No special factors are identified to make SE Wales different from areas where MBT has been chosen.  The failure to explore sensitivity to other choices and failure to follow the recommendation for a peer review shows that the conclusion is neither secure nor robust.

Annex D   Extracts from e-mail from Dr Andy Rees, Head of Waste Strategy Branch, WAG

"Rees, Andy" andy.rees@environment-agency.wales.gov.uk 23 Jan 2008

Subject: RE: 'Future Drections' waste policy

We were faced with the very real prospect of a number of local authorities going for high rates of EfW and maintaining recycling at 40%.  This is on the basis of the assumption in some professional circles that EfW is better than recycling in greenhouse gas terms (I of course completely disagree with this, but there are many who don't share my view).  So our modelling was designed to show that higher rates of recycling and lower rates of EfW were the best option in greenhouse gas terms. So we are now focussing our efforts on securing acceptance of 70% as the future recycling target, with a cap on EfW of 30%, and a cap on landfill of 5%.  This is perfectly in line with the waste hierarchy, which in itself is only a guide and not a legal requirement. We are facing a lot of resistance to this from certain quarters, and are having to expend a lot of time and effort to hold the line on 70%.

In respect of the role of MBT and landfill, I think we will have to agree to disagree on this. I contend that EfW with high energy efficiency is higher up the waste hierarchy than landfill, and clearly performs better than landfill in respect of overall greenhouse gas emissions. I believe that the proposed revision to the Waste Framework Directive will confirm this hierarchy.  This is also what WRATE shows. It is of course our current policy that CHP should be incorporated where possible with EfW, and we have stated in the "Future Directions" paper that we will consult on setting a legal requirement that any new EfW plant built must have a minimum energy efficiency. I would expect this to be probably be set at around 60% efficiency.  We will also consult on banning the landspreading of the residue from MBT plants on the grounds of the precautionary principle. As a dedicated environmentalist the thought of spreading MBT residue on any land frankly appals me.

The EA's WRATE report in relation to the 70% target - this is the only report that we have had from them.

I am still awaiting the final version of the Eunomia report on the costs of achieving high recycling rates, and the practicalities of meeting high rates.   It is the establishment of an acceptance of a high recycling rate by local authorities that has been the focus of our work, and of the Eunomia report.   The whole aim was to reduce a potential over-reliance on energy from waste, and at the same time get landfill to as close to zero as possible (in accordance with the "Zero Waste" ethos).