SWR13
Legislation Committee No 1
Response to the Consultation on the Proposed Shipment of Waste for Recovery (Community Involvement in Arrangements) (Wales) Measure
Cylch-Wales Community Recycling Network
Cylch is an umbrella organisation that promotes sustainable resource (waste) management through education and practical action. Cylch champions community ownership of the waste issue as the most effective way of making the changes to a sustainable resource recovery system that is now required by legislation. Waste materials are a valuable resource and, if managed effectively, can create environmental, social and economic benefits for local people. Cylch Membership includes over 70 community waste minimisation, reuse, recycling and composting enterprises throughout Wales. These organisations provide employment and training for a broad cross-section of the local community, including the long-term unemployed, and people with special needs. In this model, sustainable resource management goes hand in hand with community regeneration.
We welcome the opportunity to comment on this proposed measure and will deal with the consultation questionnaire directly.
Consultation questions
1. Do you think that the proposed Measure will achieve the desired aim of improving transparency and openness in the way that Welsh local authorities deal with recyclate?
One thing is certain and that is that the current situation is not transparent.
Waste trafficking is poorly recorded, poorly policed and the resulting recycling performance data is suspect for those reasons. The fact that most of the responsibility for reducing waste in National Waste Strategies to date is given to Local Authorities is a limiting factor because waste departments in Local Authorities and their waste contractors have little interest in doing anything other than complying with the law using resources within their budgets. Budget management is not the same as being efficient because only costs are considered. There are still Local Authorities in Wales that are almost proud of the fact that they are not commercially minded in that they do not concern themselves overly with maximising revenues from recyclate sales.
They are also focused on avoiding infraction fines - not on providing value for money or using the change for regenerative purposes. In other words we are losing an opportunity to make radical changes, reach very high targets and cut waste costs dramatically for the general good. Recycling should be seen as the first step people can take towards a sustainable and better, more resilient quality of life rather than a chore involving lots of large bins.
The new Wales Waste Strategy, currently out for consultation is an exception because it demonstrates the leadership implied above. It takes a materials rather than a sector approach. Thus it targets all waste across the piece.
Requiring Local Authorities to declare the destination of their recycled materials and report exactly how much of the tonnage delivered to market ACTUALLY gets recovered rather than landfilled or burned MUST aid transparency. There will be siren voices claiming that, due to commercial confidentiality, LA’s will find it difficult to know the final destination of their materials with any certainty. These voices are impotent and should not be heeded.
Cylch takes the view that this is errant nonsense because there is no genuine market as yet for recycled material. The market in all materials depends on subsidy from the public purse. For this reason it is only right that the public should know that public money is being used ethically, not subsidising the practice that requires materials to be sorted in sweatshops in the Philippines or China. People here have a right to know that their efforts in putting materials out for recycling are treated with respect rather than being profiteered from by multi-national utility companies whose only motive is market share or profit maximising. LA’s in particular can use their procurement and supply chain powers to insist on accountability.
The UK markets are mostly still importing vast quantities of recyclate from Europe because they can’t get enough high quality material from the UK collectors. Particularly the two heaviest materials in the domestic recycling bin (80% by weight) - paper and glass
2. Do you consider that the proposed Measure is the best means of improving transparency and openness in the way that Welsh local authorities deal with recyclate? If not, which other approaches should be used?
Yes agree that the measure will improve matters dramatically and should be pursued vigorously. The paper trail of duty-of-care certificates regarding waste is a well established process conferring responsibility on waste producers to ensure that they hand over tonnages to competent collection and disposal authorities which are registered and policed by the Environment Agency. This process should not be allowed to be compromised by commercial confidentiality as at present and this measure prevents that. This measure will shame those authorities that might be acting without this due care - hence change their practice. This will also improve the data because at present MRF operators are disguising reject rates by selling on tonnages of mixed material to commercial MRF operators and declaring the total throughput of their own operation as having been recycled - no material sent to landfill. We know from inspection and from insider knowledge of MRF operations that getting less than 10% reject rates at MRF’s is a miracle and that tonnage delivered to reprocessors as "clean” by MRF operators contains another 10% reject that goes unrecorded. What is more (and logically) as the total tonnage of material rises as more people participate in recycling schemes MRF’s are put under more pressure to shift that tonnage and the quality continues to deteriorate at the reprocessors gate.
The measure will counter this if properly enforced yet it needs to be backed by better information as to any other options involved, including incentives for applying the proximity principle in dealing with recyclate. The trend is for providing regional, rather than local, facilities. Again to please the profiteers. Cylch takes the view that it is better to provide smaller treatment facilities that have a smaller footprint, taking materials from a smaller area. This is more acceptable to communities for a host of reasons. The Community Recycling sector has over 1200 depots in the UK of varying sizes, all dealing with re-use, recycling and composting operations on municipal waste materials. None of these have bad neighbour problems because they are seen to benefit the community.
3. Are there additional powers that could be included in the Measure to further promote this approach in local authorities?
Yes - make provision for Mandatory recycling credits.
A payment made from the Local Authority’s waste disposal budget to any registered and authorised collection agent to contribute to the cost of collecting materials that would otherwise have been land-filled or incinerated. The amount should be equivalent to the most expensive waste disposal cost that applies to that Local Authority. (The 1990 Environment Protection Act makes provision for this). This provision would revolutionise recycling at a stroke.
As mentioned, the fact that Local Authorities are the fulcrum of the waste minimisation policy in National Strategies is limiting because LA’s contain many of the vested interests that actively defend the status quo of high tech, high budgets and career/job protection. Recycling credits would create instantly a more competitive field where efficient collectors could build relationships with all waste producers (especially householders) that would drive costs down and improve the wealth being derived from waste.
Also create a brokerage for Local Authority Tonnage such that revenues are maximised whilst stabilising expected revenues so that operations can plan - hence reduce the investment risk. This would enable healthier funding of recycling operations for longer term sustainability.
4. Do you consider that the implementation of the proposed Measure would lead to residents encouraging local authorities to use recycling facilities that are closer to the source of the recyclate, than those that are further away? Do you agree that publication of the required information will lead to increased interest, and therefore participation, in recycling?
The general public does understand what is required for recycling to happen properly. Witness the avid protests from residents when their Local Authority does something contrary. Caerphilly residents, for example, were astounded when the Council compactor trucks came around and tipped their kerbside boxes into one truck and then paid Cardiff to accept this "valuable” recyclate. This is the equivalent of selling £5 notes to Cardiff so that Cardiff Councillors can boast that their MRF "made a profit.” Participation increases when people are given the right information as to what to do with the kit they are provided with to enable collection of clean materials. Bryson House Recycling in Northern Ireland operates both co-mingled collection followed by MRF sorting as well as kerbside sorted methods of collection. When customers were surveyed they were both equally loyal to the system they were using despite the fact that the kerbside-sorted system is 30%-40% better performing in terms of tonnage and revenues. So customer surveys tell us nothing really except that people are resistant to change.
5. What unintended consequences, if any, could arise from the implementation of the proposed Measure?
The measure will increase the information flow amongst participants and traders that, via the influence of public opinion transmitted through local councillors, will cause the operators to be sensitive to public opinion until the high targets have been reached. This may well cause operators to use indigenous re-use, recycling and composting infrastructure - but there will also be a back-lash
There will be a strong focus on justifying exports to China and the Far East based on the "good global market” hypothesis. The LCO will be seen as a challenge to the commercial freedom of waste merchants who need to maintain secrecy in their deals to be competitive and this might result in strange market behaviour. Most markets are monopsonies and there is always a strong drive for cartelisation.
6. What do you estimate the costs of complying with the proposed Measure to be for your organisation? Do you consider these costs to be excessive?
Any cost incurred by real recyclers will be far outweighed by the revenues gained from accessing top quality recyclate and selling it directly into UK markets which is waiting to receive it. For Local Authorities the cost will be minimal - merely an entry into the contract to provide data to the client.
Mal Williams
CEO Cylch
June 2009
