I understand you are seeking views on the recently released Government waste strategy. Magpie Recycling Co-op Ltd supports Zero Waste, which is fast becoming the new mantra for the community recycling sector in the UK. A concept imported from New Zealand and Australia, where a number of towns and cities (including Canberra) have adopted zero waste as official policy. In its most basic form it means zero waste to landfill and zero waste to incineration. However, it represents a far more holistic attempt to create sustainable communities in terms of resource use, consumer habits and manufacturing systems.

  In this country we have not even started to address these issues. UK environmental policy, in general, is been dragged screaming and kicking into the 21st century, mainly as a result of pressure/directives from the EU. In waste management, a combination of EU Directives and a shortage of landfill are forcing us to change current practices. However, we have failed to move the debate beyond simplistic arguments about which is the most suitable system landfill, incineration or recycling. And we end up trading percentages between the various methods. The idea of a sustainable environmental strategy has yet to see the light of day, either nationally or locally.

  The Governments waste strategy is in our view fatally flawed for a number of reasons. Primarily, because the strategy fails to provide a vision. Targets (certainly as they currently stand) are an inadequate substitute. It is a relatively short-term strategy, which is out of step with the reality in this Country, where Disposal Authorities are entering into 25/30 year contracts.

  It is flawed because it is dishonest, in earlier drafts the Government suggested up to 160 incinerators would be required. No numbers have now been suggested. The Government must be open about the implication of their strategy. We believe they have avoided this because incineration is so unpopular. Again this is out of step with local realities, where active protest groups are emerging in response to waste local plans, most of which are dependent on an element of incineration. In many cases these groups initially start life as single-issue protest organisations, although they mature fast and will (not happening yet, but it will) start joining into alliances. These groups will be a serious challenge for Local Authorities and in time the Government, its waste strategy and environment policy in general.

  It is not a sustainable strategy. It is an incineration led waste strategy. Incinerators are a waste treatment method; they are not environmentally sustainable. Worse, because Disposal Authorities are forced into long-term contracts, where they exist there is effectively a limit to the amount of recycling which can be done. This will make it difficult or impossible to increase recycling levels for the next 25 years. Further, the private sector can only build incineration capacity 20 to 30 per cent larger than the tonnage contract from the Disposal Authority. Because they cannot borrow against commercial contracts as no business is going to sign a 25 year disposal contract. Incinerators initially will be able to handle both household and commercial waste. However, as waste (apparently) increases at 3 per cent per annum in the 25 year period they will have insufficient capacity for all waste in their areas. This is a serious structural flaw in the waste infrastructure currently being haphazardly planned in this country.

  Incineration appears to be the prime waste management method deployed to meet the Landfill Directive, in particular the amount of untreated organic material, which can be landfilled. Organic material is a significant element in the household waste stream. This material must and should be put back to use, it should not be burned to become a contaminated disposal problem. No justification exists for burning organic materials, they have little or no calorific value. In this country we have in many areas exhausted our soil with modern farming methods. Extracting high yields based on chemical inputs and more than one crop a year has been very damaging. Organic farming is for many farms the only salvation in terms of producing a value-added product and to preserve soils. A significant percentage of production will be organic in the next five years. These farms (in particular) will need the nutrient value of the organic waste stream, although it can be demonstrated most farm land is in the same position.

  An increase in incineration appears inevitable for a number of reasons. Incineration is, unlike other waste management systems, artificially subsidised. Reduced rates? At least spread this benefit to Material Recycling Facilities (MRF's). The PFI system is another method of giving Disposal Authorities subsidies to build incinerators. NFFO is also a subsidy, which cannot be justified as plastics are being burned. Incineration is also more likely because it represents a "one stop shop" for Local Authority waste managers. Officers do not want and (putting it politely) often cannot understand more complicated solutions. In a lovely quote from the recent Panorama program "Incineration is the slob solution".

  A more efficient use of resources may happen as a result of the Waste Strategy, but we are not convinced it will make any meaningful contribution. No incentives are in place to encourage households to use resources better. Education and awareness raising will not work when the government is being dishonest about incineration, it will just lead to an increase in cynicism. Manufacturing and commercial enterprises equally have little incentive. The Landfill Tax is insignificant even with the extra £1 per tonne/per annum. Recycling credits should be mandatory, more than one instance of Authorities keeping this money exists. The Packaging regulations are simply not working or leading to a significant increase of recycled materials. It has led to no significant increase in value for materials, which would encourage more collections.

  An increase in material recycling will happen. It will happen in strict proportion to the amount of money given to Authorities to meet their statutory targets. So far new Government money announced will not be enough to meet these targets. It remains to be seen if cuts are made elsewhere by Authorities to meet these targets. Almost inevitably Authorities will establish schemes based initially on paper, as this is the easiest material to target followed by glass. We doubt extra capacity will be built in the time-frame the Government has set to achieve the targets for 2005, given there has not exactly been a stampede by repressors to announce new capacity, in the wake of publication of the waste strategy.

  The recent approval to use glass as an aggregate may be the most significant development in terms of markets. As mentioned there is a huge market for on-farm composting, particularly green waste from CA sites. We do not yet know if money for market development will produce a significant increase in material recycling. We doubt it, as £25 million sounds a lot, but is relatively insignificant in terms of R&D, constructing, reprocessing infrastructure. It is also a very small amount when spread nationally. The average credits awarded to Disposal Authorities for waste PFI bids is more than this! Our own Disposal Authority is indifferent to market development as they are determined to just burn everything. Why bother developing markets if this is the strategy!

  We are absolutely flabbergasted the Government has not made any meaningful changes to the Landfill Tax credit scheme. Who even considered giving private companies the power to distribute tax money? Of course they can not materially benefit from this money. They also do not have to do any meaningful work on waste minimisation or recycling. We do accept, some good projects have been funded. We would also argue it is completely inappropriate to give organisations with a vested interest in the status quo, the ability to distribute this money.

  I understand The Guardian has collected a considerable amount of evidence regarding the Landfill Tax, which exposes miss-use of funds and even corruption, much of this material has been published prior to the launch of the Waste Strategy. Beyond this there are research projects into waste composition, research used latter by the waste management companies to help justify the need for incineration. Research work on the potential for local coppicing, essential for an incinerator, which is not running at capacity. This type of project may not mean immediate financial gain, however the information contained comes in pretty handy for those companies! Our own local landfill company has redistributed less than 15 per cent to waste related projects. If it is a tax on waste (and it is), the money should be spent on mitigating the impact of waste and not by companies which derive their income from waste. The credit scheme must be reformed and taken out of the hands of the landfill operators. We do not see the problem with giving all the tax liability to a "lottery" type grant giving body, certainly with waste management company representation (but not majority) on the board.

  We completely support the principles of the landfill tax (not the existing landfill tax credit scheme), although we would argue an extra £1 per year is simply not enough. For most commercial organisations, waste is a tiny fraction of their overheads. An extra £1 per tonne, per year tax makes very little difference to organisations costs. It is certainly not enough to encourage changes in manufacturing processes, or to make an office switch from using disposable plastic cups! To really stimulate diversion from landfill requires a considerably more robust approach, we suggest an additional £5 per tonne per annum. We would only concede a lower rate for household waste, for a short period of time. We would also suggest an immediate introduction of an Incineration Tax @ 50 per cent of the landfill rate. This would also encourage disposal further up the waste hierarchy.

  Finally, the strategy is flawed because it does not (except in a few irrelevant lines) promote the Community Recycling Sector. This sector has consistently demonstrated "best value" in the past 10 years. It has consistently demonstrated innovation in many areas of waste management. It has consistently demonstrated an ability to engage with local residents. The Waste Strategy is a very real threat to many organisations because of the size of the contracts involved. They are threatened with being bulldozed out of existence. No mechanism is in place to ensure their continued survival. By some paradox many of those working in these groups may turn their skills to full-time opposition to incineration. By lack of support for the groups and individuals needed to make the strategy work, they will create a highly skilled core of active individuals working against government strategy.

September 2000