Memorandum by the Environment Agency
INTRODUCTION
1.0 The Environment Agency is the Government's
principal advisor on the environment. We regulate waste management
activities and are also a principal delivery body for the Government's
Waste Strategy 2007. We have a keen interest in waste reduction
and resource efficiency as part of our role in protecting the
environment.
BETTER DESIGN
AND THE
USE OF
MATERIALS
2.0 Clearly, manufacturing methods and designs
that maximise resource efficiency will tend to reduce waste production.
Similarly, the use of designs that facilitate the removal and
recovery/recycling of materials, and the use of materials that
are easily recovered/recycled will help to reduce the volume of
wastes sent for disposal when products come to the end of their
life.
2.1 We do not have the remit or technical
expertise to comment in any detail about the role that better
design or materials might play in the creation of waste. Although
we are not the organisation to lead in this, we will be pleased
to advise in any relevant field where we have expertise.
2.2 We are pleased to note that the Government
plans to set up a new products and materials unit. This will identify
and catalyse actions across the supply chain, to improve the environmental
performance of products throughout their life cycle. The precise
remit and membership of this unit is not yet clear. However, the
Government's plan for the unit to produce a progress report on
delivery by Spring 2008 is to be welcomed.
2.3 We would welcome clarity on responsibilities
for driving and delivering the Government's waste reduction and
resource efficiency programmes.
2.4 We believe that the wider use of life
cycle assessment techniques in assessing alternatives should help
to engender more sustainable product design.
BUSINESS FRAMEWORK
2.5 Our work with a number of industries
on the development of Sector Plans has promoted sector improvement
targets for environmental performance. These include waste reduction,
as well as reuse, recycling and recovery.
2.6 The Sector Plans include many industries
that are regulated under the Integrated Pollution Prevention and
Control (IPPC). IPPC places a statutory duty on industry to reduce
waste and we are using our regulation of these companies to require
them to reduce the amount of material used and the amount of waste
produced or, where this represents the best available technique,
to recycle more. We have set a target of a 15 per cent reduction
of waste disposal for these companies between 2006 and 2011.
GOVERNMENT POLICY
2.7 We support the Government's continued
commitment to producer responsibility arrangements. It is right
that businesses should be required to take financial responsibility
for the environmental impact of products they place on the market.
To date, these initiatives have focused on increasing recycling
rates for end-of-life products. In the decade that producer responsibility
legislation has been in force for packaging in the UK, recovery
rates have more than doubled. However, there has not been a reduction
in the amount of packaging used or packaging waste discarded.
2.8 We expect that the future implementation
of the Batteries Directive will reduce the proportion of batteries
going to landfill, an outcome we welcome. However, the legislation
is unlikely to have a significant impact on the number of batteries
used. We would like to see Government come forward with proposals
aimed at promoting viable environmentally preferable alternatives
to batteries.
2.9 We believe that, wherever possible the
primary purpose of producer responsibility schemes should be to
reduce the amount of waste produced in the first place, not just
to increase the amount of waste recycled.
2.10 We support the use of suitable financial
incentives to encourage waste reduction. For instance, increased
levels of landfill tax, combined with the relatively high cost
of alternative waste management methods, is now beginning to provide
a real incentive for businesses to reduce their waste production.
Similarly, the recent reductions in the number of landfill sites
through the implementation of the Landfill Directive, together
with bans on the landfilling of certain wastes and requirements
for pre-treatment for other wastes have increased the financial
viability of waste reduction.
2.11 The Government's Waste Strategy for
England 2007 sets out a number of objectives and targets to reduce
waste production. It includes a high-level action plan to deliver
these objectives.
WASTE QUALITY
PROTOCOLS
3.1 Our work on waste protocols will be
of interest to the Committee.
3.2 The BREW waste protocols project was launched
in May 2006. It is a joint project between the Environment Agency,
the Waste Resources Action Programme (WRAP) and industry, and
is funded by Defra's Business Resource Efficiency & Waste
programme.
3.3 The purpose of the protocols work is
to either:
Produce a quality protocol which
sets out criteria on how to produce a product from a specific
waste type or;
Produce a regulatory position statement
or;
Agree a low risk position.
3.4 So far the project has published:
Compost Quality Protocol (15 March
2007);
Blast Furnace Slag Technical Report
(24 August 2007-a steel making by-product, Blast Furnace Slag
(BFS), will no longer be classified as a waste, a move that will
cut red-tape and allow the construction industry easier access
to more than 3 million tonnes of the material produced annually);
Regulatory clarification statement
for waste wood.
3.5 The project is set to launch 12-week
consultations for five Quality Protocols in the next two months.
They are:
The production of biodiesel from waste vegetable
oil;
Tyre-derived rubber materials;
Non-packaging plastics;
3.6 The project is currently considering
the following waste streams:
Boiler ash from the disposal of paper
sludge through combustion;
Uncontaminated topsoil;
Incinerator bottom ash;
Outputs from anaerobic digestate.
CONCLUSIONS
4.1 The Environment Agency is keen to promote
waste reduction as a business opportunity and not be seen as a
regulatory burden. We want to play our part in changing attitudes
towards waste and waste reduction in particular in accordance
with our vision that waste will be reduced and have the smallest
impact on the environment.
October 2007
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