Freepost
Defra Waste Strategy Review
Freepost SEA 12430
Thornton Heath
CR7 7XT
May 6 2006
Dear Sir or Madam
Please treat this
letter as my response to the consultation on Englands Waste Strategy.
Q1 I call on Defra to:
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give more weight to waste separation,
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to base all parts of the waste strategy
on a sound understanding of waste composition so that facilities are matched to
waste materials,
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to show leadership in setting waste reduction
targets for all sectors and
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to
ensure that incinerator-free options are made available to communities. Anaerobic Digestion, which fared well in
assessments, and generates energy, is being ignored.
The way incineration and fuel for incinerators are being
favoured and promoted troubles me.
Q2 I consider that the new national recycling
and composting targets should be at least 60% by 2025.
Q3 I believe very strongly that municipal
waste recovery targets should be scrapped.
If a) recycling and composting targets and b) targets for diverting
biodegradable waste from landfill are met, recovery rates will have to be
high. To set an arbitrary recovery
target will simply serve to restrict options as to how these other more
important targets are met. For example,
the draft recovery target for the South East of 84% recovery would rule out
technologies such as Anaerobic Digestion that the South East Plan itself
advocates as good environmental options!
Q5 I am worried by the suggestion that you
might encourage some waste recovery by exempting it from needing a
licence. Public confidence in
regulation in the waste sector is already low.
Q10 Yes, there should be a lot more effort to
encourage waste prevention as well as promotion of recycling. There needs to be a high profile advertising
campaign, on a scale with that used to encourage wearing of seat belts, to
promote waste prevention and recycling.
The importance of separating food waste, which cleans up the bin, should
not be underestimated in changing attitudes to recycling.
Figure 9 is missing a
key motivation. Many people are changing their behaviour when it comes to waste because
they want to avoid incineration.
Avoiding undesired consequences is a key driver that can be harnessed to
change attitudes.
Q13 A major information gap is ignorance about
waste composition. For example, the
composition of waste remaining after 60% recycling has been achieved is needed
to determine the most appropriate treatment facilities. There is also a need for research into MBT
configurations that avoid incineration.
Best options should be established for various waste compositions. This will offer an effective alternative to
incineration that also meets targets.
Q15-18 Reducing the built-in obsolescence of goods
should be encouraged, as should the potential to upgrade rather than replace
products.
Companies such as
supermarkets should be given compulsory targets for reducing the amount of
waste they produce, particularly waste which cannot be recycled or composted.
Q22 An
effective way to engage consumers to reduce waste would be to offer
incinerator-free waste management options if they play their part.
Chapter 5: I disagree with the following from the
summary and consider that:
-
incineration
should not be encouraged as part of energy recovery
-
while unclean, unsorted landfill is
bad, landfill of clean, biostabilized material could be a good environmental
option
-
composting, including home composting,
should not be overlooked given that 68% of waste is biodegradable.
Challenges listed
should include failure to develop
environmentally sound options that respect the strong public aspiration in some
communities to avoid incineration.
It is notable that while incinerator industry concerns are
acknowledged, legitimate public concerns about incineration are dismissed as
misguided. Community partnership based on an incinerator-free approach could be a
very strong motivator in meeting targets.
Q24 I believe strongly that Local Authorities
should have waste separation targets to promote this vital stage in managing
waste to recover resources. Communities
should also have waste prevention targets.
Q25 All communities should be expected to play
an equal part in achieving national waste prevention and recycling
targets.
Q26 I am shocked by the section on recovering
energy from waste. This completely
disregards Anaerobic Digestion (alone or as part of MBT) even though it comes
out very well in assessments, produces energy (gas) and heat and it would
prevent methane- generating landfill.
The fact that Austria has already met its landfill avoidance targets
with no more incinerators than the current UK level, and that Spain is opting
for AD, should be explored. The fact that
with a recycling rate of 31% Hampshire no longer generates enough black bags
for its incinerators is a recent reminder that flexibility in waste treatment
capacity s required rather than relying on large facilities.
I am deeply unhappy that the Government is suggesting
incineration (EfW) should be expanded from about 10% to 25% of waste treatment
capacity and will be considering financial and other support to deliver these
facilities.
Q28 A place for well-managed landfill of clean,
bio-stabilized or separated material should be recognized. This place would be after maximum recycling,
composting and biological treatment have been achieved.
Q29 Delivery of waste facilities could be
speeded up if technologies with greater public acceptability, and that make
better neighbours, were used. Defra-funded research and assessments have
shown that incineration is not necessarily the best option. This finding needs to be fed through into
policy. EG Entec study for Surrey Local
Government Association.
Q38 I strongly support moves to improve facilities for taking hazardous materials out of household waste and wish to see public education about the consequences of putting hazardous materials such as batteries in mixed waste.
Yours Faithfully
Additional comments
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