Building a Sustainable UK Recycling System

I want to concentrate on the regulatory landscape around waste disposal in the UK. What’s your opinion about the implications of national policies on the system?

It’s more difficult to talk about on a global level, although there’s a direct correlation with the waste which is produced and if there’s opportunities to do something smarter with waste by exporting it then, if it makes economic and environmental sense then why wouldn’t you do that.

But if you look at it on a national level, the reason why landfill is still prevalent in the UK waste market and will continue to be prevalent in some form or another for the next 15-20 years, is because landfill tax has done what it needs to do. It’s encouraged the diversion of waste away from landfill and putting it into other treatment technologies. It’s changed the behaviors of commercial and municipal customers in terms of segregating waste which is recyclable. What makes the capacity gap more difficult to fill is that it’s very difficult to obtain planning permission for an energy-from-waste facility.

There are some obvious cases around, there is a planning application for an energy-from-waste facility in Waterbeach in Cambridgeshire. I was involved with that application. When it went to planning it had officer recommendation for approval, but when it was put in front of members of the planning committee it was rejected on the grounds of impact on local heritage and visual impact in the local area.

Putting that aside, there are arguments for and against the facility in that particular location, but it was already identified in the local waste plan as a potential site, it sits alongside a mechanical/biological treatment site and also a landfill site. It would make a logical place to put it, but local councilors rejected that proposal. It’s now in appeal and going through judicial review and been called up for the secretary of state for the environment to make a final decision on. Which coupled with the fact that there’s a General Election, who will be the secretary of state for the environment for the new year, who knows?

So, the process itself is very difficult to secure these facilities and if you want to build a facility of any particular scale (for example 500,000 tons and beyond), you’re then applying directly into central government, bypassing the local authority planning process. Because it’s a significant infrastructure project the time it takes to get that planning approval is delayed further. From concept to taking a development site where you go through the initial designs, work through technology, look at the processes you have to go through for planning, that can be anything between 3-5 years just to obtain planning for the site. Before you start to build and get it towards the construction work that you have to go through. The time it takes to build these facilities from planning to service commencement is significant and that’s a real challenge. Some of the capacity gap we face is because I don’t think the planning process in the UK lends itself to trying to develop these facilities without huge amounts of bureaucratic process to go through.

So, the landfill tax has done its job and diverted waste away from landfills to encourage investment into recycling facilities and energy-from-waste facilities but the planning permission hasn’t kept pace with that change in the market?

I think the planning process is the same, I don’t think it’s changed, but it’s just that nobody wants one of these facilities in their back garden. Fundamentally, they have to go somewhere and unfortunately to make them economically viable they need to be built in locations which are not requiring huge amounts of transport to take waste from where it’s produced to where it’s processed. I think the challenge is more about the clumsiness of the planning process rather than it being anything that’s obstructive. I think it's a process that’s very bureaucratic and it’s a process that can take a long time and come across numbers of delays. Veolia have had this challenge in Hertfordshire, they’ve had two planning applications turned down for two different sites and Hertfordshire are now faced with the challenge of having no long-term arrangements in place for processing their waste. It’s been very much a consequence of the planning process.

What’s your view on the implications of the Chinese purity rules on UK exported waste?

I think that a lot of waste was being exported from the UK in the guise of recycling, it was being exported but it was heavily contaminated. I think we have a moral duty to make sure that any waste that we do export for processing overseas is prescribed correctly and is of a level of purity so that the reprocessing can be undertaken cost effectively and efficiently without huge amounts of contamination.

I think it’s unfortunate that China has to impose some of those rules but it could have been any country that was accepting waste for reprocessing. The issue here is about having the markets available to reprocess recyclable waste. Whether that comes down to legislation making sure you’ve got a minimum amount of recycled material in every form of packaging (e.g. 25%, 30%, or 40%). There’s a need to create internal markets, a Deposit Return Scheme would be a good way to try and get funding back into developing these markets for recycling and reprocessing. I think there should be extended producer responsibility, one issue is that we buy goods in packaging that can’t be recycled, but at the moment there is little or no consequence on the producer for that. But actually, if the producer can be responsible about the types of packaging which users buy with extended producer responsibility, then that would make some sense.

The issues of the purity rules with China are much wider than it being an export issue. The reason that waste is having to go offshore is simply because we don’t have the internal markets driving demand for recycled products. That’s got to be legislation that drives that change.

You’re suggesting that we should start with the producer of the material, so the consumer-packaged goods companies that don’t use a very high percentage of recycled waste in the packaging?

I think that has to be the starting point, but in reality, what it comes down to is the fact that we need internal markets in the UK and we need legislation that requires producers to have a percentage of recycled or recovered product material within their packaging material of choice. So, if it’s cardboard based packaging it could have 50-60% of recycled content. The same for plastics. Metal, to a lesser extent because it’s easier to recycle metal. Likewise, with glass, rather than trying to reprocess glass, maybe we revert back to some of the processes we saw years ago such as returnable milk bottles and drinks containers which are sterilized and re-used. I think that legislation has to drive that change and drive the markets.

Biffa was recently fined for exporting contaminated waste to China which didn’t meet the new impurity guidelines. Can you outline the challenges the waste management companies have in balancing the recycling margin and meeting the regulations required?

I think Biffa were unfortunate in that situation because that level of contamination in the waste was argued by Biffa to be a one-off. But you could argue that any waste operator or exporter could have found themselves in a similar position. What has happened over the years is you’ve seen the quality of materials that were acceptable at one point has changed and as a consequence of that, there is a misunderstanding around what exactly the level of purity required is. It comes down to having standards and some guidelines around what is a ‘pure’ recyclable material, what does it look like, in terms of whether plastic, metal, fiber based, what is the level of purity and does everybody have that same level of understanding?

The purity issue with China means the price that you receive for recovered materials has dropped significantly, some of that material is probably going to landfill or thermal treatment because there aren’t any external markets for it. The other challenge is that when you start to think about the markets that could be created for it, what does that purity need to look like? There is a total lack of understanding around what that purity looks like.

As soon as that material is exported to other countries who may accept it, are you just moving the problem? That’s my concern. Fundamentally what you have to do is create internal markets or create a demand for this material at the right level of purity. If it’s there and in the UK and avoids all of that hassle of transferring to your shipments, transport and additional logistics cost. If you’ve got something UK-based where the processing takes place onshore, then it’s probably better to get some clarity around what that material looks like but it’s very much dependent on the market.

So there needs to be guidelines from the policymakers in terms of what purity means, or guidelines on those materials and what percentage of recycled material is expected?

I think some of that clarity is out there, people generally know when material is contaminated and what’s acceptable and what’s not. But I guess the one thing that we still lack is having markets which demand some recovered content to be blended or used with virgin materials, in order to come up with packaging or alternatives to the types of goods and packaging we buy at this moment in time. That’s got to be driven by legislation which requires a certain percentage of recovered material to be included. But it also has to incentivize either the producer or the end user to want to have that type of material. That comes through having these internal markets and you have to create those internal markets.