Ray Parmenter, FCIWM, Head of Technical and Policy
The date was the 18th October 2023, the time was 9am and Sir John Armit approached the lectern and announced the publication of the National Infrastructure Commission’s second National Infrastructure Assessment. It started like so many of these events do with the big stuff; power, water, transport, etc. but very early on in his opening speech Sir John made mention of the stagnating [English] recycling rates. This was music to my ears, at last we were getting noticed I thought, albeit in not a very positive light. However, later on Prof. Jim Hall devoted about four minutes to our sector and there was even a question from the floor on energy from waste.
So what, you may ask is the NIA2 and why is it such a big thing? Well it’s a Plan that sets out the UK’s infrastructure needs for the next thirty years, things like energy, transport (both road and rail), water and wastewater, flood management, digital and now waste. It makes recommendations to the government about where and when these need to be built and estimates how much (in very broad terms) these will cost. This second assessment sets out three challenges for UK infrastructure:
• Decarbonising energy and achieving net zero emissions
• Supporting economic growth across all regions
• Improving climate resilience and the environment (including waste)
I’m sure, like many of you are, that the inclusion of the [resources and] waste sector in the NIA2 is a refreshing change, given that it was missing in action in the first assessment published in 2018.
The Commission’s recommendation number 36 calling on the government to accelerate progress towards 65% recycling by 2035 and to stop procrastinating and delaying the implementation of the recently renamed ‘simpler recycling’ initiative will be applauded and supported by many in our sector.
The Commission’s call for implementation of ‘simpler recycling’, is something we have all been calling the government to do for well over a year now and all we get back in reply is “soon”; how much longer do we need to wait for this? The Commission points both to the successes in Wales of their collection reforms and the potential (government acknowledged) failure of England’s attempt to reach 65% by 2035, even with the implementation of the current set of Collection and Packaging Reforms, which is often know by the acronym CPR; unfortunately the acronym is also used in emergency healthcare sector, rather ironic methinks.
One only has to look at Wales to see the benefits of a clear policy direction and comprehensive collection system, backed with financial and technical support to see how to do it. Wales started this journey in about 2010 and have gone well beyond the English governments 65% target in just 13 years, so to admit defeat in England even before we start is perplexing, because we still have about 12 years to get this done, but we must start now, not ‘soon’.
Wales has another advantage in my opinion and that is combined waste collection and disposal authorities, (i.e. single tier) and perhaps England ought to look at this, it was after all said at the launch event on Tuesday that many of England’s local authority boundaries date back to medieval times and if we were started again from scratch we perhaps would do it differently.
The Commission’s call for better data on the composition and fate of resources and waste is without doubt a given, because without robust data it will be nigh on impossible to create the right infrastructure in the right place. This is especially the case for commercial and industrial waste, as recognised in the NIA2 and I would urge the government to progress digital waste tracking as a priority.
The Commission’s recommendation number 37 calls on the government to create stronger incentives for investment in the recycling infrastructure that will be needed in the future, and recommends that the building of new energy from waste (EfW) plants that are not carbon capture and storage ready is a really bad idea and that no local authority should sign up to such a deal. This recommendation also calls for EfW to be included in the UK Emission Trading Scheme by 2028 and that landfill tax should keep rising to ensure that landfill is always more expensive than EfW, all of which makes perfect sense.
However, it also somewhat debatable (and here I’m going to be controversial and many may not agree with me), that the carbon impact and the places on the waste hierarchy between EfW and landfill are not as black and white as the Commission paints. This is especially the case when you consider the disposal of biogenically derived waste such as paper, card and food waste, EfW could be a better overall environmental option and could lead to a positive carbon outcome by emitting biogenic carbon back into the atmosphere to be reabsorbed by plants.
Whereas landfilling unrecyclable plastic waste, which is almost exclusively derived from oil and gas (i.e. fossil), burying it in a landfill might be a better environmental outcome as it locks that carbon away (e.g. a carbon sink). Perhaps therefore rather than using the blunt tool that is landfill tax, we have a more nuanced tax system that recognises this differential; I said earlier I was going to be controversial, you were warned.
Back to the launch event on Tuesday and a question was asked of the panel about EfW and Carbon Capture Use and Storage (CCUS), the nub of which was, what about EfW plants that are not or cannot be located near to the proposed CO2 pipelines, how can they decarbonise? The answer back from the panel baffled me a little bit, because they suggested only two options; tanker it away or relocate the plant nearer the pipeline. The former to my mind makes no sense, because of the transport emissions, at least until road and rail transport has been fully decarbonised. The latter showed something of a lack of understanding of the purpose of waste infrastructure, in that it serves local needs, and by relocating the opportunity to develop domestic heat networks from EfW plants could be lost, somewhat negating another part of the NIA2 recommendations about public engagement and benefit.
However, there is much that is missing still and I was disappointed to note that the much of the good work by some operators on biodiversity has not been recognised, especially those projects that have created thriving ecosystems on restored landfills. It was also disappointing that the contribution that the resources and waste sector has made to renewable energy over the last few decades went largely unrecognised, I’m speaking here about landfill gas and EfW contributions to the electricity grid and EfWs contribution to district heating in some parts of the country.
There was also much talk about coastal flooding but no mention of the enormous risk that our marine ecosystems face from coastal landfills washing out to sea, which given that many of these were constructed in the 60’s and 70’s as sea defences would be ironic if it wasn’t such a tragedy in the making.
It was also in my view somewhat disingenuous to say that the sectors GHG emissions are not declining, given since 1990 they have reduced by half, largely because of the EU Landfill Directive and the imposition of the landfill tax, but as recognised by the UK Climate Change Committee in their 2023 report to Parliament this reduction has now plateaued and beginning to rise again because more waste is being incinerated.
To wrap up this ramble, the government has six months to respond to the Commission on this second assessment, but Sir John did recognise that the impending election in 2024 may get in the way of that response, but rather than wait he hinted that a sensible government should look at including much of this infrastructure assessment into their manifesto. I for one hope all parties will heed this advice, because without adequate, reliable and resilient infrastructure I believe that the UK will be left behind, and I don’t believe anyone wants that.
So, my final thought is to quote Monty Python from the Life of Brian - what have the Romans ever done for us?
Infrastructure of course!!