A Waste Developer’s perspective on the Government’s Resources and Waste Strategy
The published “Resources and Waste Strategy” (PDF) is a 25 year aim to reduce the financial and environmental cost of UK waste and seeks to cause behaviour changes in house-holders, producers, carriers and end destinations.
This article focuses on the digital elements of the proposals, identify the risks & opportunities for both government and for the wider industry. Whilst a large proportion of the policy is on the general public with policies to tackle food and plastic waste, I’ll focus on Chapters 4 & 8 (Recording and Reporting of Waste Data).
At its most basic for, waste data is gathered, prior, during and after collection and then during the separation, aggregation and disposal phases:
1) What the waste is 2) Who produced it 3) Who collected it 4) Where it was taken to 5) Conversion of the waste into a new EWC code 6) End Destination depot / export location
For each of the above steps each one is covered within the proposals, but seeks to have a number of consultation processes before any action is taken.
4.2.1 Mandate the digital recording of waste movements, subject to consultation
This feeds into “8.1.5 Working with tech firms to develop innovative digital solutions for tracking waste”.
Currently the legislation states that individual waste movements must have a waste transfer note, and that waste collected data should be returned to the authority (e.g. Environment Agency) for a specific “reporting period” i.e. Quarterly Returns. The move to make digital the default should be seen as the first step in the process of having traceability and accountability for waste collection.
Previously have been attempts to digitise this process through the £1.4m eDoc system, which produces a compliant waste transfer note, with the ability for multiple signatures to be added to that transfer. The current InnovateUK SmartWaste competition from DEFRA is featured in the Waste Strategy which seeks to produce a system to “Record and Track waste through the economy”. I submitted an unsuccessful bid titled “Unification of Regulatory Authority Waste Carrier + Permit reference data”, in which I proposed creating a single public register and linking the two data sets in order to be able to validate a waste collection with its end destination. It is the ability to know that company X runs site Y that allows the tracking of waste data, I hope this suggestion will be taken forward.
- Create a standard data exchange specification for transmission of waste data
- Require a carrier to provide to the waste producer (in an electronic format) the details of the movement - to allow the producer to evidence their duty of care
- Require the transmission (including transport reference) of a waste collection + disposal between the carrier and the destination (and the subsequent return of the disposal reference back to the carrier and the weight / volumetric calculation of the waste to be transmitted back)
- Require the transmission of this data to DEFRA with 24 hours of the movement
These recommendations would allow the complete tracking of waste through the economy.
8.1.2 Moving away from weight-based targets and reporting towards impact-based targets and reporting, focusing initially on carbon and natural capital accounting
The construction industry already monitors its carbon impact and can use this data to determine the total movements occurred on a site, this can then be linked to the container type and total weight removed from site to determine the total efficiency of a site, which directly correlates to environmental impact (taking both energy required in transport and disposal of waste produced). It is understandable that weight based calculations miss out on light weight waste items (such as plastics), but so long as the initial classification, waste breakdown into constituent parts is accurately collected then the “best of both worlds” can be achieved. To achieve this the government could mandate the separation of mixed waste at transfer stations, however this would increase the overall transport carbon impact.
PAS402 should be mentioned at this point as a methodology for standardised reporting of waste data, notably utilising density in the conversion for volume to weight. I would advocate this being mandatory.
Currently the government CO2 calculation is based on either a full average or empty vehicle type, with a large spreadsheet used to extract a eCO2/kg figure. In line with the theme of this proposal it should be recommended that the vehicle manufacturers be required to provide a CO2 formula based on the weight carried. This could be combined with vehicle tracking data and the waste collected to more accurately provide a CO2 calculation for a movement, ideally after the transport has occurred.
4.3.1 Tightening the waste permitting regime by introducing financial provision
Once waste is collected it is often processed, aggregated and stored before being disposed of and this provision seeks to provide an insurance policy that if a site were ever to shut down that the cost burden of end disposal of the existing waste on site does not go to the tax payer. This would be done via monitoring of the total waste on site at a particular moment in time and should be seen as a welcome step as it allows DEFRA to use the waste movement data above to validate the theoretical waste on site, and ease the process of compliance spot checks.
Obviously there will be a significant cost burden on the industry and discourages the “playing the commodity market”. It would be wise to take other factors into account, such as on site compacting, segregated storage and location of pre-treatment piles reducing the risk payment.
For many UK residents fly-tipping is one of the most visual forms of waste movements
It is interesting to note that there is provision that the government can direct waste carriers to transport waste, which potentially could be enacted to ensure that fly-tipping is quickly dealt with.
- Carrier licenses to be linked with Vehicle Operator licences and vehicle registrations linked back to that carrier licence - This
- Carrier licences dependant on regular reporting of the end destination site used
- Spot checks for businesses advertising house-clearances that they are operating vehicles linked to that carrier licence
Waste exemptions + permits
Currently a waste exemption can be applied for as an “alternative” to a waste management licence, of which can be varied multiple times, have standard rules and exemptions applied to it. This hugely complicates the ability for a producer or broker to know the legal position of whether a waste site is able to receive or handle the waste. Knowing which sites in a local area can handle a specific waste stream allows for a more competitive and collaborative environment.
- Remove exemptions - move to a “Site permit with permitted activities”, each permitted activity can then have requirements.
- Site permits have an expiry date
- Site permits to include the types of customers and vehicles that can enter
- Public listing of “responsible person”
- Transparent compliance and enforcement regimes