Response to the Environment Scrutiny Panel Report on Waste Recycling 3 July 2007.

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A decision made (27/07/2007) regarding: Response to the Environment Scrutiny Panel Report on Waste Recycling Presented to the States on 3 July 2007.

Subject:	Response to the Environment Scrutiny Panel Report on Waste Recycling Presented to the States on 3 July 2007
Decision Reference:	MD-T-2007-0071		Exempt clause(s):
Type of Report: (oral or written)	Written		Person Giving Report (if oral):
Telephone or e-mail Meeting?			Report File ref:	I:Minister:2007:Ministerial Decisions:MD 00 Formal Response to Scrutiny – Waste Recycling
Written report – Title	Response to the Environment Scrutiny Panel Report on Waste Recycling Presented to the States on 3 July 2007
Written report – Author (name and job title)	William Gardiner – Director – Waste Strategy Project
Decision(s): The Minister approved the formal response to the Environment Scrutiny Panel following the publication of the Panel’s report on Waste Recycling presented to the States on 3rd July 2007.
Reason(s) for decision: To provide a formal response to the Environment Scrutiny Panel’s report.
Action required: Forward a copy of the Minister’s formal response to the Publications Editor at the States Greffe for distribution to the Environment Scrutiny Panel and all States Members.
Signature: (Minister/ Assistant Minister)		Date of Decision: 27 July 2007

Response to the Environment Scrutiny Panel Report on Waste Recycling 3 July 2007.

TRANSPORT AND TECHNICAL SERVICES

RESPONSE TO THE ENVIRONMENT SCRUTINY PANEL

REPORT ON WASTE RECYCLING

PRESENTED TO THE STATES ON 3 JULY 2007

17 JULY 2007

TRANSPORT AND TECHNICAL SERVICES

RESPONSE TO THE ENVIRONMENT SCRUTINY PANEL

REPORT ON WASTE RECYCLING

PRESENTED TO THE STATES ON 3 JULY 2007

17 JULY 2007

Ministerial Introduction

I have recently received the Environment Scrutiny Panel’s long awaited Report on Waste Recycling.

Despite the lengthy compilation, the Report is unfortunately bereft of any new evidence of relevance to Jersey , includes many unsubstantiated claims and merely revisits most of the old arguments that have been robustly addressed within the Solid Waste Strategy developed by my Department.

The Report again demonstrates the current Environment Scrutiny Panel’s poor understanding of the whole waste management process and its economics - focussing on the claimed potential of recycling - not its realities.

The Report concentrates on the collection of waste for recycling, but fails to deal with the crucial realities of sorting, bulking, transporting and reprocessing of collected materials in the Jersey context.

Of particular concern in this Report is the misleading information on the cost of recycling on Jersey which is substantial and is likely to increase in future.

My Department will continue to pursue the introduction of the sustainable services identified within the Solid Waste Strategy including working in partnership with the Parishes to increase waste recycling.

Deputy Guy de Faye

Minister for Transport and Technical Services

1.0 Summary

1.1 The Environment Scrutiny Panel has produced a Report on Waste Recycling that contains criticisms of the Solid Waste Strategy approved by the States on 15 July 2005.

1.2 Whilst there is much that is correct in the Report, there is also much that is misrepresented and misleading.

1.3 This response has been issued to ensure States members and the Jersey public are clear about the true potential for waste recycling on the island and why the approved Solid Waste Strategy still offers the best solution for managing the island’s waste.

1.4 This response is intended as a summary. A further document addressing the less significant findings within the Environment Scrutiny Panel Report will be provided to the Panel within the next three months.

2.0 Environment Scrutiny Panel - Main Recommendation

2.1 The Environment Scrutiny panel suggests that, within the Solid Waste Strategy:

A. waste arisings are overstated

B. recycling rates are seriously underestimated, and therefore

C. the amount of residual waste that will need treatment is unjustifiably high.

2.2 All three elements of the main recommendation in the Environment Scrutiny Report are fundamentally wrong.

A. “Waste arisings are overstated”

2.3 The Environment Scrutiny Report suggests that the Solid Waste Strategy is not based upon sound waste composition data. This is absolutely incorrect.

2.4 The Strategy is based upon robust household and commercial waste assumptions, two specific composition analyses of Jersey’s unique bulky waste (not acknowledged by the Environment Scrutiny Report) and a calorific analysis of the energy value of Jersey waste of unparalleled detail.

2.5 This is supported by regular reviews of waste growth on a material by material basis in a format that has now been advocated as best practice in the recently published English National Waste Strategy (2007). Added to this is the detailed knowledge of the content of the Jersey dustbin amongst our waste operatives through hands-on experience that is a result of the island’s unique constraints.

2.6 The Environment Scrutiny Report suggests that waste growth assumptions are overstated. This statement is not substantiated in their Report.

2.7 The Environment Scrutiny Report criticises the Solid Waste Strategy that assumes the waste will grow at 2.6% at first (in 2005), then fall to 1.9% by 2014 and 1.8% by 2024. The criticism is based upon the reduction in household and commercial waste observed in England over the last 5 years.

2.8 Jersey is different for the following reasons:

· Waste is still growing in Jersey – last year it increased by 6%. (The Environment Scrutiny Report misrepresents a necessary reclassification of waste as evidence of waste falling in Jersey).

· The Island Plan 2002 indicated that population was set to increase significantly in Jersey – an assumption reflected in the Strategy. If recent economic population growth scenarios are implemented the Strategy waste growth assumptions will be under-estimates not over-estimates.

· Where population is set to increase at a similar level in the UK, local authorities will not be revising their waste growth figures down and there are considerable financial safeguards in place to assist these authorities should they miss their waste targets.

· The examples of authorities with low growth assumptions in the Environment Scrutiny Report also have low growth or declining populations (Cornwall and Scotland). There are many other examples of waste strategies in the UK which assume a waste growth profile similar to Jersey.

· Only 60% of Jersey’s waste is similar to UK household and commercial waste. The remaining waste -which has been subject to specific waste analysis in Jersey - is the result of other commercial and industrial economic activity and is not expected to fall in Jersey.

· The UK have numerous other financial incentives that are causing waste to be reclassified out of the national waste figures that are not applicable in Jersey. These include Landfill Tax (currently £28 per tonne and rising by £8 per year) , Landfill Allowance targets and penalties (£150 per tonne), Packaging Waste Recovery Notes (PRNs) and Renewable Obligation Certificates.

· The Mayor of London is protesting to the European Court about the reclassifications of commercial waste out of the Municipal Waste figures. This might account for a significant proportion of the down-turn observed in English waste arisings.

· Jersey has no alternative waste disposal options. The residual waste facility must be sufficient to deal with all of Jersey’s waste growth as export of residual waste is not environmentally or financially sustainable and is against international agreements on waste movement.

2.9 The Department regularly reviews waste arisings (the last wholesale review was in February 2007) and adjusts its estimates on the basis of evidence.

2.10 There has been no evidence of reductions in waste growth in Jersey over the period since the Strategy was approved and all the evidence points to waste growth increasing above the levels expected in the Strategy.

B. “Recycling rates are seriously under-estimated”

2.11 The Environment Scrutiny Report makes obvious key findings about the benefits of recycling but makes many misleading statements about the benefits of deriving energy from waste.

2.12 The Department constantly reviews the opportunities for increasing and optimising recycling, reinvesting wherever possible to provide a sustainable and good value service for Jersey.

2.13 Before commencing any recycling service the Department ensures that there is actual environmental benefit, that all material collected for recycling will actually be recycled and that the service once started can be financially sustained.

2.14 This is vital to retain public confidence in recycling and ensures that a truly sustainable service is provided.

C. “the amount of residual waste that will need treatment is unjustifiably high”

2.15 The Department is following the internationally recognised waste hierarchy in delivering its Strategy by;

· promoting waste avoidance and re-use as the best option (The Department promotes home composting, nappy and furniture re-use and works with many other organisations to promote waste reduction)

· targeting a sustainable recycling rate of 32%

(This rate is an appropriate minimum for an island environment and is achievable over the long term. If a viable market for food waste can be found the target would be revisited, but - even with food waste composting and higher levels of recycling - the size of the residual energy from waste facility will not be significantly reduced because the calorific energy of the remaining waste will not significantly change.)

· recovering energy from remaining residual waste (the Bellozanne energy from waste incinerator, whilst unreliable and out of date, enables electricity to be generated from all residual waste.)

2.16 The Environment Scrutiny Report overlooks the fact that Jersey already hits all of the waste recovery targets set within the English National Waste Strategy (2007) - these being to recover energy value from 53% of Municipal Waste by 2010, 67% by 2015 and 75% by 2020. All of Jersey’s non-inert waste is used to recover energy value.

2.17 The Department considers that, given:

· the absence of any evidence that waste arisings will not continue to increase in line with expectations within the Solid Waste Strategy

· the possibility that population may increase beyond that projected

· the robust nature of the minimum recycling rate set within the Strategy

· the fact that increasing recycling to higher rates will not significantly effect the calorific energy value of the waste requiring disposal

· the distinct possibility that additional waste may have to be dealt with (for example 10 - 12,000 tonnes of treated sewage sludge)

· the absence of any alternative facility to deal with the island’s non-inert waste, and

· the operational life of the proposed Energy from Waste Facility being extended as a result of waste tonnages growing more slowly or the Department’s recycling rate being exceeded

there is no justification for the Environment Scrutiny Panel’s claim that the amount of residual waste that will need treatment is unjustifiably high.

3.0 Recycling targets

3.1 The Environment Scrutiny Report compares the new (May 2007) English National Household Waste Re-use, Recycling and Composting target against the Jersey target that applies to all waste (commercial and household). This is a misleading comparison.

· The English target is a national aspiration. Individual authorities will set targets appropriate to their local circumstances, as has been done in Jersey.

· The English National Waste Strategy now proposes targets to include assumptions for how much waste is re-used and composted at home. Jersey could include these elements to artificially increase its “recycling” rate - but the Department sees no real benefit in doing so, as these are not what the public understand by recycling.

· If a like for like comparison were to be made, the Jersey recycling target figures would be much closer to the English targets because the UK does not recycle so much commercial waste.

· The English National Waste Strategy targets depend heavily on the composting of food waste – waste for which there is no current market on Jersey (see below) and on kerbside collection – from 2010 all English authorities will be legally required to operate kerbside recycling schemes.

3.2 The Environment Scrutiny Report also misrepresents and misinterprets much of the information provided by the Department. These misrepresentations could have been corrected had the Environment Scrutiny Report’s authors clarified their claims with the Department.

4.0 Collection methods

4.1 The Environment Scrutiny Report makes brief mention of the Zero Waste trial undertaken by the Parish of St Helier.

4.2 This trial is welcomed by the Department for the following reasons:

· The Solid Waste Strategy indicates that door to door collection services will be needed to achieve the recycling rates indicated.

· The Zero Waste trial and other trials provide useful information on participation levels and capture rates.

· The trial reinforces the Solid Waste Strategy assumptions achieving similar rates for diversion of recyclables to the levels targeted in the strategy.

· It increased the awareness of recycling amongst a small group of residents in St Helier.

4.3 But the Department has the following concerns:

· The trial claims to have achieved a 56% recycling rate – this falls far below the figures claimed as sustainable by members of the Environment Scrutiny Panel in public (90%) or implied within the Environment Scrutiny Report (70%).

· The rates achieved followed a uniquely intensive campaign that would not be sustainable across the island

· Unfortunately due to the way the collection was run, the 56% was only a “capture” rate not a true “recycling” rate.

· As far as the Department is aware only some of the cardboard and some of the glass from the St Helier “Zero Waste” trial has ever been actually “recycled” into new products. The rest has either been incinerated or rejected as unusable and disposed of.

· Both the Zero Waste trial and Environment Scrutiny Report seriously underestimate the costs of recycling (see below).

4.4 Unfortunately, the Department has yet to be consulted by the Parish or the Environment Scrutiny Panel about the trial and therefore it has many queries about how the performance figures and costs have been presented.

5.0 Recycling opportunities

5.1 The Environment Scrutiny Report makes many inaccurate statements about the recycling services that are already offered or are in the process of delivery by the Department.

For example:

Misleading claim	Evidenced response
“there are no facilities for recycling plastic for households”	The new re-use and recycling facility at Bellozanne has such facilities. The Solid Waste Strategy includes a commitment to introduce a high grade plastic collection scheme and plastic bottles will be collected within the enhanced “bring” bank scheme during 2007.
Misleading claim	Evidenced response
“households have no opportunity to separate metal from their domestic rubbish”	The door to door collection service supported by the Department in the Parish of St John gives such an opportunity. The new re-use and recycling centre means all residents can now easily recycle metal. There are 80 aluminium can recycling collection points already provided around the island and the new mini recycling sites being rolled out by the Department will all have such facilities in accordance with commitments within the Solid Waste Strategy. A metal skip has been in place at Bellozanne for many years.
There are no organised facilities for the recycling or re-use of domestic wood products.”	The new re-use and recycling facility at Bellozanne has such facilities.
Household hazardous wastes “there should be separate facilities to deal with these products”.	Such facilities have been available at Bellozanne for many years. There are 10 household battery collection points around the island. The new re-use and recycling centre includes a collection of Waste Electrical and Electronic Equipment.

5.2 The Environment Scrutiny panel have failed to recognise the very substantial recycling improvements achieved by the people of Jersey using the Department’s services since the Solid Waste Strategy was approved.

5.3 The amount of recycling tonnage collected has increased by almost half again (45%) since 2004.

6.0 Recycling costs

6.1 The Environment Scrutiny Report claims that high recycling rates can be achieved by relatively small increases in collection costs. This is simply not true.

6.2 The Environment Scrutiny Report and Chair of Environment Scrutiny claim that there is between £1 and £3 million of income within the waste stream.

6.3 This assumes that 100% of the waste of value in the waste stream is recycled and makes no allowance for the cost of collection, sorting, bulking, transporting and finally reprocessing the waste into new products.

6.4 The claim that there is £3 million of potential income in the waste stream is meaningless and could mislead the public and States members into thinking that there is money to be made from recycling in Jersey.

6.5 The Department has significant experience of true recycling over many years and unlike the Environment Scrutiny panel has the benefit of actual tendered and market tested costs for collecting, sorting, bulking, transporting and reprocessing waste to inform its recommendations.

6.6 For example, the cost of collecting, transporting and reprocessing a single fridge in Jersey is approximately £15. The cost of doing the same in England is approximately half (£6.20 - £8.50).

6.7 With the exception of aluminium cans and high quality office paper, there are no materials within the waste stream that are or could currently be collected for recycling that would not require a financial subsidy from either the States or the Parishes or both.

6.8 In the case of the materials particularly promoted by the Environment Scrutiny panel which are not currently proposed for collection by the Department – for example, kitchen vegetable wastes, mixed plastics and mixed wood - the costs of recycling to the Parishes would be substantial.

6.9 A table of market-tested costs for recycling different materials is included as Appendix 1 to this response. This demonstrates the significant costs that the Department outlays to support recycling but excludes the cost of collection which is the highest element of cost.

6.10 The collection costs included within the Environment Scrutiny Report are misleading. The Report quotes high-recycling English local authority costs of collection per household, but these are total figures for all waste collected.

6.11 The actual costs of recycling collection from an English Government Report this year are less attractive:

Table 1. Summary Kerbside Collection Costs
	Average (£/t)
Refuse	33.8
Co-mingled	64.0
Glass	158.0
Paper	105.8
Sorted Dry	149.8
Green / Garden	74.6

Source: A Department for Environment Food and Rural Affairs Report published in March 2006, detailing the experiences of household kerbside collections for twenty Local Authorities receiving funding from the National Waste Minimisation and Recycling Fund.

6.12 It must be remembered that these are UK figures for collection only and exclude the additional costs of bulking, sorting, and the unique transport costs in Jersey from shipping waste for recycling set out in Appendix 1.

6.13 The Environment Scrutiny Report gives indicative costs for shipping waste. Unfortunately, these costs are misleading. For the bulky materials that the Environment Scrutiny Panel wants to target for recycling, the costs would be significantly more expensive. The Department has market tested costs that confirm this.

6.14 The Environment Scrutiny Report suggests waiving Harbour dues on recycled wastes. Whilst this is a matter for the Minister of Economic Development, the Department acknowledge that this would provide a modest incentive for recycling – but the overall cost of recycling to the people of Jersey would be the same.

7.0 Food Waste

7.1 The Environment Scrutiny Report and Parish of St Helier Zero Waste trial again raise the recommendation that separate collection of food waste should be re-evaluated.

7.2 The Solid Waste Strategy requires the Department to regularly review the option of food waste collection and the Department acknowledges that food waste composting would potentially increase the recycling (and composting) rate to close to the 50% rates now targeted by the UK National Waste Strategy.

7.3 Unfortunately, the Environment Scrutiny Report, the Environment Scrutiny Panel and the Working Party into Composting did not consider one crucial matter – the fact that there is currently no beneficial use for composts derived from composted food waste on Jersey.

7.4 The Department provided crucial evidence to the Environment Scrutiny Panel and Working Party on Composting which indicates that the supermarkets, who require Jersey farmers to follow strict protocols for what is spread to land used for growing food, will not buy produce from those farmers who spread waste derived compost on their land – whether this meets defined waste standards or not.

7.5 Until this changes, the view of the Department will be that set out within the Strategy in 2005. Food waste composting is not currently a sustainable waste management option on Jersey.

7.6 Even if it was possible to return food waste compost to land, the costs of this would be substantial as a separate food waste collection system would be required, along with additional in-vessel composting capacity than is currently proposed within the Solid Waste Strategy, and further subsidy to encourage the use of compost on land than is currently paid for the use of green waste compost.

7.7 The Department currently has to pay a subsidy of approximately £2 per tonne to dispose of green waste derived compost to agricultural land. The Department do not believe that the additional risk of spreading food derived compost to land would be at lower cost even if this met UK product standards.

The Minister of Transport and Technical Services Response to Recommendations within the Environment Scrutiny Panel Report on Waste Recycling.

Environment Scrutiny Panel Main Recommendation

The Environment Scrutiny Panel strongly recommends that T&TS take the opportunity to review the estimates of both waste arisings and recycling rates for the period of the strategy. The Panel believes that the residual waste arisings estimated in 2005 for the next 25 years are seriously overstated and that recycling rates are seriously underestimated. This combination leads to an estimate for residual waste that is unjustifiably high.

Ministerial Response

The main recommendation is not accepted as the waste growth and recycling rate assumptions presented in the Environment Scrutiny Panel Report are unrealistic.

Other Recommendations