|NATIONAL WASTE STRATEGY: SCOTLAND|
The Royal Society of Edinburgh (RSE) is pleased to respond to the Scottish Environmental Protection Agency’s (SEPA) consultation on Scotland’s National Waste Strategy. The RSE is Scotland’s premier Learned Society, comprising Fellows elected on the basis of their distinction, from the full range of academic disciplines, and from industry, commerce and the professions. This response has been compiled with the assistance of a number of Fellows with direct experience of environmental and waste management issues.
At first sight the title of the document appears to be offering a comprehensive treatment of the issue of waste management. It was disappointing, therefore, to discover that the scope of the document (para. 1.4) was limited, with subjects such as radioactive wastes and discharges to air and water only mentioned in passing. Their omission is especially surprising given the references to air and water in Table 1, Schedule 12, Objectives (para. l. l0), and SEPA’s recent launch of its report on Improving Scotland’s Water Environment. A National Strategy should be integrated and include the disposal of radioactive wastes (an important category in the Scottish context), the critically important subjects of liquid and gaseous wastes (the most dynamic and potentially hazardous categories) and all waste releases to the hydrosphere and atmosphere (including rivers, lochs/lakes, estuaries, seas and oceans). Another important factor, which a National Waste Strategy should include, is a strategy for the environmental monitoring, impact assessment and auditing of waste disposal sites to ensure their compliance with acceptable and pre-defined risk factors to humans, flora and fauna. The Society would advocate the inclusion of the above areas for a comprehensive, forward-thinking strategy for Scotland.
The topics addressed in the document are, however, covered comprehensively, well researched and include sound proposals for future strategies and actions. If eventually fully implemented, these could be of very significant benefit, not least in achieving economies in resource use and reducing adverse effects of waste disposal on the environment. The key to achieving the outlined strategies, however, will be to convince all sections of the community of the need for change with a series of success stories to sell the concepts. Simply highlighting EU legislation will not be sufficient in itself and the document could give greater emphasis to the important requirement to educate business and domestic waste-makers on why change is essential.
The specific questions raised in the consultation document are addressed below:
Question 1: Landfill capacity (p.9)
Do you consider a rolling 5-year future licensed landfill bank to be adequate?
Probably yes, as a rolling policy there should always be a minimal five year’s capacity coming on stream. However, the capacity must be sufficient to meet expected demand, which should gradually decrease as waste re-use strategies come into operation. In creating this capacity, however, a five year rolling programme might be too tight a timescale, given the need to identify suitable sites, allow time for purchase, obtain planning permissions, and establish acceptable infrastructure requirements, for example, roads. In this respect, perhaps a 10-year perspective would be a preferable time frame for a sustainable long-term policy.
Should different provision be made for different types of landfill operation (bio-degradable/inert)?
Yes, different wastes will degrade at different rates and for planning purposes the separation of wastes into half-life categories would be sensible, as would separation based upon chemical, physical and biological properties, potential leachability and potential environmental impact. This could influence the period of use and re-use of sites, and be valuable if the treatment of one type of waste was cheaper than another.
Should this forward capacity be maintained on an area by area basis or as an all Scotland average?
Waste production is generally a function of population size and will vary considerably between areas of high and low concentrations of population. It will also depend on types of industrial and commercial activities. It is, therefore, concentrated in specific areas which will normally require local solutions. An area-by-area basis would be preferable for non-hazardous wastes to avoid excessive transportation. However, specialised central disposal sites will be necessary for more hazardous disposals.
Question 2: Additional Statutory Powers (p.27)
Do you consider that additional statutory powers as discussed above will be necessary to ensure the strategy is made to work effectively?
Yes, the additional powers will be necessary if the objectives set out in Table 1 (para. 1.4) are to beachieved throughout the country. Reliance on market response and the voluntary principle is likely to be inadequate, or at the best patchy, and there will be many reasons and ways used by the producers of waste to slow down implementation of the strategy. By having a strong and effective regulatory system this will be minimised.
Are there any additional powers that you consider may be necessary?
In addition to those additional powers identified in the draft strategy, SEPA should have powers to ensure environmental survey, monitoring, assessment and compliance by an independent body or bodies.
Do you consider a target trading mechanism between the different areas of Scotland could be an effective and flexible way of achieving the targets nationally?
It could be argued that a target trading mechanism misses the point of the exercise, in that by permitting an area to exceed its target it thereby fails to establish the culture intended by the strategy for that area. Target trading would also be complicated by the trans-boundary movement of liquid and gaseous discharges and because many hazardous wastes will require centralised or regional disposals.
The operation of any target trading mechanism would need to include a compliance and environmental policing component to ensure that no credit was given to disposers who generated low audited environmental health impacts. It would also need to be expensive enough to ensure that trading was not a soft option chosen by a particular Authority in preference to positive action to implement locally agreed strategies.
Question 3: Targets (p.34)
Is the range of targets in Table 5 appropriate?
The targets seem to be realistic and, if adhered to, should make an appreciable difference. The costs of meeting these targets, however, are likely to be substantial. Most of these extra costs will fall on local authorities and for the targets to be met local authorities must be allowed the resources to meet this cost, either by central funding or by local levies on domestic and commercial waste makers.
Are there any additional targets you would consider necessary?
The strategy should include integrated targets for gaseous, liquid and solid waste disposals to atmosphere, hydrosphere and land, as well as for the crucial area of radioactive wastes. There should also be independent environmental monitoring, audit, impact assessment and compliance-proving targets.
Question 4: Waste Strategy Areas (p.40)
Do the areas outlined provide an adequate basis for strategic waste planning in Scotland?
Waste Strategy Areas should be based around existing Local Authority Areas to minimise administrative difficulties and arguments over allocation of costs. Ideally there should be fewer areas than those outlined, thereby increasing the possibility of more uniform procedures and strategy implementation. However, in practice it might be necessary to increase the number, or at least to redraw some boundaries. For example, the proposal to include Scottish Borders with connurbationsin the Central Belt is likely to prove problematic, given the disparity in volumes and types of waste involved and thus the differing methods and scale of waste disposal required. Perhaps the Borders would be better grouped with Dumfries and Galloway in this regard. On the other hand, perhaps Fife could be included in the Stirling, Clackmannanshire and Falkirk Waste Strategy Area (WSA). In identifying these areas it would be useful if Table 6 indicated the areas and populations of the WSA’s.
Should there be fewer or more areas?
As noted above, there should ideally be fewer areas to increase the possibility of more uniform procedures and strategy implementation.
Question 5: Priority Waste Streams (p.43)
Do you consider that the principle of studying specific waste streams in terms of their specific requirements is a useful way forward for certain wastes?
Yes, the principle of studying specific waste streams is a good one as no general solution is likely.
Additional waste streams which would require specific attention at a national level include high level radioactive wastes and toxic chemical wastes such as sheep dip.
Question 6: Landfill Tax Credit Scheme (p.49)
Could improved value in support of the strategy’s objectives be gained from the landfill tax credit scheme?
The Landfill Tax Credit Scheme is a valuable source of support for environmental improvement measures. It could, however, be further developed and improved. For example, the Tax Credit could work in both directions. Tax Credits, as described, could be given to landfill operators, but more importantly perhaps, additional credits could be awarded to those disposing of waste to reward efficiency, re-use, good practice, etc. It would also be important to build in environmental monitoring, audit, impact assessment and compliance-proving into the credit system.
In terms of supporting the strategy’s objectives, a proportion of the Tax Credits obtained could be targeted on relevant research projects in support of priority waste stream projects and basic fundamental work in these areas.
Question 7: Research & Development proposals (p.52)
Do you consider the R&D activities indicated here are appropriate to support the development of the strategy?
Substantial further research is required along the lines indicated and it is to be hoped that SEPA will be very active in influencing and promoting this. There is a clear case for UK-wide collaboration on these R&D topics and the statements in 4.74 (page 51) are welcome as recognition of this. While the topics listed are all worthy of support, with limited funds available some prioritisation may be necessary with research into BPEO Methodology Development, Promotion and Education, Clean Technology and developing incentives for waste producers being particularly relevant.
What additional issues do you consider important for R&D in the future?
Additional important issues for R&D include:
Further information is available from the Research Officer, Dr Marc Rands