Following extensive consultation, Scottish Government has set out a Policy Statement that will underpin the final form of the Zero Waste (Scotland) Regulations that will be laid before the Scottish Parliament.
The main changes from our consultation in January 2011 are (policy statement in italics):
· A refined timetable that will drive forward the changes needed to meet the Zero Waste Plan and our recycling targets, while also providing sufficient lead-in times for local authorities, businesses and other waste producers. This includes moving the requirement for small businesses to recycle their food waste to 2015;
This requirement will potentially have a significant impact on certain business sector particularly cafe, restaurant, and hotel businesses in rural communities. Businesses will either need to consider having a treatment method on site or rely on a waste collection system. The collection system is liable to increase cost as food waste will need to be collected weekly. Also in this sector they will also need to put in place system for segregating food waste from other wastes for examples plates, cups etc. This may prove difficult in cafeteria type establishments which rely on the customers.
Overall it is liable to encourage these businesses to look after food better and reduce quantity of waste produced.
There would appear to be an obvious commercial opportunity for companies supplying on site treatment systems and / or collection systems.
· More time to establish the right mix of waste treatment infrastructure across Scotland by moving the date for introducing the ban on landfilling biodegradable material to 2020. The longer lead-in time between the requirement for separate collection (of food waste) and the ban on landfilling biodegradable material will allow recycling behaviours and practice to become more established. This will provide a more accurate picture of what infrastructure is needed to deal with non recyclable (residual) waste and will help avoid unnecessary reliance on residual waste treatment
This would appear to be a sensible extension time to allow system to become established. Effectively if you remove food waste and recyclate from the waste then there should in reality be little or no biodegradable waste remaining.
The issue of having a landfill site with no biodegradable waste present also needs to be considered. Currently landfill sites are engineered to decompose and stabilize over a period of time. During this period the liquid (leachate) is extracted and treated and the landfill (methane) gas is extracted and used to produce electricity / heat. A site with no biodegradable waste will decompose and stabilize very slowly and may pose a risk to future generations. This then leads to the natural conclusion that as systems develop very little material will go to landfill as it will ultimately be able to be separated into specific material types.
• An extended roll-out period for local authorities to introduce food waste collection services. This will ensure that local authorities have time to establish robust collection services and raise awareness of these services and their importance with householders;
This is probably going to be the hardest (and most expensive) part of this plan to implement. The main costs that the council face are collection costs and treatment costs. Councils will fundamentally have two main choices in terms of how they approach this –
• Collect food waste along with green waste on either weekly or fortnightly basis (it is unlikely that they would be able to extend time between collections to over two weeks). Treatment option will then be either in vessel composting (IVC) or anaerobic digestion (AD). Council will obviously benefit from combining food waste with an existing green waste collection (Note – green waste collection is often only every four weeks so there will still be an additional collection required).
As all waste will need to go through an IVC treatment cost will increase as green waste would historically have been composted in open windrows and also material needs to be shredded to a specific standard to meet Animal By product regulations (ABPR). Result is you treat food waste however the cost for composting green waste significantly increase.
Similarly for AD waste would need to be treated in a “dry AD” process again increasing treatment costs but with the added benefit of production of methane gas and potential energy generation.
• The second option would be to separately collect food waste. This would provide a good feed stock for AD facilities however the council would incur the significant additional cost of an additional weekly collection to ever household.
Although this policy provides councils with difficult choices the separate collection of food waste will encourage public to change behaviour and reduce quantity of food waste produced as they will realise how much food (and money) they are throwing away.
• A set of criteria establishing where local authorities must offer a food waste collection to householders and businesses, thus ensuring that households across Scotland benefit from a similar level of service;
This is an important measure which will be especially important in rural locations. From experience with similar requirements it is likely that councils will be allowed to set cost and if it does not fit in with their system they will set the cost artificially high to reduce take up. If this were the case it would obviously provide a commercial opportunity for private sector collection operators.
Introduction of a ban on the non-domestic use of food waste disposal units and digesters to macerate or pre-treat food and dispose of it through the sewer network. This will ensure that the resource value of food waste as a source of green energy and as a replacement for traditional fertiliser can be realised;
This is a very sensible measure as already stated above businesses will be investigating a range of options to allow on site treatment and this would have been one such cost effective method. As the statement quite rightly states this would lose the opportunity to produce green energy and replacement fertilizer and it would also potentially overload sewage works causing a deterioration in discharge quality.
• Introduction of measures to ensure that the quality of materials collected and processed is maintained, thus helping to extract the best environmental and economic value from waste. In the longer term, this will help ensure that there is a greater likelihood that key materials are recycled in Scotland, supporting the local economy and insulating industry from global fluctuations and unpredictable future quality demands;
Again this proposal would appear to be a sensible measure. It will probably rule out for example the co mingled collection of typical “blue bin” waste (i.e. paper, cardboard, plastic and metal) along with glass. A number of councils are considering this approach (potentially saves on collection costs and increases quantity of glass taken out of the waste stream) however it would be unlikely that this could be done so that glass could be recovered for re melt while at same time maintaining the same quality for the remaining recyclate. Any new Quality Standards / Codes of Practice would be welcomed by the industry.
- provision to allow local authorities to co-mingle food and garden waste, but only where similar environmental benefits to separate food waste collection can be demonstrated and achieved;
There are a number of local authorities already using this approach very successfully. This approach has the benefit of combining the food collection costs with an existing collection and can also deliver a PAS100 compliant compost product.
We would suggest that this should be altered to read “co mingled food and garden or residual waste”. With the correct system in place we believe it should be possible to collect residual waste and food waste (in bio bags), extract the bio bags and compost the food waste. The risk to the operator doing this is if they cannot demonstrate that similar environmental benefits can be demonstrated and achieved. A trial should be considered to assess whether PAS100 could be achieved in this way. If it can then this would provide an additional collection option for the council at nominal cost. We understand why this has not been included however we think that providing the standard can be met there is no reason why it is not an acceptable option.
- a requirement (or a voluntary agreement) for local authorities to provide the public with a biennial report showing how and where collected materials are being recycled, and the actions that are being taken to ensure the best environmental outcomes are being achieved.
Again a sensible approach as the public who do recycle are usually genuinely concerned as to what is happening with their material. It would be particularly welcome if it a common approach could be taken. It could however be argued that the SEPA Waste data flow should already hold this information and rather than needing a voluntary agreement, the SEPA waste data flow could be extracted and reported tot he public.
The comments based above are our initial thoughts on this document. We would welcome any comments or issues you have with our comments above and / or the Scottish Government Proposal.
Having reviewed the complete document and on the whole it provides a lot of clarity to the current situation and details an approach that the sector can work with.
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