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Making waste work in London 

The Mayor’s Draft Business Waste Management Strategy 

February 2008

February 2008 

Making waste work in London 

The Mayor’s Draft Business Waste Management Strategy

Copyright 

Greater London Authority 

February 2008 

Published by 

Greater London Authority 

City Hall 

The Queen’s Walk 

More London 

London SE1 2AA 

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ISBN: 978 1 84781 113 4 

Photography © Adam Hinton, Arup, Biffa, BREW Centre - London 

Borough of Richmond, Bywaters, C40, Chartered Institute of Waste 

Management, City of London, Construction Photography, GLA, 

Greenfinch, Greenworks , London Borough of Camden, London Borough 

of Greenwich, London Hydrogen Partnership/Transport for London, 

London Remade, Mayor of London’s Green Procurement Code, 

Nick Philips, Project Freesheet, PureFuels, Recycle for London, 

Recycle Now Partners, Shutterstock, TfL Visual Image Service, 

Visit London, West London Waste Authority. 

The GLA is committed to reducing the environmental impact of its printed 

materials. This document is printed on Revive 100 paper: 100 per cent 

recycled fibre content from post-consumer reclaimed material; FSC and 

NAPM certified. Printed by FM Print, an FSC and ISO14001 certified printer.

Making waste work in London The Mayor’s Draft Business Waste Management Strategy Mayor of London 

Contents 

Foreword by Ken Livingstone, Mayor of London 1 

1 The challenge ahead: 18 million tonnes of waste, one London 2 

2 Setting the scene: The context for this strategy 9 

2A Understanding the priorities 10 

2B A framework for change 18 

2C An exemplary sustainable world city 20 

3 Enabling change: An opportunity to make waste services work 30 

3A Tipping the balance 31 

3B Making producers responsible 37 

3C Increasing awareness and providing information 43 

3D Facilitating the development of collection services 49 

3E Facilitating the development of infrastructure 54 

3F Getting to grips with data 70 

4 Motivating change: An opportunity to save money 72 

4A Managing commercial waste 74 

4B Managing construction, demolition and excavation waste 83 

4C Managing industrial waste 92 

4D Making waste safe 95 

4E Avoiding fines 99 

5 Incentives for change: An opportunity to make money 102 

5A Designing waste out 103 

5B Designing waste in 110 

5C The power of procurement 114 

5D It’s what’s on the inside that counts 120 

5E The icing on the cake 124 

6 Leading by example: Putting our own house in order 130 

Appendices 134 

1 Summary of the key legislation relevant to this strategy 134 

2 Implementation plan 136 

3 Contact details for listed organisations 146 

4 Case study index 150 

5 Glossary, acronyms and key players 155 

Endnotes 167

Making waste work in London The Mayor’s Draft Business Waste Management Strategy Mayor of London 1 

Foreword by Ken Livingstone, 

Mayor of London 

Waste produced by businesses – be it from shops, restaurants and offices, 

industrial operations, or construction and demolition sites – makes up 

three-quarters of London’s waste, over 13 million tonnes each year. 

My vision is for London to develop as an exemplary sustainable world 

city and that means that we must change the way we treat our waste. 

No longer is it acceptable to bury it in a hole in the ground or burn it. 

This strategy sets the framework for how we can think differently about 

our waste: by minimising the amount we generate in the first place, 

by reusing and recycling materials and then by recovering energy 

as electricity, fuels and heat from waste that cannot be recycled. 

I said in my Climate Change Action Plan that a strategy to cut carbon 

emissions is essentially about cutting out waste and improving efficiency. 

This strategy is exactly that – it is a call to action for London’s businesses, 

whether they are large or small, and operate in the public or private sector. 

The waste that London’s businesses generate and the way it is currently 

disposed of makes a small but significant contribution to London’s 

greenhouse gas emissions. We need to work together to minimise our 

impact on climate change. Making smarter use of our resources and 

reducing the amount of waste we produce has an important part to play. 

After all, waste is actually a resource that has not been used productively 

by a business, which has a real impact on their bottom line, through the 

cost of buying the product in the first place, the cost of not using 

it productively and then the added cost of disposing of it as waste. 

The benefit to businesses of better managing their waste will be 

economic, but the benefit to London and Londoners is far greater: 

it is a cleaner, healthier environment where resources are properly valued. 

This draft strategy has been published for public consultation. Its vision 

will be achieved only if businesses heed its message and take action. 

I want all of London’s businesses to care about how much waste they 

produce and how it is managed. I invite London’s businesses to tell 

me how this strategy affects them, and how they will contribute to 

its implementation. 

Ken Livingstone 

Mayor of London 

© Liane Harris

2 Mayor of London 

Making waste work in London The Mayor’s Draft Business Waste Management Strategy 

1 The challenge ahead: 18 million tonnes 

of waste, one London 

Introduction 

1.1 London produces over 18 million tonnes of waste every year and this 

is forecast to rise to 23.6 million tonnes by 2020 1 . The quantity and 

rate at which London is using resources and producing waste is 

unsustainable. Just a little over half the total waste is recycled, largely 

as a result of high levels of construction waste recycling (Table 1). 

The Mayor believes that ’if London is to catch up with the remainder 

of the country then it is necessary to move faster than anyone else‘ 2 , 

inaction will lead to a worsening environment that will harm London’s 

businesses and communities. 

1.2 London is a dynamic world city. As a result of its population size, density, 

affluence and economic influence, London has a great opportunity to 

innovate and take action. This strategy shows that its position can be 

strengthened in a way that is environmentally, economically and socially 

sustainable through better managing its business waste. 

Table 1 Total waste produced and disposal method, London 2003 

Source of waste Quantity Disposed Recycled Incinerated Other 

produced at landfill (%) (%) (%) 

(millions 

of tonnes) 

(%) 

Municipal solid waste 4.3 70 11 ** 19 0 

Commercial and industrial 

(estimated) 

6.6 40 44 5 11 

Construction, demolition 

and excavation (estimated) 

7.2 15 85 0 0 

TOTAL * 18.1 37 53 6 4 

* of which hazardous waste 0.3 62 4 1 32 

Source: The London Plan Spatial Development Strategy for Greater London: Housing Provision 

Targets, Waste and Minerals Alterations, Greater London Authority, December 2006 

** Note: This is the most recent data available for commercial and industrial and construction, 

demolition and excavation waste, from the Environment Agency. However, more recent 

data is available for municipal waste, for example showing that 20 per cent was recycled 

in 2006/07. 

1.3 Climate change is now recognised as an international problem that the 

world can no longer ignore and the Mayor has made it his top priority 

for London 3 . The Mayor’s Climate Change Action Plan sets a target of 

stabilising London’s (and the UK’s) emissions at 60 per cent below 1990


levels by 2025 5 . The implementation of this strategy is fundamentally 

designed to support the Mayor to realise the goals set in the Climate 

Change Action Plan because the way we use resources and transport and 

manage waste has a fundamental impact on the production of 

greenhouse gases that cause climate change. Unfettered consumption 

and a landfill-dominated waste management strategy is no longer 

acceptable and a change in culture, with greater emphasis being placed 

on preventing and reusing waste and on treatment options further up the 

waste hierarchy, is required. 

1.4 London’s businesses must prevent waste and implement systems 

to achieve high rates of reuse, composting and recycling. They must 

establish green procurement policies and environmental management 

systems. Products and packaging must be designed in a way that makes 

the most productive use of resources and prevents waste. Businesses 

must identify opportunities to develop reprocessing infrastructure and 

generate energy from any waste that cannot be recycled, by using 

advanced waste technologies. 

1.5 The production and poor management of waste is an economic burden 

and represents a loss of valuable resources with additional costs for 

treatment and disposal. Treating waste as a resource will stimulate the 

development of a secondary materials economy. Commercial and 

industrial waste streams are larger and more homogenous than municipal 

waste and can provide the volume of material needed to catalyse 

investment in recycling industries. Developing the required infrastructure 

and expertise within London to achieve these goals will expand the green 

economy and benefit Londoners through the provision of jobs and 

training opportunities. Furthermore, the development of key waste 

facilities will enable businesses and the waste management industry to 

maximise the efficiencies in waste and recycled materials transportation. 

1.6 This strategy sets out measures so that London’s businesses can take 

responsibility for the waste they produce and take action to use resources 

productively and, with London’s waste industry, maximise the social, 

environmental and economic opportunities of reprocessing and managing 

waste within London.



The Mayor’s vision for how London manages its business waste in 2020 

is that: 

■ there is a high level of recycling and composting, more waste is reused 

and less waste is produced 

■ advanced waste technologies are used for treating non-recyclable 

waste, particularly technologies that produce energy 

■ London’s waste is primarily managed in London, reducing the impact 

on surrounding regions 

■ high quality advice, support and recycling services are offered to all 

businesses consistently across London 

■ the contribution of London’s waste to climate change is minimised. 

The scope of this strategy 

1.7 The term ‘business waste’, in this strategy, refers to commercial, industrial, 

construction, demolition, excavation and hazardous waste, which account 

for around three quarters (13.8 million tonnes 6 ) of all waste produced 

within London. 

1.8 Business waste is produced by organisations operating in the public, 

private and third sectors and includes all establishments, from those 

where people work for themselves to multinational corporations, across all 

economic sectors. Actions for businesses within this strategy are aimed at 

both those providing services and those procuring services. For example, 

proposals designed to increase the sustainability of events need to be 

considered by businesses procuring event management services and by 

staff managing or working for event management companies. 

1.9 There is no simple solution to removing the many obstacles required 

to effect the changes that will make the management of London’s 

business waste sustainable. The scale and complexity of resource use 

and waste management in London makes developing a coherent, 

accessible and realistic strategy a significant challenge. Business waste 

management is ultimately outside the Mayor’s direct control, it is 

a private relationship between the waste producer and service provider. 

1.10 This strategy establishes a vision for the scope and extent of change 

required and sets out a framework for action that will make London’s 

continued development sustainable. It marks the start of an inclusive 

and iterative process through which London’s businesses, as waste 

producers and waste service providers, can work together and develop 

partnerships to make change happen.


Delivering change through partnership 

1.11 As the Mayor in isolation cannot deliver this strategy, it has been crucial 

to its development that the views of London’s key delivery partners and 

other stakeholders have been sought and incorporated. The Mayor first 

received comments from stakeholders following the launch of the 

background study 7 to this strategy. This was followed by a programme 

of engagement in early 2006 and by listening to the views of those 

who participated in a stakeholder dialogue in February 2006 8 . 

1.12 In May 2007, a draft strategy was produced for consultation with the 

London Assembly and Functional Bodies, which make up the Greater 

London Authority (GLA) group. This was an excellent opportunity to 

discuss the draft policies and proposals with a wide audience. A report 

documenting the consultation process and summarising the discussions 

and meetings held during the period of consultation, has been produced 

as a supplementary document to this strategy. Key messages included: 

■ ensuring the strategy engages with the small business sector and that 

the most effective channels are developed to communicate and 

support their green growth 

■ putting a stronger emphasis on waste prevention. 

1.13 Shortly after the Mayor’s draft Business Waste Strategy was published 

for consultation with the London Assembly, the government’s Waste 

Strategy for England 2007 was launched. The Mayor has to have regard 

to a number of matters when preparing statutory strategies and has, 

in practice, adopted the same standards when preparing non-statutory 

strategies. One of the matters to which the Mayor must have regard 

is the consistency of his strategies with national policies. Some of the 

most substantial revisions to the strategy have therefore been to align 

Mayoral policy with government policy. 

1.14 The London Development Agency (LDA) will be a key partner in the 

delivery of this strategy: Regional Development Agencies have an 

increasingly important role in resource efficiency and waste management. 

In addition, there are a number of other stakeholders, whose involvement 

is crucial if change is to be made inevitable and achievable. Delivery 

organisations, such as the London Climate Change Agency and London 

Remade, will have a key role in developing partnerships to deliver the 

services and infrastructure required by London’s businesses. The business 

liaison groups, such as London First, the Federation of Small Businesses 

and the Asian Business Network, are able to access London’s businesses 

and translate the resource management agenda into the language of 

economic growth and competitiveness appropriate to a business audience.



They will be able to identify issues and actions specific to businesses 

of different sizes and operating in different sectors. They will be 

crucial partners during the public consultation and implementation 

of the strategy. 

1.15 The Mayor welcomes the opportunity to consult widely on this draft 

strategy and its impact assessment reports for sustainability, equalities 

and health produced as supplementary documents to the strategy, 

particularly recognising the role of the business liaison groups in this process. 

The structure of this strategy 

1.16 To achieve the Mayor’s vision, five policies (shown below together with 

their rationale) will be delivered through a range of proposals, given 

throughout the document. The strategy sets out an overarching framework 

of policy until 2020. As this strategy is the first of its kind, the text is 

largely intended to set the scene and take account of London’s current 

waste and resource management position with proposals for action 

focusing on the period to 2012/13, when the strategy will be updated. 

London recycles just half of the waste that it produces, a performance 

that requires major improvement. 

Policy 1 London’s businesses will achieve the reuse, recycling and composting 

targets in the London Plan by: 

■ achieving recycling or composting levels in commercial and industrial 

waste of at least 70 per cent by 2020 

■ achieving recycling and reuse levels in construction, demolition and 

excavation waste of at least 95 per cent by 2020 

■ generating energy from any waste that cannot be recycled using 

advanced waste technologies, which will contribute to the Climate 

Change Action Plan goals. 

London is reliant on landfill outside the region and is not realising 

the economic opportunities and environmental benefits that local 

infrastructure could bring. 

Policy 2 The Mayor will work with partners to ensure facilities with sufficient 

capacity are provided to achieve the London Plan self-sufficiency targets 

of managing 75 per cent of waste arising within London by 2010, rising 

to 80 per cent by 2015 and 85 per cent by 2020.


As a result of the size and complexity of London’s economy and 

the range of wastes produced, the management of business waste 

is poorly coordinated. 

Policy 3 The Mayor will work with partners to ensure information and advice 

is reaching all target audiences by: 

■ coordinating the provision of information and advice 

■ developing additional services that enable London’s businesses to use 

their resources more productively and manage their waste sustainably. 

Responsible management of the environmental impact of business 

operations can be simple and cheap to implement, can yield financial 

savings and improve performance. 

Policy 4 The Mayor will work with partners to raise and maintain awareness of 

resource productivity, sustainable waste transport and sustainable waste 

management among London’s businesses to bring about positive and 

permanent behavioural change. 

The Mayor expects the GLA group’s activities to meet the targets and 

policies set out in his strategies. By demonstrating excellence, the Mayor 

expects London’s businesses to be inspired to take responsibility and take 

action and contribute to London’s sustainability. 

Policy 5 The Mayor will ensure the GLA group leads by example to encourage 

London’s businesses to take responsibility and take action for their waste 

in accordance with the waste hierarchy and reduce London’s contribution 

to climate change. 

1.17 Chapter two provides a brief introduction to the foundation of the 

strategy, the waste hierarchy. It goes on to provide an overview of London’s 

businesses and the legislative context for the strategy and sets out how the 

strategy delivers the Mayor’s vision for London and his strategic priorities. 

1.18 Chapter three sets out the way in which change can be enabled through 

the shifting of economic drivers to make environmentally sustainable 

actions economically sustainable. This will be achieved through providing 

information and raising awareness among the business community of 

resource productivity and through the development of appropriate 

services and infrastructure, including reprocessing infrastructure. In doing 

so there are exciting economic and regeneration opportunities for 

London. Additionally, there are opportunities to expand the delivery of 

waste management services beyond the usual suspects and create the



conditions by which entrepreneurs can develop businesses to collect, 

manage and reprocess London’s most abundant resource. 

1.19 Chapter four details the way in which sustainable waste management 

and resource use has financial implications for businesses that should 

motivate change among the business community. Taking action to prevent 

and manage waste in line with the waste hierarchy can save businesses 

money, and being better informed can lead to lower compliance costs and 

prevent fines for environmental mismanagement. 

1.20 Chapter five demonstrates how businesses can take their environmental 

performance to the next level. It discusses waste prevention, through product 

and packaging design and developing green procurement policies and 

procedures. It focuses on managing the environmental impact of a business 

through an environmental management system and on cascading that 

environmental excellence to other businesses by engaging with suppliers. 

Actions such as these can help businesses retain and win new contracts, 

access niche markets and act as an incentive for businesses to change. 

1.21 Chapter six explains how the Mayor intends to lead by example. 

The Mayor and the GLA group’s activities produce business waste 

and impact on London’s sustainability. It is crucial that the Mayor’s 

operations are exemplary. The Mayor will stimulate the market for 

more sustainable goods and services through the GLA group’s 

procurement, pioneer sustainable waste management initiatives 

and demonstrate the business case for environmental excellence. 

1.22 Included in the appendices are contact details, or document links, 

to all the organisations and guidance documents mentioned in this 

strategy. As such, the strategy can act as a starting point for London’s 

businesses to take action to implement the proposals and as a point 

of future reference. 

1.23 Case studies are peppered throughout the strategy to support assertions 

made within the text. An index is included in Appendix 4. Their purpose 

is to illustrate ways in which some businesses have already implemented 

and profited from sustainable resource management and to demonstrate 

the business case for improved environmental performance. The Mayor 

wishes to thank the case study organisations for agreeing to have their 

work showcased in the strategy; they have inspired its development and it 

is hoped they will motivate others to rise to the challenge.


2 Setting the scene: 

the context for this strategy 

Introduction 

2.1 The strategy’s overall objective is to reduce the negative environmental 

impacts of the inefficient use of resources in a growing economy. It seeks 

to ensure that the consumption of resources and their associated impacts 

do not exceed environmental limits and aims to break the linkages 

between economic growth and waste production. 

2.2 This chapter explains the foundation of the strategy, the waste hierarchy. 

It then examines the challenge of delivering a meaningful strategy for 

London’s businesses, which are not a single homogenous group but 

have very different needs and priorities according to their size, sector, 

ownership and location. It also sets the strategy in its legislative context 

and identifies the links between this strategy and the Mayor’s vision for 

London and his strategic priorities.



2A Understanding the priorities 

Aiming for the top 

2.3 The Mayor’s waste hierarchy (Figure 1) sets out the priority for waste 

management options, based on their environmental impact. Sustainable 

waste management is about preventing waste and minimising disposal 

by generating energy and recovering materials through optimising reuse, 

recycling and composting. 

Figure 1 The Mayor’s waste hierarchy 

Reduction 

Reuse 

Recycling, composting and anaerobic 

digestion of separately collected waste 

Treatment of non-recyclable waste using 

advanced waste treatment technologies 

for recovery of energy and materials 

Disposal of treated non-recyclable waste 

using landfill or incineration that 

generates only heat or electricity 

Greater carbon savings 

Higher carbon emissions 

In making waste management decisions, the waste hierarchy should be applied 

in sequence from the top down. 

If there is a tension between implementing the waste hierarchy and achieving 

greater climate change benefits, then the Mayor will favour those options achieving 

greater climate change benefits. 

2.4 Although the waste hierarchy seems to establish waste management 

‘stages’, of course each step in the hierarchy should not be viewed 

as mutually exclusive. In designing a recycling system, for example, 

a business will become aware of the composition and volumes of the 

wastes they are producing. This information should be used to inform


the next iteration of their reduction and reuse strategies. In making 

waste management decisions, the waste hierarchy should be applied 

in sequence from the top down. 

Reduce 

2.5 Waste reduction is at the top of the waste hierarchy. Avoiding 

unnecessary waste, for example excessive packaging, reduces the 

demand for raw materials, which would otherwise have been extracted. 

Extracting and processing these raw materials uses energy and often 

generates large quantities of production waste. Preventing waste 

and minimising packaging reduces transportation needs and 

associated impacts such as fuel consumption, congestion, noise 

and air pollution. Waste prevention therefore significantly reduces 

emissions of carbon dioxide from fossil fuels. The knock-on effect 

of this saving is cumulative throughout the whole cycle, preventing 

the emission of greenhouse gases and reducing economic costs. 

2.6 There are a number of ways to prevent waste: 

■ through commissioning and designing buildings, products 

and packaging to prevent waste and enable disassembly for 

reuse and recycling 

■ through more efficient production processes 

■ by managing procurement decisions to only buy what is required 

and to specify recycled content and recyclable content materials 

■ by changing behaviour to use resources productively. 

Reuse 

2.7 Reusing products and materials prevents the carbon within materials 

from being released to the environment, reduces the pressure 

on primary resources and lessens the impact from extraction and 

transportation. An added benefit is that while recycled materials 

are often shipped many miles from London for reprocessing, the 

markets for reusable items are more likely to be within London. 

Designing for reuse ensures that the whole product (or its component 

parts) can be used again without requiring any processing. Reuse 

activities can be as simple as reusing scrap paper or delivery crates, 

passing furniture and electrical equipment on to another person or 

business or disassembling and reconditioning equipment. 

2.8 Although higher than recycling in the waste hierarchy, reuse is often 

considered outside mainstream waste management, for a number of 

reasons; waste management traditionally deals only with products at 

the end of their life, reuse is often undertaken by different players from



those traditionally involved in waste management and the contribution 

of reuse to waste targets and goals is difficult to measure. However, 

in recognition of the social, environmental and economic benefits that 

reuse can deliver, it is being increasingly drawn into the regulatory and 

policy system. 

Recycle and compost 

2.9 Recycling prevents valuable resources being disposed of to landfill and 

reduces the need for raw materials. Recycling requires an energy input 

to reform the materials into different products, but it is generally much 

lower than the energy required to process raw materials. This results 

in more efficient use of resources and lower greenhouse gas emissions. 

UK recycling currently saves between 10 and 15 million tonnes of carbon 

dioxide equivalent greenhouse gases per year compared to other waste 

management options 9 . Through this strategy the Mayor has set 

challenging reuse, recycling and composting targets for London’s 

businesses and seeks to develop new recycling and reprocessing 

infrastructure for London and prioritise recycling that achieves the 

greatest carbon benefits. 

2.10 Composting is a controlled process where organic materials, such as food 

and garden waste, are broken down in the presence of oxygen to produce 

compost for use as a soil improver and other landscaping uses. Wastederived 

compost can replace peat, which provides a natural carbon store 

and helps protect the UK’s natural landscapes. Composting avoids the 

production of methane (a powerful greenhouse gas 10 ), which is generated 

if organic materials are disposed of to landfill. 

2.11 The compost industry is in the midst of dramatic change. Until recently, 

composting has been a largely low-tech process, principally used for the 

management of green waste (leaves and trimmings from gardens and 

parks) the majority of which has taken place using open-air windrows. 

However, in order to meet the targets of the Landfill Allowance Trading 

Scheme, London boroughs have been required to divert greater quantities 

of biodegradable waste, including food waste, from landfill. To protect 

human health the Animal By-Products Regulations (2005) restrict the 

composting of food waste to specialist facilities. These factors have 

required the composting industry to develop enclosed facilities, such as 

in-vessel systems, suitable for the urban environment and which meet 

stringent regulations. 

2.12 Anaerobic digestion is the treatment of biodegradable wastes in the 

absence of oxygen. The process produces a methane-rich biogas, which 

can be converted into heat and power. Ultimately, it can be used as a


renewable source of hydrogen, suitable for very high efficiency transport 

or energy applications. The anaerobic digestion process has been widely 

used to treat sewage sludge. Recent findings from Defra 11 illustrate that 

generating energy via anaerobic digestion shows significant potential for 

greenhouse gas emission reductions and fossil-energy savings. 

2.13 The government has put anaerobic digestion on a level with recycling 

and composting, as a way to treat organic kitchen waste 12 and notes 

that anaerobic digestion facilities have been situated successfully in light 

industrial estates within towns 13 . There is a real opportunity for London’s 

waste industry to develop in-vessel composting and anaerobic digestion 

facilities for commercial organic kitchen waste. 

Generate energy using advanced waste technologies 

2.14 Waste that cannot be recycled is still a valuable resource and its energy 

can be recovered using advanced waste technologies such as pyrolysis and 

gasification, whose outputs include a hydrogen-rich gas (synthesis gas), 

which can be used as a fuel to generate electricity or as a transport fuel. 

2.15 According to the Climate Change Action Plan, the ‘treatment of residual 

waste streams could produce a whole new market in renewable gases and 

liquid fuels – with the potential to turn non-recycled waste into London’s 

largest source of renewable energy’ 14 . Both biodegradable waste and 

some residual waste can be used to generate bio and synthesis gases that 

are either partially or entirely renewable (depending upon the feedstock). 

These can be used for heating and cooling homes and workplaces and for 

transport. A key element of the Climate Change Action Plan’s push for a 

decentralised, sustainable energy supply in London is the rapid 

development and delivery of mechanisms to produce energy from waste, 

through advanced waste technologies. 

Recover energy using incineration 

2.16 Data provided by the Environment Agency 15 shows that 450,000 tonnes 

of business waste was incinerated in 2005. 

2.17 Research commissioned by the GLA 16 has shown that advanced waste 

technologies can save as much as 413 kg of CO 2 equivalent emissions 

per tonne of waste treated. In contrast, the best performing incineration 

option modelled, with some pre-treatment and operating in combined 

heat and power (CHP) mode, achieves emission savings of less than 

40 kg of CO 2 equivalent per tonne of waste treated. All other incineration 

scenarios, including the method used by London’s existing and proposed 

incinerators (no pre-treatment and electricity only), perform far worse,



generating up to 83 kg of CO 2 equivalent per tonne of waste treated and 

therefore contributing to climate change. 

2.18 Given incineration’s inherent inflexibility and inefficiency, the Mayor believes 

that there is no place for incineration in a modern world city like London. 

Landfill 

2.19 Around 55 per cent of London’s business waste is landfilled each year. 

Reducing landfill is important because it accounts for 40 per cent 

of UK methane emissions and three per cent of all UK greenhouse gas 

emissions 18 . Further, London is heavily dependent on landfill sites in 

surrounding regions for its landfill disposal, which is unsustainable. 

Many landfills in London and in surrounding regions only have three 

to five years remaining capacity. 

2.20 Landfill will continue to be needed for the management of some residual 

waste over the lifetime of this strategy, however the focus needs to shift 

from landfilling unsorted, untreated wastes containing recyclables and 

organics to the disposal of residues from recycling and of certain waste 

streams where landfill offers the greatest benefit, such as asbestos. 

Making it relevant 

2.21 The biggest barrier to the effective delivery of this strategy is that 

London’s businesses are not a single homogenous group, which has 

implications for how services are communicated and delivered. Services 

need to be tailored to businesses in relation to their type, size and sector. 

This strategy defines these three strands as follows: 

■ type: public sector (local and central government), social enterprises/ 

third sector, private sector 

■ size: small (and micro), medium and large businesses 

■ sector: 

- professional and business services, including education, media 

etc. in other words, businesses producing largely ‘office’ waste, 

such as paper, plastics, food and card 

- retail (grocery and goods), hospitality (hotels, contract catering, 

restaurants, pubs) and the food processing industry, which produce 

mainly food, card and glass 

- construction, highways and industry, producing a range of 

construction, demolition, excavation and industrial wastes 

- healthcare organisations, which produce a range of ‘office’ 

and food wastes should be separately considered due to the 

clinical hazardous waste they produce.


Type 

2.22 The public sector is the part of the economy, which provides basic 

government services and implements government policy. The government, 

however, does not control the private sector, which is engaged in private 

enterprise. The third sector pursues social and environmental objectives 

and reinvests any surpluses in the pursuit of their objectives. Clearly, the 

method by which these three types of businesses conduct their activities 

in relation to waste is heavily influenced by their relationship with the 

government, the public and the economy. 

Size 

2.23 Larger firms tend to have more resources and time to devote to 

developing policies and systems to manage their environmental impact, 

but small and medium sized firms do not have this luxury. They require 

more flexible support, characterised by easy access and targeted 

information 19 . Without such support they will find it difficult to move 

towards sustainable waste and resource management and will ultimately 

become uncompetitive. This strategy must lead to the development 

of services and support for small business and these must be tailored 

to their particular needs and resources. 

2.24 Small and medium sized enterprises make up a large part of Europe’s 

economy, representing some 99 per cent of all businesses and 57 per cent 

of economic value added 20 . LDA research 21 shows that there are a similarly 

large proportion of small businesses in London. Small businesses have a 

primary role to play in shifting London’s economy to more sustainable 

production and consumption patterns for two reasons: 

■ representing such a large percentage of economic activities, small 

businesses have a significant impact on the environment. The problem 

is not so much individual firms (although in some cases there can be 

serious individual impacts on the local environment and communities) 

but their combined total impact across sectors 

■ small businesses are often not fully aware of the environmental impact 

of their activities. A survey of 4,490 small businesses 22 , showed that 

just 15 per cent were aware that their business could pose a threat 

to the environment, a rate that rose to 49 per cent when respondents 

were supplied with a list of potentially damaging activities and less 

than a quarter were able to name a specific environmental law.



Most businesses in London are small employing less than 50 people. 

■ Seventy-six per cent of businesses employ less than five people and 

21.3 per cent of businesses employ between five and 49 people 

■ Just 2.5 per cent of businesses employ more than 50 people (with 

1.4 per cent employing between 50-99 employees and 1.1 per cent 

employing over 100 employees. 

However, bigger employers do account for the majority of jobs in London 

■ Almost half (48.5 per cent) of business employment is in the 2.5 

per cent of businesses employing more than 50 people and one 

quarter of this is in organisations employing more than 1,000 people 

■ Just 26 per cent of business employment is in businesses employing 

ten people or less. 

Source: London Annual Business Survey 2005, London Development Agency 

2.25 The LDA’s London Annual Business Survey shows that a higher proportion 

of black-led and Asian-led businesses are small, than white-led 

businesses. Further, a higher proportion of white-led and Asian-led 

businesses are medium and large than black-led businesses 23 . The survey 

also shows that a far higher proportion of women-led businesses are small 

and far fewer women-led businesses are medium or large, than male-led 24 . 

Therefore advice and support to small businesses must also take account 

of their ownership. Business liaison groups, representing black, Asian and 

minority ethnic (BAME) owned businesses, are crucial in the consultation 

and delivery of this strategy. 

2.26 The geographic spread of businesses could have considerable impact 

on the type of services required. For example, small businesses are likely 

to be less attractive contracts to private waste management companies 

and therefore will rely more heavily on local authority services. Central 

London contains the most businesses (35 per cent of London’s 

businesses) while south London and north London have the fewest 

(15 per cent and 11 per cent respectively). Yet north London contains 

the most small businesses 25 . If local authorities do not take control of 

business waste, particularly in areas with large number of small 

businesses, for example high streets and small retail areas comprising flats 

above shops, an area may suffer from fly-tipping and litter problems. 

Sector 

2.27 Alongside developing targeted services and support according to 

business size, consideration also needs to be given to the sector in which 

a business operates because this dictates the types of products used


and wastes produced. There is often significant homogeneity of the wastes 

produced, with each sector producing one material of significant volume. 

2.28 Another reason to group businesses by sector is to tackle specific areas 

of under-performance. London’s extraordinary social and cultural diversity, 

for example, is reflected in over 60 different cuisines provided in over 

12,000 restaurants 26 . However, there is a higher level of inactivity in 

waste management by the hospitality sector, compared to those in the 

retail and business services sector 27 and targeted intervention is required. 

2.29 Proposal 16 suggests that sector-specific action plans, which include 

tailored guidance and support for smaller businesses, are developed 

with London’s businesses to sit beneath this strategy. London Assembly 

research found that a ’sector focused approach could pay dividends by 

addressing waste streams of direct relevance, using their terminology‘ 29 . 

The production of action plans would be led and owned by key 

stakeholders from each sector. Criteria will need to be developed 

by which stakeholders can assess the principal environmental impacts 

of the sector and a material-led approach developed as appropriate. 

2.30 At a strategic level, the development of a range of sector-specific action 

plans is required to generate understanding as to how issues around type, 

size and sector interact.



2B A framework for change 

The legislative context 

2.31 The European Thematic Strategies on the Prevention and Recycling of 

Waste 30 and on the Sustainable Use of Natural Resources 31 were published 

in December 2005. By placing waste management within the context of 

resource management the thematic strategies set out how preventing 

waste and promoting recycling and advanced waste technologies will 

strengthen the European economy and reduce the negative environmental 

impact of using natural resources. 

2.32 The government set out its vision for sustainable waste management 

in Waste Strategy for England in May 2007. The government’s key 

objectives are to: 

■ decouple waste growth (in all sectors) from economic growth and put 

more emphasis on waste prevention and reuse 

■ meet and exceed the Landfill Directive diversion targets for 

biodegradable municipal waste in 2010, 2013 and 2020 – although the 

Mayor has questioned the narrow definition of municipal waste applied 

by Defra, which has effectively prevented the realisation of the 

directive’s intention, to reduce waste to landfill 32 

■ increase diversion from landfill of non-municipal waste and secure 

better integration of treatment for municipal and non-municipal waste 

■ secure the investment in infrastructure needed to divert waste from 

landfill and for the management of hazardous waste 

■ get the most environmental benefit from that investment, through 

increased recycling of resources and recovery of energy from residual 

waste using a mix of technologies. 

2.33 There are a wide range of legislative controls on the production and 

management of business waste, such as: 

■ The Landfill Directive (1999) 

■ Producer responsibility legislation 

• Producer Responsibility Obligations (Packaging Waste) Regulations 

2007 

• End-of-Life Vehicles Regulations 2003 

• Waste Electrical and Electronic Equipment (WEEE) Regulations 2006 

• Directive 2006/66/EC on batteries and accumulators and waste 

batteries and accumulators 

■ The Hazardous Waste (England and Wales) Regulations (2005) 

■ Integrated Pollution Prevention & Control (IPPC) 

■ The Environmental Protection (Duty of Care) Regulations (1991) 

■ The Animal By-Products Regulation (2005) 

■ Controlled Waste Regulations (1992).


2.34 In September 2003, the Mayor’s 

Municipal Waste Management Strategy 33 

was published. It sought to ensure that 

by 2020 municipal waste no longer 

compromised London’s future as a 

sustainable city. Municipal waste 

accounts for a quarter of the waste 

London produces. 

2.35 In February 2004, the Mayor launched 

the London Plan 35 ; the Mayor's spatial 

development strategy. It established a 

waste planning framework and set 

regional self-sufficiency targets for all 

waste streams. 

Municipal 

Construction/ 

demolition/ 

excavation 

2.36 The Mayor’s statutory powers of direction for waste (under part 8 

of the GLA Act 1999) are limited to municipal waste, leaving the 

majority of London’s waste outside the Mayor’s policies and controls. 

Clearly, to deliver the London Plan the Mayor needs to be given the 

power to provide a comprehensive strategic framework for all wastes 

produced in London. 

2.37 This strategy fulfils the Mayor’s commitment, first made within the 

municipal strategy 36 , to produce a wider strategy covering business waste 

and deliver the waste policies in the London Plan. It is the Mayor’s view 

that the Mayor should have the powers to produce a statutory business 

waste strategy 37 . 

2.38 Appendix 1 summarises the key legislation, which has been taken into 

consideration when developing this strategy. 

Hazardous 

Commercial 

Industrial



2C An exemplary sustainable world city 

Introduction 

2.39 Sustainable development is about ensuring we have a better quality 

of life now and for the future whilst protecting and enhancing the earth’s 

resources (Figure 2). The GLA Act 1999 imposes general duties in relation 

to the Mayor’s strategies. These are the promotion of: 

■ economic development and wealth creation in London 

■ social development in London 

■ the improvement of the environment in London. 

Figure 2 Diagram showing the three elements of sustainable development 

Economy 

Society Environment 

2.40 The impact of the strategy on the environment, sustainable development, 

health and equalities has been assessed and a set of impact assessment 

reports produced as supplementary documents to this strategy.


Delivering the Mayor’s vision 

The Mayor's vision is to develop London as an exemplary sustainable 

world city, based on three interwoven themes: 

■ strong and diverse economic growth 

■ social inclusion to allow all Londoners to share in London's 

future success 

■ fundamental improvements in environmental management 

and use of resources. 

Strong and diverse economic growth 

2.41 This strategy’s approach to waste management will create new 

opportunities for economic development. The Environment Agency has 

found that consumers are increasingly demanding goods and products 

to be manufactured and delivered in an environmentally responsible 

way 38 . London’s entrepreneurs should seek to develop creative, high 

value green industries that reprocess waste and create fit-for-purpose 

products and secondary materials. Breaking new ground to develop 

sustainable products that prevent waste and incorporate recycled 

materials is an exciting opportunity enabling London’s businesses 

to capture new markets. 

2.42 The development of green industries will lead to new training 

and employment opportunities for Londoners and further contribute 

to London’s sustainable economic growth. 

2.43 Sustainable resource use presents an opportunity for London’s 

businesses to improve business practice, profitability and competitiveness. 

Waste production is too often seen as an inevitable part of business 

processes and waste management as a necessary cost. Businesses that 

continue to take this approach will find their waste costs rising as 

dependence on landfill increasingly attracts financial penalties and the 

costs of regulation and taxes are passed to waste producers. 

2.44 Manufacturers, for example, could benefit financially from reduced energy 

costs as a result of implementing efficient and productive manufacturing 

techniques and be protected from rising raw material costs by using 

recycled materials. Road transport costs are also rising through increased 

congestion on London’s strategic roads, compliance costs and rising diesel 

prices. The case for waste-derived fuels and fuel-efficiency measures, 

such as better routing and scheduling planning, is compelling. Businesses 

that invest now in systems, processes and infrastructure will save on these 

higher costs in the long run.



2.45 The successful implementation of this strategy, which seeks to improve 

resource productivity and decouple economic growth from waste growth, 

will contribute to the sustainability of London’s economy. The productive 

use of resources contributes to growth, while inefficient use undermines 

the resource base on which the economy depends. 

Social inclusion to allow all Londoners to share in London's future success 

2.46 The Mayor believes that ‘whatever your religion, race, sex, age, disability 

or sexuality, you should be able to live your life free from discrimination. 

Leading London's equality agenda is a key aim and lies at the heart 

of all the work that is undertaken by the GLA group‘ 39 . 

2.47 There are enormous opportunities to deliver the Mayor’s vision for 

equality of opportunity and diversity through this strategy because 

it is predicated on realising the economic benefits inherent in productive 

resource use. This will result in enhanced economic growth for London 

and more diverse employment and business opportunities for Londoners. 

Diversity of employment can overcome social exclusion caused by a lack 

of appropriate employment opportunities. 

2.48 Waste facilities have traditionally been sited next to, or within, the poorer 

and more deprived areas of London and this strategy relies on the London 

Plan to ensure that new waste management facilities are designed and 

located in appropriate locations and stimulate regeneration. 

2.49 London’s waste producers and waste service providers are diverse in their 

size and range of operations. In supporting the development and growth 

of London’s green industries, this strategy seeks to maintain and 

strengthen the role of public, private and third sector waste service 

providers. With regards to waste producers - London’s businesses - it is 

essential to ensure that access to information and services is consistent 

and inclusive so that they are all able to implement waste management 

systems that result in cost savings and new business opportunities and 

to contribute to improving London’s sustainability. 

Fundamental improvements in environmental management 

and use of resources 

2.50 In reality, the use of natural resources is heavily subsidised. Exploitation 

is often underestimated or not accounted for at all. As a result, prices 

and price changes do not necessarily signal scarcity, as market-based 

economic theory would assume. As ecological problems often have 

systemic impacts, characterised by a long delay between activity and 

damage, costs may not escalate until something dramatic occurs and 

feedback in the market could come too late to prevent environmental


damage. This strategy aims to stimulate change now, to change wasteful 

consumption patterns and avoid global climate change catastrophe. 

2.51 Significant behaviour change is required to reduce waste and treat waste 

as a resource. To manage waste in line with the waste hierarchy will 

require a massive amount of fixed infrastructure. This must be linked 

to a transportation network that does not add to congestion and be 

interlinked with a local supply of energy. 

2.52 This strategy goes further than just dealing with London’s business waste. 

It forces a rethink at every part of the supply chain and sets out proposals 

for action that will commit London’s businesses to a fundamental 

improvement in their use of resources. 

Linkages with the Mayor’s strategic priorities 

Biodiversity 

2.53 The Mayor’s Biodiversity Strategy 40 sets out his aim to ensure everyone 

has a chance to enjoy and benefit from nature and ensure Londoners 

are aware of their responsibility to protect and conserve these areas 

for the future. 

2.54 Although the London Plan identifies the requirement for approximately 

300 waste management facilities, it seeks to preserve land for biodiversity 

by prioritising the use of brownfield sites for waste management 

activities. Similarly, this strategy promotes the use of recycled materials 

in place of virgin materials, which will conserve natural resources and 

reduce mining and excavation, although this is very limited in London. 

2.55 The London Plan has established the planning framework by which the 

correct aftercare treatment techniques are applied to landfill sites at the 

end of their working life, ensuring that they are restored to parkland, 

proactively providing access to nature. Proposed waste management sites 

may be rich in biodiversity and the use of any land in London will be 

managed through the planning and waste management licensing process, 

actively avoiding conflict with London’s wildlife. 

Climate change and energy 

2.56 In his Climate Change Action Plan, the Mayor states that ’he has no 

doubt that climate change is the single biggest threat to the future 

development of human civilisation‘ 41 . London is responsible for eight 

per cent of the UK’s total emissions. Given London's forecast economic 

and population growth, this will increase to 15 per cent by 2025 42 .



2.57 If London is to make its contribution to reducing climate change and 

show leadership, Londoners and London’s businesses must change their 

behaviour. To reach the target of stabilising London’s (and the UK’s) 

emissions at 60 per cent below 1990 levels by 2025 43 , London must 

achieve ongoing reductions in emissions of four per cent every year. 

To achieve this, businesses must move from a high energy-use, 

wasteful economic model to one that conserves energy and makes 

productive use of resources. 

2.58 The effects of climate change on London are already visible and 

include higher temperatures in summer and winter aggravated 

by the urban heat island effect, wetter winters, drier summers and 

extra pressure on London's water resources 44 . The exceptionally high 

concentration of people and assets at risk means that any extreme 

event will have major consequences. Without adaptation, the impacts 

of climate change are likely to be detrimental to everyone’s quality 

of life and will be particularly ‘likely to affect vulnerable social groups 

disproportionately (for example those on lower incomes may be more 

significantly affected)’ 45 . The same will be true for the ’adverse health 

impacts of climate change‘ 46 . Clearly this is a concern for the Mayor 

and is something that will be further substantiated in the Mayor’s 

forthcoming Climate Change Adaptation Strategy. 

2.59 The Mayor’s top priority for reducing carbon emissions in the Climate 

Change Action Plan 47 is to move as much of London as possible away 

from reliance on the national grid and on to local, lower-carbon energy 

supply. In the current environment, a saving of 7.2 million tonnes 

is achievable by 2025, and 15 per cent of this is to be met by an 

increased contribution from energy from waste using advanced waste 

technologies 48 . The treatment of residual waste streams could produce 

a whole new market in bio and synthesis gases and liquid fuels that are 

either partially or entirely renewable (depending upon the feedstock), 

which can be used for heating and cooling homes and workplaces and for 

transport. The objectives of the London Climate Change Agency include 

stimulating markets for the supply of, and the demand for, waste-derived 

fuels such as bio and synthesis gases and bio-diesel as well as to advise 

on Combined Cooling, Heat and Power (CCHP) systems for developments. 

Economic Development 

2.60 The LDA produces the Economic Development Strategy 49 on behalf of 

the Mayor of London. The strategy supports the development of London’s 

economy, promotes employment, helps people participate in London’s 

economy and supports businesses to be more competitive - all within the 

context of economic development being fair and sustainable.


2.61 The Economic Development Strategy focuses on four major investment 

themes, which are supported by this strategy: 

■ places and infrastructure – this strategy seeks to develop waste 

management and reprocessing infrastructure to achieve the selfsufficiency 

targets set by the London Plan. The Panel Report produced 

as a result of the Examination in Public of the draft Further Alterations 

to the London Plan supports the Mayor’s assertion that waste 

management is a regenerative opportunity 50 

■ people - waste presents an exciting opportunity for developing skills 

and employment opportunities in London. The waste industry 

is a major employer of people across the social spectrum. Aspects 

of the waste industry, for example the reuse sector, present key 

opportunities to develop skills for people who are unemployed 

or underemployed 

■ enterprise – proposals to improve the management of waste and 

resources present an exciting opportunity for London’s entrepreneurs 

to develop and expand London’s green industries sector 

■ marketing and promoting London – consumers are increasingly 

demanding goods and services to be delivered in a sustainable way. 

This strategy highlights the opportunity for London’s businesses to 

take the lead in creating new sustainable products and services. 

Health 

2.62 The Mayor has a duty to promote the health of Londoners and to take 

into account the effect of his policies on their health. He is not 

responsible for the provision of healthcare but works in partnership with 

the NHS and others to secure improvements in Londoners' health and 

to reduce health inequalities in London. The GLA Act 2007 has given the 

Mayor new health responsibilities, in addition to his previous duty to 

promote health. These include a duty to work to reduce health inequalities, 

for example by leading on a Londonwide Health Inequalities Strategy. 

2.63 The management of business waste is relevant to health inequalities 

because ‘physical environments are conducive to good health’ 51 . 

This includes good housing, safe neighbourhoods, high quality public 

places, accessible services, clean air and green space the delivery 

of which can be negatively affected by poor waste management. 

The Mayor’s draft Health Inequalities Strategy makes it a priority 

to ‘more explicitly link action on the environment and health’ 52 . 

2.64 This strategy supports the Mayor’s work to combat environmental 

crime by promoting compliance with the Duty of Care and seeking to 

reduce litter and fly-tipping. This may help to reduce health risks (for



example from needles) and reduce the likelihood of areas attracting crime, 

which can influence the impact that local environments have on people’s 

health. Poor management of business waste can have a negative 

impact on social cohesion as people may be less likely to want to spend 

time out in their local community, local streets and parks, for example 

affecting their likelihood to participate in physical exercise. 

2.65 Preventing waste prevents the associated need to transport waste, 

a major source of air pollution and noise, both of which can affect 

people’s health. Additionally, the London Plan 53 has established the 

planning framework by which it is ensured that waste management 

facilities are designed and located in a way which minimises their 

impact on air quality, for example through managing and minimising 

vehicle movements and dust. 

2.66 The strategy specifically addresses the management of waste from 

healthcare facilities. This is important because the healthcare sector 

produces vast quantities of waste, a large proportion of which is 

hazardous. More widely, this strategy contributes indirectly to the 

safe management of all hazardous waste, for example, by promoting 

compliance with the Integrated Pollution Prevention and Control 

legislation which reduces the likelihood of pollution incidents which 

could have negative health impacts. 

2.67 Research 54 has shown that the number of fatal incidents within the UK 

waste management industry is over ten times the national average and 

accident rates over four times the national average. Being struck 

by a refuse collection vehicle or a car are the most common workplace 

transport accidents. The Environment Agency, local authorities and private 

sector waste management companies must work together to minimise 

workforce accidents taking place within the waste management industry. 

Transport 

2.68 The Mayor published his Transport Strategy 55 in 2001. A crucial aspect 

of the scope of this business waste strategy is its consideration of the 

transportation of waste and recycled materials and adopts the approach 

being implemented in the Mayor’s Transport Strategy and London Freight 

Plan ‘Sustainable Freight Distribution: A Plan for London’. Developed with 

Transport for London, the London Sustainable Distribution Partnership 

and the Freight Transport Association, the plan will improve the quality 

of life in London by reducing the negative impacts of freight and 

servicing in London, such as noise, vibration and emissions of local 

air pollutants and carbon dioxide.


2.69 It is estimated that one in ten lorries on Europe’s roads transport waste 56 . 

Waste transport movements represent about eight to ten per cent of all 

freight traffic movements in the capital 57 . Waste transport operators, and 

the businesses that they serve, must work together to reduce the impact 

of waste collection on London’s roads. 

2.70 There are significant synergies and opportunities for joint working 

between the Mayor’s waste and transport policies. This strategy will 

encourage waste transport operators, private sector waste management 

companies and local authorities to develop management and control 

systems that will minimise congestion on London’s roads, improve 

Londoners’ quality of life and reduce climate change gas emissions 

through proposals that: 

■ prevent waste arising 

■ encourage the on-site management of waste (for example on-site 

reuse of construction, demolition and excavation waste) 

■ prioritise the use of local infrastructure, the strategic co-location 

of businesses producing, and facilities managing, particular waste 

streams and develop facilities for materials collected by local 

authorities and private companies 

■ seek a proactive and cooperative approach to waste service 

procurement by neighbouring businesses and promote better 

journey planning - reduced journeys and reduced journey distances 

■ increase the modal switch from road to water or rail 

■ promote waste-derived fuels. 

2.71 Planning authorities should assess detailed waste transport impacts 

as part of the criteria for approval of planning applications. Transport 

for London is working in partnership to develop a pan-London waste 

transport logistics model, which will collect and collate information 

on waste transport movements. This will help in monitoring and 

coordinating strategic information on the Mayor’s targets for reuse, 

recycling and composting and inform decisions such as the optimum 

location for the waste facility, site capacity and inter-modal opportunities. 

Air quality and noise 

2.72 Air pollution has a major impact on health and quality of life. ‘Poor air 

quality can have negative effects on respiratory and cardiovascular health, 

particularly for young children and older people’ 58 . The Mayor’s Air Quality 

Strategy 59 sets out his proposals for improving air quality in London. 

2.73 Noise is a problem for many Londoners. It can disrupt conversation or 

other activity, increase stress or disturb concentration, rest or sleep. Many



see it as a key quality of life issue. The Mayor's Ambient Noise Strategy 60 

is part of a Europe-wide move towards more active management of 

ambient noise, mainly from transport sources. The strategy sets out his 

proposals for reducing noise through the better management of transport 

systems, better town planning, and better design of buildings. 

2.74 Transport proposals, given above, will have a positive impact on London’s 

air quality and reduce noise. 

2.75 The London Plan has established the planning framework by which it 

is ensured that waste management facilities are designed and located 

in a way which minimises their impact on air quality and noise, for 

example through managing and minimising vehicle movements, 

ensuring their machinery is properly housed, minimising emissions from 

the process/technologies themselves (for example, through adequate 

arrestment/abatement plant being specified in the planning approval) 

and switching to sustainable transport modes and fuels. 

2.76 This strategy proposes that any waste that cannot be recycled or reused 

is turned into energy using advanced waste technologies and wastederived 

fuels, including hydrogen. Hydrogen used in modified petrol 

engines produces much lower levels of local air pollutants than diesel 

or petrol powered vehicles. Fuel-cell powered vehicles also tend to run 

more quietly than their diesel counterparts and may offer benefits to 

local communities for night-time working. 

2.77 The GLA is undertaking research into the air quality impacts of waste 

treatment technologies, which will inform the onward implementation 

of the Mayor’s energy, waste and air quality strategies. 

2.78 The Mayor and Transport for London will also work closely with local 

authorities, businesses and private sector waste management companies 

(for example, through the Freight Operator Recognition Scheme) to 

improve driving standards and reduce service noise. Promoting the use of 

recycled materials could increase their use in noise reduction and mitigation 

(for example, quieter road surfaces incorporating recycled rubber). 

Water 

2.79 Climate change, population growth and lifestyle changes are all placing 

increasing demands on London's water supply. Historically the UK has 

received uniform rainfall throughout the year. However, average 

household water demand has increased dramatically over the past quarter 

century and climate change is contributing to the problem, for example, 

2005 and much of 2006 were exceptionally dry 61 . ‘Water Matters’, the


Mayor’s draft Water Strategy 62 was launched for consultation in March 

2007, and seeks to to ensure that all the relevant agencies work together 

for an adequate water supply for London, which will accommodate 

London's future population growth. 

2.80 The London Plan has established the planning framework by which flood 

risk in relation to the location of waste management facilities can be 

managed, where appropriate. London’s businesses must work closely 

with the Environment Agency to ensure their operations are compliant 

with the Integrated Pollution Prevention and Control legislation. In doing 

so, they will prevent water quality being put at risk by pollution from 

waste management facilities and industry. Additionally, this strategy 

supports the Mayor’s work to combat enviro-crime and promotes 

compliance with the Duty of Care legislation, which may reduce the 

pollution of waterways from litter and fly-tipping. 

2.81 This strategy promotes resource productivity and of course water 

is a resource so the same ideals apply. Producing products that are 

more sustainable, by preventing waste during the manufacturing 

process, may indirectly lead to the more efficient use of other resources 

such as energy and water.



3 Enabling change: an opportunity 

to make waste services work 

Introduction 

3.1 The productive use of resources can improve business practice, 

profitability and competitiveness. However, the constraints of 

competitive markets mean that it is often difficult for companies 

to act alone. Therefore, the European Union and the UK government 

are increasingly stimulating change in how businesses use resources 

and manage waste through legislative and fiscal measures. To remain 

competitive, London’s businesses need to take action now and reduce 

their environmental impact. 

3.2 Whilst more must be done to encourage all of London’s businesses 

to become environmentally aware, the Mayor recognises that for many 

businesses, it may not be a lack of understanding of the urgency or of 

the opportunities to change, or a lack of willingness that is preventing 

them from taking action, but a lack of consistent advice, a disparity of 

information about services, and a lack of suitable services. 

3.3 This chapter sets out the economic and legislative drivers for improved 

environmental management. It details methods to improve the provision 

and the coordination of information and advice on managing business 

waste and aims to stimulate the development of appropriate services 

and waste management facilities for London’s businesses.


3A Tipping the balance 

An escalating landfill tax 

3.4 A report by the Institute of Public Policy and Research and Green 

Alliance found that the economics are against recycling; ‘the monetary 

losses represented by [disposing of waste to landfill] are not high enough 

or visible enough to make a difference‘ 63 . The government, therefore, 

has an important enabling role to play, by using policy levers, 

to create the economic space in which all companies can carry 

out their operations sustainably. 

3.5 The government’s landfill tax has so far failed to change the way the UK 

handles waste or stimulate the necessary investment in recycling 

infrastructure, with the majority of London’s waste (excluding construction 

waste) still being landfilled. The Panel Report of the Early Alterations to 

the London Plan stated that ’few [participants] see [the landfill tax] as 

biting quickly enough to generate the commitment and certainty 

commensurate with meeting the earlier targets in the London Plan’ 64 . 

3.6 In the April 2007 Budget Report 65 , the Chancellor announced that the 

landfill tax will increase annually by £8 per tonne from April 2008 until 

at least 1 April 2010. This is a significant increase and will mean that the 

landfill tax will rise from £21 per tonne in 2007 to £48 per tonne by 2010. 

For businesses that dispose of their waste to landfill, the increasing 

landfill tax will start to impact heavily and will help drive investment in 

alternatives to landfill. 

3.7 Large businesses will likely have taken action as part of their waste 

management contract procurement process to reduce their waste costs 

and introduce recycling systems. Often this will also have been driven by 

a Corporate Social Responsibility (CSR) agenda. Small businesses produce 

only small amounts of waste and will therefore be only slightly affected. 

3.8 In the short term, it is likely that medium sized businesses, that may not 

yet have taken action to prevent waste, will be most affected by 

increasing costs. Higher costs will provide an incentive to reduce waste 

and make other methods of dealing with waste, such as recycling and 

advanced waste technologies, more attractive and financially viable. 

Businesses are already seeing this escalating cost affect their bottom line 

and have begun to seek out more sustainable waste management options.



Case study 1 - Asda signs up to send zero waste to landfill by 2010 

As part of Asda's commitment to zero waste, the supermarket has 

invested £32 million in four recycling facilities at Lutterworth, Wakefield, 

Skelmersdale and Bedford. This enables Asda's fleet of delivery trucks 

to collect cardboard and plastic packaging from the back of stores, 

which is baled and sent for reprocessing. Food waste is sent for in-vessel 

composting, while photographic chemicals are collected to recover the 

precious metals contained in them, such as silver. Two million litres of 

waste oil fats are sent for bio-diesel production and Asda has committed 

to redesign all of its products over the next 18 months to reduce 

packaging volume by at least 10 per cent. 

Source: Asda 

Case study 2 - Banning the waste bin sees recycling levels soar 

Henderson Global Investors is a leading investment manager providing 

a wide range of investment products and services. As part of the 

company’s environmental commitment, recycling in their London 

offices has been stepped up by removing all personal desk bins and 

replacing them with paper bins, putrescible waste bins, lockable bins 

for confidential papers and glass recycling bins. Recycling levels 

have reached 217 tonnes per year, marking a 343 per cent increase 

on previous rates and a dramatic reduction in costs for waste. 

Source: London Remade 

A requirement to prevent waste and recycle 

3.9 From October 2007, the government has required that all waste must 

be treated before it is disposed of to landfill. The new pre-treatment 

requirements, which partly implement the EU Landfill Directive, restrict 

waste that has not been pre-treated from being disposed to landfill. 

The legislation is designed to increase waste recycling and reduce the 

impact of waste when landfilled. Waste producers therefore have 

a choice. They can treat the waste themselves or ensure that it is 

treated elsewhere before being landfilled. 

3.10 The legal obligation for ensuring that no waste ends up in landfill, 

which has not been pre-treated, lies with the landfill operator. 

However, when arranging for their waste management, waste producers 

must understand who is going to treat it, be it themselves or their 

waste collector. This is particularly the case for those businesses 

that contract out their waste management and such businesses 

are responsible for ensuring their contractors work within the law.


3.11 The Environment Agency has stated 66 that for waste that is sent to 

landfill, they consider it good practice for a written declaration to be 

given to landfill operators confirming that treatment has taken place. 

The government is consulting on strengthening the requirement for 

written records to support the implementation of the pre-treatment 

requirements for landfilled waste 67 . 

3.12 The introduction of this legislation could be a truly exciting development. 

By requiring businesses to sort and manage their waste, more businesses 

will seek out recycling services and fewer recyclable materials will be 

disposed to landfill. In reality however, it will only be effective if the 

government requires auditable evidence to support its implementation. 

Making municipal business waste management make sense 

3.13 The government’s Landfill Allowance Trading Scheme (LATS), introduced 

in 2005 to implement the Landfill Directive, focuses on municipal waste, 

collected by local authorities. Around 68 per cent of 

municipal waste is biodegradable 68 , a significant greenhouse gas 

contributor when landfilled 69 . 

3.14 To reduce this negative environmental impact the Landfill Allowance 

Trading Scheme sets targets to reduce the amount of biodegradable 

municipal waste that can be sent to landfill, which will force local 

authorities to make greater use of alternative methods of biodegradable 

waste treatment. Given the huge contribution that landfilling 

biodegradable waste has on climate change some businesses are also 

seeking innovative ways to reduce the quantity of biodegradable waste 

requiring disposal. 

Case study 3 - A socially responsible solution to food waste 

The food sector accounts for over a third of the waste produced in the UK, 

an estimated 17 million tonnes of waste. Some research estimates that 

up to 3.8 million tonnes of this could be recovered for consumption by 

humans or animals. FareShare is a national charity that works with the 

food and drink industry to redistribute quality food to a community 

food network working with disadvantaged people. In 2004 the network 

covered 34 cities and saw the redistribution of 2,000 tonnes of food. 

As a result of the food regularly supplied by over 100 companies, over 

12,000 people eat a meal every day with food provided by FareShare. 

Source: FareShare through London Community Recycling Network 

3.15 The Landfill Allowance Trading Scheme has caused a considerable 

disconnect for local authorities between their obligations under



the Landfill Directive for municipal waste and their statutory recycling 

and composting performance targets, which are only for household waste. 

LATS has effectively acted as a disincentive for local authorities to 

undertake a role in non-household waste management because by reducing 

their non-household waste collections they can artificially provide 

themselves with a ‘safety net’. London's local authority-provided business 

collections peaked in 2004/05, when over a million tones of non-household 

waste was collected. In 2006/07, just 680,000 tonnes was collected 70 , a fall 

of around a third. The implication is that a reduction in waste to landfill is 

being reported where in fact much is still going to landfill, just under a 

different label – as commercial waste rather than municipal waste. 

3.16 Offering waste services to businesses would not negatively affect local 

authorities’ ability to achieve LATS, where services manage the collected 

waste through recycling, composting or advanced waste technologies. 

Equally, as the types of materials produced from retail, office and 

hospitality activities are closely similar to those produced by households, 

household services could be delivered to commercial businesses without a 

significant change to services. 

3.17 This opportunity is not yet being realised in London. Non-household 

municipal waste accounts for about a quarter of London’s municipal 

waste, around one million tonnes, yet just 8.1 per cent of non-household 

municipal waste was recycled in 2006/07 71 . 

3.18 Setting statutory targets for local authorities has made a huge impact on 

household recycling performance over the last few years. In 2006/07, 

22.9 per cent of London’s household waste was recycled, up from just 

nine per cent in 2000/01 72 . The Mayor believes that setting statutory 

municipal recycling targets would increase the amount of business 

municipal waste recycled and would act as an incentive to local authorities 

to get involved in local business waste management. It is unfortunate that 

the new indicators 73 , announced by the government in November 2007, 

again fail to incorporate all municipal waste. 

Targeting waste 

3.19 The government expects levels of commercial and industrial waste 

landfilled to fall by 20 per cent in 2010 compared to 2004 and is 

proposing to set a new national target for the reduction of commercial 

and industrial waste going to landfill 74 . Setting landfill reduction targets 

will send a signal of the improved sustainability expected from the 

business community but must be ambitious and be accompanied by 

recycling targets.


3.20 The government proposes, in Waste Strategy 2007, and subject to further 

analysis, to restrict certain materials from landfill and develop policies 

to effect a reduction in its use 75 . In February 2007, in response to 

disappointment in the impact of the Thematic Strategy on the Prevention 

and Recycling of Waste 76 , the European Parliament called for a total ban 

on landfilling of all recycled materials by 2020, which would be extended 

to all residual waste by 2025 77 . The Mayor supports further restrictions 

as part of the drive to continue to reduce landfill. Table 2 shows how far 

behind the government is in introducing further restrictions compared 

to European neighbours and provides a considerable incentive to move 

forward on their proposal. 

Table 2: EU Member States with supplementary approaches to landfill 

State Action 

Germany 1993 Ban on all non-treated wastes to landfill 

Netherlands 1995 Ban on all wastes that can be reused or recovered 

Sweden 1996 Ban on non-treated municipal waste to landfill 

France 2002 Ban on landfilling non-residual waste 

Sweden 2005 Ban on organic waste to landfill 

Source: Waste Strategy 2007, Defra May 2007, Table 3.1, page 47 

3.21 A concern with the Landfill Allowance Trading Scheme is that it drives 

waste from the bottom of the waste hierarchy up only one step to the next 

poorest solution – incineration – rather than focusing on implementing the 

waste hierarchy from the top down. Research commissioned by the GLA 78 

has shown that the incineration of mixed biomass and non-biomass waste 

is a net contributor to climate change. In electricity only mode, the mode 

under which all of London’s existing and proposed incinerators operate, 

incineration generates up to 83 kg of CO 2 equivalent per tonne of waste 

treated and therefore contributes to climate change. 

3.22 It is likely that the government’s proposed policy to restrict recyclable 

materials from landfill will be linked to their priority waste materials: 

paper, food, glass, aluminium, wood, plastics and textiles. Such a 

restriction could force waste into management routes further up the 

waste heirarchy unless government sets material-specific recycling 

targets and puts recycling infrastructure in place to ensure recycled 

materials are not simply burnt, in the drive to divert material from landfill. 

The government’s carbon assessment 80 of the policy assumes plastics, 

paper and card, textiles, metals and glass are recycled but sets no further 

policy to guarantee this.



3.23 To make progress against the issues raised throughout this chapter, the 

Mayor calls on the government to ensure that effective fiscal and 

legislative instruments are in place to stimulate resource productivity and 

sustainable waste management among London’s businesses. 

Proposal 1 The Mayor calls on the government to ensure that effective fiscal and 

legislative instruments are in place to stimulate resource productivity and 

sustainable waste management among London’s businesses including: 

■ a clear commitment to continue to escalate the landfill tax significantly 

after 2010 

■ a requirement for auditable evidence to support the implementation 

of pre-treatment requirements for landfilled waste from October 2007 

■ statutory recycling and composting targets and indicators for municipal 

waste rather than household waste 

■ recycling and composting targets and indicators for non-municipal 

business waste to complement the national target for the reduction 

of commercial and industrial waste going to landfill 

■ statutory diversion targets and measures to reduce the quantity 

of non-municipal biodegradable waste disposed of to landfill.


3B Making producers responsible 

Introduction 

3.24 Producer responsibility places some of the costs for the management 

of products when they become waste, onto the producers that place 

the products on the market. This is to encourage waste reduction through 

product design and to stimulate high levels of reuse and recycling of 

products at the end of their useful life. 

3.25 A producer responsibility policy underlies the approach taken in 

implementing the European Directive on Packaging and Packaging 

Waste in the UK and is the approach taken in the European Directive 

on Waste Electrical and Electronic Equipment (WEEE) and End of Life 

Vehicles (ELV) Directives, as well as the forthcoming directive on 

Batteries and Accumulators. These products were identified in the 

European Union’s Fifth Environment Action Programme 81 as priority 

waste streams because of growing concern about their impact on the 

environment. The Environment Agency is charged with monitoring 

industry compliance with these producer responsibility regimes. 

Packaging waste 

3.26 For many of the government’s priority material streams 82 (paper, glass, 

aluminium and steel, plastics and wood), legislation already exists to 

encourage recycling. Under the Producer Responsibility Obligations 

(Packaging Waste) Regulations (1997) obligated producers of packaging 

are required to bear the costs of collection, sorting, treatment and 

recycling or recovery. Producers do not have to collect and recycle their 

own materials, instead they must carry out their producer responsibility 

by purchasing packaging waste recovery notes (PRNs) or their export 

equivalent (PERNs). 

Case study 4 - Failing to comply with legislation results in fine 

A luxury car company was ordered to pay more than £27,000 in April 

2006 for failing to comply with the Packaging Waste Regulations. 

Previously advised that it was below the 50 tonne threshold, the company 

should have continued to monitor its activities, particularly since it has 

recorded a marked increase in sales since regulations were introduced. 

Source: Environment Agency: DF/57/06 

3.27 The Mayor has concerns about the ongoing implementation of the 

packaging regulations, in particular that they fail to support local 

recycling and reprocessing and do not consider the quality of recycling 

that is undertaken.



3.28 The Mayor is disappointed that low, incremental targets have been 

proposed by the government for the period beyond 2008 83 . Such minor 

increases will not deliver the required step change in packaging design 

and recycling. Significantly higher targets are required to ensure: 

■ packaging waste producers reduce the quantity of materials 

in packaging products and achieve waste reduction 

■ the waste industry has incentives to extract increasing volumes 

of packaging materials for recycling and reprocessing. 

3.29 Since the introduction of the packaging regulations there has been 

a 20 per cent increase in the level of packaging waste recovery since 

1999 84 . However, the generally comfortable situation for packaging 

producers will mean PRN and PERN values are likely to remain relatively 

low. This will reduce the profitability of collecting packaging materials 

and limit investment in new recycling facilities within the UK. 

3.30 Although the packaging regulations place responsibility on producers, 

the way in which the legislation is implemented in the UK impacts on 

local authorities significantly. Packaging makes up 15-25 per cent by 

weight of household waste 85 and local authority collections are 

responsible for supplying a large proportion of the materials to fulfil 

producer responsibility obligations. The government is developing a joint 

protocol to help local authorities and producers identify the best systems 

for cost-effective collection of packaging waste 86 . The Mayor expects the 

government to ensure that local authorities are fully compensated for the 

role they play in achieving packaging targets. 

3.31 Further, the Mayor expects the government to resolve the flaws in the 

way in which the regulations are implemented, through the PRN/PERN 

system, which are that: 

■ the requirement for obligated businesses to register annually restricts 

long-term investment decisions by compliance schemes 

■ PRN prices are largely fixed by contracts between obligated 

businesses/compliance schemes and domestic reprocessors. Many 

PERNs, however, are sold on a spot market basis, often at a higher 

price, particularly when there appears to be a shortage of tonnage to 

meet obligations. Furthermore, whilst PRN revenues from domestic 

reprocessing must be made transparent and reinvested in new recycling 

infrastructure, there is no such requirement for PERN revenues. As 

a result, there can be more profit to be gained from exporting the 

material than from reprocessing it within the UK – a significant loss 

to the UK economy


■ the PRN/PERN system supports reprocessing without regard for its 

carbon impact. For example, an equivalent PRN/PERN is generated 

from recycling glass bottles back into new glass bottles (closed-loop 

recycling), or from recycling glass into aggregate (open-loop 

recycling). Given the volumes and quality of material sent for recycling, 

both types of recycling play an important role, yet in carbon terms, 

some open-loop recycling, such as recycling glass into aggregate, has 

a negative impact on climate change 87 . The government should look 

to establish a weighting system for PRNs/PERNs, weighted in favour 

of carbon positive recycling, similar to the weighting system given in 

the government’s Energy White Paper 88 for the Renewables Obligation. 

Waste Electrical and Electronic Equipment 

3.32 The Waste Electrical and Electronic Equipment (WEEE) Directive became 

European law in February 2003, setting collection, recycling and recovery 

targets for all types of electrical products. The directive set a household 

collection target of four kg of equipment per head per year by 2006 and 

the government has not yet set a new target. 

3.33 Though accurate data is not available, research 89 indicates that the four 

kg target has been met. However, this relies heavily on the collection 

of fridges picked up under the Ozone Depleting Substances Regulations 

(2002) and it is not yet clear how the UK is doing in all ten categories 

of electrical and electronic equipment covered by the directive. 

3.34 Under the directive, retailers have an obligation to give consumers the 

opportunity to return electrical equipment free of charge when they 

purchase new equipment and producers are responsible for funding the 

collection, treatment, recovery and recycling of electrical equipment 

delivered to authorised facilities, in line with their market share. However, 

the government has chosen to implement the directive by largely relying 

on the existing network of reuse and recycling centres, thereby offering 

a far lower standard of service than specified in the directive as there 

are few collection facilities in London. 

3.35 This approach is unacceptable to the Mayor because the government 

has not reviewed the density of reuse and recycling centres in London 

nor surveyed their suitability to separately collect electrical equipment. 

The Mayor believes the priority should be to provide a network of 

services that are convenient for Londoners and maximise the capture 

of electrical equipment. 

3.36 The Mayor has concerns about the government’s implementation of the 

directive and wants to see:



■ in-store take-back and like-for-like take-back on delivery, which would 

increase the volume of electrical equipment collected because it would 

be the easiest way for all Londoners to participate 

■ collection facilities across London at a suitable density, and that are 

convenient to Londoners, in order to minimise the transport impact 

of collection 

■ greater awareness of the directive by consumers through point of sale 

literature and signage to ensure consumers are aware of their 

responsibility to separate their electrical equipment for collection. 

3.37 While London faces significant challenges as a result of the directive there 

are huge opportunities for London from its implementation. WEEE reuse 

and refurbishment is an industry that fits particularly well with the 

Mayor’s vision for London to be self-sufficient because it can be easily 

located within existing industrial estates. The development of the 

Environcom WEEE recycling facility in the London Borough of Enfield 

is a positive step for London's green economy. The facility will develop 

60,000 tonnes of waste electrical and electronic equipment each year, 

sourced from across London through the new WEEE compliance 

schemes. It will create 150 semi-skilled, full time jobs in an area which 

the London Plan has identified as a priority for the promotion of 

employment opportunities. 

End-of-Life Vehicles 

3.38 Under the European End-of-Life Vehicles Directive producers of vehicles 

are responsible for achieving recycling targets as well as environmental 

standards for the storage and treatment of End-of-Life Vehicles (ELVs). 

3.39 The government’s ELV regulations introduced design standards for vehicle 

manufacturers and environmental standards for the dismantling, recycling 

and disposal of vehicles by authorised treatment facilities, at no cost to 

last owners. 

3.40 The implementation of systems by local authorities, such as Operation 

Scrap-It, to collect abandoned vehicles makes a significant contribution to 

meeting the regulation targets. The Mayor believes that the government 

needs to fully compensate local authorities for their costs, such as for the 

collection, storage and disposal of waste vehicles and officer time. 

Batteries and accumulators 

3.41 The European directive on batteries and accumulators became law in 2006. 

It aims to make businesses that produce and sell batteries responsible for 

the collection and recycling of waste batteries. The directive must come 

into force in the UK in 2008.


3.42 The average household uses 21 batteries a year, all of which could be 

recycled 91 . Under the directive, 25 per cent of batteries will have to be 

collected by 2012 and 45 per cent by 2016. Sweden and Belgium already 

collect 55 and 59 per cent of batteries respectively 92 , compared with a 

collection rate of between 0.5 per cent and two per cent in the UK 93 . 

3.43 Under the directive, any net costs from the collection, treatment and 

recycling of waste batteries are to be met by producers. However, WRAP, 

in addition to working with not-for-profit organisations to establish drop 

off points at supermarkets, has been working in partnership with a range 

of local authorities to trial kerbside battery collections. Currently, 23 of 

London’s local authorities provide at least one collection point for 

household batteries for their residents, six through their kerbside recycling 

service whilst car batteries can be recycled at reuse and recycling centres 

across London. 

3.44 Local authority collection systems will make a significant contribution to 

meeting the batteries directive when it is implemented into UK law, 

for which the Mayor believes they should be compensated. 

Voluntary Producer Responsibility Agreements 

3.45 The government has been working in conjunction with key industry 

sectors to establish voluntary producer responsibility agreements. 

For example, Defra has negotiated voluntary producer responsibility 

agreements with the Direct Marketing Association to increase the 

recycling of direct mail and promotions material (junk mail), the 

Periodical Publishers Association to increase the recycling of magazines, 

and the Newspaper Publishers Association to increase the recycled 

content of newsprint. 

3.46 The government is looking to other sectors of the paper industry 

to establish similar agreements 94 . However, experience clearly shows 

that voluntary agreements too often simply allow industry to avoid 

significant behavioural change 95 . Shortcomings include low participation 

rates and a lack of monitoring. 

3.47 The Mayor believes that the further development of voluntary 

agreements is not appropriate and statutory measures are required. 

It is unclear to what extent businesses will properly enact voluntary 

commitments to prevent waste or promote reuse, composting and 

recycling when there is no immediate economic or regulatory stimulus.



Proposal 2 The Mayor calls on the government to ensure that: 

■ businesses are aware of, and comply with, their producer 

responsibility obligations 

■ the Environment Agency is adequately resourced to enforce 

the regulations 

■ challenging recycling targets are set for producer responsibility 

legislation 

■ the packaging regulations are amended to favour local recycling 

and reprocessing and carbon positive recycling 

■ statutory measures are established to implement producer 

responsibility legislation rather than persisting with voluntary 

agreements 

■ obligated businesses adequately compensate London boroughs 

operating schemes for producer responsibility wastes 

■ the government and obligated businesses run effective communication 

campaigns about producer responsibility legislation to raise and 

maintain awareness of consumers’ responsibilities.


3C Increasing awareness 

and providing information 

It’s not what you know, it’s who you know 

3.48 Making it easier for businesses to recycle by supporting the development 

of convenient and cost effective recycling services should stimulate 

demand for those services. However, while demand is low, there is 

little incentive for the waste management industry to develop and 

expand their waste management services in line with the waste hierarchy. 

This is particularly the case for the private sector, which does not have 

the same legislative drivers as local authorities and is generally driven by 

profit and therefore by demand. During the London Assembly 

consultation, representatives from the waste industry argued that the lack 

of business recycling services in London is a failure of market demand 

not market supply. 

3.49 To inform research undertaken for the London Assembly, a number 

of small businesses were asked what drove their current approach to 

their waste management. For those that were doing nothing or little, 

the responses (Table 3) ranged from a lack of services to costs. 

Table 3: Reasons given by businesses that recycle little or no waste, 

for their inactivity 

Reason % * 

No services provided by my local authority 42 

Will cost us money 20 

Don’t know 18 

No time (either to look into it or to actually separate their wastes) 12 

No space 10 

Source: SMEs and Sustainable Waste Management in London Research Findings, GfK Business, 

July 2007, page 40 

*Note: Respondents could give more than one reason. 

3.50 There are multiple funding routes for environmental initiatives (such 

as the European Union, UK government, local authorities, business 

associations and non-governmental organisations), which have led to a 

fragmented series of initiatives addressing business waste management 

and business environmental performance. The LDA found that over 20 

organisations are working in each London borough to provide 

‘sustainability’ information and advice to London’s businesses, often 

independently of each other 96 . As a result, the Environment Agency 

believe that the majority of small businesses do not know where to turn 

for information and advice on environmental issues 97 . It is crucial that 

businesses are able to easily access advice and information about services



and that services are developed in a coordinated manner to avoid 

duplication and to provide consistency across London. 

3.51 The LDA is already helping to improve coordination of environmental 

business support in London and to deliver advice and support on waste 

and resource management issues to more businesses. The Business 

Resource Efficiency and Waste (BREW) programme is funded by Defra 

using Landfill Tax credits. The programme provides information and advice 

to businesses to help them manage their resources more productively. 

There are a number of national partners delivering a valuable programme 

of free, confidential and independent advice to UK businesses. The 

Regional Development Agencies are coordinating the delivery of the 

BREW programme at the regional level and carrying out strategic resource 

efficiency projects in the regions. The LDA is providing a coordinating role 

to ensure projects fit with the wider goals for London. 

3.52 The LDA will continue to play a key role in providing this coordination 

by delivering support through Business Link London in conjunction with 

the London Environmental Support Service (LESS). LESS is a pan-London 

environmental business support service funded by the LDA and was 

launched in November 2006. Regional development agencies are tasked 

with promoting streamlined advice on resource efficiency, delivered 

through Business Links, as part of the wider programme to reduce the 

complexity of business support and better tailor services to business 

needs 98 . The LDA is developing LESS to provide an enhanced business 

resource efficiency service that is consistent with, and coordinated 

through, the Business Support Simplification Programme 99 . The LDA 

is raising awareness within the business community, and with those 

who have contact with businesses, of the London Environmental Support 

Service and developing partnerships with environmental support providers 

to improve the referrals process. 

3.53 LESS helps businesses improve their environmental performance by: 

■ providing businesses, whether as part of their start-up phase or once 

their business has started operating, with a simple way to access free, 

environmental advice, support and services 

■ developing and promoting best practice examples to demonstrate the 

business opportunities of sustainable resource and waste management 

■ promoting the ‘Enworks’ tool for businesses to collect and manage 

their operations data, including waste and resource management data 

through a specific module


■ maximising the market penetration of publicly funded environmental 

programmes in London, such as Envirowise, the Carbon Trust and 

LDA-funded regional initiatives 

■ identifying where support providers operate to ensure minimal 

duplication and maximise the overall effectiveness of programmes 

operating in London. 

3.54 Most small businesses, however, see their local authority as the most 

credible channel for information and advice 100 and if no information 

is available they may believe they are doing enough 101 . In light of this, 

the London Assembly make the following recommendations to ensure 

small businesses are able to access appropriate support through LESS: 

■ links should be secured to and from the LESS website to relevant 

pages on local authority websites 

■ the LDA should promote LESS to staff working in local authority call 

centres and one-stop-shops. 

3.55 To progress these recommendations, the LDA will be working in 

conjunction with LESS and Business Link London to establish much 

stronger links with local authorities so that they refer businesses to LESS. 

3.56 WRAP is developing an on-line search tool to help small businesses find 

recycling services. The directory will be linked to their website and 

provides a postcode based search facility. Service providers will be able 

to add and amend information on their services and a regional advisor will 

maintain the directory. This service was launched in September 2007, and 

is a really positive addition to London’s business support service portfolio. 

The call to action 

3.57 Increasing numbers of businesses are seeking out support from bodies 

such as Business Link London and LESS, but it is still essential to raise 

and maintain awareness among businesses of their legal environmental 

responsibilities and the significant and negative economic impact of 

unsustainable resource use. 

3.58 It is significant that 18 per cent 102 of small businesses that do not recycle 

do not know why they are not more active. Evidently they have not 

thought about the issue or realised that they could do more. Small 

businesses are largely self-reliant and may not think they need any advice 

as their existing processes run well. They are less likely to be prompted to 

think about their waste, as they are outside regulatory mechanisms such 

as producer responsibility 103 .



3.59 A coordinated, business-focused communication campaign, similar 

to the Mayor’s Recycle for London campaign targeted at householders, 

is required to demonstrate the environmental and economic case for 

sustainable resource management. Linking to existing messages and 

initiatives, the campaign could be targeted towards specific business 

sectors and would be sensitive to businesses’ widely varied motivation 

to change, be that cost savings, business and market opportunities 

or a responsibility for the environment. 

3.60 Such a campaign would also need to attract employees; a survey 

of Londoners found that while 83 per cent say that that their 

workplace provides adequate recycling facilities, nearly half do not 

use those facilities 104 . 

3.61 An awareness-raising campaign will not be sufficient in isolation. 

New methods of communicating with businesses should also be 

considered. Local authorities already communicate with local businesses, 

through the collection of business rates, for example, and this could 

provide an ideal conduit by which to communicate environmental 

information and advice. This could particularly be used to raise awareness 

of legal environmental responsibilities, for example, by working with 

the Environment Agency to promote NetRegs, a website that contains 

comprehensive business-focused information about environmental 

legislation and obligations. 

3.62 Some local authorities have established their own green business 

programmes, for example: 

■ the Clean City Awards Scheme, for businesses within the City of 

London’s square mile, runs business seminars at which best practice 

can be shared 

■ Envibe, for businesses within the London Borough of Croydon, 

provides links to a network of specialist organisations 

■ Positive Environment Kingston, a joint initiative between Kingston 

upon Thames Council and Kingston University, provides students 

as Environmental Mentors to local businesses. 

3.63 Business Improvement Districts are developing environmental forums 

and programmes for local businesses, such as ‘Go Green’ the London 

Bridge Environment Forum launched in October 2007. Businesses 

within the London Bridge area will be able to attend networking 

meetings, access environmental support and receive regular emails 

detailing local environment issues.


3.64 These programmes are welcome and the Mayor would like to see more 

local authorities and Business Improvement Districts establishing green 

business programmes, through which local businesses can access 

sustainable waste management services and support. 

3.65 It is essential that organisations that provide information and advice 

to London’s businesses, and universities that educate London’s business 

managers of the future, investigate ways in which environmental issues 

can be integrated into their programmes. This would enable them to 

demonstrate the business opportunities that are possible from improved 

environmental management and foster a responsibility for the 

environment among London’s business community. This is a particular 

opportunity for those involved in providing information to start-up 

businesses to establish best practice regarding waste management right 

from the start. 

Case study 5 - Environmental seminars ensure business start ups 

are ahead of the game 

In 2003 the Prince’s Trust won European Regional Development Funding 

to extend its ‘Young Entrepreneurs’ business seminars to include 

environmental awareness. Since then, London Remade has delivered ten 

sessions to over 100 environmental entrepreneurs. The Prince’s Trust was 

driven by the need to ensure those starting out in their business are well 

informed about their waste management obligations and well equipped 

to take advantage of the opportunities that sustainable resource 

management brings. As a result of the training, the entrepreneurs are 

equipped with information they need to control their environmental 

impact and increase their competitiveness. 


Proposal 3 The London Development Agency will coordinate the provision 

of information and advice about resource productivity and sustainable 

waste management to London's businesses by: 

■ promoting coordinated advice on resource efficiency delivered primarily 

through Business Link London, and developing strong links between 

the relevant delivery provider and other stakeholders including 

London’s business support programme providers and London boroughs 

■ working with the Mayor and partners to deliver a targeted 

communications campaign to raise and maintain awareness 

among London’s businesses of resource efficiency and sustainable 

waste management



■ ensuring their partners integrate information about resource efficiency 

and sustainable waste management into their business support 

programmes. 

3.66 Some businesses, large and small, are already well ahead, implementing 

innovative programmes and striving for higher and more wide-reaching 

environmental targets. The Mayor wants to work with these businesses 

in London to establish a cross-sector business-led council. These 

environmental champions will forge the path by which London can 

achieve environmental excellence. 

3.67 The council would offer strong leadership and disseminate best practice 

to the wider business community. The council’s activities will encourage 

all businesses to take action to use resources and manage waste 

sustainably and reduce the business community’s contribution to climate 

change. The council could link to the London Sustainable Development 

Commission’s London Leaders, the UK Business Council for Sustainable 

Development and the International Panel on the Sustainable Use of 

Natural Resources proposed in the Thematic Strategy on the Sustainable 

Use of Natural Resources 105 and WRAP’s Courtauld Commitment. 

Proposal 4 The Mayor will establish a London business council to bring together 

London’s business leaders to champion resource productivity and 

sustainable waste management within a business environment.


3D Facilitating the development 

of collection services 

The collection conundrum 

3.68 The collection of business waste for recycling or treatment is complicated 

by two issues: 

■ service providers are found in the public, private and third sectors and 

each sector has very different reasons for collecting, or not collecting, 

business waste 

■ waste producers have differing motivations for reconsidering their 

current arrangements and looking for more sustainable options. 

It is small businesses that are a particular concern with regards 

effectively changing waste behaviour. Medium and large businesses 

are more likely to be motivated by economic drivers to put in place 

waste reduction and recycling systems since they generally produce 

larger volumes of waste. 

3.69 Currently, around one million tonnes of business waste (largely from the 

commercial sector) is collected and managed by London’s boroughs. The 

remaining 13.8 million tonnes of business waste is managed by the private 

sector. Therefore, although local authorities play a key role, particularly for 

small businesses, they will never dominate the business waste service market. 

3.70 Local authorities’ roles are complicated by: 

■ the private sector, which is likely to cherry pick businesses that produce 

more waste, leaving local authorities with a less profitable portfolio 

■ the Landfill Allowance Trading Scheme (LATS), which acts as a 

disincentive for local authorities to undertake a role in providing 

business waste and recycling services and may make local authority 

services uncompetitive 

■ geographical limitations, which is a hindrance for companies with 

sites across a number of boroughs. Instead they will seek a contract 

with a waste management company that can operate across 

borough boundaries. 

3.71 These factors mean that businesses cannot rely on their local authority for 

a waste or recycling service. In London, a recent survey reported that 

27 of the 33 London boroughs provide trade waste services and 15 

offer a trade waste recycling service 106 . 

3.72 Small businesses, particularly, look to their local authority to manage their 

waste. In a survey conducted for the London Assembly, 42 per cent of 

businesses claimed they do not recycle because there were no services



provided by their local authority and 22 per cent believed (incorrectly) 

that their waste is the responsibility of their local authority 107 . 

3.73 Defra published guidance to local authorities on municipal waste in June 

2006 108 . The guidance states that waste collection authorities have a duty 

under the Environmental Protection Act 1990 to arrange for the collection 

of commercial waste where requested to do so. 

3.74 In a letter to local authorities, Defra clarified that ‘if a waste collection 

authority declines to collect commercial waste when requested to do so, 

and does not arrange for its collection by a private sector contractor, it is 

likely to be acting in breach of its duty… If a request is made of the 

authority to collect commercial waste, the authority must have in place 

arrangements to meet the request’ 109 . The Mayor expects the government 

to monitor the way in which waste authorities are meeting their duty and 

how they will enforce the act. 

3.75 The potential community benefits from borough-run business waste 

and recycling services include: 

■ making business waste services consistent with household services, 

which could help employees bring their good habits from home 

into work 

■ having a single vehicle collecting from every property on the street, 

rather than one for households and (at least) one for commercial 

properties, could reduce noise and air pollution associated with the 

collection of waste 

■ by controlling local business waste and recycling collections, local 

authorities can significantly improve the street scene by reducing litter 

arisings, harmonising collection times and ensuring materials are put 

out for collection in consistent and suitable containers. 

3.76 Clearly, however, if local authorities are to have an enlarged role in 

business waste management, they need specialised advice and support 

and may require start-up funding. 

3.77 Waste Strategy 2007 states that the government will encourage local 

authorities to take on a wider role, in partnership where necessary, to help 

local, particularly small, businesses reduce and recycle their waste 110 . As 

part of Defra’s Business Resource Efficiency and Waste (BREW) 

programme, the BREW Centre for Local Authorities 111 has been 

established to be a central support service for local authorities by:


■ developing a network of local authority officers providing services to 

their local business community 

■ collecting and disseminating best practice on how to support 

businesses in using their resources more productively. 

It’s not what you do, it’s the way that you do it 

3.78 There is significant homogeneity of the wastes produced by businesses 

within the commercial sector, with each type (offices, retail and 

hospitality) producing one material of significant volume. It is, therefore, 

likely to be economically and environmentally preferable to provide 

dedicated services to collect and reprocess these materials, separately – 

saving on processing costs and guaranteeing a higher quality, higher 

value material – rather than replicating a co-mingled collection scheme 

the local authority may use to collect recycling from households. 

3.79 Another consideration is to ensure services are tailored to businesses’ 

operational needs. As Table 3 shows, issues concerning the space required 

to store additional recycling containers are a concern for small businesses. 

So too is the perception that introducing a recycling service will be 

difficult and using it will be time consuming. Small businesses may 

not have the resources to site containers and analyse their waste 

composition and may need an irregular or infrequent collection frequency. 

3.80 In March 2005, the Mayor launched a Trade Waste Recycling Best Practice 

Guide 112 for local authorities, which aims to demonstrate the opportunity 

that business waste recycling presents. Based on case studies, it builds on 

the lessons learnt by local authorities that are operating successful 

business waste recycling schemes. The guidance identifies the key 

considerations that need to be taken into account when implementing a 

business waste or recycling scheme, and develops the considerations into 

a practical, action-oriented plan. 

Case study 6 - Encouraging the sustainable option through 

pricing mechanisms 

Southwark Council provides a trade waste recycling collection service 

for materials including glass, cans and paper via a range of receptacles. 

The council provides collection on a flexible basis, collecting up to five 

times a week where its customers require such a service. The council 

charges for receptacles on a per-lift basis, with an additional weekly 

charge to rent each container. Charges for recycling collection are at 

a reduced rate from normal refuse collection. The reduced rates have 

significantly contributed towards requests for trade waste recycling 

services over the past year. Charging per lift and implementing a weekly 

container hire charge offers incentives for waste reduction. 

Source: Greater London Authority Trade Waste Best Practice Guide



3.81 Another opportunity for local authorities is to collect business waste and 

recycled materials at their reuse and recycling centres, however, the current 

network of reuse and recycling centres is not sufficient to offer a 

comprehensive service Londonwide. Local authorities should investigate 

the capacity of their reuse and recycling centre network to collect business 

waste and identify sites for new centres to build capacity within London. 

Proposal 5 The Mayor expects London boroughs to offer competitive waste and 

recycling collection services for local businesses, in partnership where 

necessary, including: 

■ recycling services of at least the same materials as their household 

collections 

■ organic kitchen waste collections 

■ accepting business waste for reuse or recycling at their reuse and 

recycling centres 

■ actively promoting their services to businesses. 

3.82 Local authorities will only ever be responsible for a small proportion of 

business waste, therefore the private and third sectors must also take 

responsibility to offer reuse and recycling services to businesses. Waste 

Strategy 2007 tasks the waste management industry with creating a 

’modern, efficient and environmentally responsible industry working 

closely with businesses, local authorities and regulators to produce the 

best balance of environmental, economic and social outcomes’ 113 . 

3.83 Support is increasingly being given to the waste management industry to 

expand their businesses and tailor their services to suit particular business 

sizes and sectors. For example, WRAP has been funding service providers 

to develop their recycling services for small businesses and the LDA 

is supporting the development of food waste collection schemes 114 . 

3.84 Organisations and services supported by WRAP, the LDA and the BREW 

Centre to develop recycling services for businesses must be sustainable 

in the long-term. Providing free or subsidised services as trials could set 

false expectations and undermine services that are run at cost to 

customers. Causing customers to swap on and off a range of free 

or subsidised services will not achieve the principle objective; to increase 

demand and expand the market. Further, results from trials will not 

be indicative of the reality of the success of an unsubsidised service 

in the long run.


Case study 7 - Help given to make recycling easy for small 

businesses 

A series of trials aimed at increasing participation in recycling by small 

businesses have received funding from WRAP. Paper Round is a large 

specialist office recycling businesses with more than 3,000 customers 

in central London. The trial is targeting small businesses in the south 

east London areas of Lewisham, Bromley, Woolwich and Croydon and 

providing a collection and recycling service for paper, cardboard, glass, 

cans, tins, plastic bottles, printer cartridges and IT equipment. The 

businesses can sign up to a membership service that allows them 

a certain number of collections each year or a pay as you go service 

which is ideal for businesses needing less frequent collections. 

Three hundred businesses will be signing up to participate in the trial. 

Paper Round is also operating a trial to target hotels in central London 

areas of Westminster, City of London, Kensington and Chelsea, 

Camden and the Docklands. Paper Round will provide a collection 

service for paper, cardboard and glass. Twenty-five hotels will be 

recruited to participate in the trial and will be provided with wheeled 

bins and regular collections. The aim of the trial is to make recycling 

more attractive and convenient for hotels by offering them a service 

that collects a range of materials. 

Source: The Waste and Resources Action Programme



3E Facilitating the development 

of infrastructure 

Introduction 

3.85 The London Plan self-sufficiency targets predict that London will be 

managing 20.6 million tonnes of waste in 2020 115 (Table 4). Targets for 

the percentage of the total waste produced that should be reused, 

recycled or composted proposed in the London Plan have been adopted 

as Policy 1 of this strategy, while targets for the amount of waste to be 

managed in London have been adopted as Policy 2. 

Table 4 Net self-sufficiency: waste to be managed in London 

Amount of London’s 

waste to be managed 

within London 

2010 2015 2020 

amount % amount % amount % 

million million million 

tonnes tonnes tonnes 

Municipal solid waste 2.4 50 3.9 75 4.6 80 

Commercial and industrial 5.9 75 7.1 80 8.4 85 

Construction, demolition 

and excavation 

7.4 95 8.2 95 7.7 95 

All wastes 15.8 75 19.2 80 20.6 85 

Source: The London Plan Spatial Development Strategy for Greater London: Housing Provision 

Targets, Waste and Minerals Alterations, Greater London Authority, December 2006 

Made in London 

3.86 Achieving the London Plan recycling targets will revolutionise waste 

management in London from a situation in which waste is exported for 

disposal in landfill to a situation in which London is processing waste and 

recycled materials and exporting recycled (i.e. secondary) materials and 

recycled products. Developing markets for recycled materials helps ensure 

that recycling is economically viable. 

3.87 The UK has traditionally been an importer of raw materials but the 

increase in recycling means that it now has its own stock of resources. 

London’s waste paper, for example, has been called an ’urban forest’ 116 . 

If material can be recovered and reprocessed more cheaply than primary 

production then a chain of new economic activity is opened up, which 

has been termed the ‘secondary materials economy’. 

3.88 However, instead of leading the change towards higher recycling and 

building an industry behind it, ’the UK has been a follower’ 117 . Waste


is still treated as waste rather than as a resource of materials and energy, 

and recycling collections have not been developed in tandem with 

reprocessing infrastructure and recycled material industries. 

3.89 In 1998, research by Ecologika asserted that ’there is clearly the potential 

for a significant increase in the capture rate of London’s recycled materials 

and an opportunity for reprocessing industries to be established in and 

around London‘ 118 . To evidence this claim in the significantly different 

economic environment that has developed over the last decade, the GLA 

and LDA commissioned research 119 into the ways in which the Mayor and 

LDA could intervene to develop appropriate reprocessing infrastructure 

within London. The report concludes that there are specific opportunities 

for London to develop recycling and reprocessing infrastructure within 

London and in partnership with surrounding regions. Three approaches 

were recommended for London: 

1 Developing reprocessing infrastructure with a relatively small land-use 

requirement and low water demands. The development in the London 

Borough of Barking and Dagenham, in 2008, of the first plastics 

reprocessing facility in the UK to produce food-grade PET and the 

first facility in the world to produce food-grade HDPE, by Closed Loop 

London, is an example of where this approach has already been 

successful in London. 

2 Supporting the development of innovative down-cycling technologies 

and markets for these products, such as the successful Day Aggregates 

glass recycling facility in the London Borough of Greenwich. Other 

opportunities may include mixed paper for use in insulation materials, 

such as Excel Fibres in South Wales, or mixed plastics for use in 

drainage material, such as Econoplas in Scarborough. Whilst this 

element of the recycling industry may not be regarded with the highest 

priority for London because the focus should always be on high value 

applications, it should be recognised as having an important role to 

play. 

3 Sorting and cleaning materials to produce a higher quality - and thus 

higher price - output for sale to reprocessors may enable a greater 

proportion of material to be suitable for domestic reprocessing. This 

is important because it would reduce reliance on potentially volatile 

global markets and reduce the distances that materials are transported. 

Getting a higher price for every tonne of material collected in London 

would additionally bring greater revenues to those collecting and 

managing the materials and stimulate further investment. 

3.90 Increasingly (and particularly in the municipal waste stream) materials are 

being collected co-mingled and sorted for recycling using Materials



Reclamation Facilities (MRFs). In many cases materials being recovered 

are of poor quality and are unsuitable for domestic markets 120 . 

3.91 WRAP has commissioned a project that aims to review the quality of MRF 

technologies and processes currently employed in the UK 121 . This will 

provide the industry with the knowledge required to upgrade MRFs so 

that materials collected can be reprocessed in the UK by meeting market 

requirements for higher-quality materials. 

3.92 For London to reap the rewards offered by the secondary materials 

economy, strategic coordination between expanded sources of supply 

and new reprocessing is required. In 2003, the Mayor's Municipal Waste 

Management Strategy 122 proposed to investigate the benefits of 

Londonwide consortia for recycled materials (Proposal 76). 

3.93 The development of a consortium or a ‘trading hub’ to coordinate the sale 

of all London’s recycled materials would enable London to amass materials 

of a sufficient volume to make the development of domestic reprocessing 

infrastructure within London and in partnership with surrounding regions 

viable 123 . It would also provide stability to the marketplace by enabling 

the development of secure and long-term contracts that would be able to 

serve larger, international markets, while seeking the best price for 

London’s recycled material. It may also enable the movement of recycled 

materials to be coordinated, which would reduce the associated transport 

impacts of recycling. 

3.94 A trading hub could work with waste collectors from the public, private 

and third sectors and reprocessors and would be expected to become 

financially self-sufficient. The GLA and LDA have held discussions about 

joint working with neighbouring regions through the inter-regional forum 

to initiate the development of partnerships. 

Proposal 6 The Mayor will investigate and, if appropriate, implement an appropriate 

vehicle to act as a trading hub for recycled materials across London. 

21st century energy 

3.95 Waste that cannot be recycled is still a valuable resource and its energy 

can be recovered using advanced waste technologies such as anaerobic 

digestion, pyrolysis and gasification. This energy will be either partially 

or entirely renewable, depending upon the feedstock. The Stern review 124 

indicated that the technical potential to produce energy from residual 

waste could be substantial, potentially accounting for as much as 

17 per cent of the UK’s electricity consumption by 2020 125 .


3.96 The Mayor is taking a leading role in developing advanced waste 

technologies. The Panel Report produced as a result of the Examination in 

Public of the Early Alterations to the London Plan, asserted that the 

‘Mayor has taken a bold but necessary step in the right direction by 

stating a preference for [advanced waste] technologies’ 126 . 

3.97 The London Climate Change Agency has been established to deliver 

decentralised energy and renewable fuels, including from waste. 

The agency will develop facilities, for example through its contract 

with London Remade, such as anaerobic digestion, gasification and 

pyrolosis, which offer the possibility of producing renewable fuels 

including hydrogen. This in turn can be used to run London’s buses 

and other vehicles, completing a cycle that links energy with water, 

waste and transport. The London Hydrogen Partnership reported 127 

that sufficient hydrogen could be produced from gasification, 

pyrolysis and anaerobic digestion of London’s waste, to fuel 13,000 

buses (compared to the present fleet size of over 8,000). 

Case study 8 - A solution for our waste and energy crisis 

The London Thames Gateway Development Corporation approved 

planning permission in September 2006 of a new technology waste 

treatment facility in Rainham. Proposed by Australian-owned Novera 

Energy, the £25 million facility will use a gasification process to generate 

electricity from secondary recovered fuel. Shanks East London are 

negotiating an agreement to supply secondary recovered fuel to Novera 

from their Mechanical Biological Treatment facility next door at Frog 

Island. The gasification facility will process about 13 tonnes of refusederived 

fuel every hour – about 90,000 tonnes each year – generating 

about 10MW of energy, which may be used by the nearby Ford Motor 

Company factory at Dagenham. 

Source: Mayor of London Planning Development Unit 

Case study 9 - Delivering the Climate Change Action Plan 

The London Climate Change Agency is providing funding and support 

to London Remade to develop four new recycling and reprocessing 

facilities in London to turn waste into renewable energy. The £225,000 

project will help deliver the aims of the Mayor's Climate Change Action 

Plan to reduce London's carbon footprint. If all of London's waste that 

cannot be recycled and currently goes to landfill were used to generate 

energy, it could generate enough electricity for up to two million homes 

and heat for up to 625,000 homes.



At least one facility will be brought to financial close by September 

2008 under the terms of the LDA funding. This is only the start of 

a programme of work that could see a renewable energy system 

developed from London’s own resources that would otherwise have 

been landfilled or incinerated. 

Source: London Climate Change Agency 

3.98 In August 2006, the Mayor announced 128 the partnership between the 

Clinton Climate Change Initiative and the Large Cities Climate Leadership 

Group (C40), which is chaired by the Mayor. Amongst other things, 

the initiative seeks to use the potential purchasing power of the C40 

cities to lower the prices of energy saving products and speed up the 

introduction of green policies. The initiative demonstrates the Mayor’s 

track record of leading the development of partnerships to effect 

change within the market. 

3.99 Amongst the procurement initiatives, to be developed by the Clinton 

Climate Initiative for the C40, will be those for advanced waste 

technologies. The approach is likely to involve negotiating links between 

customers, suppliers and financial institutions to create a mass market 

with economies of scale, together with funding mechanisms. Procurement 

initiatives are not confined to the C40 cities but are expected to roll 

out to cities worldwide. 

Making productive use of kitchen waste 

3.100 More than half the nation’s total restaurants are in London 129 and there 

is a real opportunity for the waste industry to develop in-vessel 

composting and anaerobic digestion facilities for commercial organic 

kitchen waste. In-vessel composting and anerobic digestion facilities 

have been developed that comply with the Animal By-Products 

Regulations (2005), which set strict conditions for the composting 

or processing of food waste that contains meat or animal by-products. 

Processing organic waste will ensure biodegradable waste is diverted from 

landfill, which will reduce the production of greenhouse gases, and ensure 

that resources are captured in the form of compost and energy. 

3.101 Recent research by the Environment Agency 130 showed that around 

514,000 tonnes of animal and vegetal (food) waste is being collected 

separately, but that over half (301,000 tonnes) is being sent to landfill, 

a missed opportunity to generate energy through anaerobic digestion. 

3.102 Consultation, undertaken by the LDA, has shown that investors have 

begun to finance the processing infrastructure needed to treat organic


commercial waste, however, collection systems are poorly developed. 

In response, the LDA has recently tendered a project to facilitate the 

development of markets for London’s food-related waste through 

supporting at least one pilot food waste collection scheme 131 . Bringing 

material to market will provide a catalyst for further investment in 

processing infrastructure. 

Case study 10 - A viable alternative to sending food waste 

to landfill 

Bexley Council is offering all businesses which generate food waste - 

such as bars and cafes - food waste collections similar to those it 

provides to householders. The move follows a six-month trial subsidised 

by WRAP and the London Development Agency, in which Bexley collected 

25 tonnes of food from 75 businesses since February 2007. Bexley 

is providing participating businesses with a kitchen caddy and either 

a 240 litre wheeled bin or two 140 litre wheeled bins and service has 

had a positive response from SMEs in the area who wanted to recycle 

more but lacked the appropriate infrastructure. The service has been 

priced to be competitive but cheaper than landfill. 

Source: ‘Bexley launches SME food waste recycling service’ Letsrecycle article, 

4 September 2007 

Proposal 7 The London Development Agency will develop at least one demonstrator 

project that develops local sources of renewable fuel from waste that 

would support a future move to a hydrogen economy. 

Growing London’s green industries 

3.103 The sustainable development of the green industries sector will lead 

to new training and employment opportunities for Londoners and 

further contribute to London’s sustainable economic growth. London’s 

environmental sector covers a diverse range of activities undertaken by 

the public, private and third sectors employing around 140,000 people 132 . 

Although there is no employment data on specific elements of the 

environmental sector, the waste industry is a major employer of people 

across the social spectrum. Creating employment and training 

opportunities through sustainable resource management is a benefit 

to London’s economy, people and environment. 

3.104 The Panel Report, produced as a result of the Examination in Public 

of the Early Alterations to the London Plan, recognises that developing 

London’s green industries ‘will be positive, with the potential to create 

jobs, produce recycled materials and energy and attract investment in 

supporting infrastructure… London must grab the opportunities or they



will go elsewhere’ 134 . The LDA is ideally placed to link in to the Mayor’s 

skills and employment agenda to ensure that the economic benefits from 

the growth of the green industries sector reach those most in need. 

Case study 11 - A social enterprise solves a big waste problem 

When HSBC relocated to Canary Wharf in 2002 the closure of 17 central 

London offices left them with over 3,000 tonnes of redundant furniture. 

The financial services group signed up with Green Works social enterprise, 

which revamps office furniture and sells it at very low cost to community 

groups. Green Works has expanded from a single pilot warehouse to a 

national network handling 12,000 tonnes of furniture a year. In the 

process it has provided more than 80 jobs almost half of them for longterm 

unemployed or homeless people. HSBC’s one-off recycling contract 

has led to an ongoing relationship and Green Works regularly processes 

furniture from HSBC sites across the UK. 

Source: Green Works 

Case study 12 - Closing the loop benefits London’s economy 

Since 2000, the GLA has been signed up to the Local Paper for London 

scheme, which is a sustainable local paper-recycling scheme for office 

paper. Once joined up to the scheme, offices send their white office paper 

to the paper mill, UK Paper in Sittingbourne, to be recycled and then buy 

back the top quality locally recycled paper that is produced. This local 

cycle reduces transport to a minimum, and ensures that high quality white 

paper is recycled rather than wasted. Jobs in London benefit too, with 

a new job in paper recycling created for every 19 new members on the 

Local Paper for London scheme. 

Source: BioRegional 

3.105 A skilled and competent workforce is vitally important if the waste 

industry is to meet the challenges presented by new and existing 

legislation and technologies. A report published by the London Energy 

Partnership 135 found that ’energy efficiency and renewable energy are not 

discrete sectors…it can therefore be very difficult to identify skills and 

training needs…and there is not a clear lead for skills and training for the 

industry as a sector’ 136 . The same is likely to be true for the waste 

management industry. 

3.106 Research undertaken for the London Development Agency 137 suggests 

that women are generally under-represented across the waste industry. 

People of black, Asian and minority ethnicity (BAME) are also underrepresented 

– 75 per cent of the waste industry workforce is white 138 –


particularly in senior roles and especially within BAME communities 

other than black and Asian communities. 

3.107 There is an opportunity to work with minority groups to promote the 

different workforces in London and specifically what the waste and 

environmental industries have to offer. The London Environmental 

Support Service, as part of its role to disseminate best practice, could 

be a conduit, for example by promoting successful, diverse businesses 

in case study format. 

3.108 In May 2007, the government announced 139 the development of a joint 

industry regulator and skills council training plan to improve levels of 

competency within the waste sector and a strategy to address any skill 

shortages or gaps. For example, ensuring enough graduates are entering 

the industry, sufficient specialists are available and that there is an 

appropriate level of training and competence within the industry. 

3.109 As part of a package of powers announced by the government in July 

2006 140 , the Mayor is chairing a new London Skills and Employment 

Board that will develop a strategy for adult skills and employment 

in London. To complement and deliver the government’s joint training 

plan 141 in London, a clear opportunity for the London Skills and 

Employment Board could be to address the issue of green industry 

skills and ensure that the opportunities for the equality target groups 

to benefit from the job creation aspects of this strategy are facilitated 

and promoted. 

Financing the development of infrastructure 

3.110 The private sector has identified that waste technologies offer a good 

investment in light of rising landfill tax and the Landfill Allowance Trading 

Scheme. Local authority contracts offer lower risk (long-term, constant 

waste streams) compared to private (business waste) contracts that tend 

to be short-term with fluctuating waste quantities. 

3.111 London Remade’s ‘Leave no Footprint’ project aims to expand London’s 

recycling capacity by matching investors with investment opportunities 

in waste and recycling. It will provide support to those bringing recycling 

and reprocessing infrastructure to London. 

3.112 Without the development of new waste facilities and associated 

infrastructure, London will not meet the London Plan self-sufficiency 

targets or realise the economic opportunities of reprocessing recycled 

materials and creating energy.



3.113 In response to the review of the Mayor’s powers and the Mayor’s proposal 

for a London single waste disposal authority, additional powers for the 

Mayor of London were announced by the Department of Communities 

and Local Government (DCLG) in 2006. One element of the new powers 

was for the establishment of a London Waste and Recycling Board, 

managing a new London waste and recycling fund. 

3.114 The government has identified £60 million over three years, from the 

Comprehensive Spending Review, for the fund to spend to develop 

London’s municipal waste management services and infrastructure. 

The Mayor, through the LDA, has committed to provide £18 million 

worth of funding over three years to support the development of 

new waste infrastructure in London. 

3.115 The Mayor is proposing to work with the commercial sector to deliver 

the vital waste infrastructure London needs and is looking to the London 

Development Agency to investigate establishing a fund to achieve his 

objectives for business waste. 

Proposal 8 To contribute to the development of business waste infrastructure in 

London, with sufficient capacity to achieve the London Plan selfsufficiency 

targets, the London Development Agency will investigate: 

■ establishing a fund for business waste infrastructure 

■ attracting partners and leverage additional investment to the fund 

■ supporting the development of businesses and social enterprises 

that prevent waste, collect and manage resources in London or 

develop products made from recycled materials 

■ delivering programmes that support innovation in the green 

industries sector. 

3.116 The government's Enhanced Capital Allowances offer tax benefits 

for businesses, including the waste industry, for: 

■ energy-saving plant and machinery 

■ low carbon dioxide emission cars and natural gas and hydrogen 

refuelling infrastructure 

■ water conservation plant and machinery. 

3.117 In Waste Strategy 2007, the government announced it is introducing 

enhanced capital allowances for investment involving the use of 

secondary recovered fuel for combined heat and power facilities 142 . The 

Mayor believes this should be extended to include equipment used in 

advanced waste technologies. These present a substantial opportunity to


divert waste from landfill and conventional incineration and produce 

renewable energy from residual waste. 

3.118 The government’s Energy White Paper 143 , through its Renewables 

Obligation includes greater support for anaerobic digestion, gasification 

and pyrolysis. These changes will encourage greater recovery of 

renewable energy from waste through anaerobic digestion and other 

advanced waste technologies. It is disappointing this strong support 

of advanced waste technologies is not continued through into the 

government’s waste strategy. 

Proposal 9 The Mayor will promote and encourage the use of advanced waste 

technologies to manage London’s business waste and calls on the 

government to make advanced waste technologies eligible for Enhanced 

Capital Allowances. 

Planning for infrastructure development 

3.119 During the London Assembly consultation, representatives from the waste 

industry argued that addressing the waste management capacity gap 

relies more on releasing land on which facilities can be developed, than 

finding finance. 

3.120 Planning for the management of London’s wastes falls within the remit 

of the London boroughs as planning authorities. Strategic planning for 

London’s waste at a regional level has been strengthened through the 

London Plan and its Alterations and at a national level through recent 

changes including Planning Policy Statement 10 (PPS10) Planning for 

Sustainable Waste Management 144 . This planning framework intends 

to create an integrated, plan-led system for managing London’s wastes. 

This strategy supports the existing planning framework and defers to 

the London Plan for planning policy. 

3.121 In 2006, Government Office for London, the GLA, London Councils 

and the Association of London Borough Planning Officers commissioned 

an exercise to apportion tonnages of municipal, commercial and industrial 

waste at London borough level, as required by PPS10. The apportionment 

was considered by the Examination in Public in July 2007, as part of the 

draft Further Alterations to the London Plan 145 . The panel supported the 

apportionment, identifying that delivering the borough apportionment 

will create real local opportunities and will lead to ’the introduction of 

newer technologies that should be seen as an employment opportunity… 

in a cleaner and much more attractive built and environmental context’ 146 .



Proposal 10 The Mayor expects London boroughs to develop Core Strategies, which 

commit the authority in their Local Development Framework to: 

■ achieve the London Plan and Municipal Waste Management Strategy 

recycling targets 

■ specify in which Local Development Scheme documents they will 

allocate sites to achieve their apportionment, set through the 

London Plan 

■ establish criteria to determine waste planning applications while 

preparing more detailed proposals. 

3.122 The Mayor expects that waste and reprocessing facilities will not be 

limited to materials and wastes from specific sources, for example, only 

accepting municipal waste, but will have contracts across the public and 

private sector. This will ensure that facilities operate at capacity, reduce 

the duplication of facilities and may assist the development of local 

facilities, which reduces transport requirements. 

3.123 This approach is supported by the government. In Waste Strategy 2007 147 

the government has stated that funding mechanisms, such as Private 

Finance Initiatives, will not prevent local authorities and their contractors 

from developing facilities to cater for both municipal and business waste. 

Defra’s Waste Infrastructure Delivery Programme (WIDP) will ensure that 

the diversion of municipal waste from landfill is achieved, but it will seek 

to do so through joint merchant/municipal facilities where appropriate. 

3.124 As an example, the East London Waste Authority’s contract with Shanks 

allows them to sell any short-term surplus capacity to third parties. 

Therefore, excess capacity created through waste prevention and recycling 

of municipal waste has a commercial value. 

3.125 Defra’s Planning Systems Guidance 148 and a Planning Health Framework 149 

encourage a constructive approach to waste planning, identifying actions 

that will facilitate favourable determinations of planning applications and 

speed the delivery of waste infrastructure. 

Proposal 11The Mayor expects London boroughs to: 

■ provide capacity, where appropriate, for non-municipal waste when 

developing waste facilities 

■ explore opportunities to develop waste management infrastructure 

that maximises the potential use of water and rail transport 

■ explore opportunities to develop waste management infrastructure 

on-site as part of any site development or redevelopment.


Minimising the transport impact of services 

3.126 The distance and mode by which materials are transported has a major 

bearing on whether the overall effect of reusing, composting, recycling 

and generating energy from waste is sustainable. Transport has a negative 

impact on London’s air quality, causes noise pollution and congestion, 

and inefficient transport can increase collection costs. The Environment 

Agency’s WRATE (Waste and Resources Assessment Tool for the 

Environment) software tool includes transport impacts and can 

be used to determine the impact that different transport modes, 

fuels and distances have on the overall sustainability of a waste 

management system. 

3.127 Waste is currently transported greater distances than is necessary with 

multiple collection and haulage vehicles operating in the same area, 

transporting waste to distant, rather than local, facilities. 

3.128 Modelling for the Transport for London Freight Unit estimates 150 

that transporting waste in London accounts for between 40 and 

50 million kilometres of travel per annum. Many of these movements 

involve vehicles of less than 3.5 tonnes, for example, by small builders 

and traders. 

3.129 The Mayor is committed to reducing the transport impacts of waste 

management, through prioritising waste prevention and on-site or 

local waste management. For waste that must be transported, 

negative transport effects can be reduced by: 

■ neighbouring businesses jointly procuring waste services 

■ using sustainable, waste-derived fuels for road transport 

■ moving waste transport off the roads and onto water and rail. 

Coordinating contracts 

3.130 Businesses could benefit from economies of scale by taking a coordinated 

contractual approach to their waste management, for example, by joining 

together with those in their building or local area, within their industrial 

estate or Business Improvement District, to jointly procure waste 

management services. Such an approach may enable them to negotiate 

more competitively priced services and is a particular opportunity 

for small businesses. Environmentally, it is an important way to reduce 

the transport and associated impacts of collecting waste and materials 

for recycling. 

3.131 This is being actively promoted by the Transport for London Freight Unit 

within their Delivery and Service Plan programme. The programme works



with businesses to develop plans that consider waste segregation, storage 

and collection and coordinate transport issues associated with access, 

loading, unloading, collection times and traffic regulations. 

Case study 13 - Commitment to sustainability sees behaviour 

change and cooperation among retailers 

In February 2003, the St Nicholas Shopping Centre, in association with 

Business Eco Logic, was awarded a grant by the Onyx Environmental Trust 

to implement a waste management programme. The Programme 

transformed the approach to waste of 81 retail outlets reaching more 

than 800 retail staff. 

The commitment of the Centre Management to the project enabled 

them to tackle logistical problems including cleaners’ timetables, number 

of waste and recycling bins allocated, bin labelling and implementing 

effective recycling schemes. In one year the centre showed a reduction 

in waste of 13.2 per cent and a cost saving of £10,960. Initiatives with 

local charities enabled furniture, old shop displays, ink cartridges and 

mobile phones to be recycled or reused by local community groups. 

Source: Business Eco Network 

Case study 14 - Tenants encouraged and supported to recycle as 

part of the management company’s commitment to the environment 

London-based property group, Workspace Group’s environmental and 

social commitment has enhanced their reputation, increased their share 

of the small business market and attracted investment. As a result of 

surveys, Workspace identified that environmental impacts were a high 

priority for them so they offered the services of a single waste contractor 

across their portfolio to help with waste reduction and recycling and 

distributed a ‘Recyclopedia’ to all of their customers. Workspace report 

year-on-year increases in the percentage of waste recycled since 2002. 

In 2005/06, 16 per cent of all waste generated across the property 

portfolio was recycled compared with just 4.5 per cent in 2002/03. 

Source: Business in the Community 

Case study 15 - Working together ensures success 

Meadowhall Shopping Centre has over 270 stores attracting over 25 

million visitors per year. Since 1992, all 230 retailers have signed up 

to an Environmental Charter. Since then, staff environmental training, 

a monthly Green Newsletter for retailers and bi-annual waste audits


have been introduced. Meadowhall developed a comprehensive waste 

management strategy in 2002. Targets include recycling 70 per cent 

of all waste and increasing awareness of waste management. 

In 2005, Meadowhall became the first UK shopping centre to develop 

an on-site recycling centre. In 2007, 94 per cent of all waste entering 

the recycling centre is being recycled. Since 2002, over 19,000 tonnes 

of cardboard, 3,196 tonnes of glass and 696 tonnes of plastic have been 

recycled, resulting in a £575,309 return on investment. Meadowhall also 

recycles and reuses coat hangers, steel delivery cages and packaging, and 

has composted 16 tonnes of waste. 


Proposal 12 Transport for London will promote Delivery and Service Plans to London’s 

businesses, to encourage them to negotiate waste services with reduced 

transport impacts. 

Get off the road, or make it green 

3.132 Where materials do need to be transported they should be transported 

in the most sustainable way. The road vehicles used to transport waste 

are generally heavy goods vehicles and, given that freight vehicles 

emit significantly higher levels of pollutants than petrol cars 151 , 

reducing the distance travelled by freight vehicles or improving their 

efficiency could have a significant impact on reducing air pollution. 

Routing and scheduling software applications could reduce emission 

levels by ten per cent 152 . 

3.133 Through introducing a Londonwide Low Emission Zone (LEZ), the Mayor 

aims to improve London’s air quality, and thereby improve Londoners’ 

health, by requiring operators of large diesel vehicles to clean up their 

fleets. Vehicles that meet the required emissions standards for the LEZ 

can be driven within the Zone without paying a daily charge. Operators 

of vehicles that do not meet the LEZ emissions standards can take action 

to avoid paying the daily charge, such as modifying the vehicle to 

improve its emissions, or using a different vehicle within the Zone. 

In recognition of the impact of the LEZ requirements on small businesses 

there will be a phased introduction of the LEZ from February 2008 

through to January 2012. From February 2008, businesses operating 

diesel engine lorries (over 12 tonnes) that fail to meet a minimum 

pollution standard must pay a daily charge if they drive within London. 

Lorries over 3.5 tonnes must comply by July 2008 and large vans by 

October 2010 (small vans are not included in the LEZ).



3.134 Changing the fuels used for waste collection vehicles is another 

opportunity to make waste management transport more sustainable. 

Biodegradable wastes can provide a renewable source of methane, which 

can be combined with natural gas to create a transport fuel. Greenwich 

Council is investigating the option to produce methane from its proposed 

anaerobic digestion facility to use as a transport fuel in its vehicle fleet 

and run its school buses. 

3.135 Bio-diesel can be produced from waste oils and other organic wastes. 

An LDA study 153 shows that bio-diesel produced from used cooking oil 

is an environmentally-benign alternative to traditional diesel, emitting 

50 per cent less carbon monoxide and 78 per cent less carbon dioxide 

than fossil-based diesel 154 . When produced to the appropriate standards, 

bio-diesel can be introduced to existing diesel engines without any need 

for engine modification. Establishing bio-diesel production from used 

cooking oil helps to absorb a waste material that is under increasingly 

strict controls and which can be problematic when incorrectly disposed 

of causing, for example, blocked drains. 

3.136 London’s first bio-diesel refinery opened in Edmonton, north London 

in March 2007 155 . Pure Fuels has the capacity to produce 3.5 million litres 

of bio-diesel each year from used cooking oil collected from businesses 

across London. Bio-diesel currently sold at public filling stations contains 

only a maximum of five per cent bio-diesel, the other 95 per cent being 

regular, mineral diesel. Increasing the percentage of bio-diesel is not 

possible without invalidating vehicle warranty, a serious limitation to 

substantial market growth. 

3.137 The Mayor’s Air Quality Strategy supports taking waste and recycled 

materials off the road and utilising the rail and water networks, which 

emit fewer air pollutants than road travel 156 . In 2003, the transportation 

of 650,000 tonnes (15 per cent) of municipal waste by river saved some 

100,000 lorry movements on London’s roads 157 , reducing congestion and 

the negative environmental impacts associated with road haulage. 

Alternative options, such as collection vehicles that can switch between 

road and water transport and underground vacuum waste collection 

systems, are being investigated. 

3.138 The majority of non-road waste movements in London are to transport 

waste to landfill. As London diverts material from landfill, it will be 

essential that wharves and rail-heads used for waste are retained for 

moving recycled materials.


Case study 16 - New recycling facility maximises use of rail and 

river for transportation 

Powerday was awarded £562,400 through the London Development 

Agency’s Economic Development Infrastructure Building (EDIB) project, 

via the London Recycling Fund, to develop a new Materials Recycling 

Facility at Old Oak Sidings in the London borough of Hammersmith and 

Fulham. The facility comprises a waste management facility and 

construction materials depot with an annual total capacity of 1.6 million 

tonnes. The scheme proposes a new wharf on the Grand Union Canal to 

allow the transfer of materials to barges for transportation to and from 

other canal-based sites and reuse of existing railway sidings for the 

transfer of waste and materials by rail. 

British Waterways supports the application stating that it will take 

advantage of 26 miles of lock-free canal and would support up to 

800,000 tonnes of material on the canal. The principle of a waste 

management facility in this location is welcome in strategic planning 

terms, as it will provide much needed extra waste management capacity. 

The facility is due to open in June 2007. 

Source: Greater London Authority Planning Decisions Unit Report PDU/0496/01, 2004 

Proposal 13 Transport for London, through its London Freight Plan, will promote the 

early adoption of new engine technologies and waste-derived fuels that 

minimise the impact of waste transport on climate change. 

Proposal 14 London’s businesses, particularly those in light industrial estates, should 

examine the feasibility of: 

■ generating energy on-site from their residual waste, particularly 

organic kitchen waste, through the use of advanced waste 

technologies 

■ using waste-derived transport fuels in their vehicle fleets.



3F Getting to grips with data 

3.139 There is sufficient data on which to estimate and plan for London’s waste 

management needs. However, the production of detailed and accurate 

data for business waste does require urgent consideration. 

3.140 In 1998/99 and 2002/03, the Environment Agency compiled the strategic 

waste management survey providing data on the 235 million tonnes of 

waste produced by households and businesses. Data from this survey 

underpins London’s business waste policy, including this strategy, and 

the survey needs to be repeated to update the knowledge of business 

waste arisings and management methods. 

3.141 Recent research by the Environment Agency 158 identified the 

following issues: 

■ much construction, demolition and excavation waste, handled on-site 

or through mobile facilities, is exempt from waste management 

licensing, therefore the quantity being managed is far greater than 

that recorded by the Environment Agency 

■ many recycling facilities are exempt, therefore a large quantity of 

recycled materials is known to be being produced and managed, 

but its destination is unknown (particularly the case for metals, 

glass, paper and card). 

3.142 With the increasing drive to reduce regulatory burdens it is likely more 

sites and waste management activities will be exempt from licensing 

(and therefore from reporting their activities to the Environment Agency). 

This could create even more data uncertainty in the future. 

3.143 The Mayor will work with partners to improve the availability, reliability 

and comparability of business waste data for London, and thereby provide 

greater certainty and confidence to the waste management industry 

on which they can base investment decisions. The Mayor considers that 

ongoing business waste data collection is essential for understanding 

London’s business waste and can be delivered through projects such as: 

■ the London Environmental Support Service ‘Enworks’ tool 

■ the Mayor of London’s Green Procurement Code 

■ the activities of the GLA group. 

3.144 A thorough understanding of business waste production and management 

is crucial to inform the development and provision of sector-specific 

tailored information and advice. Detailed knowledge is required to 

highlight linkages and potential synergies across sectors, waste streams 

and material types. Examples of further analysis required, include:


■ how waste arisings and composition relate to business sectors, size 

and turnover and the relevance this has for London in terms of 

London’s business make-up and geographical business spread 

■ the volume of potential recycled materials by material and sub-material 

within the business waste stream 

■ how external factors such as climate change will affect waste arisings 

and composition 

■ how factors such as London’s projected economic growth will affect 

waste arisings and composition. 

Proposal 15 The Mayor expects Defra and the Environment Agency to take action 

to address business waste data gaps, including: 

■ undertaking the strategic waste management survey every five years 

■ ensuring relevant data is collected from exempt waste management 

facilities 

■ making data available and accessible 

■ integrating data collection into government policy making, for example 

as part of the implementation of site waste management plans.



4 Motivating change: 

an opportunity to save money 

Introduction 

4.1 The economic benefit to London’s businesses of sustainable waste 

management and the smart use of resources is significant. Whilst 

a business will spend a certain amount of time and money per week 

disposing of their waste, when the materials, the wasted energy 

and wasted labour are also considered, the real price tag of waste 

management is often 5 to 20 times higher than simply the cost of 

disposal 159 , typically four per cent of the turnover of a business 160 . 

Resource productivity is therefore not just an environmental initiative; 

it has financial implications for London’s businesses. 

4.2 However, cost savings are not a universal motivator. Research 161 

undertaken for the London Assembly shows that for small businesses, 

the perception is that the additional time and effort required to consider 

and change their waste management behaviour is significant and 

outweigh any possible financial saving. This can be because waste 

management costs are outside their control, perhaps because they 

are included in a service charge, or savings from waste reduction and 

recycling are too minimal to be of importance as a percentage of their 

total (small) waste management budget. 

4.3 To encourage change among small businesses, they should be made 

aware that environmental management can provide wider benefits 

through a general improvement in formalised management procedures 

and basic management capabilities, thereby turning it into a positive 

driver. Linking waste management into the health and safety agenda 

may also be a fruitful catalyst for encouraging small businesses to 

re-think their waste practices 162 . 

4.4 This chapter sets out ways in which businesses can implement sustainable 

waste and resource management systems and techniques. Businesses that 

realise the opportunities of more productive resource use will ensure both 

their own and London’s continued, sustainable economic growth. 

4.5 Sector-specific action plans will be developed with London’s businesses 

to sit beneath this strategy. Although they will be focused around each 

sector, they will include tailored guidance and support for smaller 

businesses. Criteria will be developed by which stakeholders can assess 

the principal environmental impacts of the sector and a material-led 

approach developed as appropriate. An indication of the actions the plans 

might cover is given throughout this chapter. Their onward development 

should be business-led.


4.6 Action plans could be developed for: 

■ professional and business services, including education, media etc. 

in other words, businesses producing largely ‘office’ waste, such 

as paper, plastics, food and card 

■ retail (grocery and goods), hospitality (hotels, contract catering, 

restaurants, pubs) and the food processing industry, which produce 

mainly food, card and glass 

■ construction, highways and industry, producing a range of 

construction, demolition, excavation and industrial wastes 

■ healthcare organisations, which produce a range of ‘office’ and food 

wastes should be separately considered due to the clinical hazardous 

waste they produce. 

Proposal 16 The Mayor will work with business sectors and their representative 

associations to produce sector-specific action plans, which identify issues 

and actions specific to businesses of different sizes within each sector.



4A Managing commercial waste 

Introduction 

4.7 Through commercial and 

public sector activity, London’s 

businesses produced 

5.6 million tonnes of waste in 

2003 of which just 40 per cent 

was recycled 163 . The 

government expects levels of 

commercial and industrial 

waste landfilled to fall by 

Municipal 

Construction/ 

demolition/ 

excavation 

Hazardous 

20 per cent by 2010 compared to 2004 and will be setting a new national 

target for the reduction of commercial and industrial waste going to 

landfill 164 . The Mayor expects London’s commercial sector to reduce, reuse, 

compost or recycle their waste to meet the London Plan targets. Although 

these targets are set for London, to achieve them, every business must 

aim to meet them within their own organisation. 

4.8 Waste audits are a useful tool for a business to assess the quantity and 

composition of its waste stream to determine the areas that give the 

greatest scope for cost savings and the development of a waste 

management plan. Undertaking waste audits regularly enable businesses 

to measure improvements in their resource management performance. 

If waste can be cut down anywhere within the business, savings will 

go straight to the bottom line. Envirowise have developed a free waste 

audit checklist 165 that can be adapted to suit particular business needs. 

Commercial 

Industrial 

4.9 The government has announced 166 it will develop a Resource Efficiency 

Appraisal and Development (READ) tool to help businesses appraise their 

resource management and improve performance. Whilst the development 

of a single tool is welcome, any tool or methodology can be used. What 

is important is that a business analyses their performance over time, using 

the same tool each year. Practical actions can then be implemented to 

achieve progress, a year on year reduction in waste for example, rather 

than comparing their performance with another organisation that may 

have different priorities and resources. 

Take action 

4.10 Businesses can take action to prevent waste by changing their systems and 

the behaviour of their employees and through reviewing the design of their 

products and the behaviour of their suppliers and customers. Waste reduction 

- through design and through procurement decisions - given its more 

targeted audience and specific opportunities, is discussed separately in 

Chapter 5. Many waste prevention examples may appear obvious or simple 

but they are not being implemented consistently by London’s businesses. For


example, a survey showed that British office workers print, on average, 22 

pages each day and a quarter said they do not give much thought to printing 

documents with eight per cent printing emails before they have read them 167 . 

4.11 There are a number of initiatives coordinated by the LDA that provide 

information and advice to businesses to help them manage their resources 

more productively. Businesses should utilise this support as they 

implement the proposals in this strategy. 

4.12 For example, Envirowise offers one-to-one practical support and aims to 

ensure that solutions are driven by the specific needs of individual firms. 

This assistance enables companies to increase their profitability by making 

more productive use of materials in order to reduce their economic costs 

and environmental impact. Savings of around £1,000 per employee are 

typically made through resource productivity programmes 168 and the 

average payback periods for such initiatives are measured in months, 

rather than years. Since 1994, Envirowise has helped UK industry save 

more than £1 billion 169 . 

Case study 17 - Waste prevention initiatives at City Hall 

Environment Champions, developed and delivered by Global Action Plan, 

was run at City Hall between May 2005 and March 2006 and continues to 

be delivered by an internal team. The project aimed to reduce the level of 

waste produced by the GLA and to raise staff awareness of environmental 

sustainability. Through two audits the team was able to measure progress 

against a challenging target that was set at the start of the project, which 

was to achieve a ten per cent reduction in waste to landfill. Through 

initiatives such as reducing the use of plastic cups (achieving a reduction 

of 27 per cent or 3,000 cups a month) this target was exceeded and 

waste reduced by 30 per cent. Purchasing of white copier paper also went 

down by three per cent, saving the equivalent of 16 trees per year, and 

£522 in costs each year. As a result of this project, staff now use just 43 

sheets of paper each per day. Work continues, however, to support staff 

to exceed the benchmark of 40 sheets of paper per day. 

Source: Global Action Plan 

Case study 18 - HSBC launches new programme to cut paper use 

HSBC customers who have registered for Personal Internet Banking can 

elect to stop receiving their monthly current account, quarterly savings 

account and twice-yearly mortgage account statements. The campaign, 

which aims to cut down on paper use has reached a major milestone. 

One million accounts have now opted to stop receiving statements,



which HSBC have estimated will save more than 13 million pieces 

of paper and about seven million envelopes in one year. 

Source: Easier Finance Banking News 

Case study 19 - Resource efficiency club reduces waste and costs 

In the London boroughs of Lambeth, Lewisham and Southwark, 

Envirowise established the Waste Alert South Thames Club. A partnership 

of small businesses, the Club provides support on waste prevention 

through a range of workshops, seminars and on-site support. Many waste 

prevention measures cost nothing, but yield big results. In its first year, 

the Club has reduced waste sent to landfill by 121 tonnes and produced 

savings of around £620 per company. Following the success of the Club, 

others have been established in the London boroughs of Camden, 

Bromley and Bexley, Harrow and Surrey. 

Source: Envirowise: GC262 

Case study 20 - Changing behaviour among employees 

As part of the Recycle Western Riverside campaign London Remade and 

Waste Watch implemented a waste prevention programme throughout the 

council offices of Hammersmith and Fulham, Wandsworth, Lambeth and 

Kensington and Chelsea. The programme aimed to meet internal waste 

reduction targets and deliver cost savings, increase recycling and meet 

the aspirations of the council environmental policies. After conducting 

baseline waste audits, printer paper and plastic disposable cups were 

selected as the initial waste streams to tackle as part of the campaign. 

A paper reduction campaign started in 2004 and, as a result, Wandsworth 

Council saved £85,705 annually in hidden print costs. Removing plastic 

disposal cups from two of Lambeth Council’s office buildings has resulted 

in savings of £430 a year. 

Source: Recycle Western Riverside, London Remade and Waste Watch 

4.13 The Mayor wants to see better use of wastes such as those produced 

during premises refurbishment and relocation. Furniture and electrical 

equipment, together with carpeting and paints are thrown away because 

businesses are unaware of opportunities to reuse these items or are 

unable to locate suitable collection and refurbishment services. In addition 

to diverting waste from landfill and preventing the need to produce new 

products, reuse and refurbishment often enables small businesses or 

consumers to acquire products at a reduced price.


Case study 21 - Reuse reduces capital costs 

CRISP, established by Elephant Jobs in 1993, works to realise the 

environmental benefits and local employment opportunities of sustainable 

resource use. CRISP runs Office Furniture Fittings and Equipment 

Recycling Scheme: Ex-IT a social enterprise, which, with Southwark 

Council, will reuse over 1,000 tonnes of Waste Electrical and Electronic 

Equipment (WEEE) in the borough by March 2007. The WEEE goods 

collected are sorted and tested by CRISP, and those suitable for reuse 

either as working goods or as parts are sent to the re-manufacturing 

workshop after which, recipient groups (including third sector 

organisations and small start-up businesses) can purchase the goods 

which may reduce the capital costs of providing their services or starting 

their businesses. 

Source: London Community Recycling Network 

4.14 When considering commercial waste, London’s businesses can be divided 

into three main groups: 

■ offices, for example, business and professional services 

■ retail, both goods and grocery 

■ hospitality, including contract catering, hotels, pubs and 

restaurant businesses. 

4.15 The main materials produced by the three business groups are: paper, 

card, glass, metals, plastics and organic kitchen waste and are key 

materials on which to focus. The proportion of each waste differs greatly 

between the business types (Table 5). 

Table 5 Proportion of potentially recyclable elements of retail, hospitality 

and office sector waste streams 

Offices Retail Hospitality 

(%) (%) (%) 

Paper 53.6 20.3 3.7 

Card 6.5 37 9.4 

Glass 4.5 2.9 42.4 

Metals 1 0.8 2 

Plastic 1 7 1.3 

Organic kitchen waste 8.3 5 12.1 

Total 74.9 73 70.9 

Source: London Wider Waste Strategy Background Study: Technical Report to the Greater 

London Authority, SLR Consulting Limited, 2004.



4.16 These proportions suggest that between 70 and 75 per cent (by weight) 

of the waste that each business type produces can be recycled. The data 

also shows that there is significant homogeneity, with each business type 

producing one material of significant volume. For example, office waste 

comprises over 50 per cent paper and hospitality waste almost 50 per 

cent glass. There is therefore a huge opportunity to provide dedicated 

services to collect and reprocess these materials. 

A plan of action 

Outline action plan for office waste 

4.17 Organisations providing business or professional services, which are 

primarily office based, account for over 40 per cent of all London’s 

businesses 171 . What is more, the majority of businesses in London have a 

head office in London or are the head office 172 , which offers the 

possibility of waste systems implemented in head office being cascaded to 

their operations in other parts of the UK. 

4.18 The following priority actions have been identified for offices, and will be 

further developed in the sector-specific action plans: 

■ reduce paper use (double sided printing, reduce print run for 

marketing materials etc.) 

■ recycle paper and cardboard, including separately collecting white 

paper 

■ separately collect and process organic food waste (for those offices 

that run a canteen) 

■ reuse or recycle electronic and electrical equipment and IT 

consumables such as ink cartridges 

■ establish green procurement systems, particularly for recycled content 

paper and stationery products. 

Case study 22 - Composting office food waste made possible 

The GLA has implemented a new initiative to recycle food waste produced 

at City Hall. All food waste generated from the café, offices and at events 

held in City Hall will be separated by the caterers for regular collection by 

the East London Community Recycling Partnership (ELCRP). Currently 

around 500kg of food waste is produced each week, which was previously 

going to landfill. All the food waste will be taken to ELCRP’s site in 

Hackney where it will be composted. Not only will this help the GLA to 

further increase the quantity of biodegradable waste that is diverted from 

landfill, it will be good for household plants and gardens too because the 

compost will be returned to City Hall and given away to staff. Annually 

this contract will reduce the amount of waste to landfill by approximately


24 tonnes and the project will contribute valuable data and information 

about separate food waste collection in an office environment. 

Source: Greater London Authority Facilities Management 

Case study 23 - Financial services company tackles paper use 

As part of their participation in the Business in the Community 

Environment Index, St James’s Place Capital’s focus has been on the key 

areas of waste, energy, water and transport. Considerably improving its 

management and impact scores in 2005, St James’s Place Capital has 

shown particular strength in paper efficiency – its submission shows a five 

per cent reduction in the company’s paper use and following the initiation 

of a paper recycling programme in 2002, the company has seen an 

impressive 54 per cent increase in the quantity of paper recycled. 


Outline action plan for retail waste 

4.19 About 38 per cent of household expenditure is spent on retail goods 

and the retail sector is responsible for nine per cent of London’s 

employment 173 . There has been a decline in small retailers in recent 

years and a decline in town centre retail, both having lost out to an 

increase in the number of large retail businesses, (particularly relevant 

to grocery retail: the largest four supermarket chains that currently 

control 75 per cent of the grocery market in the UK 174 ) and a growth 

in out-of-town retail. 

4.20 Also of relevance to retail waste arisings and composition is the increase 

in internet shopping and the increasing effort amongst retailers to link 

to the leisure economy. 

4.21 The following priority actions have been identified for the retail industry, 

and will be further developed in the sector-specific action plans: 

■ establish green procurement systems, particularly to reduce 

packaging waste, encourage the use of reusable packaging and 

delivery receptacles 

■ specify products and packaging that are sustainably designed 

■ recycle packaging, particularly cardboard and plastics 

■ process organic food waste from grocery retail businesses. 

4.22 The retail sector action plan will complement the government’s work 

through the Courtauld Commitment and the Environment Agency’s 

partnership plan, which will cover consumer and transit packaging and



identify company milestones for reduction of waste and increasing 

resource efficiency in stores and operations 175 . 

Case study 24 - Retailer turns waste cardboard into a revenue stream 

In 2004, the Gold Group, a Surrey-based retailer, participated in a waste 

prevention programme run by Business Eco Network. Prior to the 

programme, cardboard was being baled and recycled. The Gold Group 

was given the free use of a baling machine in return for the bales of 

cardboard. During the year, the Gold Group reviewed their cardboard 

recycling and received quotes from other recycling companies. These 

companies have quoted as much as £40 per tonne for baled cardboard 

which could generate an estimated £8,000 to the Group. Therefore, they 

are planning to purchase their own baling machine to generate revenue 

from the baled cardboard. 


Case study 25 - Innovative retail display units reduce waste 

Boots The Chemists is the UK’s leading retailer of health and beauty 

products, and is uniquely positioned to maximise eco-efficiency processes 

from the design of products through to their manufacture and beyond. 

Boots’ strategy to minimise waste at source whilst reducing reliance on 

landfill has reduced waste costs and reduced use of virgin materials. 

Since 2001/2002, Boots’ percentage of total waste recycled increased 

from 37 per cent to 50 per cent, which delivers around 67 per cent saving 

in waste costs. Part of this strategy includes developing a 100 per cent 

recyclable Free Standing Display Units resulted in transport cost savings 

of £240,625, waste disposal saving of £165,000, saved 83 tonnes of 

cardboard annually and diverted 429 tonnes of waste from landfill and 

recycling redundant shop fittings saved £15,000 in landfill costs. 


Case study 26 - Collect Green Clubcard Points 

As part of their commitment to the environment, Tesco has developed a 

new programme to help customers reuse their carrier bags. In addition to 

their Bag for Life scheme and biodegradable carrier bags, in August 2006, 

Tesco started to give customers Green Clubcard Points every time they 

reused a bag. The system covered any sort of bag because it sought to 

prevent the use of new carrier bags rather than simply encourage the use 

of the Bag for Life scheme. It is hoped this initiative will help Tesco cut 

carrier bag use by over 25 per cent over the next two years. The Green 

Clubcard Points can be spent like any other Clubcard Points and they


are highlighted on the Clubcard statement to show how many points 

the customer has received for supporting green initiatives. 

Source: Tesco 

Outline action plan for hospitality waste 

4.23 There are about 12,000 restaurants in London 176 and approximately 

1,500 hotels, guest-houses and bed and breakfast establishments 177 . 

The average size of the businesses is significantly larger than the 

UK average and around 300 hotels have full restaurant facilities 178 . 

It is estimated that on average, a hotel creates around one kg 

of waste per guest per night 179 . 

4.24 A large concentration of restaurants and hotels is found in inner London 

with another cluster of accommodation near Heathrow airport. Hotels in 

the City of Westminster, the London Borough of Camden and the Royal 

Borough of Kensington and Chelsea account for approximately 65 per 

cent of hotel bed-spaces in London. The largest hotels are found in the 

City of London and the London Borough of Tower Hamlets 180 . 

4.25 Some 90 per cent of business and industry catering is now contracted 

out, compared to 50 per cent of private schools and 40 per cent 

of government departments 181 . Five companies contract 85 per cent 

of the contracted catering market 182 . 

4.26 The following priority actions have been identified for the hospitality 

industry, and will be further developed in the sector-specific action plans: 

■ recycle packaging, particularly cardboard and plastics 

■ establish systems to reuse furniture (for hotels and restaurants). 

■ recycle glass 

■ separately collect organic food waste for treatment 

■ establish green procurement systems that minimise food waste 

and encourage the use of reusable packaging and delivery receptacles. 

4.27 Procuring recycling and composting services can be problematic 

due to limited provision of services. However, as demand increases 

so will the supply of services.



Case study 27 - East end pub sets recycling and composting target 

Working with the London Sustainability Exchange, a pub in East London 

has sought to dramatically improve its recycling and composting rate. 

With an annual turnover of £888,000, the pub already benefits from 

recycling over 200 wheelie bins of glass each year. Currently spending 

over £4,000 each year on waste disposal, following an audit, additional 

materials have been identified that could bring the recycling rate up to 

15 per cent, generating savings of up to £600. Approximately six per 

cent of the waste that is left after recycling is food waste, which by 

investigating on-site or community composting opportunities could 

save the pub a further £200 each year. 

Source: London Sustainability Exchange 

Proposal 17 London’s businesses should conduct waste audits to: 

■ establish waste prevention and reuse systems 

■ identify the materials streams that they can recycle or compost 

and seek recycling and composting services alongside their waste 

management contracts.


4B Managing construction, demolition 

and excavation waste 

Introduction 

4.28 The construction industry 

is vast; its output is worth £100 billion per 

annum, contributes almost nine per cent to the 

UK economy 183 and is the biggest consumer of 

material resources – some 420 million tonnes 

per year 184 . It is also responsible for 20 to 30 

per cent of the UK’s waste, amounting to over 

90 million tonnes per year 185 , of which an 

estimated 13 million tonnes of materials that 

are delivered to site 

are not used 186 . 

Municipal 

Construction/ 

demolition/ 

excavation 

4.29 In 2003, it was estimated that London produced 7.2 million tonnes 

of construction, demolition and excavation waste 187 . Though this is the 

second lowest amount of construction waste produced by any of the English 

regions 188 it represents the largest fraction of all London’s waste. Without 

sustainable waste and resource management systems being adopted across 

the industry, London’s continued development will not be sustainable. The 

London Plan 189 has set a minimum target for housing provision of 30,650 

additional homes per year to 2016/17, which must be achieved alongside 

realising the Mayor’s environmental objectives. 

4.30 London’s construction sector can make a valuable contribution to London’s 

sustainability. More efficient use of materials during refurbishment 

or redevelopment would make a major contribution to reducing the 

environmental impacts of construction, including reducing demand 

for landfill and the depletion of natural resources. Better waste and 

resource management will ultimately lead to the industry’s improved 

economic performance. 

4.31 The design of a development is critical to ensure that sustainable waste 

management can be achieved during both the building’s construction 

and operation, for example, recycling facilities should be integrated 

into the design. 

4.32 The government’s consultation on a Sustainable Construction Strategy 

ended in November 2007 190 . The draft strategy proposed setting the 

following targets for the construction industry: 

Hazardous 

Commercial 

Industrial



■ by 2012, a 50 per cent reduction of construction, demolition 

and excavation waste to landfill compared to 2005 

■ by 2015, zero net waste at construction site level 

■ by 2020, zero waste to landfill. 

4.33 The Mayor welcomes these targets because they will create long-term 

certainty so that the industry can innovate and take the lead to develop 

products and services for sustainable construction. However, the 

government’s strategy does not go far enough, particularly in relation 

to making better use of the tools and systems available to prevent and 

manage waste and in ensuring that the best use is made of construction 

waste materials. The Mayor expects government to set high construction 

waste reuse and recycling targets and establish systems to monitor their 

delivery alongside landfill reduction targets. 

4.34 The Mayor expects London’s construction, demolition and excavation 

sector to reduce, reuse, compost or recycle their waste to meet the London 

Plan targets. In light of future increases in the landfill tax, reducing the 

amount of waste produced and improving its management will produce 

ever-increasing financial savings as well as environmental benefits. 

Case study 28 - Construction resource efficiency for London 

Construction resource efficiency (CoRE) is part of Defra's BREW 

programme and was set up as a regionally based pilot to draw together 

the work relating to construction resource efficiency across London 

and the South East and East of England. The London Development 

Agency is providing funding and Constructing Excellence has been 

chosen as the regional champion to drive forward the delivery of CoRE 

in London. The Building Research Establishment (BRE) is providing a 

centralised support to CoRE, principally through providing a means of 

construction waste benchmarking (using SMARTStart), identifying best 

practicable environmental options for waste generated (using BREMAP), 

and training of the regional champions/associated delivery bodies. 

The project will: 

■ increase awareness of existing help, information and best practice 

guidance available to reduce resource use 

■ provide access to tools and services that will measure waste and 

provide targets for improvement 

■ develop practical workshops where solutions and best practice can 

be shared and learned from 

■ provide in-depth support for those organisations willing and able to 

provide exemplar projects in terms of construction resource efficiency 

and progress waste prevention activities


■ provide pre-demolition audits for selected sites. 

Source: Construction Resource Efficiency (SmartWaste) 

Take action 

4.35 The construction sector often over-specifies materials by as much as 

14 per cent, amounting to approximately 13 million tonnes of wasted 

materials each year 191 . In addition to generating waste, this is a wholly 

avoidable cost to the developer. The lost value of wasted materials and 

the cost of waste disposal are a double economic loss for the sector. 

The increasing costs of landfill, of raw materials (partly as a result of 

the Aggregates Levy) and of transportation provide real economic 

incentives for waste prevention through more accurate specification 

and reuse or sale of leftover materials, for example through material 

exchange programmes. 

4.36 Waste can be prevented in construction projects by: 

■ ordering the correct amount of materials at the right time, rather 

than over-specifying 

■ ensuring material storage areas are safe, secure and weatherproof 

to prevent damage and theft 

■ setting up agreements with suppliers to take back surplus materials. 

4.37 Refurbishing buildings (i.e. keeping the existing shell of the building), 

rather than redeveloping them (i.e. knocking the building down and 

putting up a new building) may also prevent waste. The Mayor’s 

essential standard, set out in his Sustainable Design and Construction 

Supplementary Planning Guidance 192 , published in May 2006 to support 

the London Plan, is that existing building will be reused where 

practicable 193 . However, when other environmental objectives are taken 

into account it is possible redevelopment will be more sustainable overall. 

Full consideration of the benefits of redevelopment over refurbishment 

should be given at the planning stage and carrying out a pre-demolition 

audit can be useful prior to refurbishment or redevelopment to identify 

recovery options for existing materials and products. 

4.38 Eighty-five per cent (by weight) of the 7.2 million tonnes of construction, 

demolition and excavation waste produced in London in 2003 was reused 

or recycled, while the rest was landfilled 194 . This high reuse and recycling 

rate suggests effective practices in the sector. However, the majority of 

reuse and recycling involves crushing concrete and reusing demolition 

spoil as bulk fill. This does not make the best use of construction 

materials. If buildings were ‘deconstructed’ rather than demolished



a far higher proportion of materials, such as wood, glass and bricks, 

could be recovered for reuse. 

4.39 The Institute of Civil Engineers’ Demolition Protocol provides a 

mechanism for the effective reuse and high value recycling from 

demolition projects as well as the procurement of recycled and reclaimed 

materials in construction. Leading companies in the industry have already 

demonstrated that waste reduction and recycling delivers worthwhile 

savings. The adoption of such protocols would benefit from a more 

consistent approach across London in order to effect wholesale behaviour 

change among private sector contractors. The Mayor will ensure that 

business support programmes funded by the LDA are consistent in the 

provision of advice. 

Case study 29 - Effective planning increases material recovery 

During the redevelopment of Wembley stadium, Brent Council and the 

developer Quintain used the Institute of Civil Engineers’ Demolition 

Protocol to prevent waste and maximise the reuse of recycled aggregate. 

Brent was the first London council to integrate the protocol into their 

supplementary planning guidance. The protocol provides a framework 

methodology to help development teams ensure that the potential for 

procuring recovered materials, as well as the recovery of materials from 

demolition (and refurbishment) has been effectively considered and 

targets set. 

Source: Brent Council 

Case study 30 - Reusing demolition waste saves construction costs 

The Building Research Establishment’s office at Watford was constructed 

on its former site and reused 96 per cent of the waste generated during 

the demolition stage in the new building. An estimated 30 per cent cost 

saving was achieved through using 80,000 reclaimed bricks and 300m2 

of wood block flooring. 

Source: The Building Research Establishment 

Case study 31 - Tackling resource management early in the 

development process led to significant reuse and recycling 

Whilst working on the Barts and The London New Hospitals Programme, 

Skanska undertook a pre-demolition waste audit. This identified items 

that could be salvaged or recycled. They then developed a materials 

and waste tool, to monitor progress towards meeting the project target 

of 95 per cent resource productivity, per trade contractor and per 

material stream.


Taking these steps resulted in more than 92 per cent of the demolition 

wastes being reused or recycled. This equated to over ten and a half 

thousand tonnes of material being diverted from landfill. The project 

team realised that by considering resource management issues at 

an early stage, they were able to use their existing expertise to innovate 

and improve the project’s environmental and economic performance. 


Planning for site waste 

4.40 A site waste management plan details the amount and type of waste 

that is expected to be produced on a construction site and how it will 

be reused, recycled or disposed of. The plan is updated during the 

construction process to record how the waste is managed and to confirm 

the disposal of any materials that cannot be reused or recycled. 

4.41 Site waste management plans can improve resource efficiency within 

the construction industry by reducing the amount of waste produced 

and recovering as much as possible of the remainder. They should simplify 

the administrative burden on the construction sector as they provide a 

mechanism for ensuring compliance with legal requirements, such as the 

duty of care, hazardous waste, waste carrier and waste broker controls. 

4.42 The government has consulted 195 on proposals to make site waste 

management plans mandatory for construction, demolition and excavation 

projects over £250,000, with more detailed requirements for projects 

over £500,000. 

4.43 The Mayor expects planning authorities’ development plan documents 

to require developers to produce site waste management plans for any 

developments, including projects under £250,000 196 . This will ensure 

effective waste management is planned into construction projects as early 

as possible and will mainstream waste prevention, reuse and recycling 

in the construction industry. 

4.44 The Environment Agency, through its Netregs website, has launched a site 

waste management plan campaign, ‘Site Waste – It’s Criminal’, in response 

to its recent survey of small businesses in the construction sector, which 

found almost a quarter of respondents had never introduced any practices 

that prevent harm to the environment and more than half admitted that 

although they try their best, they could work harder at being 

environmentally friendly. Most concerning was that two thirds of 

respondents (66 per cent) said they did not know what a site waste



management plan was and 63 per cent were not aware that site waste 

management plans could soon become a legal requirement 197 . 

4.45 Data collected through site waste management plans could provide 

the basis for a centralised construction database to improve the 

understanding and knowledge of the industry’s waste management 

practices. The database would record the quantities of waste produced, 

its composition, transportation, management method and location of 

recycling or disposal facilities. 

4.46 Transport for London’s Construction Logistics Plans provide for the 

detailed planning of construction waste movements to appropriate waste 

facilities. This is intended to increase the use of sustainable transport 

modes to move construction materials and waste. Through the Freight 

Plan it is expected that planning applications for all major developments, 

along with smaller developments over an agreed threshold, will require 

the submission and implementation of Construction Logistics Plans. 

Better coordination of journeys to and from major project sites using the 

Construction Consolidation Centre in Bermondsey for example, has been 

demonstrated to 198 : 

■ a reduction in the number of construction vehicles that would have 

entered the City of London and delivered to the construction site 

by 68 per cent 

■ reduction in supplier journey times by an average of two hours 

■ increased productivity of the labour force by up to 30 minutes per day. 

4.47 Almost half of London’s hazardous waste is from the construction, 

demolition and excavation sector (Figure 3) such as contaminated 

soils from brownfield land. Site waste management plans would improve 

the management of hazardous waste, by identifying the hazardous waste 

that will arise and specifying how it will be managed. Through the use 

of technologies, such as bioremediation, contaminated soil can be 

reused within the construction project thereby reducing associated 

transport implications.


Figure 3 The principal components of hazardous waste in London 

Other (27,085 tonnes) 9% 

Waste water treatment (31,180 tonnes) 11% 

Construction and demolition 

(138,419 tonnes) 

49% 

General industry (17,995 tonnes) 6% 

Chemicals/refining (19,515 tonnes) 7% 

Oils and solvents 

(51,086 tonnes) 

18% 

Source: The Environment Agency Strategic Waste Management survey for hazardous 

waste 2002/03 

Proposal 18 The Mayor will encourage developers to perform beyond the proposed 

minimum regulatory standard for site waste management plans, for 

example by: 

■ producing site waste management plans for major developments 

■ identifying the hazardous waste that will arise and how it will be 

managed 

■ stating how waste is being transported for recycling or disposal 

and the volume of waste being transported by each mode 

■ aiming to achieve the London Plan reuse and recycling targets 

and support the principles of self-sufficiency and proximity. 

A building industry standard 

4.48 Construction waste is not simply produced by large, strategic development 

and refurbishment projects. Waste will be produced from small building 

projects, such as renovation or repair jobs on private households. Clearly, 

given their small scale, they are likely to be outside many legislative 

regimes. Although their individual environmental impact is likely to be 

small, their combined impact will be considerable. In European countries, 

such as Denmark, the Netherlands, Germany and Belgium green 

construction values have been cascaded across the industry through 

the implementation of standards and quality assurance schemes. 

4.49 TrustMark (previously Quality Mark) is a scheme supported by the 

government, consumer groups and the building industry to help 

businesses and consumers find reputable firms to do repair, maintenance 

and improvement work. To display the TrustMark logo the firm must 

have been checked by an approved trade association or other certification



organisation and found that it meets the standards the government 

has set. 

4.50 Currently, the TrustMark is awarded to companies that have, for example, 

a code of practice that includes insurance and good health and safety 

procedures and that an approved scheme operator has checked the firm’s 

technical skills, trading record and financial position. The Mayor calls on 

TrustMark to include sustainable waste management criteria in their list 

of standards. This will increase the number of businesses operating in 

London that are taking action to reduce their environmental impact. 

Proposal 19 The Mayor calls on TrustMark to include sustainable waste management 

as one of its certification criteria. 

Construction procurement goes green 

4.51 Waste generated from demolition and construction activities is only one 

aspect to be considered in a construction project. The ability to manage 

waste during the lifetime of the building and maximising the use of 

recycled materials in the building itself also need to be considered. 

4.52 The Mayor’s Sustainable Design and Construction Supplementary 

Planning Guidance (SPG) 199 provides guidance on promoting sustainable 

waste behaviour in new and existing developments, including providing 

adequate waste and recycling storage facilities and supporting 

the development of decentralised energy systems, including energy 

from waste. 

4.53 Budding designers and architects should consider using recycled 

materials and design buildings for easy deconstruction as part of the 

design process. The Mayor’s preferred standard, given in the SPG 200 , 

is for 10 per cent of the total value of materials used in the construction 

to be derived from recycled and reused products and materials, which 

WRAP asserts is now common and that levels exceeding 15-20 per cent 

can be achieved 201 . 

4.54 Waste neutrality, where the value of materials wasted is matched by 

the value of additional reused and recycled content materials bought, 

is a particular opportunity for the construction industry. WRAP is 

developing a tool for the construction industry to help them become 

waste neutral. The Net Waste Method 202 is aimed at enabling developers 

and contractors to optimise a project’s design and delivery, rather than 

influencing the types of materials used. The web-based tool will produce 

outcome-based targets to encourage contractors to consider various ways 

of reducing waste and to prioritise those where the business and


environmental case is strongest. The government’s draft strategy for 

Sustainable Construction proposes that the government ‘achieve wasteneutral 

construction in its major construction projects by 2012’ 203 . 

However, further work is required to identify a suitable cross-sector 

definition for waste neutrality, for example whether to use weight, 

environmental impact of project value as the criteria. 

Case study 32 - Cement goes green 

Lafarge Cement supplies six million tonnes of cement per year, the 

manufacture of which incurs significant environmental impacts. To tackle 

these impacts, the company has increased the use of recycled materials 

and reduce the use of virgin materials. An example of Lafarge Cement’s 

eco-efficiency initiatives is the use of pulverised fuel ash in packed 

cement, which accounts for approximately 20 per cent of their sales, 

was on pure cement. Their activity has: 

■ reduced the amount of waste sent to landfill by more than 

600,000 tonnes per year by using materials otherwise destined 

for landfill 

■ reduced use of natural raw materials by four per cent per 

tonne produced 

■ led to estimated reductions of 180,000 tonnes CO 2 per annum 

■ ensured the company received an 80 per cent reduction in Climate 

Change Levy by achieving targets to reduce carbon emissions through 

the recovery of energy from waste. This equated to more than £9m 

per annum 

■ made savings of £1.5m per annum on landfill charges based on 

reduction in tonnage disposed of between 2000 and 2005. 


Proposal 20 The Mayor will revise his Sustainable Design and Construction 

Supplementary Planning Guidance to set a preferred standard for: 

■ developers to provide a green procurement plan with their planning 

application, setting out the types of materials used, quantities and 

their environmental provenance and efficiency 

■ developers to adopt WRAP's requirements for good practice in recycled 

content and waste management and specify the requirement for at 

least 15 per cent of the total value of materials used to derive from 

recycled and reused content by 2010, rising to 20 per cent by 2012.



4C Managing industrial waste 

Introduction 

4.55 Large industrial processes are 

heavily regulated and industry 

must comply with the 

Integrated Pollution 

Prevention and Control 

legislation, which introduced a 

new integrated permitting 

regime for major industrial and 

waste sites covering air, water 

Municipal 

Construction/ 

demolition/ 

excavation 

and land pollution. It targets industrial sectors considered to have a high 

potential to cause pollution and aims to provide a high level of protection 

for the environment. 

4.56 London has increasingly become a service-based economy. The two 

decades to 2004 have seen significant increases in employment in 

business services (up 560,000) and hospitality (up 300,000) 204 . Over the 

same period, employment in manufacturing has decreased by 410,000 205 . 

A similar pattern is expected for the next two decades 206 . However, 

London’s industry still generated 1.9 million tonnes of waste in 2002/03, 

of which over 50 per cent was recycled 207 . Industrial waste is typically 

a more difficult and diverse material stream than commercial waste and 

requires specialist treatment. This provides a strong economic incentive 

for industry to implement sustainable waste management practices. 

4.57 The government expects levels of commercial and industrial waste 

landfilled to fall by 20 per cent by 2010 compared to 2004 and will 

be setting a new national target for the reduction of commercial and 

industrial waste going to landfill 208 . The Mayor expects London’s industrial 

sector to reduce, reuse, compost or recycle their waste to meet the 

London Plan targets. 

Take action 

4.58 Envirowise is working with industrial businesses to prevent waste by 

developing more efficient industrial and manufacturing techniques. 

Such techniques can be a simple, cost effective way to improve 

productivity and boost profits, for example by: 

■ increasing yield of saleable product 

■ improving product quality 

■ improving productivity and reduced process time. 

Hazardous 

Commercial 

Industrial


4.59 The London Manufacturing Advisory Service, funded by the LDA and 

delivered by manufacturers provides practical hands-on support to help 

businesses become more competitive. London is home to 16,000 small 

and medium sized manufacturers 209 , therefore, the service could have an 

enormous impact on waste prevention but this has not been the focus 

to date. 

Case study 33 - Taking action after waste audit delivers 

cost savings 

The introduction of a system to ensure accurate waste reporting has 

allowed Kappa Packaging to progressively reduce its process waste. 

Kappa has used the waste data to identify and control the main sources 

of process waste. A detailed study of the machines found that the two 

main problems were poor glue application and machine jams. New gluing 

systems have virtually eliminated the glue problem, while a new brush 

system (for removing tabs) and new sensors have reduced the amount of 

waste generated as a result of machine jams. Following the introduction 

of the waste reporting system and initiatives to reduce waste, the overall 

figure for process waste fell progressively from the base-line figure of 

14.6 per cent to 13.1 per cent by the end of 2002. The annual cost 

savings of over £199,000 achieved by the end of 2002 equated to over 

£1,000 per employee. 

Source: Envirowise: CS406 

4.60 The National Industrial Symbiosis Programme (NISP), launched in April 

2005, aims to identify wastes within one business that can be reused as 

a feedstock by another business so that previously unwanted or low value 

wastes or by-products become useful and competitively priced resources 

for others. NISP has helped to divert more than 1.1 million tonnes of 

waste from landfill and prevented the use of 1.9 million tonnes of virgin 

materials leading to a reduction in carbon dioxide emissions of over 1.3 

million tonnes 210 . The programme has led to £34 million of private capital 

investment in reprocessing and recycling technologies, created 356 new 

jobs and generated £39 million in additional sales for its members. 

4.61 NISP, through the LDA, promotes industrial symbiosis in London. Since 

its launch in September 2005, the programme has helped its 507 London 

members to divert nearly 300,000 tonnes from landfill, and prevented the 

use of nearly 200,000 tonnes of raw material leading to a reduction in 

carbon emissions of nearly 80,000 tonnes.



Case study 34 - Innovative programme develops environmentally 

and financially beneficial partnership 

UK Coal Mining Ltd was introduced by NISP to metal product manufacturer 

and distributor, Corus, at one of its regional workshops. For environmental 

reasons, Corus was already importing large amounts of coal for its 

manufacturing process and paying a premium to do so. UK Coal Mining 

Ltd, on the other hand, was looking for outlets for coal fines recovered 

from an old settling pond. The two companies are now working together 

in a synergy, which sees Corus making substantial cost savings by 

purchasing coal fines direct from UK Coal Mining Ltd in a niche 

application, while UK Coal Mining Ltd saves on disposal costs and 

increases its sales revenue. Learning from the initiative’s success, UK Coal 

Mining Ltd has independently found another company to buy a further 

170 tonnes of coal fines each week. 

Source: National Industrial Symbiosis Programme 

Case study 35 - Big cost savings through targeted reuse 

programme 

Merck Ltd is a leading UK manufacturer and supplier of chemical 

reagents, laboratory apparatus, pharmaceuticals and liquid crystals. 

Initiatives it has adopted have shown that waste prevention, reuse and 

recycling can produce very beneficial results in both financial and 

environmental terms. For example: 

■ non-returnable large steel drums are retained for the disposal 

of chemical wastes. This minimises the need to purchase containers 

for this purpose. The total cost savings to the company of drum reuse 

is £17,000 per year 

■ sheets of plastic are used as packaging between layers of items 

stacked on pallets. These can be used several times and are therefore 

collected and segregated before being reused in the packaging of 

bottles. This initiative saved the company an estimated £370 in 1995. 


Proposal 21 The London Development Agency will provide information and advice 

to London’s businesses about how to change their manufacturing 

techniques to use resources more efficiently.


4D Making waste safe 

Introduction 

4.62 Hazardous waste may pose a risk to the environment and human health 

and must be managed in accordance with the Hazardous Waste Directive 

1991. Hazardous waste includes a range of products and materials from 

batteries, fluorescent light bulbs and TV screens to oils, contaminated soils 

and clinical wastes. 

4.63 London produces one of the lowest amounts of hazardous waste of any 

English region 211 . However, the absence of infrastructure to deal with it 

within London, and the reduction in the number of available disposal sites 

around the country 212 , means the cost of disposing of hazardous waste 

to specialist sites has risen and that London’s hazardous wastes will have 

to travel increasingly long distances for treatment and disposal, incurring 

high haulage costs. 

Take action 

4.64 Hazardous waste arising from business operations may be disposed of 

incorrectly by businesses that are unaware of the legislation and their 

obligations to separate hazardous waste for specialist treatment and 

disposal. The Environment Agency has produced guidance 213 for 

determining the classification of wastes as hazardous or non-hazardous 

and their HAZRED project aims to help small businesses prevent 

and reduce the production of hazardous wastes, saving them money 

in the process. 

Case study 36 - A different kind of tube station offers 

a sustainable solution 

The suitable disposal of fluorescent tubes is a matter of concern, because 

they contain highly toxic heavy metals, for example mercury. The Mayor 

ensures that fluorescent tubes arising at City Hall are recycled through the 

waste collection contract with Bywaters. Bywaters Tube Station System 

offers a safe, reliable method of recycling fluorescent tubes. 

Source: Greater London Authority 

Case study 37 - Delivering greener print 

In 2005, to replace its plate-making facility, Kent Art Printers were the 

first to commit to using Kodak ‘No process’ plates, in the UK, having 

worked closely with Kodak to commercialise it. The new plates have 

reduced their water use in the pre-press by 100 per cent (31 per cent 

of the total company use) and eliminated the disposal of 1,500 litres 

of hazardous waste per year. Alcohol-free dampening on all presses 

saves two tonnes of solvent emissions per annum. 

Source: Business in the Community



Proposal 22 The Mayor will work with the Environment Agency, London boroughs and 

private companies providing hazardous waste management services to 

ensure London’s businesses reduce the quantity of hazardous waste they 

are producing and collect it separately for safe disposal. 

Healthcare sector waste 

4.65 The healthcare sector produces large quantities of waste from its 

hospitals, doctors’ surgeries and other clinics. This comprises general 

waste and recycled materials arising from offices, canteens and waiting 

areas and clinical hazardous waste, which includes: 

■ drugs or other pharmaceutical products 

■ swabs or dressings 

■ blood or other bodily fluids 

■ syringes, needles or other sharp instruments. 

4.66 In 2001, the NHS generated an estimated 385,000 tonnes of healthcare 

sector waste, one per cent of the total waste produced in England and 

Wales 214 . Of this, roughly two-thirds was general waste and one-third 

clinical hazardous waste 215 . There are strict controls to ensure it is handled 

and disposed of safely. As a result, it is expensive to manage; 

approximately ten times the cost of general waste. 

Take action 

4.67 Proper segregation of clinical waste for safe disposal is critical because 

prevention of infection is the priority. However, a large proportion 

of non-hazardous healthcare sector waste is likely to be recyclable 

or compostable and it is possible to establish a recycling scheme for 

healthcare sector waste without compromising safety. A waste audit 

can assist in the design of a collection system that enables the 

segregation of clinical waste from general waste and recyclable materials. 

4.68 Such measures could help control waste management costs by ensuring 

healthcare sector wastes are correctly disposed of. Up to 60 per cent of 

waste collected in hazardous waste bins is actually general waste 216 , which 

has huge cost implications. Larger healthcare facilities should consider 

using the savings from correctly identifying and disposing of clinical waste 

to fund a post responsible for waste management.


Case study 38 - Significant cost savings from hospital waste 

management programme 

The University College London NHS teaching trust undertook several 

measures to better manage their clinical waste. Conducting a waste audit 

enabled them to set targets to reduce the amount of clinical waste 

produced and identify material streams for recycling. The trust also ran 

a staff-training programme and reviewed the provision of clinical waste 

sacks. These measures reduced their clinical waste arisings from 60 tonnes 

per month to approximately 45 tonnes per month within three months 

of the programme starting. This has resulted in an annual cost saving 

of £40,000. The trust also now recycles between 40 and 60 bales of 

cardboard every week as well as smaller amounts of paper, glass, cans, 

fluorescent tubes and pallets. 

Source: Department of Health Healthcare waste minimisation: A compendium 

of good practice 

Case study 39 - Awareness and infrastructure make hospital 

recycling easy 

London Remade has been delivering a new recycling initiative in Chelsea 

and Westminster Healthcare NHS Trust across its administration and 

catering departments. The programme addresses changes in European 

legislation, which requires Trusts to demonstrate good practice in 

environmental performance. The green overhaul includes the provision 

of recycling bins across the hospital to encourage staff to recycle all 

general waste including paper, cardboard, plastics, cans and glass. To make 

the process as straightforward as possible, a co-mingled recycling system 

is in place meaning all recycled materials can be placed in the same bin 

and posters have been placed across the hospital to raise awareness of 

the scheme. Soon after the initiative commenced, the Trust was recycling 

over two tonnes of materials per month. 


4.69 There is no single Londonwide NHS waste and recycling collection 

contract, each hospital or healthcare centre has an individual contract. 

For some this will be with the private sector although for others the 

contract will be with the local authority. Most of the general waste 

produced by the healthcare sector is considered by law to be household 

waste and as such local authorities are obliged to collect it if requested, 

although they may charge for the service 217 . Under the Household Waste 

Recycling Act 2003 local authorities are obliged to provide a basic 

recycling service for household waste by 2010, which will provide an



excellent opportunity for healthcare organisations with local authority 

waste services to increase their recycling. 

4.70 The Department of Health has drafted a best practice guide 218 

for the management of healthcare sector waste. The guide’s key 

recommendations include: 

■ conducting waste audits to assess the composition of a waste stream 

and for monitoring waste segregation and prevention strategies 

■ introducing a revised colour-coded best practice waste segregation and 

packaging system. Adoption of this system will achieve standardisation 

across the UK and aid the identification and segregation of healthcare 

sector wastes. 

4.71 The NHS has nine regional Strategic Health Authorities, including one 

for London. There are approximately 65 hospitals in London and around 

70 other large health trusts, along with hundreds of doctors’ surgeries, 

nursing homes and private health clinics that produce clinical waste, 

however there is no organisation that has overall authority over the 

operation of these facilities to ensure good waste management practices 

are employed. 

Proposal 23 The Mayor expects the London Strategic Health Authority to take 

responsibility for implementing the waste aspects of the Department 

of Health sustainable development policy.


4E Avoiding fines 

Introduction 

4.72 Failure to comply with environmental legislation can potentially result 

in court action, fines and in some cases imprisonment. In 2006, the 

Environment Agency prosecuted 380 businesses for environmental 

damage resulting in total fines of £3.5 million that averaged £11,800 

per business, compared to a total of £2.7 million and an average of 

£8,600 in 2005 219 . Five of the top ten fines were for illegal 

waste activities 220 . 

4.73 Many businesses, particularly small businesses, have poor knowledge 

of their environmental obligations and are failing to take the sustained 

action needed to reduce their environmental impact. A City and Guilds 

survey 221 of 600 employees in small manufacturing businesses found 

that 46 per cent of those in management roles were unaware of the 

environmental laws affecting their business, with one in seven not 

knowing that the company could be fined for failing to comply with 

environmental regulations. 

Fly-tipping and the Duty of Care 

4.74 Fly-tipping impacts badly on London’s image and costs local authorities in 

London almost £1 million every month to clear up 222 . The Environment 

Agency estimates that 15 per cent of fly-tipping incidents are business 

waste, particularly construction waste, which accounts for about one fifth 

of fly-tipped waste 223 . 

4.75 Businesses have a legal duty to ensure that any waste they produce is 

handled safely and within the law. This is the Duty of Care. Businesses 

must check that an authorised waste carrier is collecting their waste. 

If a business does not check that their waste carrier is authorised and 

their waste is illegally disposed of, the business could be held responsible. 

4.76 One of the aims of the Duty of Care legislation is to prevent waste 

producers simply handing their waste over to anyone prepared to take 

it away, without giving consideration to where it is going and whether 

it will be dealt with properly. Businesses need to be made aware of their 

responsibilities so that they are able to comply and business support 

organisations, particularly those advising start-up businesses, should 

be equipped to provide relevant information. The Environment Agency 

manage an online register of authorised waste carriers to enable 

businesses to check their waste carrier is legal. London’s businesses 

should use the Environment Agency’s register of authorised waste carriers 

to ensure they are using a registered business to collect their waste and 

keeping transfer note records in good order to facilitate inspection.



Case study 40 - Business fined for waste dumping 

A Hounslow-based firm has been fined £6,000 after pleading guilty 

to dumping 55 loads of soil from a construction site without a waste 

management licence. This material could have contained contaminants 

including heavy metals and other toxic elements. Even small quantities 

of these pollutants could contaminate large areas of groundwater, 

damaging a valuable water resource for decades. The company was 

charged under Section 33 of the Environment Protection Act 1990: 

depositing soil and subsoil without a waste management licence 

and ordered to pay £1,492 in legal costs. 

Source: Environment Agency: TA/52/06 

4.77 The government, in response to the Better Regulation Task Force's 2005 

report 224 , intends to ’cut red tape… so that businesses can be more 

productive and public services more efficient’ 225 , however, the importance 

of enforcing the Duty of Care legislation cannot be underestimated and 

the Mayor believes it should not be sidelined through the government’s 

‘Better Regulation’ agenda. 

4.78 The Mayor believes that the government should adequately resource 

the Environment Agency and local authorities to deal with illegal waste 

activity and thereby make regulation more effective. Whilst it is at the 

Environment Agency’s and local authorities’ discretion how often and in 

which areas to undertake targeted inspection, there are benefits to a 

regular Duty of Care inspection programme, such as: 

■ improved compliance 

■ reduced fly-tipping and related enforcement costs 

■ improved uptake of trade waste services as businesses without 

adequate arrangements comply 

■ building better relationships with businesses. 

4.79 Transport for London’s Commercial Vehicle Education Unit provides 

education-led enforcement to improve legal compliance and management 

of occupational road risk for freight operations in London. Results have 

identified a link between freight traffic offences and other illegal activities 

such as fly tipping. Consideration is being given to extend the role of the 

unit to cover waste carrier and transfer offences as a means of tackling 

fly-tipping in London.


Proposal 24 The Mayor will work with the Environment Agency and London boroughs 

to ensure all London businesses are aware of, and comply with, their Duty 

of Care responsibilities. 

Proposal 25 The Mayor expects London boroughs, in partnership with the 

Environment Agency, to undertake targeted inspection of businesses, for 

example in areas prone to incidents of fly tipping, to ensure they are 

complying with their Duty of Care responsibilities.



5 Incentives for change: an opportunity 

to make money 

Introduction 

5.1 The environmental impacts from consumption and production patterns 

remain severe. Research undertaken by Green Alliance has shown that 

98 per cent of resources going into the economy end up as waste after 

six months 226 . Product and packaging design has a clear role in reducing 

waste and using resources productively. Design can determine up to 

80 per cent of a product’s environmental impacts 227 . Integrating 

environmental considerations at the design stage, preferably mandated by 

the client through their procurement requirements, is the most effective 

method to improve the environmental performance of the products that 

are bought and sold. Waste, after all, is simply a design flaw. 

5.2 Whilst London’s declining manufacturing industry may indicate a small 

role in waste prevention, design in fact extends beyond the studio and 

the production floor, to the boardroom. As the majority of businesses in 

London have a head office in London or are the head office 228 , they wield 

considerable design power by being at the forefront of decisions made 

at the commissioning stage. Specifying the branding, look and feel, 

market positioning and target audience for a product will have a 

significant influence over the materials used. 

5.3 Another area of huge potential is the direct procurement of goods. 

At 13 per cent of GDP 229 or a budget of over £125 billion per annum 230 , 

the scale of the public sector spend is capable of stimulating the 

market for more sustainable goods and services through direct 

procurement decisions. Increasing London’s green public and private 

sector procurement would cause the market of green products to 

change overnight. With this sort of investment, green products would 

become a more viable alternative for small businesses in terms of 

availability and price. 

5.4 Consumers are increasingly demanding goods and products to 

be manufactured and delivered in an environmentally responsible way. 

Shoppers spent about £26 billion in 2004 on ethical and environmental 

products, an increase of 15 per cent on the previous year 231 . Many 

businesses are increasing their green product range to satisfy this demand. 

5.5 This chapter will outline the principles of sustainable design. The effective 

implementation of which, through design and procurement, will shape 

business purchasing and consumer behaviour across London and beyond.


5A Designing waste out 

Introduction 

5.6 Better design and specification of materials helps to minimise the 

environmental impact of a product throughout its life cycle, for example, 

by preventing waste and minimising the use of hazardous substances 

and enabling the product to be easily reused or recycled. Sustainable 

design should ensure that products are able to be a link in a chain of 

continuous reuse and recycling potential not just an intermediate stop 

on the way to final disposal. 

5.7 Businesses are being pushed by producer responsibility legislation to take 

financial ownership for the environmental impact of their products from 

manufacture right through to disposal. However, a number of products 

fall outside producer responsibility, such as clothes, books and nonelectrical 

toys. For these products, the government is using product 

standards and sector agreements to stimulate change 232 . A business 

that anticipates the need to shift to more sustainable resource use 

patterns is making an investment in its future. 

Case study 41 - Multinational takes early lead to win customers 

Xerox has developed a number of environmental principles addressing 

sustainable waste management, including operating an extensive take 

back and recycling programme, which, in 2004, ensured 71,000 tonnes 

of waste was diverted from landfill and saved over £100 million through 

remanufacturing and parts reuse. Xerox recognized that the best results 

— both environmental and financial — are achieved when products are 

designed from the outset with waste prevention goals in mind. 

Customer feedback, along with a forward-looking view of global trends 

in technology, regulations, and eco labels, led Xerox to develop 

a comprehensive set of standards. Xerox engineering teams are 

incorporating, into product designs, increasingly challenging targets 

for energy efficiency, reuse and recycling and minimised use of 

hazardous materials. 

Source: Xerox 

Case study 42 - Graduates learn about the business benefits 

of sustainable design 

Developed by QED Consulting and London Remade, the Enviro 

Entrepreneur School is open to all aspiring entrepreneurs who want 

to create an exciting recyclable and recycled content product. The school 

aims to overcome the gap between designers who understand how to 

use and add value to exciting new recycled materials and the world of 

marketing and manufacturing. Aimed at graduates and alumni, over 

three years the school has supported 76 start up businesses into the



marketplace by taking delegates through a three-day programme 

delivered by successful entrepreneurs and environmentalists. 

Source: Enviro Entrepreneur School 

Case study 43 - Redesign to improve material productivity 

significantly reduces costs 

To maintain its competitive advantage and prepare for legislation for 

mandatory product take back, Varian Medical Systems UK Ltd applied 

sustainable design techniques to the redesign of part of its radiotherapy 

simulator with support from Envirowise. The first key output was a 

checklist of general design guidelines developed by the design team. 

The checklist will prompt designers to challenge existing practices and 

assumptions by posing questions intended to minimise the use of toxic 

materials, reduce part numbers and raw material use, and make 

disassembly and reuse easier. The £162,000 per year saving in parts 

costs represents a 14 per cent reduction in annual costs. 

Source: Envirowise: NC201 

Case study 44 - Market advantage as a result of resource 

focused redesign 

Fulleon Ltd designs and manufactures elements for fire alarm systems. 

To maintain its position in a highly competitive market, Fulleon is 

committed to continual improvement to reduce manufacturing costs 

and to enhance the functionality of its products. Applying an holistic 

approach to the redesign of its break-glass call point product allowed 

Fulleon to achieve significant cost and environmental benefits, such as: 

■ a 35 per cent reduction in the number of components making 

up the product 

■ a 27 per cent reduction in weight of plastic used 

■ a 24 per cent reduction in packaging costs. 

The average cost of materials to manufacture the call point has fallen 

by 11 per cent and the average labour cost to assemble the call point 

by 34 per cent. The average overall unit cost has therefore fallen by 

21 per cent. Based on the total combined sales for the old and new 

designs over 12 months, the saving in manufacturing costs amounted 

to £92,650 per year and enabled Fulleon to steal a considerable market 

lead over its competitors. 

Source: Envirowise: CS326


Legislating design 

5.8 Packaging legislation 233 requires that: 

■ packaging volume and weight are the minimum amount to maintain 

necessary levels of safety, hygiene and acceptance for the packed 

product and for the consumer 

■ packaging is suitable for material recycling, energy recovery 

or composting, or for reuse (if reuse is intended) 

■ hazardous constituents of packaging have minimum impact 

on the environment at the end of their life. 

5.9 Local authority Trading Standards departments enforce the regulations. 

They can make test purchases, request compliance documentation 

and ultimately prohibit the supply of packaging, which is considered 

to breach the regulations. 

5.10 The Waste Electrical and Electronic Equipment and End-of-Life Vehicles 

Directives also provide a clear incentive to design goods in a way which 

reduces waste and maximises reuse and recycling. 

5.11 Proper application of the directives should ensure businesses undertake 

an assessment of their product’s environmental impact and make changes 

to its design to reduce that impact. However, the government admits that 

producer responsibility directives have ‘not sufficiently targeted waste 

reduction‘ 234 or reduced the environmental impacts of products through 

their life cycle. 

5.12 Envirowise, through its product and packaging design work, promotes 

‘life cycle thinking’, an approach it uses to reduce environmental impacts 

as well as costs for businesses. Life cycle thinking does not require a full 

life cycle assessment of a product, but does require key stakeholders to 

be involved in openly discussing a product or packaging and thinking 

about its design, taking into account its environmental impact across 

its entire existence; covering materials (both extraction and processing), 

manufacture, retail, use and end-of-life. 

Taking responsibility 

5.13 Taking a proactive approach to prevent waste and making products and 

packaging recyclable can reduce the costs of complying with producer 

responsibility legislation and is therefore a key opportunity for obligated 

businesses. The government is working with the retail sector on waste 

issues primarily through the Courtauld Commitment, whose signatories, 

all major retailers and suppliers, have pledged to:



■ design out packaging waste growth by 2008 

■ deliver absolute reductions in packaging waste by 2010 

■ identify ways to reduce food waste. 

5.14 The commitment is being extended to include an increase in the use 

of recycled content materials in their products and packaging. 

5.15 Under the Courtauld Commitment, WRAP works in partnership with 

retailers, brand owners, manufacturers and their packaging suppliers to 

develop solutions across the whole supply chain. These solutions include: 

using innovative packaging formats, reducing the weight of packaging, 

increasing the use of refill and self-dispensing systems and collaboration 

on packaging design guidance. Signatories can access support through 

the government’s Innovation Fund, launched in November 2004, which 

supports household waste reduction initiatives and gives producers the 

opportunity to reduce their producer responsibility compliance costs. 

Seventeen projects have been funded through the innovation fund, with 

a combined investment of over £2 million and potential tonnage savings 

of over 300,000 tonnes 235 . 

Case study 45 - Slimmer packaging possible following funded trial 

With £250,000 from WRAP’s Innovation Fund, Heinz, in conjunction with 

Impress, has carried out successful trials of a new lightweight ‘easy open’ 

steel can end. The new end has a thickness of just 0.18mm – beating the 

lightest food can end previously available by 0.02mm. Heinz now intends 

to convert its entire range of 200g and 400g cans to use the new 

lightweight can end, a move that will eliminate around 1,400 tonnes 

of steel waste annually. The second part of the WRAP-funded project 

will see the project partners working together to develop and trial lighter 

can bodies. If this proves equally successful and the findings are taken 

up across the sector, the scheme could reduce UK household waste by 

as much as 28,000 tonnes per year. 

Source: The Waste and Resources Action Programme 

Case study 46 - Award for innovative packaging designed 

to reduce waste 

Marks & Spencer has received £38,400 of support from WRAP’s 

Innovation Fund to develop a reduced weight ready-meal pack and to 

carry out consumer and market research into its commercial and technical 

feasibility. The project commenced in November 2005 and also involves 

Northern Foods, who have a long-standing relationship with Marks & 

Spencer to manufacture their ready meals. The new design for ready-meal


packaging, which uses 30 per cent less material, won the Innovation 

Award at the Institute of Packaging 2006 Starpack Awards. 


5.16 Working with a range of suppliers WRAP has identified many successful 

retail packaging formats, product dispensing and distribution systems, 

merchandising approaches and product designs. A web-based, 

international packaging database has been developed, to enable retailers 

to identify opportunities to develop product and packaging innovations 

that reduce waste and reduce costs. WRAP has also developed a range 

of tools and resources to support businesses to re-think and re-design 

their products and packaging. 

5.17 The government has indicated that producers will be expected to use 

the lightest weight packaging where such an option exists 236 . There is 

a tension between this policy and the waste hierarchy. For some 

packaging materials, which are designed for one-use only, such as tin 

cans, reducing its weight will reduce the quantity of materials that are 

recycled or disposed of. However, soft drinks, for example, used to be 

produced in thick glass bottles that were returned for reuse. In recent 

years making packaging lighter has meant bottles are now produced on 

a one-use basis. This means that recycling is the only option, which is 

lower down the waste hierarchy than reuse. The government should, 

therefore, make lifecycle thinking part of decision-making at the design 

stage to ensure full account is taken of the waste hierarchy. 

5.18 Despite a focus on reducing packaging, it is possible that consumer trends 

(for example, that large amounts of packaging, particularly for fresh food, 

denotes good quality and the increase in Internet shopping, which may 

increase the use of cardboard to package goods) may prevent any 

absolute reduction in packaging waste to be achieved. However, the 

following case study shows that it is possible to reduce product packaging 

without decreasing market share. 

Case study 47 - No eggstra packaging is needed 

In 2005, Sainsbury’s supermarkets reduced its own-label Easter egg 

packaging by 40 per cent compared to 2004. The packaging was designed 

to be either easily recyclable or reusable in the form of ribbons, gift boxes 

or toys. Easter egg sales were the best ever, proving that larger boxes 

were not needed to increase sales. 

Source: Environment Agency



Busting the recyclable myth 

5.19 Producers should consider available recycling infrastructure as part of the 

design process. Clearly, a product is only recyclable if it can be dismantled 

easily and inexpensively and if there are the facilities and technologies 

available to recycle it, a factor that needs to be better taken into account 

by producers. It is not enough to produce new compostable packaging, 

for example, if composting facilities, equipped to handle compostable 

packaging, do not exist locally or if it conflicts with local recycling 

messages. Local authorities may not have the local infrastructure to 

manage certain packaging materials, or packaging products may be 

composed in such a way as to make them difficult to recycle or 

uneconomic to collect, in terms of having a viable onward market. 

5.20 Research on packaging from 29 everyday food items purchased from six 

supermarkets, a local market and a local high street, found that around 

five per cent of the weight of the goods was made up of packaging and 

that 40 per cent of the packaging waste could not be recycled 237 . In this 

situation these materials must be disposed of as waste, at cost to the tax 

payer. Producers’ claims about how recyclable their products are must 

reflect the local recycling infrastructure or producers need to work with 

local authorities to develop collection and reprocessing facilities. 

5.21 Good product information is a necessary condition for effective policies 

to improve the environmental performance of products and there is 

a strong case that effective labelling becomes a policy priority at EU 

level 238 . The British Retail Consortium and WRAP are proposing a 

consistent approach to recycling information labelling on consumer 

packaging across the UK retail sector in order to help consumers recycle 

more packaging 239 . 

Case study 48 - Carton manufacturers take responsibility seriously 

Each year, UK beverage carton manufacturers produce 55,000 tonnes of 

paper-based cartons for milk, juice, sauces and other liquid food/drinks. 

This equates to around two kilograms of cartons per household which 

could be recycled instead of thrown in the rubbish bin. The Alliance for 

Beverage Cartons and the Environment in the UK (ACE UK), has launched 

a £1.2 million National Recycling Fund to help local authorities 

dramatically boost beverage carton recycling in the UK. Agreed between 

member companies the fund will substantially increase industry support to 

local authorities and other organisations in order to help them establish 

carton collection systems, either through their kerbside service or bring 

bank network.


The cartons will be taken to a bulking facility in east London and from 

where they will be shipped to a mill in Sweden before being recycled into 

plasterboard linings. Currently there is not enough capacity in the 

market to recycle the cartons in the UK, something the Alliance 

is hoping to change. 

Source: Tetrapak Recycling 

Proposal 26 The Mayor will call a conference of producers, grocery retailers and 

London boroughs to: 

■ commit to reducing product and packaging waste 

■ discuss the production and retail of materials that cannot be recycled 

or composted in London (e.g. compostable packaging) and use their 

resources to develop processing and reprocessing capacity 

■ discuss the issues around the development of consistent and clear 

product labelling.



5B Designing waste in 

Introduction 

5.22 London has strengthened its position as a global centre for the creative 

industries, which now provide more jobs for Londoners than do financial 

services 240 . Moreover, although low-value manufacturing in London 

has declined significantly, high-value manufacturing, often related to 

scientific, creative and design fields, remains one of London’s most 

important industries 241 . London should therefore be at the forefront 

of initiatives to design innovative products that prevent waste but also 

incorporate recycled materials. 

5.23 Environmentally, using recycled materials prevents the need to extract 

raw materials and, where they are reprocessed close to the point of 

production, may reduce the transport implications of material use. 

Replacing virgin materials with recycled materials can additionally lower 

the energy demand required to manufacture the materials, which can 

help to reduce London’s contribution to climate change. 

Case study 49 - Using recycling reduced energy consumption 

and carbon dioxide production 

There is a compelling case for using recycled materials in the manufacture 

of container glass, since glass has the ability to be infinitely recycled 

without compromising its quality. Using present technology the UK glass 

industry has the capacity to recycle over one million tonnes of glass each 

year. Despite this, 600,000 tonnes of glass bottles are thrown out from 

pubs, clubs, hotels, restaurants and cafes every year (a quarter of the 

UK’s waste glass containers) the majority of which are landfilled 242 . 

Glass manufacture is very energy intensive with furnaces operating at 

around 1,550°C. However, for every ten per cent of recycled glass in 

furnace feedstock, energy consumption decreases by about two per 

cent 243 . After accounting for the transport and processing needed, 

recycling glass saves 315kg of carbon dioxide per tonne of recycled glass 

and in addition to reducing carbon emissions, every tonne of recycled 

materials used in the manufacture of new glass preserves 1.2 tonnes 

of raw materials 244 . 

Source: Waste Online, Waste Watch 

5.24 Financially, where recycled content is used as a product or marketing 

feature, using recycled materials may improve competitiveness, for 

example, by winning business from the increasing number of green 

consumers. The incentive to use recycled materials may be simpler 

however; to use materials that may be cheaper to buy than virgin 

materials. The Aggregates Levy, introduced in 2002, has increased the 

cost of virgin aggregates, for example, making the use of recycled and


secondary materials more viable. Responses to the government’s 

consultation on Waste Strategy 2007 245 made suggestions as to building 

on the impact of the levy by developing a beneficial VAT on recycled 

materials or refurbished products. 

Secondary materials are first rate 

5.25 Obviously, it is not enough simply to create new green products, there 

must be people wanting to buy products that incorporate recycled 

materials. London Remade, funded by the LDA, has been formed to 

help stimulate and coordinate the development of new markets and 

new uses for recycled materials, bringing to London the benefits of 

international best practice and experience. London Remade occupies 

a unique niche in the waste management industry; acting as an 

intermediary, identifying and stimulating demand for recycled products 

and working with suppliers to increase the quality and range of recycled 

content products manufactured. 

5.26 The Sustainable Consumption Roundtable 246 recommends that the 

government takes urgent action to increase the popularity of 

environmentally friendly products with consumers, including working 

with advertisers to promote green products and encourage businesses 

to do more to make consumers aware of the environmental impact 

of their purchasing behaviour. 

5.27 Defra has updated the Environment and Greener Living pages on 

Directgov 247 to act as an environmental information service for consumers. 

It will provide simple information and advice about the impacts of a range 

of goods and services. WRAP’s ‘Recycled Products Guide’ and the 

‘Recycled Product Directory’ developed by the LDA through the Mayor 

of London’s Green Procurement Code are also comprehensive consumerfacing 

tools. 

Case study 50 - London’s entrepreneurs lead the way 

Chris Carey’s Collections was founded 25 years ago, starting out on 

a market stall in Deptford, selling used textiles. In June 2005, the 

company benefited from a £185,000 capital grant from the London 

Development Agency’s Economic Development Infrastructure Building 

(EDIB) project, through the London Recycling Fund, to assist with the 

relocation of premises and purchase of new machinery. As a result, the 

company will divert 11,000 tonnes of waste textiles from landfill every 

year. The materials are sorted and reused in schools and universities, 

art and drama colleges and film productions and sold to export markets.



‘Fabrications’ is an independent gallery, shop and studio dedicated to 

all aspects of contemporary textiles and design, with a particular interest 

in recycled materials and sustainable design. Fabrications sells a range 

of recycled content products including, in response to recent legislation, 

soft furnishings made from tyres. 

London alone produces approximately one tonne of redundant fire 

hose every two months. Environmental supplier Bio-Supplies is currently 

developing a range of furniture made from redundant fire hose no longer 

used by the London Fire Brigade. The range includes chairs and furniture 

frames for beds and sofas. The innovative range of furniture is being 

targeted at businesses wanting to enhance their environmental credentials 

and 50 per cent of the profits will be donated to the Fire Brigade and 

other related charities. 


Case study 51 - Recycled content product comes out on top 

The Hispaniola is a restaurant ship permanently moored at the 

Embankment in London. After refurbishing the interior and exterior 

of the ship they wanted to upgrade the existing access walkway with 

a contemporary design to compliment the high quality of finishes in the 

restaurant. The selected product needed to be able to cope with changes 

in level and differential movement between the different substrates and 

be hard wearing but low in maintenance. Following detailed comparison 

analysis a recycled glass product was selected. The recycled glass product 

was fit for purpose but had the advantage of coming in a range of 

striking colours and the lightweight material also allowed savings to 

be made in the steel substrate sections. 


5.28 Whilst niche recycled content products are an essential part of London’s 

sustainable economy, London’s greatest opportunity to influence recycling 

markets comes from boardroom level decisions to use recycled materials 

on a mass scale. In such cases, and in order to mainstream them, it may 

be preferable not to promote their recycled content in order to be 

accepted by consumers. 

5.29 In recent years, work has been undertaken, for example by WRAP 

and London Remade, to reduce the perception that products containing 

recycled content are inferior to products made with virgin materials. 

As a result of improved material collection and sorting processes, 

a number of fit for purpose, cost competitive recycled content products 

are now on the market. For example, various mainstream products


can contain a high percentage of recycled materials, notably in paper 

and construction applications, at no extra cost and of equal quality 248 

to virgin materials. 

5.30 Extending the Courtauld Commitment to increase the signatories’ use 

of recycled content materials is an exciting development. The government 

is also developing a specification for minimum recycled content for 

glass products 249 , which would increase the use of recycled glass 

and mainstream its use. Clearly, this could be extended to other 

material streams. 

Case study 52 - Retailer pioneers range of recycled content 

food packaging 

Work is underway to investigate innovative processes to recycle plastic 

bottles (PET: used for soft drinks and bottled water etc.), with the aim 

using the recycled plastic in the production of food-grade PET. The work 

has been led by Closed Loop London in collaboration with London 

Remade and plastics experts from UK universities and European 

reprocessors. Marks & Spencer’s became the first retailer in the UK 

to trial the use of recycled plastic in food and drink packaging on a large 

scale and to gauge customer reaction to the concept. Funded by WRAP, 

the 6-month trial involves around 1,500 tonnes of recycled PET being 

incorporated into salad bowls, beverage bottles, recipe pots and trays, 

with the recycled content ranging from 30 per cent to 50 per cent. 

Marks & Spencer has subsequently won the Tetra Pak Environmental 

Award and the National Recycling Award for their work with Closed 

Loop London. 

Source: Closed Loop London



5C The power of procurement 

Introduction 

5.31 In terms of influencing procurement budgets, the government has 

focused on increasing the percentage of public sector spending on 

green products and services. However, private sector businesses should 

also adopt green procurement policies and contribute to London’s 

sustainability. London is Europe’s greatest financial centre and a world 

leader 250 and changing the procurement behaviour of businesses in 

London would have an impact well beyond the capital’s boundaries. 

In recognition, green procurement is increasingly being integrated within 

mainstream procurement policy and practice. For example: 

■ the Johannesburg Earth Summit in 2002 called for the ‘promotion 

of public procurement policies that encourage development and 

diffusion of environmentally sound goods and services’ 251 

■ in September 2006, the European Commission announced 252 that 

it would propose Europe-wide targets for green public procurement 

for 2010 and called for the development of harmonised standards 

and greater resources to train procurement staff 

■ the UK government is seeking change within the public sector 

to ensure the UK is among the leaders in sustainable procurement 

in Europe by 2009 253 and established a Sustainable Procurement 

Taskforce in May 2005 to bring about a step-change in sustainable 

public procurement. Publishing its Action Plan in June 2006, the 

government made a range of recommendations 254 , such as for 

government to lead by example and to put in place the right 

budgetary mechanisms and to build capacity within the public sector 

to deliver sustainable procurement. 

Case study 53 - Adopting a responsible procurement policy 

embeds good practice into decision-making 

The GLA legal and procurement team, together with counterparts across 

the GLA group, have brought together all current sustainable 

development work streams under a GLA group Responsible Procurement 

Policy. Seven policy themes have been adopted: 

■ encouraging a diverse base of suppliers 

■ promoting fair employment practices 

■ promoting workforce welfare 

■ addressing strategic labour needs and enabling training opportunities 

■ promoting community benefits 

■ encouraging ethical sourcing practices 

■ promoting greater environmental sustainability.


By adopting the policy, the GLA group is making it clear that public 

bodies are able to pursue sustainability objectives through their 

procurement practices, without compromising their compliance with 

legislation. In working together, the GLA group is benefiting from 

knowledge gained across the group and has been able to devise a 

comprehensive set of best practice that everyone can learn from. 

The GLA group spends around £4 billion each year on procurement and 

the Mayor is committed to responsible procurement and the direct socioeconomic 

and environmental benefits it can have on London’s businesses, 

workers and environment. By jointly applying the policy the group can 

make a bigger impact for London. 

Source: Greater London Authority Procurement Team 

5.32 Green procurement has a number of elements including specifying 

and buying products and services that: 

■ prevent waste and are reusable or recyclable 

■ are energy efficient 

■ are from renewable sources, for example, energy 

■ are sourced locally, in order to minimise transport and associated 

impacts and support market development within London, creating 

employment and skill opportunities 

■ are transported by the most sustainable mode 

■ incorporate recycled materials, which reduces the demand for virgin 

materials and can reduce energy demand in manufacture). 

5.33 While there is strong support for green public procurement, there 

is also increasing demand from both the government and the public 

to deliver greater efficiency in public services. Research 255 has shown 

that green procurement has been encouraged through legislation 

but that ’momentum was lost following the Gershon review’ of public 

sector efficiency 256 . 

5.34 It is possible, however, for the public sector to fulfil its commitment 

to sustainable procurement and be more efficient. The Sustainable 

Procurement Taskforce has stated that ’sustainable procurement, as part 

of an improved procurement process… will reduce, rather than add to, 

public spending in both the short and long run’ 257 . One way is for the 

public sector bodies to work together to broker competitive deals, for 

example, in the way the GLA group is jointly applying its responsible 

procurement policy.



Case study 54 - An environmental product range makes green 

procurement easy 

Since 1999 the GLA has been buying its stationery from Banner 

Business Supplies Limited using the OGCbuying.solutions framework. 

The framework enables the GLA to achieve significant efficiencies 

in its purchasing by being able to take advantage of a multi-million 

pound contract. Banner is able to supply a range of environmentally 

sustainable products through its award-winning Globe & Tick 

range. In 2005/06, just under 50 per cent of the GLA’s total 

procurement budget on stationery was spent on Globe & Tick 

products and they are working together to continually increase 

the percentage of green products purchased. 

Source: GLA and Business Business Supplies Limited 

Take action 

5.35 The Mayor of London’s Green Procurement Code is an innovative 

programme that is delivered by the LDA through London Remade. A free 

support service for London based organisations, it drives businesses’ 

commitment to reducing their environmental impact through responsible 

purchasing. Developed in 2001, the Green Procurement Code has over 

500 signatories 258 from the public, private and third sectors. It works with 

these signatories to help them identify opportunities to recycle more and 

buy products manufactured from recycled materials. 

Case study 55 - Fit for purpose recycled plastic finds widespread 

application in vehicle manufacture 

Ford Motor Company signed up to the Mayor of London’s Green 

Procurement Code in April 2003 in line with its environmental priorities 

to reuse and recycle non-renewable materials and use recycled materials. 

As part of its environmental commitment, Ford Motor Company has 

developed a complete vehicle-recycling programme, encompassing design 

for recycling guidelines, reducing hazardous materials and increasing the 

use of recycled material. Recycled content plastic is used in 500 vehicle 

components, diverting 24,000 tonnes of plastic waste from landfill. 

Source: London Development Agency through London Remade 

5.36 All signatories to the Mayor of London's Green Procurement Code 

can participate in the annual purchase report, which measures the 

amount of recycled content products bought by signatories in the year. 

In 2006/07, signatories reported 259 a total spend of £181.3 million on 

recycled content products. The quantity of recycled materials the products


incorporated resulted in carbon savings of over 200,000 tonnes and nearly 

500,000 tonnes of waste diverted from landfill. 

5.37 On an individual level, these accomplishments represent a strong 

commitment to corporate social responsibility (CSR) and good business 

policies and processes. On a Londonwide scale, members of the Green 

Procurement Code are driving best practice in green procurement and 

helping to achieve the Mayor’s vision for London as a world leader 

in green policies. 

Case study 56 - Major supplier goes the extra mile 

The James McNaughton Group supplies graphic and office paper, boards 

and plastics to 4,500 customers in the UK and Ireland. In 2006 turnover 

was £260 million. Environmental initiatives were introduced to distinguish 

McNaughton from its competitors. Recycled products account for 15 per 

cent (approximately £39 million) of total sales, making it the company’s 

fastest growing product sector. 

Meetings have been arranged with their suppliers to convey their 

environmental policy and suppliers are asked to complete an 

environmental questionnaire. All non-product specific marketing materials 

are printed on recycled paper and plastic laminating is no longer used, 

replaced instead by a water based varnish or a biodegradable laminate. 


5.38 In October 2007, the Mayor of London’s Green Procurement Code was 

re-launched with an improved and extended service. The new Green 

Procurement Code will offer advice and information on energy and water 

saving products, in addition to the traditional focus on recycled content 

products. It will also work with public sector signatories to deliver the 

key milestones in the Sustainable Procurement Taskforce Action Plan 260 . 

The Green Procurement Code will manage the needs of small businesses 

through a range of tools and structured events that will ensure 

continuous improvement at their own pace. 

Proposal 27 The Mayor expects all public sector organisations based in London 

(including government offices, their departments, agencies, schools 

and hospitals) and London's FTSE 250 companies, to sign up to the 

Mayor of London’s Green Procurement Code. 

The domino effect 

5.39 Green procurement policies enable businesses to engage suppliers 

in improving their environmental performance, and thereby cascade 

improvement across several different organisations and sectors.



London’s vast and growing purchasing power can bring about real 

and lasting change. 

5.40 Success requires businesses to adopt more responsible purchasing 

practices, which select suppliers based on their commitment to 

sustainable resource management. Implementing this sort of procurement 

policy and routinely assessing suppliers based on their environmental 

performance will support the growth of green suppliers and encourage 

others to adopt similar practices. 

Case study 57 - Fast track to waste prevention across the supply 

chain leads to incredible cost savings 

After several years of implementing a waste prevention programme 

at its own sites, Allied Distillers Ltd decided to involve its key suppliers 

in a similar initiative to encourage resource productivity. Seven supply 

companies were selected to participate in a waste prevention 

programme. Training workshops and waste reviews were followed 

by on-site implementation, and advice from independent consultants, 

which resulted in: 

■ cost savings of £1.2 million per year (overall potential of £1.7 million 

per year) 

■ a reduction in materials use of 945 tonnes per year. 

Source: Envirowise CS407 

Case study 58 - Improved environmental performance cascades 

through supply chain 

Since signing up to the Mayor of London’s Green Procurement Code 

in 2003, Croydon Council has implemented a wide range of steps to 

achieve sustainability both internally and externally by actively 

encouraging suppliers to reduce their environmental impact. Croydon 

Council also stipulates that all companies responding to tenders must 

use recycled content products wherever possible. Increasingly, contractors 

are required to report on specific environmental performance indicators, 

including those relating to the use of recycled materials. The Mayor of 

London’s Green Procurement Code is cited specifically in tender 

documentation to help contractors achieve targets and therefore win 

the council’s business. 


5.41 There is a role for large businesses to support the green development 

of suppliers, particularly small businesses, which may require support 

to implement changes to their business processes and operations.


Working with a supplier in this way can strengthen the relationship 

with them and support the green development of small businesses. 

Proposal 28 The London Development Agency, including (but not exclusively) through 

the Mayor of London’s Green Procurement Code, will work with London’s 

businesses to adopt responsible purchasing practices, which: 

■ use a procurement strategy to ensure that environmental issues 

are proactively addressed in all aspects of the procurement process 

■ specify environmental criteria when commissioning products 

or packaging.



5D It’s what’s on the inside that counts 

Introduction 

5.42 Increasingly businesses are recognising that managing their environmental 

impact is not just a matter of compliance. By taking action over and 

above minimum legal requirements, they can address both their own 

competitive interests and the interests of wider society. 

5.43 The opportunities for businesses that choose to be environmentally 

responsible go beyond financial savings. Consumers are increasingly 

demanding improved environmental performance and for goods and 

services to be delivered in a socially and environmentally responsible 

way. Corporate Social Responsibility (CSR), which describes how 

a business takes account of the economic, social and environmental 

impacts that result from the way it operates, is increasingly mainstream. 

Organisations that ignore this demand may find it harder to compete 

in London’s future marketplace. 

5.44 There is a positive link between improved environmental performance 

and enhanced financial performance. According to a literature review 

undertaken for the government; ‘though the evidence is not able to 

prove causality, it does suggest a virtuous cycle of financial and 

environmental performance’ 261 . Research conducted by the Environment 

Agency 262 has shown that companies with above average environmental 

standards can financially out-perform those that are below average by 

up to 43 per cent. Further, one in ten people would be prepared to take 

a pay cut to work for a company with a better environmental performance 

and 14 per cent would decline a job offer from an employer with a poor 

environmental record 263 . 

Environmental Management Systems 

5.45 Certification to an accredited Environmental Management System (EMS) 

demonstrates commitment to reduce an organisation’s environmental 

impact and provides a practical framework within which environmental 

issues can be managed. A properly managed EMS can help with managing 

risks, liabilities and legal compliance, thereby avoiding costs associated 

with prosecution and enforcement notices by regulators. Government has 

stated that implementing an EMS ‘can help organisations improve their 

resource efficiency and reduce costs’ 264 . 

5.46 The universally accepted benchmarks for environmental management 

systems are ISO 14001 and the Eco-Management and Audit Scheme 

(EMAS). Both systems provide organisations with a structured approach 

to implementing a bespoke management tool that integrates 

environmental management with other management functions.


Case study 59 - Tough targets met by top down implementation 

of Environmental Management System 

As the third largest car manufacturer in the world, Toyota is committed 

to reducing its impact on the environment. In 1996 Toyota was the first 

car manufacturer to gain ISO 14001 accreditation for all its UK factories. 

It developed its environmental management system to stay on top of its 

environmental objectives and ensure that all processes are dealt with 

in an environmentally responsible way and are implemented across all 

the factories. In December 1999 Toyota started its ‘environmental action 

plan’, which included a target to send zero waste to landfill by 2005. 

It achieved this target in 2004 and continues to reduce its overall 

environmental impact. 


Case study 60 - ISO 14001 benefits company by reducing waste 

Coca-Cola Enterprises’ Milton Keynes site has been working to reduce the 

amount of waste it sends to landfill. As part of its ISO 14001 certification 

it made a number of changes to its manufacturing processes. The site, 

which produces more than a third of all canned Coca-Cola products in 

Great Britain, has invested £100,000 in infrastructure and equipment to 

support segregation, processing and containment of waste for recycling. 

As a result the site saves more than £2,000 each month through sales of 

recycled materials and the much lower amounts of waste sent to landfill. 

Source: Environment Agency 

Think small, act big 

5.47 Defra has stated that ‘suppliers are increasingly expected to have 

an accredited environmental management system in place to satisfy 

requirements of major customers’ 265 . The successful implementation 

of an environmental management system is often seen, however, 

as the preserve of large companies and it is likely that small businesses 

will find it more difficult than large companies to achieve certification. 

ISO 14001 or EMAS can appear daunting and expensive and the smaller 

the firm the smaller the economic benefit of implementing an 

environmental management system 266 . 

5.48 The British Standards Institute has developed a new standard, BS 8555, 

which breaks down the implementation process for ISO 14001 or EMAS 

into six stages, making the implementation of an EMS accessible to small 

businesses. The LDA has part funded the London Environment Centre 

to deliver the Business Environmental Efficiency Green Mark project. 

Working through the three Green Mark levels, businesses take a flexible



approach to environmental improvement and use a set indicators to 

measure progress. To keep the Green Mark, businesses have to 

demonstrate, annually, that they have sustained their level of 

environmental good practice. 

5.49 Such programmes are an important way in which small businesses 

can continue to compete in London’s economy. They are able to use 

the phased approach to demonstrate their environmental good practice 

to potential customers and, if necessary, their progress towards 

full certification. 

Case study 61 - Small business benefits from Environmental 

Management System 

In January 2004, Chessington Garden Centre started to develop 

an environmental management system using a programme based 

on BS 8555. At the beginning of the programme the centre recycled 

33 per cent of its waste stream. As a result of developing an 

environmental management system their recycling rate had risen to 

81 per cent by December 2005. A key element of the BS 8555 approach 

has been the way it encourages environmental performance improvement 

at an early stage in the implementation process and the introduction of 

performance measures at an early stage in the programme. 


Environmental Reporting 

5.50 Environmental and corporate social responsibility reporting is increasingly 

a public expectation of major companies. Research undertaken by the 

Environment Agency found that 41 per cent of the first 100 FTSE All- 

Share companies reported on their environmental performance in 2006 267 . 

5.51 European legislation 268 requires large businesses (1,200 British companies) 

to provide a Business Review, which includes environmental matters. 

Defra has produced a set of Environmental Reporting Guidelines 269 

to help businesses report on their environmental impacts in a consistent 

way that meets the needs of regulators, their shareholders and other 

stakeholders. Whilst aimed at businesses, the guidance is relevant to 

public sector organisations. 

5.52 The government’s sustainable development strategy 270 required all central 

government departments and their executive agencies to produce action 

plans to ensure the delivery of their strategy. The Sustainable 

Development Commission acts as the independent ‘watchdog’ and reports, 

annually, on government progress.


5.53 Producing data and information on environmental and social impacts 

allows a full range of stakeholders, from city analysts to local 

communities, to scrutinise the environmental performance of the 

business community. 

Proposal 29 The London Development Agency will promote the take up of standards 

for environmental management among London’s businesses.



5E The icing on the cake 

A standard for London’s streets 

5.54 Litter can affect the economic effectiveness of the city and also residents’ 

and visitors’ perceptions of London. 

5.55 In 2002 the Mayor launched the Capital Standards campaign to improve 

the cleanliness of London’s streets. The campaign, delivered in partnership 

with most London boroughs, seeks to bring about a dramatic 

improvement in London’s street environment and encourage and 

implement schemes to recycle street waste. Some businesses are 

recognising that they should share the responsibility for litter produced as 

a result of their activities and have actively sponsored the Mayor’s ‘Litter 

Fairy’ campaign or worked with local authorities and neighbouring 

businesses to sponsor litterbins and signage. 

5.56 ENCAMS has developed a new business engagement programme to 

improve trade waste management and reduce litter 271 . The Keep Britain 

Tidy Business Awards are a positive recognition of good practice and 

provide businesses with an opportunity to communicate messages about 

reducing and recycling litter to the public. 

5.57 Businesses should take responsibility for litter that is generated as a result 

of their activities, for example retail or take-away food, and work with 

their local authority, neighbouring business or Business Improvement 

District to take action. Local authorities have legislative support 272 to work 

with businesses to reach agreement. Good examples include the recent 

agreement between London’s free newspaper distributors and the 

City of Westminster to site litter recycling bins. 

Case study 62 - Freesheets agree to voluntary measures 

to tackle waste 

The publishers of London's two evening free newspapers, London Lite 

and thelondonpaper, have agreed a protocol with Westminster City 

Council for a voluntary regime to tackle the problem of waste newspapers 

in the West End. As part of the new regime, they will purchase and install 

around 40 council-approved recycling bins and recycle the contents. 

Regular litter collections will also be carried out by the newspapers, 

in addition to the council’s existing street sweeping. 

The new regime follows extensive negotiations between the council 

and the publishers to tackle the problem of newspaper waste. In July 

2007, the council’s cabinet agreed to invoke powers under the Clean 

Neighbourhoods and Environment Act 2005 if a voluntary agreement 

could not be reached.


In large parts of the West End discarded newspapers currently account 

for around a quarter of all street waste, and as it is contaminated with 

other litter is not recycled. The new regime will significantly reduce 

waste on the streets of Westminster. 

Source: Westminster City Council press release 22 August 2007 

Proposal 30 The Mayor will encourage Capital Standards to expand its membership 

and involve London’s businesses in programmes that tackle enviro-crime 

in the public realm. 

Proposal 31 The Mayor expects London Boroughs to utilise available legislation, 

including the Clean Neighbourhoods and Environment Act (2005), to 

improve street cleanliness, for example, by working with producers of free 

newspapers, to expand litter and street recycling services. 

Making resource management the main event 

5.58 Events in London’s public spaces and exhibition centres are a major part 

of London life. However, waste management requirements are often not 

considered in the event planning process or by the exhibition centres and 

conference facilities. Producing a sustainable event, including marketing 

materials, delegate packs and catering , requires organisers to reduce the 

amount of materials distributed, increase recycling and use recycled or 

reusable goods. 

5.59 There is a range of best practice guidance for businesses to use when 

planning events, for example: 

■ the London Sustainability Exchange has produced practical guidance 273 

on how to reduce the environmental and social impacts of events 

■ working with Closed Loop London, London Remade have developed 

a step-by-step guide 274 to increase recycling during an event by 

ensuring anything provided or sold at the event is recyclable 

■ a new British standard has been developed for sustainable event 

management. BS 8901:2007 will help companies reduce the carbon 

emissions and waste generated as a result of the event and improve 

the resource efficiency of the entire event supply chain. 

Case study 63 - Iconic venue achieves amazing recycling results 

London’s newest entertainment destination – The O2 – has set a new 

standard for sustainable waste management with its comprehensive 

recycling programme. Up to ten tonnes of organic kitchen waste from the 

arena is being composted on-site in an in-vessel composter, reducing the



waste by 90 per cent. The food waste is turned into compost that 

will be used for landscaping on the Greenwich Peninsula. 

Waste cooking oil is collected from The O2’s restaurants and sent for 

processing into bio-diesel. Cardboard and plastic film, collected from 

back-of-house activities, is baled and recycled, as is glass, which is sent 

to local processor, Day Aggregates. 

Front-of-house recycling is designed to be as easy for the public to use 

as possible. So five materials are collected commingled and sent to the 

nearby Materials Reclamation Facility owned by Greenwich Council for 

sorting and onward reprocessing. 

Source: The O2, AEG Europe 

Case study 64 - London festival sets recycling precedent 

The annual Bedford Park Festival in Chiswick provides a good example 

of how waste should be managed at local events. Over two days in June, 

it attracts thousands of people with fairground attractions, live music and 

stalls. Working with Ealing Council and Hounslow Council, litterbins were 

taken out of use and sets of supervised open bins for all materials, 

including food, were installed. Latymer Upper School, provided pupils 

to supervise the bins. At the end of the event, a total of 1,040 kg, 

including 180 kg of food waste was recycled or composted. 

Source: Bedford Park Festival 

Case study 65 - Early planning limits non recyclable waste at event 

A closed-loop recycling programme was successfully implemented at the 

Frieze Arts Fair at Regents Park in October 2005. Closed Loop London 

worked with beverage suppliers DP Cappuccino to ensure their packaging 

range was able to be recycled. Food suppliers Baker and Spice also used 

a range of recyclable food packaging. Purpose-built recycling bins were 

used to capture general waste and mixed recycled materials including 

paper, cardboard, plastics and cans. Glass generated by the opening night 

cocktail party was also collected and recycled. Nine tonnes of mixed 

recycled materials and four tonnes of glass were diverted from landfill, 

a 47 per cent increase on the previous year. 

Source: London Remade


Case study 66 - Setting the standard for sporting stadia 

England’s final test match against Pakistan saw more than 75 recycling 

stations set up around the Brit Oval in an initiative to capture materials 

generated during the match for recycling. Following the success of a pilot 

scheme during the Natwest-Series One Day International against Sri Lanka 

in June 2006, at which 40 per cent of the waste generated was recycled, 

Leisure Support Services worked with London Remade to ensure recycling 

was maximised at the final test match. With expectations that the sell-out 

crowds at the Brit Oval would generate over 50 tonnes of waste during 

the five days, the new initiative aimed to ensure the waste was collected 

for recycling. Catering and cleaning teams underwent special training to 

ensure that materials were recycled resulting in over 17 tonnes being 

collected for recycling. 


Proposal 32 London’s businesses should use available guidance to implement 

sustainable waste management practices at their events, including 

developing and adhering to a waste management plan that addresses 

waste reduction for example by: 

■ using reusable and recyclable materials that incorporate recycled 

materials 

■ providing recycling facilities, including for organic materials. 

The most sustainable Games ever 

5.60 London, host of the 2012 Olympic Games and Paralympic Games, 

has committed to making them ‘the greenest Games in history’ 275 . 

The proposals state that London will host a zero-waste, low carbon 

Games, which will be based on the ‘One Planet Olympics’ principles 

and will deliver long-term social and environmental benefits to the city. 

The delivery plan 276 for the Games sets out key areas for delivering 

sustainable Games, which are to: 

■ set sustainability standards, including setting targets for energy, 

climate change, waste, biodiversity, access, inclusion and healthy 

lifestyles 

■ require independent sustainability assurance by the Commission 

for a Sustainable London 2012 

■ use the Games as a catalyst for sustainable business and lifestyles: 

increasing the take-up of sustainability standards in London’s business 

showcasing new sustainable technologies.



5.61 There is an opportunity for London, through the delivery of the Games, 

to lead by example in reducing waste and using resources more 

sustainably, including: 

■ reducing waste in construction and demolition, particularly in the use 

of temporary structures and prioritising on-site waste management 

■ maximising the scope for the reuse, composting, recycling and recovery 

of waste, at each phase of the Games and their legacy 

■ minimising merchandising, marketing and catering waste. Where it is 

produced, ensuring it is recyclable and incorporates recycled materials. 

Case study 67 - Olympic Park sets construction recycling standards 

Over 95 per cent of 10,827 tonnes of demolition materials from the 

Olympic Park is being recycled or reused so far, beating the 90 per cent 

target set out in the Olympic Delivery Authority’s (ODA) Sustainable 

Development Strategy earlier this year. 

Over 9,823 tonnes of the materials from the demolition of buildings 

on the Eton Manor and Clays Lane areas of the Olympic Park has been 

sorted and prepared for reuse on site. A further 638 has been recycled 

or reclaimed off site, including timber turned into chipboard, plasterboard 

turned into gypsum powder and steel recycled as scrap. 

Of 9,823 tonnes of demolition materials: 

■ 176 tonnes of timber recycled for chipboard 

■ 326 tonnes of metals reused as scrap 

■ 30 tonnes of plasterboard turned into gypsum powder 

■ 106 tonnes of general waste recycled (plastic bottles, cans, tyres, etc). 

Source: ‘Olympic Park clean up beats green targets’ press release 17 April 2007


Case study 68 - Olympic Park sets construction procurement 

standards 

At least 20 per cent of materials used in permanent venues and 

associated works and the Olympic Village are to be recycled content. 

Designers will incorporate recycled materials into the Olympic Park, 

such as: 

■ 9,741 tonnes of crushed brick and concrete 

■ 70 tonnes of Yorkstone walling 

■ 10 tonnes of reclaimed London stock bricks 

■ 2 tonnes of roofing tiles. 

During a nine month programme, 256 buildings will be demolished, 

most of them industrial. Furniture removed from buildings is being 

supplied to an organisation that provides low cost furniture to schools 

and community groups. 

Source: ‘London 2012 – Sustainability strategy launched’ press release 23 January 2007 

’Olympic Park clean up beats green targets’ press release 17 April 2007 

Proposal 33 The Mayor will support the Commission for a Sustainable London 2012 

to act as an independent assuror of the sustainability of the waste related 

activities of the Olympic Delivery Authority and the London Organising 

Committee of the Olympic Games to ensure that the 2012 Games are the 

most sustainable ever. This will be achieved, for example by: 

■ achieving the London Plan reuse and recycling targets for all strategic 

developments 

■ achieving the recycling and composting targets for all waste produced 

during the Games and ensuring infrastructure is developed to ensure 

this target is met throughout the Games’ legacy 

■ implementing BS 8901: Specification for a sustainable event 

management system 

■ adopting the GLA group responsible procurement policy and achieving 

the highest levels of the Mayor of London’s Green Procurement Code.



6 Leading by example: 

Putting our own house in order 

Taking action 

6.1 The Mayor expects the GLA group’s activities to meet the targets and 

policies set out in his strategies. Particularly, in relation to this strategy, 

to meet the London Plan recycling and reuse targets. 

6.2 Throughout this strategy, some of the case studies have been drawn from 

the work of the Mayor and the GLA group and illustrate ways in which 

the Mayor is already seizing the opportunities presented by sustainable 

resource use. To illustrate they way in which the Mayor has fulfilled his 

commitment to lead by example, the following section details some of 

the sustainable waste management activities of the GLA group to date. 

Reduce and reuse 

■ An environmental champion programme has been established at 

City Hall to work with staff to reduce waste and encourage recycling. 

Since August 2007, the GLA has reduced its waste from 1.7 tonnes 

to 1.3 tonnes 

■ Transport for London’s Oyster card has enabled paper ticket figures 

in 2004/05 to drop by 32 million, reducing paper consumption 277 

■ By implementing a battery take-back and recycling contract the 

London Fire and Emergency Planning Authority (LFEPA) have 

prevented over 200kg of battery waste from going to landfill each 

year 278 and by identifying a new method of supplying water to 

firefighters at operational incidents, LFEPA is saving 200,000 plastic 

bottles, annually 279 

■ In 2006, Transport for London reduced their waste by 18 per cent 280 . 

Recycle and compost 

■ A comprehensive recycling scheme operates at City Hall, in addition 

to a relationship with East London Community Recycling Partnership 

to compost food waste from the City Hall café and tea points. Since 

August 2007, the GLA has achieved a monthly recycling rate in excess 

of 80 per cent 

■ The Metropolitan Police Service has developed a sustainable waste 

management service including integrating internal collection into the 

cleaning contract and providing training to staff 281 . A target has been 

set to recycle 45 per cent of waste by 2010 282 

■ In 2005/06, Tube Lines expanded its dedicated paper recycling scheme, 

collecting waste paper from 26 stations and six depots on the Jubilee, 

Northern and Piccadilly lines to recover over four tonnes of waste, 

mostly comprising newspapers, for recycling every day 283 

■ Transport for London recycled 87 per cent of the 115,000 tonnes 

of construction waste it produced in 2005/06 284 .


Buy green 

■ A GLA group Responsible Procurement Policy has been developed 

to ensure the annual £4 billion spend benefits London’s businesses, 

workers and the environment 

■ All the Functional Bodies are signed up to the Mayor of London’s 

Green Procurement Code 

■ Following their success in winning the Most Innovative Organisation 

at the Mayor of London’s Green Procurement Code awards in 2005, 

LFEPA has continued to develop contracts with the recycling industries 

and is actively promoting the use of their waste fire hose for 

commercial reuse in innovative furniture, footwear and clothing 

accessory designs 285 

■ LFEPA were again highly commended at the 2007 awards for their 

procurement activities 286 and won both the overall award at the City 

of London’s Sustainable City Awards and the Sustainable Procurement 

Award in February 2007 287 

■ The Metropolitan Police Service were runners up in the City of 

London’s Sustainable City Awards in the Sustainable Procurement 

category in 2007 and were highly commended at the 2006 Mayor 

of London’s Green Procurement Code awards 288 

■ Data provided to the Mayor of London’s Green Procurement Code 289 

showed that in 2006/07, the GLA group had a combined spend 

of over £8 million on recycled products, representing an increase 

of almost nine per cent on the previous year. 

Managing environmental impacts 

■ Transport for London have developed and implemented an integrated 

health, safety and environmental management systems across the 

organisation following internationally recognised standards of good 

practice, including ISO 14001 290 

■ LFEPA’s Procurement Department gained accreditation under ISO 

14001 in September 2005 291 

■ The LDA’s new office - Palestra – was built to achieve a ‘very good’ 

BREEAM rating (Building Research Establishment Environmental 

Assessment Method) 292 

■ The LDA have established a Green Office Programme, which will 

target resource efficiency, recycling, and travel to work policies 293 

■ The LDA was named National Green Champion in Building and 

Construction for its clean-up of contaminated land at White Hart 

Triangle, east of Woolwich, where it plans to create a one million 

square foot industrial park 294 . 

6.3 The Mayor and the GLA group will lead by example in implementing 

this strategy through the improved management of GLA group waste,



events, fleet vehicles, environmental reporting, management systems 

and procurement. 

6.4 By demonstrating excellence the Mayor expects London’s businesses 

to be inspired to take responsibility and take action for their waste 

in accordance with the waste hierarchy and contribute to London’s 

sustainability. 

Proposal 34 The Mayor and the GLA group will lead by example in resource 

productivity and sustainable waste management by: 

■ producing a sustainable waste reduction and reuse plan for the 

GLA group 

■ achieving the London Plan composting and recycling targets across 

the group within each of their offices 

■ implementing BS 8901: Specification for a sustainable event 

management system 

■ achieving the Mayor’s preferred standard for sustainable design 

and construction for their strategic developments 

■ demonstrating compliance with an environmental management system 

(such as ISO 14001 or equivalent standard) by December 2009 

■ annually reporting on their environmental performance in line with 

Defra’s Environmental Reporting Guidelines 

■ ensuring that their own and contracted fleets are registered to the 

Freight Operator Recognition Scheme by 2010 

■ achieving the highest levels of the Mayor of London’s Green 

Procurement Code 

■ adopting responsible purchasing practices, which use a procurement 

strategy to ensure that environmental issues are proactively addressed 

in all aspects of the procurement process.

Making waste work in London The Mayor’s Draft Business Waste Management Strategy Mayor of London 133



A1 A summary of the key legislation which has 

been taken into consideration when 

developing this strategy 

STRATEGIC DIRECTION PRODUCER RESPONSIBILITY OTHER 

EUROPEAN LEGISLATION 

Framework Directive on Waste 

(75/442/EC, as amended) 

Landfill Regulations 2002 

European Thematic Strategies on the Prevention and 

Recycling of Waste and on the Sustainable Use of 

Natural Resources (Dec 2005) 

Packaging and Packaging Waste Directive 

(94/62/EC) 

End-of-Live Vehicles (ELVs) Directive 

(2000/53/EC) 

EC Regulations No 2037/2000 on substances that 

deplete the ozone layer 

EU Council Directive (91/689/EEC) on Hazardous Waste 

Waste Electrical and Electronic Equipment (WEEE) 

Directive (2002/96/EC and 2003/108/EC) 

Directive (2006/66/EC) on batteries and accumulators 

and waste batteries and accumulators 

Integrated Pollution Prevention and 

Control Directive (96/61/EC) 

Consolidated EU Regulation on 

Animal By-Products (1774/2002)


NATIONAL LEGISLATION REGIONAL POLICY 

Environmental Protection Act 1990 

The Environmental Protection (Duty of Care) 

Regulations 1991 

Landfill Regulations 2002 

Landfill Allowance Trading Scheme 2005 

Waste Strategy 2007 

UK Government Sustainable Development Strategy: 

Securing the Future, 2005 

GLA Act 1999 and 2007 

Producer Responsibility Obligations (Packaging Waste) 


The End-of-Life Vehicles (Producer Responsibility) 


Ozone Depleting Substances Regulations 2002 

The Hazardous Waste (England and Wales) 


Restrictions of the Use of Certain Hazardous Substances 

in Electrical and Electronic Equipment Regulations 2005 

Waste Electrical and Electronic Equipment 


Regulations – TBC 

Pollution Prevention and Control (PPC) Legislation 

(including Integrated Pollution Prevention 

and Control) 2005 

Animal By-Products Regulations 2005 

The Mayor’s Municipal Waste Management 

Strategy 2003 

The London Plan 2004, its early alterations 2006 

and further alterations 2008 

The Climate Change Action Plan 2007 

Economic Development Strategy: 

Sustaining Success 2005 

The Mayor’s Business Waste Management Strategy


Proposal 


Proposal 1 – The Mayor calls on the government to ensure that effective fiscal and legislative instruments are in place to stimulate 

resource productivity and sustainable waste management among London’s businesses including: 

■ a clear commitment to continue to escalate the landfill tax significantly after 2010 

■ a requirement for auditable evidence to support the implementation of pre-treatment requirements for landfilled waste from 

October 2007 

■ statutory recycling and composting targets and indicators for municipal waste rather than household waste 

■ recycling and composting targets and indicators for non-municipal business waste to complement the national target for the 

reduction of commercial and industrial waste going to landfill 

■ statutory diversion targets and measures to reduce the quantity of non-municipal biodegradable waste disposed of to landfill 

Proposal 2 – The Mayor calls on the government to ensure that: 

■ businesses are aware of, and comply with, their producer responsibility obligations 

■ the Environment Agency is adequately resourced to enforce the regulations 

■ challenging recycling targets are set for producer responsibility legislation 

■ the packaging regulations are amended to favour local recycling and reprocessing and carbon positive recycling 

■ statutory measures are established to implement producer responsibility legislation rather than persisting with voluntary agreements 

■ obligated businesses adequately compensate London boroughs operating schemes for producer responsibility wastes 

■ the government and obligated businesses run effective communication campaigns about producer responsibility legislation to raise 

and maintain awareness of consumers’ responsibilities. 

Proposal 3 – The London Development Agency will coordinate the provision of information and advice about resource productivity 

and sustainable waste management to London's businesses by: 

■ promoting coordinated advice on resource efficiency delivered primarily through Business Link London, and developing strong links 

between the relevant delivery provider and other stakeholders including London’s business support programme providers 

and London boroughs 

■ working with the Mayor and partners to deliver a targeted communications campaign to raise and maintain awareness among 

London’s businesses of resource efficiency and sustainable waste management 

■ ensuring their partners integrate information about resource efficiency and sustainable waste management into their business 

support programmes. 

Proposal 4 – The Mayor will establish a London business council to bring together London’s business leaders to champion resource 

productivity and sustainable waste management within a business environment. 

Proposal 5 – The Mayor expects London boroughs to offer competitive waste and recycling collection services for local businesses, 

in partnership where necessary, including: 

■ recycling services of at least the same materials as their household collections 

■ organic kitchen waste collections 

■ accepting business waste for reuse or recycling at their reuse and recycling centres 

■ actively promoting their services to businesses. 

A2 Implementation Plan


Timescale Responsible Degree Monitoring 

organisation of priority Evaluation 

Ongoing Mayor High Legislative change 

Ongoing Mayor Medium Legislative change 

LDA and partners/ High 

Mayor 

From 2007 Penetration of Business Link London, number of 

businesses accessing business support programmes 

In 2008/09 Mayor, High Council established, profile of council members, 

London’s businesses agenda and minutes of sessions 

Ongoing Waste authorities High Non-household municipal waste recycling rate, 

and partners number of businesses served, promotion on website


Proposal 


Proposal 6 – The Mayor will investigate and, if appropriate, implement an appropriate vehicle to act as a trading hub for 

recycled materials across London. 

Proposal 7 – The London Development Agency will develop at least one demonstrator project that develops local sources 

of renewable fuel from waste that would support a future move to a hydrogen economy. 

Proposal 8 – To contribute to the development of business waste infrastructure in London, with sufficient capacity 

to achieve the London Plan self-sufficiency targets, the London Development Agency will investigate: 

■ establishing a fund for business waste infrastructure 

■ attracting partners and leverage additional investment to the fund 

■ supporting the development of businesses and social enterprises that prevent waste, collect and manage resources in London 

or develop products made from recycled materials 

■ delivering programmes that support innovation in the green industries sector 

Proposal 9 – The Mayor will promote and encourage the use of advanced waste technologies to manage London’s 

business waste and calls on the government to make advanced waste technologies eligible for Enhanced Capital Allowances. 

Proposal 10 – The Mayor expects London boroughs to develop Core Strategies, which commit the authority in their Local 

Development Framework to: 

■ achieve the London Plan and Municipal Waste Management Strategy recycling targets 

■ specify in which Local Development Scheme documents they will allocate sites to achieve their apportionment, 

set through the London Plan 

■ establish criteria to determine waste planning applications while preparing more detailed proposals. 

Proposal 11 – The Mayor expects London boroughs to: 

■ provide capacity, where appropriate, for non-municipal waste when developing waste facilities 

■ explore opportunities to develop waste management infrastructure that maximises the potential use of water and rail transport 

■ explore opportunities to develop waste management infrastructure on-site as part of any site development or redevelopment. 

Proposal 12 – Transport for London will promote Delivery and Service Plans to London’s businesses, to encourage them to negotiate 

waste services with reduced transport impacts. 

Proposal 13 – Transport for London, through its London Freight Plan, will promote the early adoption of new engine 

technologies and waste-derived fuels that minimise the impact of waste transport on climate change.




2008/2009 Mayor and LDA Low Feasibility study published 

2011/2012 LDA, LCCA Medium Demonstrator project developed 

2008/2009 – Mayor, LDA, High Fund established, private sector funding leveraged, 

2010/2011 waste authorities businesses created/expanded, programmes delivered, 

and London’s 

businesses 

London Plan targets met 

Ongoing Mayor Low Legislative change 

Ongoing Planning 

authorities 

High Local Development Frameworks 

Ongoing Waste authorities 

and planning 

authorities 

Medium Local Development Frameworks, facilities developed 

Ongoing London’s businesses Low Adoption of Delivery and Service Plans, 

and business support 

agencies, Transport 

for London 

local air quality surveys 

Ongoing Transport for London Low Adoption of new engine technologies and waste-derived 

fuels, implementation of the Freight Plan


Proposal 


Proposal 14 – London’s businesses, particularly those in light industrial estates, should examine the feasibility of: 

■ generating energy on-site from their residual waste, particularly organic kitchen waste, through the use of advanced 

waste technologies 

■ using waste-derived transport fuels in their vehicle fleets. 

Proposal 15 – The Mayor expects Defra and the Environment Agency to take action to address business waste data gaps, including: 

■ undertaking the strategic waste management survey every five years 

■ ensuring relevant data is collected from exempt waste management facilities 

■ making data available and accessible 

■ integrating data collection into government policy making, for example as part of the implementation of site waste management plans. 

Proposal 16 – The Mayor will work with business sectors and their representative associations to produce sector-specific action plans, 

which identify issues and actions specific to businesses of different sizes within each sector. 

Proposal 17 – London’s businesses should conduct waste audits to: 

■ establish waste prevention and reuse systems 

■ identify the materials streams that they can recycle or compost and seek recycling and composting services alongside their waste 

management contracts. 

Proposal 18 – The Mayor will encourage developers to perform beyond the proposed minimum regulatory standard for site waste 

management plans, for example by: 

■ producing site waste management plans for major developments 

■ identifying the hazardous waste that will arise and how it will be managed 

■ stating how waste is being transported for recycling or disposal and the volume of waste being transported by each mode 

■ aiming to achieve the London Plan reuse and recycling targets and support the principles of self-sufficiency and proximity. 

Proposal 19 – The Mayor calls on TrustMark to include sustainable waste management as one of its certification criteria. 

Proposal 20 – The Mayor will revise his Sustainable Design and Construction Supplementary Planning Guidance to set a preferred 

standard for: 

■ developers to provide a green procurement plan with their planning application, setting out the types of materials used, quantities 

and their environmental provenance and efficiency 

■ developers to adopt WRAP's requirements for good practice in recycled content and waste management and specify the requirement 

for at least 15 per cent of the total value of materials used to derive from recycled and reused content by 2010, rising to 20 per cent 

by 2012.




Ongoing London’s businesses/ Medium London Plan targets met, adoption of waste-derived fuels, 

London Climate number new plant developed, pollution and carbon 

Change Agency reduction targets met 

Ongoing Defra and High Business waste data collection systems implemented, 

Environment 

Agency 

strategic waste management survey repeated 

By 2009/10 Mayor, London’s 

businesses and 

business liaison 

groups 

Medium Sector-specific action plans developed 

Ongoing London’s businesses High London Plan targets met, number of businesses 

accessing LESS and accessing support from 

business support programmes 

Ongoing Planning authorities Medium Local Development Frameworks, London Plan targets met, 

and London’s 

businesses 

legislative change, site waste management plans 

Ongoing Mayor, TrustMark, Low TrustMark standard amended, number of London 

London’s businesses businesses certified to the standard 

Ongoing Mayor, London's Medium Sustainable Design and Construction Supplementary 

developers and Planning Guidance revised, brought into local 

planning authorities planning policy


Proposal 


Proposal 21 – The London Development Agency will provide information and advice to London’s businesses about how to change 

their manufacturing techniques to use resources more efficiently. 

Proposal 22 – The Mayor will work with the Environment Agency, London boroughs and private companies providing hazardous waste 

management services to ensure London’s businesses reduce the quantity of hazardous waste they are producing and collect 

it separately for safe disposal. 

Proposal 23 – The Mayor expects the London Strategic Health Authority to take responsibility for implementing the waste aspects 

of the Department of Health sustainable development policy. 

Proposal 24 – The Mayor will work with the Environment Agency and London boroughs to ensure all London businesses are aware of, 

and comply with, their Duty of Care responsibilities. 

Proposal 25 – The Mayor expects London boroughs, in partnership with the Environment Agency, to undertake targeted inspection 

of businesses, for example in areas prone to incidents of fly-tipping, to ensure they are complying with their Duty of Care responsibilities. 

Proposal 26 – The Mayor will call a conference of producers, grocery retailers and London boroughs to: 

■ commit to reducing product and packaging waste 

■ discuss the production and retail of materials that cannot be recycled or composted in London (e.g. compostable 

packaging) and use their resources to develop processing and reprocessing capacity 

■ discuss the issues around the development of consistent and clear product labelling. 

Proposal 27 – The Mayor expects all public sector organisations based in London (including government offices, their departments, 

agencies, schools and hospitals) and London's FTSE 250 companies, to sign up to the Mayor of London’s Green Procurement Code. 

Proposal 28 – The London Development Agency, including (but not exclusively) through the Mayor of London’s Green Procurement 

Code, will work with London’s businesses to adopt responsible purchasing practices, which: 

■ use a procurement strategy to ensure that environmental issues are proactively addressed in all aspects of the procurement process 

■ specify environmental criteria when commissioning products or packaging. 

Proposal 29 – The London Development Agency will promote the take up of standards for environmental management among 

London’s businesses. 

Proposal 30 – The Mayor will encourage Capital Standards to expand its membership and involve London’s businesses in programmes 

that tackle enviro-crime in the public realm.




Ongoing LDA, London’s Low Number of businesses accessing 

businesses business support programmes 

Ongoing Environment Agency, Medium Number of businesses accessing business support 

waste authorities and programmes, hazardous waste arisings, number of fines 

London’s businesses for illegal dumping/ hazardous waste pollution incidents 

2008/09 London Strategic 

Health Authority 

High Guidance issued 

Ongoing Environment Agency, 

local authorities and 

London’s businesses 

Medium Number of fines for non-compliance within London 

Ongoing Environment Agency, 

local authorities and 


Low Number of fines for fly-tipping offences within London 

2009/10 Mayor, London’s 

businesses, 

waste authorities 

Medium Conference held, development of action plan 

2008/09 LDA and London’s High Number of businesses signed to the Mayor of London’s 

businesses Green Procurement Code (business size/sector) 

Ongoing LDA and London’s Medium Number of businesses accessing business support 

businesses programmes, number of businesses signed to the 

Mayor of London’s Green Procurement Code 

Ongoing LDA and London’s Medium Number of businesses accessing business support 

businesses programmes, number of signatories to the Mayor of 

London’s Green Procurement Code with or implementing 

an EMS/seeking certification to an EMS 

2008/09 Capital Standards, 

waste authorities and 


Low Membership expanded, Londonwide promotional campaign


Proposal 


Proposal 31 – The Mayor expects London boroughs to utilise available legislation, including the Clean Neighbourhoods and Environment Act 

(2005), to improve street cleanliness, for example, by working with producers of free newspapers, to expand litter and street recycling services. 

Proposal 32 – London’s businesses should use available guidance to implement sustainable waste management practices at their 

events, including developing and adhering to a waste management plan that addresses waste reduction for example by: 

■ using reusable and recyclable materials that incorporate recycled materials 

■ providing recycling facilities, including for organic materials. 

Proposal 33 – The Mayor will support the Commission for a Sustainable London 2012 to act as an independent assuror 

of the sustainability of the waste related activities of the Olympic Delivery Authority and the London Organising Committee 

of the Olympic Games to ensure that the 2012 Games are the most sustainable ever. This will be achieved, for example by: 

■ achieving the London Plan reuse and recycling targets for all strategic developments 

■ achieving the recycling and composting targets for all waste produced during the Games and ensuring infrastructure is developed 

to ensure this target is met throughout the Games’ legacy 

■ implementing BS 8901: Specification for a sustainable event management system 

■ adopting the GLA group responsible procurement policy and achieving the highest levels of the Mayor of London’s 

Green Procurement Code. 

Proposal 34 – The Mayor and the GLA group will lead by example in resource productivity and sustainable waste management by: 

■ producing a sustainable waste reduction and reuse plan for the GLA group 

■ achieving the London Plan composting and recycling targets across the group within each of their offices 

■ implementing BS 8901: Specification for a sustainable event management system 

■ achieving the Mayor’s preferred standard for sustainable design and construction for their strategic developments 

■ demonstrating compliance with an environmental management system (such as ISO 14001 or equivalent standard) 

by December 2009 

■ annually reporting on their environmental performance in line with Defra’s Environmental Reporting Guidelines 

■ ensuring that their own and contracted fleets are registered to the Freight Operator Recognition Scheme by 2010 

■ achieving the highest levels of the Mayor of London’s Green Procurement Code 

■ adopting responsible purchasing practices, which use a procurement strategy to ensure that environmental issues are proactively 

addressed in all aspects of the procurement process.




Ongoing Waste authorities and 


Low Performance indicators (BVPI 199 or equivalent) 

Ongoing London’s businesses Low Number of businesses accessing support, 

London Plan targets met 

Ongoing to 2012 Mayor, Commission Medium Policies and plans for the Games assessed 

for a Sustainable 

London 2012, 

Olympic Delivery 

Authority and the 

London Organising 

Committee of the 

Olympic Games 

and changes incorporated 

Ongoing Mayor and High ■ Plan produced 

GLA group ■ Targets met 

■ Checklist used, targets met 

■ Standard incorporated 

■ Standard achieved 

■ Report produced 

■ Registration 

■ Levels achieved 

■ Development of environmental stream of GLA 

responsible procurement policy, with indicators, 

number of GLA contracts with companies listed 

on the database


Organisation Weblink 

Aggregain www.aggregain.org.uk 

Agrivert www.agrivert.co.uk 


A3 Contact details for listed organisations 

Alliance of Beverage Cartons/ 

Tetrapak Recycling 

www.tetrapakrecycling.co.uk 

Banner Business Supplies www1.banner-online.biz/sustainability/globeandtick_77.html 

BioRegional www.bioregional.com 

Bio-Supplies www.bio-supplies.com 

Bio-diesel Initiative for Sustainable 

Transport from Recycled Oil 

www.seltrans.co.uk/bistro.asp 

BREMAP www.bremap.co.uk 

BREW www.defra.gov.uk/environment/waste/brew 

BREW Centre for Local Authorities www.oxfordshire.gov.uk/brew 

BS 8555 See ACORN and Institute 

of Environmental Management 

and Assessment(IEMA) 

www.iema.net/acorn/acornhome 

Building Research Establishment www.bre.co.uk 

Business Council for Sustainable 

Development – UK 

www.bcsd-uk.co.uk 

Business Eco Network www.eco.uk.com 

Business in the Community www.bitc.org.uk 

Business Link London www.bllondon.co.uk 

Bywaters www.bywaterswaste.co.uk 

C40 www.c40cities.org 

Capital Standards www.capitalstandards.com/index.jsp 

Capitalwastefacts www.capitalwastefacts.com 

Carbon calculator for construction www.environment-agency.gov.uk/business/444304/502508/1506471/1506565/ 

activities (Environment Agency) 1508048/1883907/?lang=_e 

Carbon Trust www.carbontrust.co.uk 

Chris Carey’s Collections www.chriscareyscollections.co.uk 

CIRIA database of construction 

recycling sites 

www.ciria.org.uk/recycling 

Clean City Awards Scheme www.cityoflondon.gov.uk/Corporation/our_services/health_safety/clean_city.htm 

Clinton Climate Change Initiative www.clintonfoundation.org 

Closed Loop London www.londonremade.com/mgpc_cll.asp 

Construction Resource Efficiency (CoRE) www.smartwaste.co.uk/core.jsp 

Corporate Social Responsibility Gateway www.csr.gov.uk 

Courtauld Commitment www.wrap.org.uk/retail/about_us/courtauld.html 

CRISP www.crispej.org.uk 

Demolition protocol http://icextra.ice.org.uk/tlml/demolition 

Department for Environment 

Food and Rural Affairs (Defra) 

www.defra.gov.uk 

East London Community 

Recycling Partnership (ELCRP) 

www.communitycompost.org/hotrotters/elcrp.htm



Eco-Management and www.emas.org.uk 

Audit Scheme (EMAS) 

Enhance www.enhancelondon.co.uk 

Enhanced Capital Allowances www.eca.gov.uk 

Envibe www.envibe.co.uk 

Enviro Entrepreneur School www.enviroentrepreneur.co.uk 

Environment Agency www.environment-agency.gov.uk www.wastedirectory.org.uk 

Environment Agency – Authorised Waste 

Carrier Register 

www2.environment-agency.gov.uk/epr/search.asp?type=register 

Oil Care Campaign www.environment-agency.gov.uk/oilcare 

Oil Bank www.oilbankline.org.uk 

Environment Agency – Strategic Waste www.environment-agency.gov.uk/subjects/waste/1031954/315439/923299/ 

Management Survey ?version=1&lang=_e 

Environment Agency – Waste Directory www.wastedirectory.org.uk 

Directgov Environment 

and Greener Living 

http://www.direct.gov.uk/en/Environmentandgreenerliving/index.htm 

Envirowise www.envirowise.gov.uk 

Fabrications www.fabrications1.co.uk 

FareShare www.fareshare.org.uk 

Global Action Plan www.globalactionplan.org.uk 

Go Green London Bridge Business 

Improvement District 

www.londonbridgebid.co.uk 

Greater London Authority www.london.gov.uk 

Green Mark www.green-mark.co.uk 

Green-Works www.green-works.co.uk 

Hazred www.hazred.org.uk 

Inspired Recycling www.inspiredrecycling.org 

International Organisation of Standards www.iso.org 

ISO 14001 www.bsi-global.com/Environmental/Management/bseniso14001.xalter 

Keep Britain Tidy Business Awards For more information contact csg-enquiries@encams.org 

Lafarge Cement www.lafarge-cement-uk.co.uk 

London 2012 www.london2012.org 

London Business Support Network www.knowledgecentres.com/lbsn 

London Climate Change Agency www.lcca.co.uk 

London Climate Change Agency Better Buildings Partnership www.lcca.co.uk/server/show/nav.005001 

London Community Recycling Network www.lcrn.org.uk 

London Development Agency www.lda.gov.uk 

London Environmental Support Service www.less-online.com 

London Hydrogen Partnership www.lhp.org.uk 

London Low Emission Zone www.london.gov.uk/mayor/environment/air_quality/lez.jsp 

London Manufacturing Advisory Service www.mas-london.co.uk 

London Remade www.londonremade.com



London Sustainable Development www.londonsdc.org/londonleaders 

Commission London Leaders 

London Sustainability Exchange (LSX) www.lsx.org.uk 

Market Transformation Programme www.mtprog.com 

Mayor of London www.london.gov.uk 


Mayor of London’s 

Green Procurement Code 

www.greenprocurementcode.co.uk 

National Industrial Symbiosis Programme www.nisp.co.uk 

ROHS – National Weights 

and Measures Laboratory 

www.rohs.gov.uk 

Netregs (Environment Agency) www.netregs.gov.uk 

NHS Good Corporate Citizenship 

Assessment Model 

www.corporatecitizen.nhs.uk 

Novera www.noveraenergy.com 

Paper Round www.paper-round.co.uk 

Positive Environment Kingston www.kingston.gov.uk/browse/environment/community_environmental_action/ 

positive_environment_kingston.htm 

Pure Fuels www.purefuels.co.uk 

Recycle for London www.recycleforlondon.co.uk 

Recycle Western Riverside www.westernriverside.org.uk 

SalvoMIE (materials information 

exchange) 

www.salvomie.co.uk 

SELTRANS (South-East London 

Transport Strategy) 

www.seltrans.org.uk 

Site Waste – It’s Criminal campaign www.netregs.gov.uk/netregs/legislation/380525/1555007/?lang=_e 

Sustainable Procurement Taskforce www.sustainable-development.gov.uk/government/task-forces/procurement/index.htm 

Trading Standards www.tradingstandards.gov.uk 

TRAID www.traid.org.uk 

Transport for London www.tfl.gov.uk 

Transport for London Freight Operator 

Recognition Scheme 

www.tfl.gov.uk/fors 

TrustMark www.trustmark.org.uk 

Waste Watch www.wastewatch.org.uk 

WasteDataFlow www.wastedataflow.org 

World Business Council for 

Sustainable Development 

www.wbcsd.org 

Waste and Resources Action 

Programme (WRAP) 

www.wrap.org.uk 

WRAP’s Guide to Evolving 

Packaging Design 

www.wrap.org.uk/retail/the_guide_to_evolving_packaging_design/index.html 

WRAP’s Innovation Fund www.wrap.org.uk/innovationfund



WRAP’s International www.wrap.org.uk/retail/tools_for_change/Packaging 

Database international_packaging_study 

WRAP Recycle at Work www.wrap.org.uk/businesses/start_recycling_at_work 

WRAP's Recycled Products Guide www.recycledproducts.org.uk 

WRATE - Waste and Resources www.environment-agency.gov.uk/wtd/1396237/ 

Assessment Tool for the Environment 

(Environment Agency) 

?version=1&lang=_e

150 Mayor of London Making waste work in London The Mayor’s Draft Business Waste Management Strategy 

A4 Case study index 

Reference number, case study title and source 

Chapter 3A Tipping the balance 

1 Asda signs up to send zero waste to landfill by 2010 - Source: Asda 

2 Banning the waste bin sees recycling levels soar - 


3 A socially responsible solution to food waste - 

Source: FareShare through London Community Recycling Network 

Chapter 3B Making producers responsible 

4 Failing to comply with legislation results in fine - 

Source: Environment Agency: DF/57/06 

Chapter 3C Increasing awareness and providing information 

5 Environmental seminars ensure business start ups are ahead 

of the game - Source: London Remade 

Chapter 3D Facilitating the development 

of collection services 

6 Encouraging the sustainable option through pricing mechanisms - 

Source: Greater London Authority Trade Waste Best Practice Guide 

7 Help given to make recycling easy for small businesses - 


Chapter 3E Facilitating the development of infrastructure 

8 A solution for our waste and energy crisis - 

Source: Mayor of London Planning Development Unit 

9 Delivering the Climate Change Action Plan – 

Source: London Climate Change Agency 

10 A viable alternative to sending food waste to landfill - 

Source: ‘Bexley launches SME food waste recycling service’ 

Letsrecycle 4 September 2007 

11 A social enterprise solves a big waste problem - Source: Green Works 

12 Closing the loop benefits London’s economy - Source: BioRegional 

13 Commitment to sustainability sees behaviour change and cooperation 

among retailers - Source: Business Eco Network 

14 Tenants encouraged and supported to recycle as part of management 

company’s commitment to the environment - 

Source: Business in the Community


15 Working together ensures success - 


16 New recycling facility maximises use of rail and river for 

transportation - Source: Greater London Authority Planning Decisions 

Unit Report PDU/0496/01, 2004 

Chapter 4A Managing commercial waste 

17 Waste reduction initiatives at City Hall - Source: Global Action Plan 

18 HSBC launches new programme to cut paper use - 

Source: Easier Finance Banking News 

19 Resource efficiency club reduces waste and costs - 


20 Changing behaviour among employees - 

Source: Recycle Western Riverside, London Remade and Waste Watch 

21 Reuse reduces capital costs - 

Source: London Community Recycling Network 

22 Composting office food waste made possible - 

Source: Greater London Authority Facilities Management 

23 Financial services company tackles paper use - 


24 Retailer turns waste cardboard into a revenue stream - 


25 Innovative retail display units reduce waste - 


26 Collect Green Clubcard Points - Source: Tesco 

27 East end pub sets recycling and composting target - 


Chapter 4B Managing construction, demolition 

and excavation waste 

28 Construction resource efficiency for London - 

Source: Construction Resource Efficiency (SmartWaste) 

29 Effective implementation of tool increases material recovery - 

Source: The London Borough of Brent 

30 Reusing demolition waste saves construction costs - 

Source: The Building Research Establishment 

31 Tackling resource management early in the development process 

led to significant reuse and recycling - 


32 Cement goes green - Source: Business in the Community



Chapter 4C Managing industrial waste 

33 Taking action after waste audit delivers cost savings - 


34 Innovative programme develops environmentally and financially 

beneficial partnership - Source: National Industrial Symbiosis 

Programme 

35 Big cost savings through targeted reuse programme - 


Chapter 4D Making waste safe 

36 A different kind of tube station offers a sustainable solution - 

Source: Greater London Authority 

37 Delivering greener print - Source: Business in the Community 

38 Significant cost savings from hospital waste management programme 

- Source: Department of Health Healthcare waste minimisation: 

A compendium of good practice 

39 Awareness and infrastructure make hospital recycling easy - 


Chapter 4E Avoiding fines 

40 Business fined for waste dumping - 

Source: Environment Agency: TA/52/06 

Chapter 5A Designing waste out 

41 Multinational takes early lead to win customers - Source: Xerox 

42 Graduates learn about the business benefits of sustainable design - 

Source: Enviro Entrepreneur School 

43 Redesign to improve material productivity significantly reduces costs 

- Source: Envirowise: NC201 

44 Market advantage as a result of resource focused redesign - 


45 Slimmer packaging possible following funded trial - 


46 Award for innovative packaging designed to reduce waste - 


47 No eggstra packaging is needed - Source: Environment Agency 

48 Carton manufacturers take responsibility seriously - 

Source: Tetrapak Recycling


Chapter 5B Designing waste in 

49 Using recycling reduced energy consumption and carbon dioxide 

production - Source: Waste Online, Waste Watch 

50 London’s entrepreneurs lead the way - Source: London Remade 

51 Recycled content product comes out on top - Source: The Waste and 

Resources Action Programme 

52 Retailer pioneers range of recycled content food packaging - Source: 

Closed Loop London 

Chapter 5C Green clauses transform markets 

53 Adopting a responsible procurement policy embeds good practice 

into decision-making - Source: Greater London Authority 

Procurement Team 

54 An environmental product range makes responsible procurement easy 

- Source: GLA and Business Supplies Limited 

55 Fit for purpose recycled plastic finds widespread application 

in vehicle manufacture - Source: London Development Agency 

through London Remade 

56 Major supplier goes the extra mile - Source: London Development 

Agency through London Remade 

57 Fast track to waste prevention across supply chain leads to incredible 

cost savings - Source: Envirowise CS407 

58 Improved environmental performance cascades through supply chain 

- Source: London Development Agency through London Remade 

Chapter 5D It’s what’s on the inside that counts 

59 Tough targets met by top down implementation of Environmental 

Management System - Source: Business in the Community 

60 ISO 14001 benefits company by reducing waste - 

Source: Environment Agency 

61 Small business benefits from Environmental Management System - 


Chapter 5E The icing on the cake 

62 Freesheets agree to voluntary measures to tackle waste - Source: 

Westminster City Council press release 22 August 2007 

63 Iconic venue achieves amazing recycling results – 

Source: The O2, AEG Europe 

64 London festival sets recycling precedent – 

Source: Bedford Park Festival



65 Early planning limits non recyclable waste at event – 


66 Setting the standard for sporting stadia - Source: London Remade 

67 Olympic Park sets construction recycling standards - 

Source: ‘Olympic Park clean up beats green targets’ press release 

17 April 2007 

68 Olympic Park sets construction procurement standards - 

Source: ‘London 2012 – Sustainability strategy launched’ press 

release 23 January 2007, ‘Olympic Park clean up beats green targets’ 

press release 17 April 2007


A6 Glossary, acronyms and key players 

Glossary 

Advanced waste technologies such as anaerobic digestion, gasification 

and pyrolysis. Such technologies may require pre-treatment technologies 

such as Mechanical Biological Treatment (MBT) to prepare the waste. 

In the Climate Change Action Plan they are referred to as nonincineration 

technologies. 

Anaerobic Digestion This is the biological degradation of organics in the 

absence of oxygen, producing biogas (typical composition of 65 per cent 

methane and 35 per cent carbon dioxide) and residue (digestate) suitable 

for use as a soil improver. 

Best Value Government programme to seek continuous improvement in 

service quality in the way in which authorities exercise their functions. 

Biodegradable waste is defined in Council Directive 1999/31/EC on the 

landfill of waste as meaning any waste that is capable of undergoing 

anaerobic or aerobic decomposition, such as organic kitchen and green 

garden waste, and paper and paperboard. 

Biomass is the total dry organic matter or stored energy of plant matter. 

As a fuel it includes energy crops and sewage as well as forestry and 

agricultural residues. 

Brownfield land Both land and premises are included in this term, which 

refers to a site that has previously been used or developed and is not 

currently fully in use, although it may be partially occupied or utilised. It 

may also be vacant, derelict or contaminated. This excludes open spaces 

and land where the remains of previous use have blended into the 

landscape, or have been overtaken by nature conservation value or 

amenity use and cannot be regarded as requiring development. 

Business Improvement Districts This concept was originally developed 

in the USA for increasing investment within defined areas of a city such as 

town centres. This is achieved through changes to local taxation, based on 

a supplementary rate levied on businesses within that defined area. 

Business waste Refers to commercial, industrial, construction, 

demolition, excavation and hazardous waste. 

Buy Recycled Collecting materials for recycling is only the first step in 

the recycling process. Once the material has been collected, sorted and 

sent to reprocessors, it is then recycled into new products. Making a 

conscious effort to seek out and buy products made from recycled 

materials is essential. The future of recycling ultimately depends on there 

being a market for the materials collected. 

Carbon dioxide is a naturally occurring gas comprising 0.04 per cent of 

the atmosphere. The burning of fossil fuels releases carbon dioxide fixed



by plants many millions of years ago, and this has increased its 

concentration in the atmosphere by some 12 per cent over the past 

century. It contributes about 60 per cent of the potential global warming 

effect of man-made emissions of greenhouse gases. 

Char is the product of partially burned biomass. The modern source of 

char is from a process called pyrolysis. In this process, biomass is heated 

to the point where volatile gases and liquids are driven off and condensed 

into a product call bio-oil. What remains is almost pure carbon, called char 

with a varying ash content that depends on the type of biomass used. 

Climate change An increase in the atmospheric concentration of 

greenhouse gases from human activities such as burning fossil fuels, leads 

to an enhanced greenhouse effect. Greenhouse gases present in the 

atmosphere absorb outgoing infrared radiation from the earth surface 

(terrestrial radiation) causing some heat to be retained. This greenhouse 

property of the atmosphere acts as a natural blanket over the earth’s 

surface making it warmer than it would otherwise be. Without this effect 

the Earth’s surface would be 20 to 30°C colder and much less suitable for 

life. However, changing the greenhouse properties of the atmosphere will 

lead to changes in the earth’s radiative energy budget (the balance 

between incoming energy from the Sun and outgoing energy from the 

Earth), which leads to a global warming and as a consequence will affect 

other aspects of the Earth’s climate. 

Clinical Waste Waste which consists of human or animal tissue, bodily 

fluids, pharmaceuticals, sharps etc. and any waste arising from medical, 

dental, veterinary or similar practices. 

Closed-Loop Recycling is when a material is recycled and returned to a 

similar state and use as when it was first consumed, for example, when 

container glass is collected, sorted, reprocessed back into cullet and 

manufactured back into container glass. 

Combined Cooling, Heat and Power The combined production of 

electricity and usable heat is known as Combined Cooling, Heat and 

Power (CCHP). Steam or hot water, which would otherwise be rejected 

when electricity alone is produced, is used for space or process heating. 

Co-mingled Recycled materials that are collected together and are 

recycled following further sorting. 

Commercial Waste Waste arising from premises which are wholly 

or mainly for trade, business, sport, recreation or entertainment as 

defined in Schedule 4 of the Controlled Waste Regulations 1992. 

Composting The biological degradation of organic materials, such 

as green garden and organic kitchen waste, in the presence of oxygen


producing gas and residue suitable for use as a soil improver 

(see anaerobic digestion, central composting and home composting). 

Construction, Demolition and Excavation Waste Waste arising 

from the construction, repair, maintenance and demolition of buildings 

and structures, including roads or produced from excavation, such as 

trenching to form foundations. It consists mostly of brick, concrete, 

hardcore, subsoil and topsoil, but it can contain quantities of timber, 

metal, plastics and occasionally hazardous waste materials. 

Conventional incineration The controlled burning of waste 

in the presence of sufficient air to achieve complete combustion. 

The heat is used to produce electricity and sometimes provide district 

heating. Unsorted waste is fed onto a, usually inclined, grate and burnt 

as it moves through the furnace. Plants are generally large-scale, 

having an annual capacity of 100,000 tonnes or more. Electricity 

generated in conventional incineration plant is not eligible for 

Renewables Obligation Certificates (ROCs). 

The term ‘conventional incineration’ is used in this strategy to refer 

specifically to this type of process as distinct from other thermal 

treatment processes such as pyrolysis or gasification processes. 

Corporate Social Responsibility (CSR) No universally acceptable 

definition of Corporate Social Responsibility (CSR) exists, but the World 

Business Council for Sustainable Development defines it as 'the 

continuing commitment by business to behave ethically and contribute to 

economic development while improving the quality of life of the 

workforce and their families as well as the local community and society 

at large'. It is the ethical behaviour of a company towards society. 

Duty of Care The Duty of Care (Section 34 of the Environmental 

Protection Act 1990) places a general duty on waste producers 

(or anyone else with responsibility for waste) to take all reasonable 

steps to keep their waste safe. If they transfer their waste to someone 

else, they must ensure that that person is authorised to take it and can 

transport, recycle or dispose of it safely. The duty of care does not apply 

to waste produced by householders in their own homes. 

End of Life Vehicles (ELV) are motor vehicles that fall into the category 

of ‘waste’ as defined by the Waste Directive. Their components are also 

classed as waste. The UK has now implemented the European End of Life 

Vehicles Directive, which introduces producer responsibility for achieving 

certain recycling targets as well as environmental standards for the storage 

and treatment of ELVs. 

Energy efficiency This is about making the best or most efficient 

use of energy in order to achieve a given output of goods or services,



and of comfort and convenience. This does not necessitate the use 

of less energy, in which respect it differs from the concept of 

energy conservation. 

Environmental Management System (EMS) help organisations control 

and minimise the impact that their products, services have on the 

environment and provide a practical framework within which 

environmental issues can be managed. 

EU Directive A type of law that is issued by the European Union - all EU 

countries then have to put this into their own legal system. 

Fly-tipping The illegal deposit of waste on land. 

FTSE is an independent company owned by The Financial Times and the 

London Stock Exchange. 

Functional bodies See GLA group 

Fuel Cell Acts like a constantly recharging battery, electrochemically 

combining hydrogen and oxygen to generate power. For hydrogen fuel 

cells, water and heat are the only by-products and there are no direct air 

pollution or noise emissions. They are suitable for a range of applications, 

including vehicles and buildings. 

GLA group The Mayor has responsibility for appointing members to, 

and setting budgets for, four organisations: Transport for London (TfL), 

London Development Agency (LDA), London Fire and Emergency 

Planning Authority (LFEPA), Metropolitan Police Authority (MPA). 

Gasification is defined in the Renewables Obligation Order 2002 

as meaning the substoichiometric oxidation or steam reformation 

of a substance to produce a gaseous mixture containing two or all 

of the following: oxides of carbon, methane and hydrogen. 

Green Industries The business sector that produces goods or services, 

which compared to other, generally more commonly used goods and 

services, are less harmful to the environment. 

Green Procurement The purchase of goods and development of 

purchasing policies, which take the environmental impact of the purchase 

into consideration. 

Industrial Symbiosis brings together companies from all business 

sectors with the aim of improving cross industry resource productivity by 

the physical exchange of materials, energy and water and sharing assets, 

logistics and expertise. 

Industrial Waste Waste from any factory and any premises occupied by 

industry (excluding mines and quarries) as defined in Schedule 3 of the 

Controlled Waste Regulations 1992.


Integrated Pollution Prevention and Control The Integrated Pollution 

Prevention and Control Directive (96/61/EC Directive), as implemented 

in the Pollution Prevention and Control Regulations 2000, is designated 

to prevent or, where that is not possible, to reduce pollution from a range 

of industrial and other installations, including some waste management 

facilities, by means of integrated permitting processes based on the 

application of best available techniques. 

Junk Mail An excessive number of unwanted or unsolicited mailings 

consisting of advertising and often addressed to resident or occupant. 

Landfill Allowance Trading Scheme (LATS) The government's key 

measure to meet the demands of the European Landfill Directive in 

England, and began on April 1, 2005. The LATS system works by local 

authorities being set allowances on the amount of biodegradable material 

they can send to landfill. In two-tier areas, this refers to waste disposal 

authorities. These allowances are tradable, so that high landfilling 

authorities can buy more allowances if they expect to landfill more than 

the allowances they hold. Similarly, authorities with low landfill 

rates can sell their surplus allowances. 

Landfill Sites are where local authorities and industry can take waste 

to be buried. The Environment Agency licenses and regulates landfill sites 

to ensure that their impact on the environment is minimised. Landfill sites 

are often located in disused quarries or mines. In areas where there are 

limited, or no ready-made voids, the practice of landraising is sometimes 

carried out, where some 

or all of the waste is deposited above ground, and the landscape is 

contoured. Designated landfill sites are managed to receive waste for 

final underground disposal under the provisions of the Waste 

Management Licensing Regulations 1996 as amended. 

Landfill Tax is a tax that must be paid by all landfill site operators 

per tonne of waste landfilled. Until the 2007 Budget, the landfill tax 

increased annually by £3 per year, per tonne, on the way to a long-term 

rate of £35 per tonne. In the April 2007 Budget Report, the Chancellor 

announced that from April 2007, the standard rate of landfill tax will 

be increased from £21 per tonne to £24 per tonne and then from 

April 2008 onwards it will increase annually by £8 per tonne until 

at least 1 April 2010. 

Large business Business with more than 250 employees 

Litter Waste that is improperly disposed of on the street, sidewalk, lakes 

and in the general environment. 

Low Emission Zone is a defined area from which polluting vehicles that 

do not comply with set emissions standards are barred from entering.



Mechanical Biological Treatment Systems consisting of a mechanical 

stage, where recyclables and rejects (batteries, tyres etc.) are separated to 

leave an organic fraction. This fraction is then sent, in the biological 

stage, for treatment using composting and digestion techniques. These 

systems provide a new generation of integrated waste management 

technology able to reduce landfill and mass burn incineration and to 

increase recycling and composting. 

Medium business Business with between 50-249 employees 

Mixed-use development Development for a variety of activities 

on single sites or across wider areas such as town centres. 

Major development this strategy uses the London Plan definition 

for Mayor Developments. There are two types of major development 

addressed by the London Plan: 

1 Strategic Developments (applications referable to the Mayor): 

The planning applications that must be referred to the Mayor 

according to Parts I - IV of the Town and Country Planning (Mayor 

of London) Order 2000. Examples include 500 dwellings, 30,000 sq 

m commercial space in the city, 20,000 sq m and 15,000 sq m of 

commercial space in and outside Central London respectively. 

2 Major Developments (applications decided by the London Boroughs): 

The definition adopted by boroughs should be that currently used by 

the Government’s PS2 form that each district planning authority 

must use to report general developments. 

Major Developments are defined as: 

■ For dwellings: where 10 or more are to be constructed (or if number 

not given, area is more than 0.5 hectares). 

■ For all other uses: where the floor space will be 1000 sq metres or 

more (or site is 1 hectare or more). Area of site is that directly 

involved in some aspect of the development. Floor space is defined 

as the sum of floor area within the building measured externally to 

the external wall faces at each level. Basement car parks, rooftop 

plant rooms, caretakers’ flats etc. should be included in the floor 

space figure. 

Municipal Solid Waste This includes all waste under the control of local 

authorities or agents acting on their behalf. It includes all household 

waste, street litter, waste delivered to local authority recycling points, 

municipal parks and gardens wastes, council office waste, civic amenity 

waste, and some commercial waste from shops and smaller trading estates 

where local authorities have waste collection agreements in place. It can 

also include industrial waste collected by a waste collection authority with 

authorisation of the waste disposal authority.


Producer Responsibility is about producers and others involved 

in the distribution and sale of goods taking greater responsibility 

for those goods at the end of the products life. 

Proximity Principle Dealing with waste as near as practicable 

to its place of production. 

Putrescible waste is material readily able to be decomposed 

by bacterial action. 

Pyrolysis is defined in the Renewables Obligation Order 2002 as meaning 

the thermal degradation of a substance in the absence of any oxidising 

agent (other than that which forms part of the substance itself) to 

produce char and one or both of gas and liquid. 

Recycled materials Waste materials which have been transformed into 

new products through reprocessing or remanufacturing. 

Recycling involves the reprocessing of waste, either into the same 

product or a different one. 

Reduction Reducing the amount of waste produced, for example through 

behaviour change, design and procurement decisions. It is at the top 

of the waste heirarchy and is also called Prevention. 

Regional Self-sufficiency Dealing with wastes within the region where 

they arise. 

Registration of Waste Carriers Any person who carries (controlled) 

waste in the course of any business with a view to profit, is required 

to be registered with the Environment Agency. 

Renewable energy Energy derived from a source that is continually 

replenished, such as wind, wave, solar, hydroelectric and energy from plant 

material such as organic waste, but not fossil fuels or nuclear energy. 

Reprocessing The treatment of recycled materials or compostable 

materials, after collection and processing, to prepare a secondary material 

that meets market specifications. For example, composting, the 

production of recycled plastic pellets, recycled paper or clean glass cullet. 

Residual waste is that portion of the waste stream that is not reused, 

recycled or composted and remains to be treated through the recovery 

of energy and/or materials or through disposal to landfill. 

Resource productivity Making the most productive and efficient 

use of resources. 

Reuse Putting materials to another use after they have fulfilled their 

original function. The processes contribute to sustainable development 

and can save raw materials, energy and transport costs.



Reuse and Recycling Centres Sites operated by local authorities where 

residents and local businesses can take their waste for reuse, recycling 

and disposal. 

Safeguarded wharves These are sites that have been safeguarded for 

cargo handling uses such as intraport or transhipment movements and 

freight-related purposes. A list of those sites that are currently protected 

and those proposed for protection is available in ‘Safeguarded Wharves on 

the River Thames’, Greater London Authority, 2003. 

Secondary materials See recycled materials. 

Secondary materials economy Term for the chain of economic activity 

based on recycled materials being used more cheaply than primary 

production/excavation. 

Separate Collection Recycling collection schemes from businesses where 

materials collected for recycling are kept apart. This avoids the need to 

mechanically sort materials at a Materials Reclamation Facility and 

sustains material quality. 

Self-sufficiency See Regional Self-sufficiency 

Soil Improver This product is ideal for improving all soil types, for 

mulching and also for planting trees and shrubs. The naturally fertile 

formula is rich in nutrients and organic matter, improving soil structure for 

better drainage and root establishment. 

Spatial Development Strategy This strategy is prepared by the Mayor, 

replacing the strategic planning guidance for London (RPG3). The Mayor 

has chosen to call the Spatial Development Strategy the London Plan. 

Small business Business with less than 50 employees. Businesses with 

less than five employees are sometimes called micro businesses. 

Statutory Recycling Targets All London boroughs have been set 

statutory targets by the government for the recycling of household waste. 

Statutory targets for recycling and composting were set for local authorities 

in England for 2003/04, 2005/06 and have been set for 2007/08. Adding 

together the results for Best Value Indicators 82(a) (recycling) and 82(b) 

(composting) measure performance against these targets. 

Sustainable Development Development that is sustainable is that 

which can meet the needs of the present without compromising the 

ability of future generations to meet their own needs. 

Sustainable Waste Management Means using material resources 

productively, to cut down on the amount of waste we produce. And where 

waste is generated, dealing with it in a way that actively contributes to 

the economic, social and environmental goals of sustainable development.


Third sector Description for voluntary organisations, charities and social 

enterprises. 

Treatment Involves the chemical or biological processing of certain types 

of waste for the purposes of rendering them harmless, reducing volumes 

before landfilling, or recycling certain wastes. 

Waste The strict legal definition of waste is extremely complex but it 

encompasses most unwanted material which has fallen out of the 

commercial cycle or chain of utility, which the holder discards, or intends 

to, or is required to discard. 

Waste Arising The amount of waste generated in a given locality over a 

given period of time. 

Waste Authorities The authority responsible for arranging for the 

collection and/or disposal of waste in their area. In London, all London 

boroughs (33) are responsible for waste collection. Twelve boroughs act as 

unitary authorities, responsible for both waste collection and disposal. The 

remaining 21 London boroughs carry out their disposal functions through 

four Statutory Joint Waste Disposal Authorities created by the Waste 

Regulation and Disposal (Authorities) Order 1985. 

Waste Disposal This is defined by the list of operations that constitute 

disposal (for under Part III of Schedule 4 of the Waste Management 

Licensing Regulations). This includes landfill, land raising, incineration, 

permanent storage etc. 

Waste Hierarchy sets out the priority for waste management options, 

based on their environmental impact. In making waste management 

decisions, the waste heirarchy should be applied in sequence from the 

top down. 

Waste Management Industry The businesses in the public, private 

and third sector involved in the collection, management and disposal 

of waste. 

Waste Management License (operated and enforced by the 

Environment Agency) authorises the treatment, keeping or disposal 

of waste. These are separate but complimentary to the Land Use 

Planning System. 

Waste neutral where the value of materials wasted is matched 

by the value of additional reused and recycled content materials bought 

World city A globally successful business location measured on 

a wide range of indicators such as financial services, government, 

business, higher education, culture and tourism. London is paralleled 

only by New York and Tokyo



Acronyms 

BAME Black, Asian and Minority Ethnic 

BRE Buildings Research Establishment 

BREW Business Resource Efficiency and Waste 

C40 Large Cities Climate Leadership Group 

CCHP Combined Cooling, Heat and Power 

CHP Combined Heat and Power 

CO 2 

Carbon dioxide 

CoRE Construction Resource Efficiency 

CRISP Community Recycling In Southwark Project 

CSR Corporate Social Responsibility 

DCLG Department for Communities and Local Government 

DEFRA Department for the Environment, Food and Rural Affairs 

DPD Development Plan Document 

EDIB Economic Development Infrastructure Building (Programme) 

ELCRP East London Community Recycling Partnership 

ELV End-of-Life Vehicle 

EMAS Eco-Management and Audit Scheme 

EMS Environmental Management System 

FORS Freight Operator Recognition Scheme 

GDP Gross Domestic Product 

GLA Greater London Authority 

HDPE High Density Polyethylene 

IPPC Integrated Pollution Prevention and Control 

LATS Landfill Allowance Trading Scheme 

LCCA London Climate Change Agency 

LDA London Development Agency 

LESS London Environmental Support Service 

LFEPA London Fire and Emergency Planning Authority 

LOCOG London Organising Committee of the Olympic Games 

MBT Mechanical Biological Treatment 

MRF Materials Reclamation Facility 

NHS National Health Service 

NISP National Industrial Symbiosis Programme 

ODA Olympic Delivery Authority 

PERN Packaging Export Recovery Note 

PET Polyethylene Teraphthalate (recycled PET (rPET)) 

PPS Planning Policy Statement 

PRN Packaging Recovery Note 

SME Small-to Medium-sized Enterprises 

TfL Transport for London 

UK United Kingdom 

WEEE Waste Electrical and Electronic Equipment


WIDP Waste Infrastructure Development Programme 

WRAP Waste and Resources Action Programme 

Key players 

Glossaries often also clarify the functions and roles of key players. 

Rather than repeat them here, the roles of several key players involved in 

London's waste and recycling sector are clarified on Capitalwastefacts at: 

www.capitalwastefacts.com/FurtherInformation/WhosWho/ 

tabid/176/Default.aspx


Making waste work in London The Mayor’s Draft Business Waste Management Strategy


Endnotes 

1 The London Plan: Spatial Development Strategy for Greater London: 

Housing Provision Targets, Waste and Minerals Alterations, Greater 

London Authority, December 2006, page 8 

2 ’Climate change is the top priority of London Plan review’ Greater London 

Authority press release: ref. 277, 30-05-06 

3 The Further Alterations to the London Plan, Greater London Authority, 

September 2006 

5 Action today to protect tomorrow: The Mayor’s Climate Change Action 

Plan, Greater London Authority, March 2007, page xiii 



London Authority, December 2006, Table 4A.1 

7 London Wider Waste Strategy Background Study: Technical Report 

to the Greater London Authority, SLR Consulting Limited, June 2004 

8 London Waste Action: Consultation on managing London’s waste: 

Report of responses from the online consultation and stakeholder 

workshop, Dialogue by Design, April 2006 

9 Environmental Benefits of Recycling, WRAP, May 2006 

10 Review of Environmental and Health Effects of Waste Management, 

Defra, May 2004 

11 Carbon balances and energy impacts of waste management of UK waste, 

ERM and Golder Associates report for Defra, WRT 237, Defra, December 

2006 

12 Waste Strategy for England 2007, Defra, May 2007, page 56 



Plan, Greater London Authority, March 2007, page vii 

15 Unpublished data provided by the Environment Agency, October 2007 

16 Greenhouse gas balances of waste management scenarios, Eunomia 

research and consulting, July 2007 

18 Waste Strategy for England 2007, Defra, May 2007, page 20, Box 1.2 

19 Buying recycled: A review of sustainable procurement by the private 

sector in London, A report for the London Assembly Environment 

Committee, GfK Business, June 2006 

20 The Commission Communication: Modern SME policy for growth 

and employment COM(2005)551



21 London Annual Business Survey, London Development Agency and 

Business Link for London, July 2005 

22 Survey carried out by Atkins for the NetRegs website. Available at: 

http://www.netregs.gov.uk/netregs/1856701/?lang=_e. 

Reported in the ENDS Report September 2007 p9 

23 London Annual Business Survey, London Development Agency 

and Business Link for London, July 2005, Table 3.1 


and Business Link for London, July 2005, Table 3.1 


and Business Link for London, July 2005, page 46 

26 Healthy and Sustainable Food for London, The Mayor’s Food Strategy, 

Greater London Authority, May 2006 

27 SMEs and Sustainable Waste Management in London Research Findings, 

A report for the London Assembly Environment Committee, GfK Business, 





30 Taking sustainable use of resources forward: A Thematic Strategy on the 

prevention and recycling of waste, COM(2005) 666, December 2005 

31 Thematic Strategy on the sustainable use of natural resources, 

COM(2005) 670, December 2005 

32 ‘Mayor takes concerns about London's waste to European Commission’ 

Greater London Authority, press release: ref. 325, 30-05-07 

33 Rethinking Rubbish in London: The Mayor's Municipal Waste 

Management Strategy, Greater London Authority, September 2003 

35 The London Plan: Spatial Development Strategy for Greater London, 

Greater London Authority, February 2004 


Management Strategy, Greater London Authority, September 2003, 

page 87 

37 The Mayor of London’s response to the ODPM’s consultation paper 

on the powers and responsibilities of the Mayor and Assembly, 

Greater London Authority, February 2006, page 47 

38 Spotlight on business environmental performance in 2005, Environment 

Agency, September 2006


39 ‘Equality and Diversity’ http://www.london.gov.uk/mayor/equalities/ 

key-documents.jsp [Accessed: 020407] 

40 Connecting with London’s nature The Mayor’s Biodiversity Strategy, 

Greater London Authority, July 2002 


Plan, Greater London Authority, March 2007, page iii 

42 ‘Climate change in London’ http://www.london.gov.uk/mayor/ 

environment/climate-change/london.jsp [Accessed: 271107] 


Plan, Greater London Authority, March 2007, page xiii 

44 ‘Climate change in London’ http://www.london.gov.uk/mayor/ 

environment/climate-change/london.jsp [Accessed: 061207] 

45 London’s warming: The impacts of climate change on London, 

The London Climate Change Partnership, October 2002, page 7 

46 London’s warming: The impacts of climate change on London, 

The London Climate Change Partnership, October 2002, page 13 


Plan, Greater London Authority, March 2007, page xxii 


Plan, Greater London Authority, March 2007, page 108 

49 Sustaining Success: Economic Development Strategy, London 

Development Agency, January 2005 

50 Draft Further Alterations to the London Plan, Examination in Public: 

Panel Report, September 2007, page 192 

51 Reducing health inequalities: issues for London and priorities for action, 

Greater London Authority, August 2007, page 18 



53 The London Plan: Spatial Development Strategy for Greater London, 

Greater London Authority, February 2004 

54 Mapping health and safety standards in the UK waste industry (RR240), 

Health and Safety Executive, June 2004 

55 The Mayor’s Transport Strategy, Greater London Authority, July 2001 

56 European Commission press release: Speach/01/302, Margot Wallström 

European Commissioner for the Environment ‘Future Directions for the 

European Waste Policy’ European Waste Forum Brussels, 21 June 2001



57 Forthcoming London Freight Data Report, Transport for London, based on 

vehicle registrations on Vehicle and Operator Services Agency databases 



59 Cleaning London’s Air: The Mayor’s Air Quality Strategy, 

Greater London Authority, September 2002 

60 Sounder City: the Mayor's Ambient Noise Strategy, 

Greater London Authority, March 2004 

61 Water matters: The Mayor’s Draft Water Strategy, 

Greater London Authority, March 2007, page v 

62 Water matters: The Mayor’s Draft Water Strategy, 

Greater London Authority, March 2007 

63 A Zero Waste UK, Institute of Public Policy and Research and Green 

Alliance, October 2006, page 17 

64 Draft Early Alterations to the London Plan, Examination in Public 2006, 

Panel Report, the Examination in Public Panel, September 2006, page 

105 

65 2007 Budget Report, HM Treasury, March 2007 

66 Your waste, your responsibility: Treatment of non-hazardous wastes 

for landfill, Environment Agency, February 2007 


68 Guidance on landfill allowance schemes: Municipal waste, Defra, 

June 2006 

69 Waste Strategy for England 2007, Defra, May 2007, page 20, Box 1.2 

70 ‘Defra National Statistics’ http://www.defra.gov.uk/environment/ 

statistics/wastats/archive/ mwb200607.xls [Accessed: 271107] 


statistics/wastats/archive/ mwb200607.xls [Accessed: 271107] 


statistics/wastats/archive/mwb200607.xls [Accessed: 271107] 

73 ‘Defra’s proposals for the new local government performance framework’ 

http://www.defra.gov.uk/environment/localgovindicators/indicators.htm 

[Accessed: 271107] 



76 Taking sustainable use of resources forward: A Thematic Strategy on the 

prevention and recycling of waste, COM(2005) 666, December 2005


77 ‘Addressing Europe’s wasteful habits: MEPs attempt to up ambition’ 

Magazine of the IEMA, April 2007 

78 Greenhouse gas balances of waste management scenarios, Eunomia 

research and consulting, July 2007 

80 Waste Strategy for England 2007, Defra, May 2007, Charts 4.1 and 4.2 

81 ‘Towards Sustainability’ (1993) the European Community Programme 

of policy and action in relation to the environment and sustainable 

development (better known as The Fifth EC Environmental Action 

Programme), European Union, 1993 

82 Waste Strategy for England 2007, Defra, May 2007, page 53, Figure 4.1 

83 Consultation on recycling targets for packaging for 2008 and thereafter: 

Producer Responsibility Obligations (Packaging Waste) Regulations 2007, 

Defra, October 2007 


85 ‘Waste Management – the facts’ http://www.incpen.org/pages/ 

userdata/incp/wastemanFS.pdf [Accessed: 301106] 


87 The case for a resource management strategy, Institute of Civil Engineers, 

January 2006 

88 Department of Trade and Industry, “Meeting the Energy Challenge, 

A White Paper on Energy”, May 2007, pg 151 

89 Status report on Waste Electrical and Electronic Equipment in the UK, 

Interim report. Industry Council For Electronic Equipment Recycling, 

January 2005 

91 ‘Battery facts & figures’ 

http://www.wrap.org.uk/local_authorities/batteries/battery_recycling_in 

formation/battery_facts_.html [Accessed: 291106] 

92 Select Committee on Environment, Transport and Regional Affairs Fifth 

Report Appendix 3: Producer Responsibility for Batteries (2001) 

93 ‘Q&A Battery Programme‘ 

http://www.wrap.org.uk/local_authorities/batteries/battery_recycling_in 

formation/qa_batteries.html [Accessed: 031006] 


95 Voluntary Environmental Agreements, BEUC/X/060/2006 ANEC-ENV- 

2006-G-048, October 2006 

96 Green Alchemy: Towards more from less: Helping London’s small firms 

adapt, London Development Agency, January 2004



97 SME-nvironment 2003 survey, carried out by WS Atkins on behalf 

of NetRegs, Environment Agency, 2003 

98 Budget 2007: Building Britain's long-term future: Prosperity and fairness 

for families, HM Treasury, March 2007, chapter 7.65 

99 Simplifying Business Support: An introductory document, 

Department of Trade and Industry, April 2007 













104 ‘Waste: Capital staff find all this recycling is hard work’, Surveyor Online, 

11 October 2007, available at: www.surveyormagazine.com 

105 Thematic Strategy on the sustainable use of natural resources, 

COM(2005) 670, December 2005 

106 BREW Centre Local Authority Trade Waste Recycling Survey, 

BREW Centre for Local Authorities, September 2007 




108 Guidance on the Landfill Allowance Scheme: Municipal Waste, Defra, 

June 2006 

109 Letter dated 12 October 2007, from Anthony Lord, Defra 

110 Review of England’s Waste Strategy, Defra, February 2006, page 15 

111 ‘BREW Centre for Local Authorities’ www.oxfordshire.gov.uk/brew 


112 Trade Waste Recycling Best Practice Guide, Enviros, March 2005 


114 Healthy and Sustainable Food for London: The Mayor’s Food Strategy 

Implementation Plan, London Development Agency, September 2007, 

page 19





116 Creating Wealth from Waste, Robin Murray for Demos and Ecologika, 

June 1999, page 49 

117 Creating Wealth from Waste, Robin Murray for Demos and Ecologika, 

June 1999, page 85 

118 Reinventing waste: Towards a London waste strategy, Ecologika, August 

1998, page 146 

119 Creating a Recycling Loop for London, Greater London Authority, 




121 ‘WRAP to review growing role of materials recovery facilities in producing 

quality recyclates’ http://www.wrap.org.uk/wrap_corporate/news/ 

wrap_to_review.html [Accessed: 230807] 


Management Strategy, Greater London Authority, September 2003, 

Proposal 76, page 249 



124 Stern Review on the Economics of Climate Change, HM Treasury, 

October 2006 

125 Quantification of the Potential Energy from Residuals (EfR) in the UK, 

Institute of Civil Engineers, March 2005 


Panel Report, the Examination in Public Panel, September 2006, page 80 

127 The Potential for Hydrogen Production from Waste in London, 

The London Hydrogen Partnership, October 2006 

128 ‘Mayor and Clinton’s climate pact’ http://news.bbc.co.uk/2/hi/uk_news/ 

england/london/5237356.stm [Accessed: 250107] 




131 Healthy and Sustainable Food for London: The Mayor’s Food Strategy 

Implementation Plan, London Development Agency, September 2007, 

page 19



132 Green Alchemy: Towards more from less: Helping London’s small firms 

adapt, London Development Agency, January 2004 


Panel Report, the Examination in Public Panel, September 2006, page 80 

135 Skills for a Low Carbon London: Skills Gaps in the Energy Efficiency 

and Renewable Energy Sector in London. Phase 1 Report: Desk Research, 

London Energy Partnership, October 2006 

136 Skills for a Low Carbon London: Skills Gaps in the Energy Efficiency 

and Renewable Energy Sector in London. Phase 1 Report: Desk Research, 

London Energy Partnership, October 2006, page iv 

137 Diversity analysis: Waste, recycling and reprocessing sectors in London, 

London Remade, July 2007 

138 Diversity analysis: Waste, recycling and reprocessing sectors in London, 

London Remade, July 2007, page 3 

139 Waste Strategy for England 2007, Defra, May 2007, pages 39 

140 ’Devolution agenda pushed forward with new powers for London‘, 

Communities and Local Government News Release 2006/0055, 

13 July 2006 

141 Waste Strategy for England 2007, Defra, May 2007, pages 39 


143 Energy White Paper: Meeting the energy challenge, Department for 

Business Enterprise and Regulatory Reform, May 2007 

144 Planning Policy Statement 10: Planning for Sustainable Waste 

Management, Office of the Deputy Prime Minister (ODPM), July 2005 



146 Draft Further Alterations to the London Plan, Examination in Public: 

Panel Report, September 2007, page 178 

147 Waste Strategy for England 2007, Defra, May 2007, pages 75 and 90 

148 Waste Infrastructure Delivery Programme Planning Systems Guidance, 

Defra, August 2007 

149 Waste Infrastructure Delivery Programme Planning health framework: 

Waste procurement Projects – Residual waste treatment facilities, Defra, 

August 2007 

150 Total estimate obtained from Mouchel Parkman Purgamentum model in 

2005 plus additional estimates made by Transport for London Freight Unit 

in 2007, to be confirmed by future modelling


151 Cleaning London’s Air: The Mayor’s Air Quality Strategy, Greater London 

Authority, September 2002 

152 Transport for London Freight Unit optimal estimate based on 

‘Vehicle Routing Software - The Benefits’ 

http://www.optrak.co.uk/en/pressben.html [Accessed: 100407] 

153 London's market potential for bio diesel from used cooking oils, London 

Remade, October 2005 

154 ’Oil recycling plant opens for business in north London‘, 

http://www.letsrecycle.com/info/waste_management/ 

news.jsp?story=6667 [Accessed: 020307] 

155 ‘Oil recycling plant opens for business in north London’ 

http://www.letsrecycle.com/info/waste_management/ 

news.jsp?story=6667 [Accessed: 020307] 

156 Cleaning London’s Air: The Mayor’s Air Quality Strategy, 

Greater London Authority, September 2002 

157 Opportunities for transporting London’s waste and recyclables by river, 

London Remade, December 2004 


159 ’Why bother?’ http://www.envirowise.gov.uk/page.aspx?o=163440 


160 ’Waste management’ http://www.envirowise.gov.uk/ 

page.aspx?o=dsur5yhjtw [Accessed: 230107] 







163 Environment Agency Strategic Waste Management survey for commercial 

and industrial waste, 2002/03, available at: http://www.environmentagency.gov.uk/subjects/waste/1031954/315439/923299/1071046 



165 ‘The site audit’ http://www.envirowise.gov.uk/MROZ5YAF6L 


166 Waste Strategy for England 2007, Defra, May 2007, Action 39 

167 YouGov survey of 2,011 people commissioned by Fujitsu Siemens 

Computers, The Observer 14/10/2007, page 24



168 ’Why bother?’ http://www.envirowise.gov.uk/page.aspx?o=163440 


169 ‘About Envirowise’ http://www.envirowise.gov.uk/page.aspx?o=about 






173 Retail in London, GLA Economics, October 2006 


Greater London Authority, May 2006, page 46 

175 Waste Strategy for England 2007, Defra, May 2007, Page 68 



177 Business Resource Efficiency and Waste, the London Hotel Industry. 

A scoping study for the LDA, Brook Lyndhurst, June 2006 



179 ’Green Hotelier‘, July 2004 published by the International Tourism 

Partnership, a programme of HRH The Prince of Wales International 

Business Leaders Forum 

180 Business Resource Efficiency and Waste, the London Hotel Industry. 

A scoping study for the LDA, Brook Lyndhurst, June 2006 





183 Draft Strategy for Sustainable Construction: A consultation paper, 

Department for Business, Enterprise and Regulatory Reform, July 2007 

184 ’Materials resource efficiency in regeneration projects‘, Brian Menzies 

and Liz Goodwin, Magazine of the IEMA, March 2006 

185 ‘Construction, demolition and excavation waste 2003’ 

http://www.environment-agency.gov.uk/subjects/waste/ 

1031954/315439/923299/995831/?lang=_e [Accessed: 071207] 


and Liz Goodwin, Magazine of the IEMA, March 2006





188 Environment Agency Strategic Waste Management survey for construction 

and demolition waste, 2002/03, Production of construction, demolition 

and excavation waste in English regions, available at: 

http://www.environment-agency.gov.uk/commondata/103196/ 

996727?referrer=/subjects/waste/1031954/315439/923299/995831/ 

996360 [Accessed: 220107] 

189 The Further Alterations to the London Plan, 

Greater London Authority, September 2006, Policy 3A.1 


Department for Business, Enterprise and Regulatory Reform, July 2007 


and Liz Goodwin, Magazine of the IEMA, March 2006 

192 Sustainable Design and Construction: The London Plan Supplementary 

Planning Guidance, Greater London Authority, May 2006 


Planning Guidance, Greater London Authority, May 2006, page 13 




195 Consultation on site waste management plans for the construction 

industry, Defra, April 2007 


September 2006, Policy 4A.21v 

197 ‘Survey shows construction businesses ‘sleepwalking’ towards new site 

waste management legislation’ http://www.arenanetwork.org/News/ 

07Jan/Netregs.aspx [Accessed: 071207] 

198 Interim London Construction Consolidation Centre report, 

Transport for London, May 2007 


Planning Guidance, Greater London Authority, May 2006 


Planning Guidance, Greater London Authority, May 2006, page 38 

201 Setting a requirement for recycled content: Procurement guidance 

for construction, WRAP



202 ’The Net Waste Method – testing a new standard for measuring waste 

neutrality. A metric for the construction sector’, Waste and Resources 

Action Programme, http://www.wrap.org.uk/downloads/ 

Net_Waste_Brochure.fc42da69.pdf [Accessed: 080807] 


Department for Business, Enterprise and Regulatory Reform, July 2007, 

page 52 

204 GLA Economics’ London Employment Projections. Panel Note for the 

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217 Letter dated 12 October 2007, from Anthony Lord, Defra 

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221 City & Guilds Manufacturing Working Practices, The Survey Shop, March 

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Better Regulation Task Force, March 2005 

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233 The Packaging (Essential Requirements) Regulations 2003 

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