International Review of Waste Management Policy - Department of ...

4) Combustible waste
5) Waste exceeding a stability standard; and
6) Waste exceeding a threshold calorific value.
What is of particular interest is the rationale for these, and how they are actually
implemented. Implementing a ban on landfilling is not entirely straightforward, and in
several countries where they are in place, exceptions have to be applied to allow for
landfilling of materials for which there is insufficient treatment capacity. In some
countries, a key objective has been to shift was from landfill and into incineration.
Bans are blunt instruments. They are, by definition, economically inefficient. They will
not always lead, unequivocally, to environmental benefits and they may impose
significant costs. Hence, to the extent that bans are deployed, they need to be
considered carefully in order to ensure that gains are commensurate with costs. It is
also worth considering that the practicalities of implementing and enforcing a ban
limits the degree to which such bans can be targeted in ways which might, on purely
environmental grounds, appear desirable (for example, banning food waste from
landfill is extremely difficult unless whole waste streams are banned from landfill, or
unless the ‘ban’ implies a requirement to source separate, in which case, it in not,
strictly speaking, a ban).
Some of the bans which seem more likely to deliver benefits are those which are not,
strictly speaking, outright bans. The above assessment of externalities suggests that,
to the extent that the externalities of landfill are associated with biodegradable
wastes, then treating waste to reduce that biodegradability seems to render
significant benefits. This implies not so much a ‘ban’ as a restriction on the
characteristics of wastes which can be landfilled. Our review highlights Austrian and
German experience in this regard. These countries use broader criteria to restrict
wastes sent to landfill. For example, in Austria, wastes which exceed a specified
calorific value cannot be landfilled. However, in our view, this type of criterion is far
less justified as the basis for a landfill ban. The presumption, presumably, is either
that waste with a higher calorific value is better utilised in energy from waste plants,
or that the environmental impacts of landfilling waste are somehow correlated with
their calorific value. Neither is true, and brief consideration of how plastics fare in
landfills and incinerators in respect of climate change supports this point. 1049
The restructured levy, discussed above, will give a signal to the market that all
residual waste treatments are to be made more expensive, most notably, landfilling of
untreated waste. This will move waste up the hierarchy and will give the market
greater certainty in respect of developments other than landfilling.
1049 We have discussed this elsewhere (D. Hogg (2006) A Changing Climate for Energy from Waste?
Report to Friends of the Earth). Subsequently, Defra stated, in Waste Strategy for England 2007,
‘Burning plastics has a general net, adverse greenhouse gas impact due to the release of fossil
carbon. Recycling shows significant potential for carbon and energy savings through displacing virgin
materials, although the scale of this varies widely with the processing route.’ The same conclusion was
reached in previous work for the European Commission (see Smith, A., K. Brown, S. Ogilvie, K. Rushton
and J. Bates (2001) Waste Management Options and Climate Change, Final Report to the European
Commission, DG Environment, July 2001).
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International Review of Waste Policy: Annexes