Matt Franklin, Communications & Programmes Officer
The European Investment Bank (EIB) has been heavily criticised for its role in the funding of an incinerator owned by Viridor in Cardiff. The bank is expected to finance the incinerator to the cost of £110 million in what the local group Cardiff Against the Incinerator (CATI) have called a ‘corrupt decision’ and a ‘disgrace’.
The incinerator which will burn 350,000 tonnes of waste annually, producing 70,000 tonnes of ash, has previously demonstrated poor levels of performance, with ‘plasticky’ smells being reported in homes 2-3km away from the facility. They have been forced to install magnetic equipment after failing to remove metals from the ash, and have been ‘forced to stop’ the processing of ash, due to the uncontrolled spread of toxic dust and pollution from the ash.
“We are disappointed to read that the EIB is still supporting incineration projects. The EIB should be supporting the circular economy and removing waste from the residual stream, not perpetuating outdated technologies that result in the lock-in of valuable resources into the bottom tiers of the waste hierarchy.”
As the new Circular Economy package is adopted by the European Commission, it is a timely reminder that we need to be moving our waste management processes up the waste hierarchy and focussing on keeping our material resources in use through reducing consumption and conserving materials, and reusing and recycling product waste rather than burning resources and producing toxic by-products.
The EIB’s support for incineration, and the subsequent landfilling of toxic ash is not a new phenomenon and has been highly criticised by a wide range of sources. In 2008 EEC Bankwatch released a report ‘Fuelling the Fire’ blaming the EIB for undermining efforts by decision-makers to develop ‘further waste prevention, reuse and recycling policies’ in contrast to EU policy which supposedly ‘privileges prevention, reuse and recycling instead of incineration’, and has led the financial support of dozens of incineration based waste projects over the past 15 years.
The EIB’s support for incineration not only ignores the waste hierarchy and the need to put the EU’s investments in line with the EU objectives and in compliance with EU law, but also ignores that the UK over-uses incineration as waste treatment. An analysis of British statistics on municipal waste management in the last 10 years corroborates that. Despite incineration remains at the bottom of waste hierarchy, it has increased spectacularly in the UK in the recent years, from 8% in 2005 to 27% in 2014, according to Eurostat figures. And while it is true that landfilling has decreased, figures show that by every 100 kilos of Municipal Waste diverted from landfilling between 2005 and 2014, 51 went to incineration and 49 to recycling.
If we are to truly move towards a zero waste society, and take waste management up the waste hierarchy and into the realms of prevention and reuse, it is essential to stop financing false solutions, and it is even more essential that public investments, which are limited are allocated for those projects making a transition towards a circular economy happen.
The Waste Management Plan for Municipal Solid Waste (MSW) for Vitoria-Gasteiz from 2008 to 2016 will soon finish and it is time to assess it. Some will certainly say that things are going perfectly because streets are clean. Others will make use of the big numbers, saying that “this year we’ve prevented 40,000 trees from being cut down”, when we don’t really know if that’s a lot or not. Gasteiz Zero Zabor has produced a report objectively assessing the results of this plan cross-checked with the announced objectives . The main conclusion is clear: the plan has not even met a quarter of its objectives, it’s a total failure. It’s a failure of all of us, but it’s even a bigger failure for the Vitoria-Gasteiz City Council who are implementing it. At the same time, given that a new plan is being drafted, Gasteiz Zero Zabor wants to raise some proposals that will help Vitoria-Gasteiz to meet EU and Basque targets on waste recycling. Our report can be found here.
In the coming weeks Gasteiz Zero Zabor will hold a series of meetings with all political parties so as to assess their commitment to our waste proposals. The overarching goal for any new plan should be Zero Waste, this might seem a utopian vision, but many cities are already working in this direction and getting closer and closer. The examples of San Francisco (USA), Treviso (Italy) or Ljubljana (Slovenia) show that it is possible to go Zero Waste and revert the situation in 10 years. What about Vitoria? Nothing new: we’re stuck at 24% separate collection, a terrible figure for a European Green Capital! It’s even more terrible, knowing that there’s a EU target of 50% recycling rate to be met in 2020. The remaining waste of Vitoria is being landfilled, wasting resources and creating toxic leachates and greenhouse gases, some plastics will also fly South in the stomachs of the storks of Gasteiz.
Europe brings new airs with the circular economy package by which waste will stop being that sticky and messy mixture to become resources. Waste if properly separated is a resource, saves money, creates jobs and can preserve the planet. By composting all the kitchen waste of the city, the Alavese plain could be organically fertilized . Wouldn’t it be nice to close down the landfill and bring organic food to plates at the same time? It is time to close the loop and reverse this situation through societal participation. It is viable and possible, it is just a matter of will.
Let’s do it then: let’s make sure that waste is prevented, reused or recycled!
Our short message to the political parties of the Council is: now that you’re creating the new Waste Management Plan, believe in citizens and civil society, don’t be afraid, it will be worth it!
Zero Waste is on the agenda at the region of Madrid. Despite the negative situation, positive changes are expected.
Last Friday 18th March, the Assembly of Madrid hosted a conference on Zero Waste. The aim was to present the initiatives already taking place in the Region of Madrid, across Spain and in Europe and to define proposals for the upcoming Waste Management Plan for the Region of Madrid.
The event was crowded with representatives of more than 15 cities and towns of the regions, among which included the cities of Madrid and Alcalá de Henares. Zero Waste Europe presented the situation of waste management across the EU and the main proposals emerging to turn the current situation upside down: institutional initiatives such as the Circular Economy Package and civil society ones like the network of Zero Waste municipalities.
The event was split into two sessions. The morning served to present the Zero Waste Madrid Platform, composed of a wide range of civil society organisations, from environmental NGOs to trade unions and neighbourhood associations, and to expose the major challenges of the current system of the region. The session addressed the main policy alternatives for the region and what the new Waste Management Plan could include to reverse their very negative situation. Among the panellists, there was broad consensus on the importance of collecting separately organic waste and addressing it specifically, and on the need to make use of fiscal instruments to incentivise the upper steps of the waste hierarchy, such as a tax on landfill and incineration. Other concerns were related to the limited existing infrastructure, and the need to shift investments away from big and rigid end-of-pipe infrastructures, such as landfills, incinerators or MBT plants, redirecting resources to those at the top of waste hierarchy, such as composting plants.
The afternoon session was mostly devoted to initiatives taking place at the local level and main plans for the municipalities of the regions. Although the session intended primarily to present changes taking place in the Region of Madrid, it also enjoyed the presence of Michele Giavini, a representative of the city of Milan, who illustrated the case of door-to-door separate collection of bio-waste in a city of 1,5 million inhabitants. Additionally, the session counted on the local councillors for the Environment of Madrid, Alcalá de Henares and Soto del Real. The three cities, along with other municipalities represented in the room committed to introducing separate collection of bio-waste and to set up a mid- and long-term strategy to become zero waste.
Despite the very negative situation of the Region of Madrid, very poor separate collection, lack of infrastructures at the top of the hierarchy, abuse of end-of-pipe solutions, landfills on the verge to close down, etc., local powers proved their commitment to redress the situation and their intention to push the regional government for an ambitious Waste Management Plan that accompanies and facilitates their transition.
Urban biomass is a common term to refer to all the food waste from restaurants, households, farmers’ markets, plus the garden waste, textiles, clothing, paper, or anything of organic origin within municipal solid waste. We call it ‘urban biomass’, given its urban origin in comparison to the agricultural, forestry or industrial origin of other kinds of biomass.
Ideally, a municipality committed to a zero waste strategy would sooner or later organise the separation and collection of this organic waste at the source, enabling for this extremely rich resource to be turned into compost (and returned to the soils as fertiliser), or to biogas, via anaerobic digestion, both of which are fundamental technologies that are required to play a key part in our low-carbon future.
However, as shocking as it may sound, most municipalities in the EU today are still mixing all of this organic waste, urban biomass, with the residual waste going to landfill and incineration, creating quite a big mess.
Organic waste going into landfills is responsible for generating methane – a greenhouse gas with a global warming potential 72-times greater than CO2 over a 20 year period, and for contaminating the soils and ground-water with leachate. Similarly, organic waste going to incinerators to produce energy (along with all kinds of fossil fuel derived plastic products) is an equal waste of resources – worse yet, this is misleadingly considered “renewable energy”.
Renewable energy from burning ‘urban biomass’?
Urban biomass like food waste, paper or textiles are a human product, i.e. it would not exist without our intervention. Moreover, it is very often the result of unsustainable modes of industrial or agricultural production, so considering it a ‘renewable’ source is definitely a challenging concept. Of course one could argue that food will continue to be produced as long as our civilization exists, but that does not make it an infinite resource, in the way that wind, solar or geothermal energy could be.
Precisely, one of the major pitfalls of the current EU Renewable Energy Directive is the consideration of this ‘urban biomass’ amongst the renewable energy sources, which allows incinerators, biomass plants or any other energy plant using biomass as a fuel, to receive financial incentives for doing so.
In this way, subsidies that should be committed to clean, sustainable and reliable sources of energies are being misused in the most inefficient way by supporting the burning resources that should be composted, recycled, reused or just never wasted in the first place. Today, harmful subsidies from renewable energy policies are one of the major obstacles to fully implementing a Circular Economy, as they continue to finance and green-wash the building of waste-burning facilities all over Europe.
Not renewable, and also not carbon-neutral
The big mess caused by considering biomass waste a renewable energy source gets even worse with the further misleading idea that the greenhouse gas (GHG) emissions from burning biomass can be considered to be zero, or carbon-neutral.
This concept originates in the idea that the GHG emissions related to cutting a tree, for example, will be compensated with another planted tree, creating a net balance in the carbon cycle of the atmosphere. Those promoting large-scale biomass energy believe that even if you would cut these trees and burn them, GHG emissions would be compensated overtime with the appropriate forestry policies, and therefore be, carbon-neutral.
That may make sense in the abstract world – and indeed sustainable forestry practices that allow for the appropriate supply of trees are extremely important, but being by being realistic, it’s easy to see the flaws of the concept. Using biomass for fuel can eventually be sustainable with the appropriate practices on a small-scale, but it’s just not going to be carbon-neutral.
Firstly, the very activity of burning biomass produces GHG emissions, regardless of whether you plant a tree or 200, in the next day or in the next year. Those emissions are unique and additional, and it’s time that that they are recognised and accounted for as such.
As Eunomia put it in our latest report: “It is a mistake to assume that CO2 from non-fossil sources does not mater. The argument that CO2 from such sources is all short-cycle, and so, it can be ignored, is tantamount to assume a separation in the pools of carbon dioxide from fossil and non-fossil sources. It is as though the argument runs that the climate only changes if emissions come from fossil sources. This is so obviously wrong that it seems genuinely surprising that this argument could ever have been considered acceptable: (…) the only correct way to process is to account for emissions of all greenhouse gases since they will all have ‘warming potential’, irrespective of their origin”.
Secondly, how does the carbon-neutral reasoning apply to ‘urban biomass’? It is stretching a concept far beyond what could be justified to assume that GHG emissions from burning food waste, paper and textiles can be ‘compensated over time’ and therefore could be counted as zero. And yet, this is what incinerators, biomass or even cement plants will argue and apply in their accounting methodologies: the ‘urban biomass’ they burn is carbon-neutral and a key climate mitigation strategy for the sector!
Thirdly, the burning of urban biomass it’s in fact a very inefficient and polluting source of energy, generating even more GHG emissions per unit of electricity than coal. Even if paper and textiles can burn reasonably well, food waste is 70% water, which makes it a rather inadequate fuel. So, burning biomass of any kind is not only not carbon-neutral, it’s in fact more carbon-intensive than coal and responsible for a great deal of air pollution, as it’s been pointed out in both this and that report.
It must be noted that the IPCC guidelines to account the GHG emissions from biomass energy in national inventories do require to report these emissions but only as an information item, mostly for methodological reasons. This is an unfortunate solution to a methodological problem, as these emissions then tend to go under-reported and are generally underestimated. Still, the IPCC remains ultimately clear on the carbon-neutrality of bioenergy and responds: “the IPCC approach of not including these emissions in the Energy Sector total should not be interpreted as a conclusion about the sustainability or carbon neutrality of bioenergy.”
Impacts of harmful subsidies and accounting errors
In practice, accounting errors related to GHG emissions feed and maintain the misuse of public funds that should be supporting low-carbon solution pathways and that are instead supporting carbon-intensive, wasteful and polluting technologies.
Ultimately, at the EU policy level, the contradiction is obvious. While the Circular Economy Package is all about resource-efficiency and material recovery, the renewable energy subsidies end up being perverse economic incentives and a fundamental misallocation of resources.
The right solutions at the right scale
As previously mentioned, urban biomass is a rich resource that can be composted or treated in anaerobic digesters to produce biogas. Paper can be recycled, textiles can be reused, and all measures to prevent these products from entering our bins will be infinitely more sustainable than burning them to extract what little and polluting energy we can get from them. Not in vain does the waste hierarchy suggests that wastes should only be combusted once the potential for reuse and recycling has been fully explored.
When it comes to using forestry or agricultural biomass for energy purposes, the matter of scale is critical. The use of agricultural or forestry biomass for energy purposes can be sustainable at small-scale and in fact, communities around the world depend on it for everyday heating and cooking.
However, in a world with increasing pressure on land, food, and forests, large scale industrial biomass energy should be questioned and avoided, along with their corresponding renewable energy subsidies. Not only there is increasing evidence of deforestation related to this practice, the large amount of biomass needed to operate an industrial plant may require additional fuel, which will often be Refuse-derived Fuel – mixed waste, including plastics and all kinds of residual waste. This dramatically increases the toxic mix of emissions and prevents the proper management of this waste.
At the end of the day, energy policies for a low-carbon economy, should progressively move away from extracting as much energy as possible from waste and instead increase measures to preserve the embedded energy in products, a far more efficient and sustainable approach to resources.
Final words for EU policy makers
Europe should become a leader in renewable energy and develop a long-term, secure, sustainable and competitive energy system, as outlined in the EU Energy Union Framework Strategy. For this, increasing the share of renewable energy sources it’s as important as ensuring that these sources are clean, efficient and science-based.
Whether the final share of RE for 2030 is 27% or higher, none of it will do any favours for climate change mitigation if it ends up increasing deforestation, resource depletion and air pollution.
According to Eurostat statistics on waste released on 22/03/16, each European generated 475 kg of waste in 2014, only 44% of this is being recycled or composted. The remaining 56% ended up landfilled (28%) or incinerated (27%).
Zero Waste Europe (ZWE) notes that two continuing trends in these statistics:
Little improvement in terms of waste generation
Waste is being diverted from landfills into incinerators (up 1.1%) and to a lesser extent to recycling (up 1%)
In general terms, the countries which are performing well in waste treatment seem to be unable to reduce their waste generation, while the most efficient ones in terms of waste generation tend to be unable to reintroduce materials into the economy through recycling and composting.
In view of these facts and in order to advance towards a circular economy ZWE calls for the adoption of targets for residual wastei of 100kg per capita as a more effective tool to increase recycling in countries with low waste generation and reduce waste generation in those countries with advanced recycling programs.
Zero Waste Europe’s Executive Director, Joan Marc Simon said “A residual waste target of 100kg per capita for 2030 is a good indicator of resource efficiency and resource use, as it works on the top levels of the waste hierarchy, effectively combining prevention, reuse and recycling policies”.
When looking at 2014 statistics from a residual waste per capita perspective one can see that, besides Malta and Cyprus (both islands) and Denmark, there is already considerable convergence between EU member states with the EU average being at 259kg per capita, hence a target of 100kg for 2030 is a feasible target.
The situation is, however, very diverse across the EU, both in terms of waste generation and waste treatment. Some Member States like Romania, Poland or Latvia are well under the average EU waste generation with less than 300 kg per inhabitant, while some others like Denmark, Cyprus and Germany generate substantially more than EU average, being over 600 kg per inhabitant and even over 750 kg, as it is for Denmark.
ZWE also notes that Slovenia, a relatively new member state, is today the best EU country implementing waste hierarchy management practices with stable waste generation well below EU average and a high recycling rate. This makes of Slovenia the best performing EU country with the lowest amount of residual waste, just 102 kg per capita in 2014.
Mr Simon added that “The Circular Economy in Europe means reducing waste generation and increasing recycling rates and Slovenia is a good example of how to both things can take place simultaneously”.
An analysis of the new EC proposal on Packaging and Packaging Waste Directive (PPWD)
Joan Marc Simon – Director of Zero Waste Europe
On December 2nd the European Commission (EC) presented the new legislative proposal aiming to amend waste directives and move the EU towards a Circular Economy. However if one analyses the text of the proposal on Packaging and Packaging Waste Directive (PPWD) in detail one wonders whether this proposal is legislating for 2030 or for 2010.
Effective action in the field of packaging is as important as it is urgent. There are many reasons for this;
packaging is growing in absolute terms both in volume and in weight. Between 2000 and 2015 the share of plastic packaging has grown 5% annually and is now 25% of the market,
once it becomes waste most packaging (notably plastic but not exclusively) is generally disposed of, not recycled,
marine litter is global problem and 80% of it is made of plastic packaging and by 2050 there may be more plastic than fish in the ocean.
Moreover current packaging recycling schemes in Europe are generally inefficient. In a study we published in 2015 we demonstrated that in Europe 70% of the municipal waste is product waste, i.e. not biowaste, 45% of which is not covered by Extended Producer Responsibility schemes which only succeed to separately collect 18% of it. Hence the recycling system is not performing very well and leads to most product waste ending up in the environment, in landfills or in incinerators.
With this in mind the European Commission presented a proposal in December 2015 aiming to create an “economy that preserves the value added in products for as long as possible and virtually eliminates waste. It retains the resources within the economy when a product has reached the end of its life, so that they remain in productive use and create further value”.
Hence, one would expect that the aim of the amended Packaging and Packaging Waste Directive (PPWD) is to go in the direction of increasingly preserving this value that we seem to be so inefficient at maintaining.
If we look into the current proposal from the EC to amend the PPWD we will see that it mainly proposes two things;
Firstly, it suggests that preparing for reuse rates can be counted as contribution to recycling efforts. One can understand the political reasons behind this move, help those countries which will see their recycling rates shrink with the new suggested methodology to account for the targets, but technically it is an objectively bad idea because it mixes apples with pears and will not help bring clarity and legal security to neither the recycling industry nor public authorities. If the EC wants to increase reuse of packaging it is a lot better to set separate preparation for reuse targets altogether.
Secondly, it reduces the targets of preparation for reuse and recycling by an order of 5 to 15 points from the 2014 proposal, although the targets proposed will remain above those of the PPWD directive of 1994. All in all this is to be welcomed but if preparation for reuse is to be counted together with recycling it might well be that many countries will be already meeting the recycling targets today.
However, before ranking the level of ambition of the EC proposal we need to zoom out and ask ourselves a simple but important question; if the aim of this legislation is to contribute to the creation of a Circular Economy which preserves the value added in products as long as possible… are the measures presented the appropriate ones?
Unfortunately the answer is a resounding no. The current proposal would have been appropriate for the discussions we had 10 years ago during the revision of the waste framework directive in which the aim was to “turn the EU into a recycling society” but not in 2016 in the framework of Circular Economy discussions.
Many stakeholders including the EC itself recognise that the real added value of products and resources is in prevention and reuse operations. A very simple example; if we recycle a mobile phone the value of the materials we will extract will not be above €2 whereas if we repair and resell it we have the possibility of getting several hundred euros. In this sense the proposals to amend the PPWD are not legislating for the future but rather for a situation which belongs to the past. Where are the proposals to reduce packaging waste? What about increasing packaging reuse? And deposit schemes? By focusing primarily on recycling the EC commits the same mistake of previous decades; work at the bottom of the hierarchy and ignore the biggest potential benefit which lies at the top.
Another sign that the proposal is legislating for the past is the fact that it does not address current market developments. The fastest growing packaging waste streams are composite packaging (multilayer packaging, pouch-ups, etc) growing at double digits rate yearly. They are difficult to collect and even more difficult to recycle yet completely absent in the directive. On the other hand we see the rise of online shopping which involves a lot of packaging which producers like Amazon put in to the EU market but for which they don’t take any responsibility… on top of evading most taxes these companies get another competitive advantage by passing the responsibility of managing their packaging waste to the public authorities. Where is the action from the EC on this front?
And what about coffee-capsules? They are a problem today which will continue to grow in the coming years and legally speaking they are not even considered to be packaging! We need a proposal that legislates not for the past but for the Europe we will have in 2025 and 2030.
Essential components to make the PPWD fit for the Circular Economy
If the objective is to build a Circular Economy which preserves the added value in the economy there are at least four instruments that the EC should be considering:
Prevention targets for plastic packaging
We need to stop the growth of packaging waste in Europe. This means that there should be prevention targets which in my opinion do not need address the totality of packaging waste but rather specific waste streams and at the very least have prevention targets for plastic packaging. There are three reasons for this; plastic packaging is the stream with lowest recyclability and the one with lowest recycling rates, it is the fastest growing packaging waste stream and it is a major problem for marine environment and hence human health. Moreover, because of its light weight it is hard to compare with metals, paper and glass and the EC is working on a strategy on plastics which needs to address plastic packaging. Why not start here?
The current PPWD directive already includes prevention targets for single use carrier bags which focus in reducing the units of plastic bags instead of addressing the stream by weight. A similar approach can be used to set prevention targets for plastic packaging.
2. Separate targets for preparation for reuse
If there are targets for recycling, there could also be separate targets for preparation for reuse or any other commitment to have refillables return to Europe. Otherwise there is the paradox that by trying to meet recycling targets by weight member states might decide to dismantle existing packaging reuse schemes. Over the past few decades the market for refillable and reusable packaging in Europe has been inexorably shrinking and without a clear sign and guidance from the EU level nothing encourages governments thinking this process could be reversed or even stopped. The current PPWD already includes good wording on packaging reuse but still lacks the teeth and targets to make it possible.
3. Modulate EPR fees according to ‘circularity’ of products
There should be a clear feedback mechanism that connects waste with product and process design. In a circular economy, waste and inefficient resource use anywhere along the value chain should translate into direct costs for business. In other words, less durable, reusable or recyclable products should be more expensive for the producer and for the consumer than the circular ones. A way to do this is by using modulate fees in the extended producer responsibility schemes as it is being used in some cases such as for paper in France. Luckily the current proposal to amend the Waste Framework Directive already dwells on this option but we need stronger legislation in order to give clear signs and legal security to producers.
4. More and better recycling, but as a last option
Recycling is very important as last stage of a circular economy but it cannot do the job alone. Yes, we need more recycling, yes we need separate targets for recycling, yes we need to have separate recycling targets for composite packaging and yes we need more directly enforceable legal formulations but recycling alone cannot bring about a Circular Economy.
To conclude, the effectiveness of the new PPWD will be judged according to two parameters; on one hand the measures to tackle plastic packaging and on the other one the measures to support reusable and refillable packaging. Both currently missing and which will need to be introduced during the co-decision process.
Disruptive legislation in this field will not be easy because of the economic interests that lay behind single-use packaging but if Europe is serious about becoming a circular economy and fighting marine pollution it will need to stop looking at the past and start legislating for the future.
This speech was delivered at Packaging & Sustainability Forum, 2/3/16.