CIWM’s Chris Murphy, turns his attention to the Waste Management and Waste Prevention Plans For England… but says there’s little satisfaction in what they have to offer.
Published in the CIWM Journal September 2013
During the summer, Defra released two allied consultation papers; the Waste Management Plan and the Waste Prevention Plan for England. Yet again we responded with disappointment at the lack of vision, ambition and the lost opportunity, particularly in the case of the Waste Management Plan when compared to what is proposed in Scotland and Wales.
Our expectations with regard to the Waste Management Plan have been managed down by Government over a prolonged period. It has consistently said that the objective of the document is to satisfy the requirements of the revised Waste Framework Directive (rWFD) to produce a National Waste Management Plan. Therefore, it is less of a Plan and more of a tick box of the mandatory requirements of Article 28 of the rWFD including references to waste generation, collection schemes, infrastructure, promotion of the hierarchy etc.
The intention of the Plan is to replace the Waste Strategy 2007 for England – the policy content to satisfy the requirements of the rWFD were included in the Government Review of Waste Policy 2011. The Institution’s views on the scope and ambition of the Waste Review were made clear at the time and it is with a degree of déjà vu that we have once again been disappointed.
The consultation paper claims that the Waste Review evaluated policies to ensure that they were fit for purpose and reflected the Government’s ambitions for a zero waste economy. It seems to be more about compliance than to challenge or take advantage of the considerable opportunities of a circular and resource efficient economy. It doesn’t clearly identify how the Government intend to release the considerable “green growth” potential of the sector and by not accepting that challenge now we are destined to have to go through revisions of the Plan as we see what can be achieved elsewhere in the UK and in response to external initiatives such as the Waste Prevention Plan, PPS10 review, revised Landfill and Packaging Directive targets and collection guidelines.
Less Than Enthused
The draft Waste Prevention Plan left us less than enthused for two fundamental reasons. Strategically, it fails to move from waste-focussed thinking, when the rest of the sector is looking at resource efficiency and the circular economy; this strategic document is mired in aged thinking. Practically, it does not include measurable objectives and actions, and far too little on data and measurement. How can success, or otherwise, be measured unless we have targets and data?
It is such a shame that the ambitious policy opportunities for this Plan seem to have been shelved during its gestation. What happened to the forward thinking on green taxation, product policy and standards, resource security and more dynamic producer responsibility? Government should be taking a lead through this Plan on potential intervention, fiscal instruments and coordinated policy. There is evidence of much good work in waste prevention in both the public and private sector, some of which is referenced in the document. I would have expected for the paper to have built on that good work by giving it the direction it deserves rather than leave the ball in other stakeholders’ court.
Because of this lack of clear objectives and failing to include an evaluation of the range of possible measures set out in the various Directives, the Commission may decide that the Plan, when finally produced, will not meet the requirements of Article 29 of the rWFD. Even if it does pass muster, there will need to be an early review simply to keep up with the pace of change.