Foreword

Exciting, yet challenging times lie ahead for the ESA believes that a large part of the solution biowaste treatment industry. We have recently lies in improved understanding of the value of seen a justified outcry over the scale of food biowaste-derived outputs. The biowaste sector waste generated both in the UK and beyond. needs to move beyond landfill diversion that is This is driving new efforts above all to achieved through blunt regulatory fixes, to prevent food waste but also to then a more product driven process that maximise the value from that truly values the outputs from which inevitably remains. biowaste treatments in line New proposals from with the biowaste hierarchy. Brussels are shaking up the Value and quality should regulatory framework and be the focus, driving accentuating the debate food and green waste over what we do with the out of landfills so it waste that is collected can be used to grow and diverted from food and plants in our landfills. fields and gardens more sustainably, as well At the same time, the as developing new and industry is faced with innovative products that a range of sometimes can help boost the so called overlapping challenges. These ‘bioeconomy’. This is the vision include inconsistent and quickly of ESA’s Biotreatment Strategy. changing regulations, a lack of suitable feedstock opportunities and a severe squeeze on local authority budgets, all of which make life increasingly difficult for operators. These David Palmer-Jones challenges should not be taken lightly. Chairman, ESA

2 CIRCULAR ORGANICS: BIOWASTE IN A CIRCULAR ECONOMY Organics Recycling in a Circular Economy A Biowaste Strategy from ESA

Introduction How to achieve a more circular economy has recycling industry in unlocking the benefits of received considerable attention in waste and biowaste and moving towards a more circular resource management policy debate over economy. the last few years, highlighting especially the benefits and challenges of treating waste as a The Strategy identifies 5 key barriers to achieving resource. However, the debate often concerns this: the technical components of a circular economy such as plastics, metal, and electronic waste 1 Failure to identify the full potential of among others. At the same time, about 40-50 % biowaste; of our household bins consist of biowaste1, an organic nutrient and potential energy source, 2 Uncertainty over feedstock security; which has received less attention until very recently. 3 Inadequate feedstock quality drivers;

Biowaste as a resource has been acknowledged 4 Unclear waste hierarchy for biowaste; as part of the UK Government’s renewable energy policy by providing green energy and 5 Increasingly complex and onerous policies using it to mitigate climate change. However, and regulations. there are also clear benefits from using organic matter and nutrients in supporting ecosystem It also presents concrete actions on how these services and benefiting sustainable farming. In barriers might be tackled, involving stakeholders addition, all these policies and feedstock across the supply chain. hold, as yet, untapped potential to drive innovation by stimulating The message from this strategy is emerging sectors within the clear: in order to move towards ‘bioeconomy’. a more circular economy for biowaste, we need to take ESA’s members are uniquely the next step beyond landfill placed to add value to this diversion to focus on the full debate as they collect, value chain of biowastes and consolidate, treat, and make biotreatments. energy and products from waste, covering a substantial element of Quality and confidence are the the sustainable circle of biowaste. key words in this new, product- driven phase, one which can only be The purpose of this strategy is to seek achieved by all partners in the supply to explore and address the main chain working together. challenges faced by the organics

1 The Waste Framework Directive’s definition of biowaste is: “biodegradable garden and park waste, food and kitchen waste from households, restaurants, caterers and retail premises and comparable waste from food processing plants”.

3 Image 1: Biotreatment Circular Economy Diagram

Source: Environmental Services Association (ESA) From Biowaste to Resource

Biodegradable waste arises from agriculture, and drink waste from households in the UK is sewage and waste from households and industry. still considered avoidable (edible, rather than say This report focuses in particular on waste from unavoidable like banana peel)2. To address the households and industry, but many of the food waste issue on the European level, the EU messages can be applied to both agriculture and has recently introduced a draft legislative package sewage. which includes a 30% aspirational food waste reduction target by 2025. Biowaste prevention WRAP is doing important work with its “Love According to WRAP, in the three years from Food, Hate Waste” campaign, for example, 2009 – 2012, 1.1 million tonnes of food waste working with the packaging industry, local were prevented (enough to fill Wembley authorities and consumers to highlight the stadium). However, 4.2 million tonnes of food benefits of packaging in preserving food.

2 WRAP (November 2013), Household Food and Drink Waste in the United Kingdom 2012, http://www.wrap.org.uk/sites/files/wrap/hhfdw-2012-main.pdf.pdf, p3

4 CIRCULAR ORGANICS: BIOWASTE IN A CIRCULAR ECONOMY Recent funding cuts have however put pressure waste prevention or local recycling. The question on this initiative and similar programmes, which is: which problem are we trying to solve? This risks limiting their impact and/or their sustained deserves further research and analysis. delivery. Diversion of near or on date food to food banks has also been an increasing trend. Animal Feed The retail industry’s ‘Courtauld 3 Commitment’ Using food waste, where possible, as animal included a waste prevention target of 5% by 2015, feed, conforms to a higher element of the waste which is a positive step in the right direction. hierarchy and should be more environmentally One example of its delivery is retailers across the friendly than disposal, recovery or recycling. sector being advised to use “best before” instead Currently, it is illegal to feed farm animals with of “use by” dates more widely, and to make sure catering food waste, but carefully selected that food close to its “use by” date that cannot be foodstuff from bakers, retailers and confectioners sold reaches food banks and food charities. can be used. Organisations such as ‘The Pig Idea’ have recently popularised the suggestion that all In addition, more can be done earlier in the source separated food waste should be allowed supply chain at farms and by manufacturers, as pig feed. However, the Environment Agency something which has attracted attention in (EA) and the Animal Health and Veterinary reports from the House of Lords, the Global Laboratories Agency (AHVLA), as well as pig Food Security Programme and the Institution of industry groups such as BPEX, are worried about Mechanical Engineers3 among others. the food safety aspects and the potential risks to animals and human health. The important thing is Finally, there are different views on the making sure the food is safe and suitable for farm environmental benefits and burdens of home animals, through better segregation at source composting. This can be seen as another form of between animal and plant-derived materials.

Image 2: Weight of household waste in 2012 by food and drink, split by avoidability (in million tonnes):

Source: Household Food and Drink Waste in the United Kingdom 2012, WRAP, November 2013, page 31

3 Institution of Mechanical Engineers (January 2013),Global food, waste not, want not, Global Food Security (2013), Food waste within global food systems, House of Lords, The European Union Committee (April 2014),Counting the Cost of Food Waste: EU Food Waste, Prevention.

5 Brief overview of the main biotreatments in the UK

For biowaste that cannot be prevented, Composting, Anaerobic Digestion (AD) Anaerobic digestion (AD) and Mechanical Biological Treatment (MBT) are the three main biotreatment Anaerobic Digestion (AD) technology treats the processes currently employed when measured in organic waste in an environment where oxygen terms of tonnages treated. Other treatments such as is substantially absent and in doing so enables fermentation are emerging as interesting options for the creation of a useful high energy content the future. gas and agriculturally useful digestate. Most household and commercial waste feedstock AD plants operating in the UK today receive Composting separately collected food waste, although Open Air Windrow (OAW) is today the biggest some technology types can accommodate a biowaste treatment type by tonnage in the proportion of green waste. Some facilities are UK, taking green waste exclusively. In-Vessel linked to MBT plants and treat the generally Composting (IVC) takes both mixed food and mechanically separated organic output in an garden waste, and separately collected food AD plant. The solid/liquid by-product of which waste. The OAW activity generally takes place can then get sent as compost or compost like in an open air facility, while IVC is primarily in output (CLO) to land for land maintenance or an enclosed facility in compliance with Animal restoration after further treatment. AD digestate By-Products legislation and operating in a more output can be presented in a whole digestate enclosed environment. The former is generally form or in the form of separated fibre and liquor less costly to build and operate but the latter fractions. Due to the relatively immature market can enable food and green waste to be collected for digestate, WRAP figures show that in 2012 together, allowing in some circumstances a more only 24% of whole digestate from commercial cost effective system compared to separate AD sites (sites accepting waste for a gate fee) food and green waste collections. Neither OAW was sold off site as a product whilst 48% was nor IVC treatment produces usable energy rich given away free of charge or deployed at a cost biogas, and IVC generally requires more energy to the producer. The remainder was mainly used to operate than OAW, and can sometimes by the operators themselves in local schemes4. struggle to effectively treat the waste if food The biogas generated by AD plants contains loading in the co-collected material is too great significant proportions of methane, which can a proportion of the whole. Compost from OAW be combusted for electricity, injected to the gas and IVC is often used in agriculture, horticulture grid, used for vehicle fuels or burnt in a boiler, or specialist plant and cropping applications. with the energy used as heat. An important benefit of the biogas produced by the AD plant process is the ability to store and transport the fuel prior to use. Image 3: UK biological treatment sector by input tonnage in 2012:

Compost: 5,850,000 (t) 25% AD (commercial, R&D and on-farm): 1,430,000 (t) 3% 58% 14% AD (industrial)*: 260,000 (t)

MBT: 2,510,000 (t)

Source: A survey of the UK organics recycling 4 WRAP (August 2013), A survey of the UK organics recycling industry in 2012, WRAP, August 2013, page 3 industry in 2012, p60

6 CIRCULAR ORGANICS: BIOWASTE IN A CIRCULAR ECONOMY Mechanical Biological Treatment Apart from the main treatment methods (MBT) described above, technology and innovation are playing an increasingly important role Mechanical Biological Treatment (MBT) takes in developing new channels for biowaste residual waste and, through the application treatments and products, and they are forming of various mechanical, thermal and biological a potentially important part of the future treatment activities, separates out the dry solids. bioeconomy6. For example, according to the These solids are often used as Refuse Derived NNFCC, a UK based consultancy, UK industrial Fuel (RDF) / Solid Recovered Fuel (SRF), (~51% biotechnology sales are projected to grow by 5 of total in the UK), organic waste (~22%) and to 11 per cent per year, or between £4bn and recyclates (~11%). The remainder is generally £12bn in total by 20257. A 2013-2014 House sent to landfill or used as aggregates5. of Lords inquiry into the Bioeconomy heard As mentioned earlier, the organic waste estimates from the Department of Business, component is then further treated in either Innovation and Skills (BIS) of £100bn in terms of IVC or AD technologies. the total economic opportunity embedded in the bioeconomy in the UK8. Image 4: UK Organics Sector 2012

Source: A survey of the UK organics recycling industry in 2012, WRAP, August 2013, page 21, 45 and 66 (the diagram has been simplified to only include the main flows above 50 000 tonnes and doesn’t capture for example green waste going to dry AD) - edited by ESA

5 WRAP (August 2013), A survey of the UK organics fisheries, food and pulp and paper production, as well as recycling industry in 2012, p69 parts of chemical, biotechnological and energy industries”. 6 According to the 2012 European Commission 7 NNFCC (2013), Newsletter 27 Summer 2013, p2 Communication Innovating for Sustainable Growth: 8 House of Lords Science and Technology Select Committee A Bioeconomy for Europe the bioeconomy (2014), Waste or resource? Stimulating a bioeconomy, “encompasses the production of renewable biological 3rd report of session 2013-2014, p24 resources and their conversion into food, feed, bio-based products1 and bioenergy. It includes agriculture, forestry,

7 The importance of collecting biowaste

Uncollected biowaste can cause nuisance, The three key reasons for treating biowaste can contamination and can be a source of be summarised as: uncontrolled pathogens and bioaerosols. Once collected, it can be safely managed through 1 climate change mitigation landfilling, although that will not enable its full beneficial potential to be utilised. It can also be 2 energy production collected as part of general waste to be used as fuel for Energy from Waste (EfW) plants, utilised 3 returning organic matter to soil in MBT facilities and if collected separately can be used in OAW, IVC and AD plants.

Key reasons for treating biowaste

Climate change mitigation benefits that are not yet properly recognised. According to the Food and Agriculture Mitigating greenhouse gases (GHG) has Organization of the United Nations (FAO), nearly effectively been the key regulatory driver for 90% of the climate change mitigation potential recycling organic waste. Diversion of biowaste of agriculture globally comes from soil carbon from landfills is one of the main purposes of the sequestration, including increasing the levels of landfill tax, which reached £80 per tonne in April organic matter in soil11. Furthermore, the net 2014. The EU 2020 EU landfill diversion target is environmental benefit of biowaste treatment currently 35% of 1995 levels of biodegradable must reflect the energy consumed in the municipal waste9. However, the legislative collection and movement of the waste from package recently presented by the European production source to treatment location. Commission proposes phasing out landfilling by 2025 for recyclable waste (including The value of using biowaste to displace peat biowaste). Diverting biowaste from landfill consumption cannot be overstated. According avoids methane emissions, which although to Defra, UK soils contain around 10 billion captured and utilised in energy production, are tonnes of carbon, half of which is found in our less efficiently collected than the gas in fully peat habitats. If this were released to the air, enclosed systems. Utilising biowaste for energy it would be equivalent to more than 50 times brings benefits in terms of offsetting fossil fuel the UK’s current annual GHG emissions12. It based energy sources. The biogenic component is vitally important that these peat wetlands in residual waste and RDF/SRF also contribute are conserved and the compost and digestate to renewable energy production. According to outputs from biowaste treatment can play an WRAP’s updated research review from 2010 important role in their reduced consumption. called “Environmental benefits of recycling” AD Currently most of the peat consumed in the UK is seen as the preferred option in terms of GHG is derived from non-renewable sources imported mitigation10. This has led the Government to from Ireland and the Baltic states and is used support AD as the optimal biotreatment for food as compost (growing media). According to the waste. However, replenishing carbon stored in latest Government estimate, the UK compost soil and diverting peat from becoming a growing market is only 58% peat free13, despite an earlier media can also have significant GHG mitigation target to reach 90% by 201014. The current

9 Official Journal (1999), Council Directive 1999/31/EC of 12 Defra (September 2009), Safeguarding our soils – A 26 April 1999 on the landfill of waste, p5 Strategy for England, https://www.gov.uk/government/ 10 WRAP (March 2010), Environmental benefits of recycling – uploads/system/uploads/attachment_data/file/69261/ 2010 update, p4 pb13297-soil-strategy-090910.pdf, p2 13 11 FAO (November 2009), Promoting climate-smart Defra (June 2011), Reducing and phasing out the agriculture, http://www.fao.org/news/story/en/ horticultural use of peat in England, p1 item/36894/icode/ 14 Defra (September 2009), Safeguarding our Soils A Strategy for England, p20

8 CIRCULAR ORGANICS: BIOWASTE IN A CIRCULAR ECONOMY ambition, laid out in the Natural Environment TWh in 2013. For AD the same figure was 707 White Paper (NEWP), is zero peat use by 203015. GWh in 201318 with an additional 761 GWh from sewage sludge digestion. The Department for In addition, replacing inorganic, or mineral, Environment, Food & Rural Affairs (Defra) and fertilisers with compost and digestate based DECC estimated in their “Anaerobic Digestion products offer significant potential for climate Strategy and Action Plan” in 2011 that electricity change mitigation. In agriculture, the majority generation from AD could grow to 3-5TWh by of GHG emissions do not come from carbon 202019. The impressive growth in AD from food dioxide, but from nitrous oxide and methane, waste, from 68 plants in September 2011 to with the former making up the larger part. The 145 in May 201420 and with a further 200 new main source of this nitrous oxide is inorganic facilities obtaining planning permission21, has nitrogen fertilisers. According to the Soil largely been sparked by a range of Government Association it takes 7 tonnes of CO2 equivalent incentives. These incentives, including the (and 108 tonnes of water) to produce each 1 Renewables Obligation (RO); Feed-in Tariffs tonne of inorganic fertilisers16. (FiTs) for small scale (under 5 MW) electricity generation; the Renewable Heat Incentive (RHI) Energy production tariff scheme (for industry, commercial premises and the public sector) and the relatively new The Government has made a legally binding Contract for Difference (CfD) all influence the commitment to having 15% of the UK’s energy biotreatment value chain in respect of the type of demand being met from renewable sources by energy produced. Furthermore, the influence of 2020, compared to about 4% in 201217. landfill tax cannot be underestimated in driving active materials away from landfill. However, Renewable energy from biowaste has there are currently no direct incentives that traditionally been produced through landfill gas support the nutrients and mineral benefits of capture, combustion (either directly or through biowaste treatment. an MBT plant pre-treatment), and to a greater extent over the last 5 years in AD. According to Another pertinent route of energy recovery is the Department of Energy & Climate Change that of capturing used cooking oils where their (DECC) “Energy trends – June 2014” report, the reuse as vehicle fuel has become a significant electricity generation from landfill gas was 5,169 industry. According to a Department for Transport

15 Defra (February 2014), Natural Environment White Paper, 19 Green Investment Bank, 2013, Anaerobic Digestion Implementation update report, p13 Market Report, p2 16 Soil Association (2008), An inconvenient truth about food – 20 ADBA (July 2014), http://adbiogas.co.uk/wp-content/ Neither secure nor resilient, p7-8 uploads/2014/06/July-2014-ADBA-AD-market-update. pdf, p1 17 DECC (November 2013), UK Renewable Energy Roadmap, Update 2013, p4 21 Defra (August 2013), Anaerobic Digestion Strategy and Action Plan Annual Report 2012-13, p3 18 DECC (June 2014), Energy Trends, https://www.gov.uk/ government/uploads/system/uploads/attachment_data/ file/326368/ET_June_2014.pdf, p47

9 (DfT) commissioned report, the UK generates an crops). Increasing the demand for organic matter estimated 250 million litres of used cooking oil from treated waste to complement manure will per year, of which 61% was turned into biodiesel however require more work on understanding in 2011-201222. In 2011, this made up 89% of all deployment and usage rates, meeting quality biodiesel feedstock for transportation23. expectations and perceptions from end users.

Returning organic matter to the soil An interesting policy tool to support ecosystem services is the Defra Action Plan on Payments for While current GHG mitigating policies are Ecosystem Services (PES)26, which looks at how critical for landfill diversion and for incentivising sustainable management of ecosystem services the energy component of the AD sector, the can be incentivised through direct payments interest in the secondary products by farmers from the beneficiaries of those services or other landowners is not as well known. The (whether public or private). The PES Action Plan relative benefits of those products in producing for example highlights a peatland carbon code to good crops and improving restored land, when drive investment in protecting peat. compared to either inorganic or non-waste alternatives, are less well accepted and have no According to CL:AIRE, a UK not-for-profit direct incentives. organisation, compost and compost like output (CLO) have an important potential role Environment policy on biodiversity and in helping to restore contaminated land by sustainable farming increasingly highlights “improving the soil fertility, increasing the water the important role of organic matter in and nutrient holding capacity, stabilising the providing vital ecosystem services, such as food soil pH, improving soil aeration and enhancing production, water regulation, erosion control, revegetation. In addition to revitalising the soil formation and retention and nutrient soil, they are also believed to immobilise cycling. This arises from the loss of topsoil which, metals thereby breaking contaminant-receptor according to the EA, amounts to 2.2 million pathways and reducing the ecotoxicity of the tonnes per year24. Organic matter is already contaminants”27. heavily utilised in farming through its use of self-generated manure. Again, the EA estimates The Organics Recycling Group (ORG), which that UK farmers use around 90 million tonnes is part of the Renewable Energy Association of manure or slurry, and 1.1 million tonnes of (REA), together with large waste management sewage sludge25 per year. A clear benefit of companies, have developed guidance on digestate compared to manure is the former’s quality standards for CLO and separated organic higher content of readily available nitrogen, materials (SOM)28 that are vitally important which, with good nutrient management by to long term deployment of these secondary the farmers, can be translated into higher crop resources. available nitrogen (i.e. nitrate taken up by the

22 Ecofys (November 2013), Trends in the UCO market, p11 23 LRS (September 2013), The market for biodiesel production from used cooking oils and fats, oils and greases in London, p5 24 Environment Agency, Our corporate strategy 2010-2015, p2 25 DECC and Defra (2011), Anaerobic Digestion Strategy and Action Plan, p12-13 26 Defra (May 2013), Developing the potential for Payments for Ecosystem Services: an Action Plan 27 CL:AIRE (April 2008), CL:AIRE subr:im bulletin, sub 10, p2 28 Organics Recycling Group (July 2013), Separated organic materials (SOMs) land restoration end-use standard, http://www.organics-recycling.org.uk/uploads/ article2633/SOMs%20Land%20Restoration%20End%20 Use%20Standard_Final.pdf

10 CIRCULAR ORGANICS: BIOWASTE IN A CIRCULAR ECONOMY Barriers to a Circular Economy for Biowaste

Moving towards a circular economy for biowaste with an often poor understanding among holds great potential, but also significant compost users of the alternatives, such challenges. The main challenges are listed below. as peat free compost, impairs its wider Their resolution is crucial to taking the next steps, acceptance and use. beyond landfill diversion to producing valuable, green products. 4 A key cost consideration for the landspreading of all biowaste products is Failure to identify the full potential the transportation burden from treatment of biowaste plant to the end user. Clever location and deployment of these resources can ensure Food waste competes with energy crops as optimum distances for transport and avoid feedstock to AD for the production of green the risks of impairing the economic benefits energy, and digestate and compost competes through poor location and expensive with inorganic fertilisers and peat for use deployment. The use and value of biowaste on land and in gardens respectively. products therefore depends to a large As long as the true cost and benefits of making degree on the proximity to, and demand choices between these types of material is from, end users. not understood and are not supported by well informed policies, the UK will fail to unlock the Lack of feedstock security full potential in biowaste. Investment in biotreatment infrastructure is More concretely, the main issues are: secured by the availability of suitable feedstock, i.e. food waste, garden waste etc. In recent years 1 Current incentives for biowaste treatment a large number of AD plants have been built or mainly focus on the production of have received planning permission, increasing renewable energy. At the same time, there the actual and potential treatment capacity. are no significant incentives or commercial At the same time WRAP and commercial recognition for high quality resource organisations have employed significant compost and digestate, for example in resources in minimising waste at source, and terms of nutrient and mineral content. the adoption of new ‘food only’ municipal and This favours AD when compared to IVC or commercial source separated food collections OAW, but also fails to recognise the benefits has only achieved limited growth in feedstock of the products from all the treatment availability. Simultaneously, increasing numbers technologies. of local authorities have adopted an additional charging mechanism for green waste collections, 2 The benefits of returning nutrients and leading in the majority of cases to less green organic matter to soil have not been waste being collected. properly recognised by Defra, as part of their support for ecosystem services, such This disparity, with new infrastructure coming as the Payment for Ecosystem Services. The on quicker than collected volumes, is leading UK therefore risks underestimating the true to local feedstock shortages. If this continues value of compost and digestate in terms of and minimisation campaigns and actions gain nutrient cycling, avoiding soil erosion and traction, there is a high risk that treatment over water retention (a pertinent issue after the capacity will result. It should also be noted that floods of 2013/14). given the cost of transporting compost and digestate, there can still be treatment under 3 The use of peat based compost (growing capacity at a regional level29, whilst having media) is a major source of greenhouse over capacity at a local level. We believe that gases. Its use is also unnecessary in many there are three main factors that need to be cases, given the availability of biowaste considered: derived compost, which can replace most of the peat. The fact that the price of using compost with peat does not always reflect 29 Eunomia (July 2011), Anaerobic Digestion Market Outlook, the full costs to the environment, together p12-14

11 1 Increasing participation in food waste is becoming available, it is currently not collections: According to WRAP about 55% of sufficiently widely available and complete to local authorities and 44% of UK households allow the modelling and analysis that is more participate in food waste collections (of common in municipal waste. Without good which 50% is collected together with data it is difficult to identify factors such green waste). Given the age of the housing as the success of minimisation campaigns. stock in the UK and therefore their design More work is needed to assess the quantity constraints for waste management, separate and quality of feedstock and how that relates food waste collections can be particularly to current and planned capacity. challenging, especially for flats and other high density living accommodation. A study 3 Classifying AD: Finally, there is uncertainty by WRAP in 2011, of 13 local authorities over what is required for Anaerobic Digestion in England and Wales estimated that the to be considered recycling instead of average participation rate for separate food recovery, prompting some local authorities collections for flats was around 30%, with an to send their biowaste to composting average yield of 0.63 kg per household30 a facilities, with reference to the waste week compared to about 5 kg generated31. hierarchy. At the same time, Defra is openly This raises questions not only about how supporting AD as the environmentally best to encourage a greater availability of food option for food waste32. Using digestate from collections but also how to increase the AD for agricultural purposes has proven participation rate, not least in urban areas. environmental benefits that need to be Consideration should be given to the taken into account as a valuable contribution structural housing limitations of existing to land bank maintenance and biowaste buildings and identifying opportunities that recycling. could be obtained through waste collection infrastructure in refurbishments and new builds. Inadequate feedstock quality drivers 2 Data from C&I sources: It is uncommon in Quality assurance schemes such as PAS 100 and the commercial and industrial (C&I) sector 110, together with Quality Protocols (QPs), are for weight and composition data to be valuable tools in providing confidence among collected. The collection of this data, and farmers to use compost and digestate. They its consolidation and analysis, is essential are however less useful in driving quality in the to understanding waste mix and generation feedstock supply chain, an area where more per industrial sector. Although more data work needs to be undertaken.

Image 5: Typical levels of rejects, all AD site classifications and commercial sites, UK 2012 (as % responses in ASORI 2012)

Source: Household Food and Drink Waste in the United Kingdom 2012, WRAP, November 2013, page 57 30 WRAP, http://www.WRAP.org.uk/content/recycling- 32 Defra (June 2011), Guidance on applying the Waste collections-flats-food-waste-collections Hierarchy, p5 https://www.gov.uk/government/uploads/ system/uploads/attachment_data/file/69403/pb13530- 31 WRAP (November 2013), Household Food and Drink waste-hierarchy-guidance.pdf Waste in the United Kingdom 2012, http://www.wrap.org. uk/sites/files/wrap/hhfdw-2012-main.pdf.pdf, p4

12 CIRCULAR ORGANICS: BIOWASTE IN A CIRCULAR ECONOMY Targeting contamination at the point of Increasingly complex and generation of the biowaste far earlier in the onerous policies and regulations supply chain, with monitoring requirements, better feedback to Councils and commercial Regulations play a crucial role in ensuring producers , is essential to drive down that biowaste treatment facilities and their contamination levels. The current system operations and outputs, are managed, designed of reporting recycling levels based on the and operated in a manner appropriate for collections rather than the output masks people, animals, and the environment. However, input quality issues and fails to drive continual increasingly prescriptive requirements by improvement. The challenge of reaching out to the EA and AHVLA to regulate a growing, residents and companies about contamination and increasingly diverse, sector bring more could be addressed by focusing on the avoidable complication and costs, which given recent and non-food related contamination, such cuts to the regulators are a growing burden as plastic bags, rather than the embedded on operators. It is therefore more important contamination such as food wrapping. than ever that regulations and guidance take a coordinated, complementary, risk The success of the PAS 100 / 110 and the and site specific based approach, with good QPs relies on the assumption that the cost of dialogue between regulators and operators. meeting the requirements is compensated for by Unfortunately, unless carefully managed the price of the end product. PAS 100 / 110 and and appropriately resourced this can make the QPs are aimed at limiting emissions while consistency between operations more difficult meeting market demands on the quality of the and puts more pressure on the regulators’ end product, which raises the question of how staff. Furthermore, it adds challenges to avoid these market demands are best understood and conflicting rules regulating emissions, handling whether all benefits listed earlier are reflected of animal by-products, planning and best in the price. According to ADBA, nutrients in available technologies (BATs). In addition, the digestate could be worth over £200 million to UK lack of clarity in terms of frequency and process farming33. for reviewing standards and regulations creates uncertainty for investors. Increased demand for PAS from consumer- facing organisations such as the Soil Association, ESA would like to see a number of points local authorities and retailers (who themselves considered: send food waste to AD) could also help to drive demand. 1 More consistency between how different materials are regulated (i.e. clear, Unclear waste hierarchy for understandable criteria to be assessed biowaste use against) The finite amount of biodegradable feedstock 2 More joined up thinking between different means it is crucial that the output is used in the regulators (EA, SEPA, NRW, NIEA and the best way possible. In order to ensure that high AHVLA) quality biowaste outputs are favoured and used appropriately, ESA calls for a clear waste hierarchy 3 Better enforced regulations for biowaste (See Image 6). This will naturally vary depending on season and weather, but the 33 ADBA (2014), http://adbiogas.co.uk/about-ad/how-ad- default should be clear to help guide both policy benefits-everyone/ makers and the market.

13 Image 6: Biowaste Use Hierarchy

Benefits for environment Explanation

Least impact on Ideal position environment Avoid creating biowaste

Maximum use of the Reuse of food for human resource, minimise Clean and fit to eat hunger consumption

Maximum use of the Uncontaminated, resource and minimise Reuse for animal suitably separated need to grow or consumption and fit for animal manufacture consumption animal feeds

Displace use of Compost or fossil based soil digestate ideally improvers, confidence Recycle to feed the land produced to a in quality products quality standard

Production of Displaces fossil Use to recover energy or energy - preferably chemicals and with land improver energy make chemical products products as well

Correctly managed - Avoids unacceptable preferably with gas emissions and Controlled disposal recovery and energy impacts production

Most impact on Illegal disposal - environment Uncontrolled disposal least ideal position

Source: Environmental Services Association (ESA)

14 CIRCULAR ORGANICS: BIOWASTE IN A CIRCULAR ECONOMY ESA’s position on...

Food waste prevention targets Landfill bans on biodegradable The Circular Economy package published waste by the European Commission in July 2014 The Circular Economy proposals from put forward an aspirational food waste the European Commission proposed reduction target of 30% by 2025 compared that biodegradable waste should not be to a 2017 baseline. ESA strongly supports landfilled by 2025. ESA strongly supports the waste hierarchy, and efforts to reduce and encourages further landfill diversion, waste are rightly at the top. However, but we believe that an outright ban the details and practicalities of a food would raise some important practical waste prevention target are important to issues; would be difficult to enforce and consider, for example how to accurately could promote solutions adverse to the measure the baseline and how to measure biowaste hierarchy. Instead, if the policy success. Using 2017 as a baseline year also and commercial drivers are correctly risks penalising those member states that established, biowaste will be recovered have already made progress on food waste because it is correctly valued and its prevention. benefits are maximised.

Mandatory biowaste collections We believe that the measures outlined in The Commission’s Circular Economy this strategy, together with the landfill tax package would require Member States to and waste targets, are better and less costly ensure separate collection of all biowaste ways of increasing recycling of organics in by 2025. ESA strongly supports separate the supply chain. Coordinated ‘push and food waste collections, but we do not pull’ policies will ultimately achieve better favour making these collections mandatory feedstock security and long term viable everywhere. Extending the requirement solutions for the industry. to all biowaste rather than just food waste would also raise a number of practical questions. ESA believes that there is “no one size fits all” collection system which is best in all circumstances. The design of waste collection schemes is complex and depends on factors such as the demographics, geography, housing stock and proximity to treatment facilities of a given local area. We believe that local authorities working with industry under a clear biowaste hierarchy understanding are best placed to decide what type of biowaste collection service is most suitable for them to achieve an optimum recycling rate of quality material within their budget. Reducing contamination in digestate should help drive separate food waste collections more widely by strengthening the value of the digestate and therefore the economic case for such collections.

15 An Agenda for Action

1 Unlocking the full benefits of Implement a peat levy biowaste As spelled out earlier in this document, a peat levy to divert peat and other fossil based Adopt a biowaste hierarchy additives from compost would have a significant ESA is committed to adopting a biowaste impact on reducing GHG emissions by reducing hierarchy such as presented earlier in this peat use. Using peat for compost, when waste document. ESA calls on Defra, the EA and other derived compost is sufficient, makes little sense, stakeholders to work with ESA and other industry not least with a growing and more quality members to support the development and focused organics sector. Our ‘Beyond Landfill’ adoption of a hierarchy in order to make sure report references RSPB research which suggests that high quality output is used for high quality that a 4p per litre levy on retail bags of peat- applications and the true value of the materials based growing medium would raise £88 million and their outputs are clearly understood and in public revenues. However, a higher levy is appreciated. likely to be needed to allow the investment in the work necessary to promote and establish the Better coordination between policy areas true value of biowaste and its products in the wider environment and market place. There are currently a number of initiatives looking at how to foster thriving ecosystem Set up a commonly adopted life cycle services. However, these initiatives lack a clear assessment (LCA) tool link to the organics recycling sector, which if made would allow a better assessment of how Since the Waste and Resources Assessment compost and digestate can play a bigger role. We Tool for the Environment (WRATE) software is therefore call on Defra to invite the waste and no longer promoted by the EA, there is a lack resource management industry to participate of an up-to-date, common and relevant LCA in activities on ecosystem services, such as the tool. ESA call on Defra and the EA to either Ecosystem Knowledge Network and the Growing develop a new tool, or update WRATE on AD Media Panel. and other treatment methods, as well as taking into account the benefits of product use and fossil source materials offsetting, and the carbon sequestration from applying compost and digestate to land. This would help continually inform an established biowaste hierarchy, and assist local authorities and industry in making better informed decisions on waste management services. ESA and its members are willing to assist in this work.

Encourage local authorities to procure waste derived products Today, there is a lack of joined up thinking within local authorities between waste management and procurement departments. Local authorities could act as a significant end user of biowaste derived compost and digestate in gardens and parks, driving up the demand for such products. ESA calls on local authorities to consider a more circular procurement approach to reduce costs and impact on the environment and better establish end use markets.

16 CIRCULAR ORGANICS: BIOWASTE IN A CIRCULAR ECONOMY 2 Improving feedstock security Clarify the classification of AD AD is classified as recovery, not recycling, in Estimate the success of waste prevention Defra’s Waste Hierarchy Guidance. Given that ESA calls on the Governments, WRAP and AD is seen by Defra as the best use for food Zero Waste Scotland to estimate, as accurately waste, from an environmental point of view, as possible, the expected tonnages saved it would be unfortunate if local authorities through waste prevention and minimisation. did not consider AD on the basis of the waste This will then help guide further investment hierarchy. We therefore urge Defra to clarify in new infrastructure according to needs. via the LGA, NAWDO, LARAC and ADEPT, under Overestimating waste prevention will risk holding which circumstances AD can, and should, be back investment, while underestimating it is classified as recycling, and correctly establish this likely to create over capacity. treatment type within the biowaste hierarchy.

Develop a Code of Practice for monitoring Learn from Scotland and Wales contamination ESA calls on Defra to produce a ‘lessons learned’ Input quality is crucial in order to drive biowaste report by the end of 2016 from initiatives in up the waste hierarchy. We therefore encourage Scotland and Wales, including the mandatory Defra, WRAP, the EA and other key stakeholders, food waste collections for businesses generating to work with ESA to develop a fit for purpose more than 50kg/week, and the target in Wales voluntary Code of Practice (CoP) for monitoring to reduce food waste by 1.5% per year. This will contamination in biowaste. The CoP would report further inform the policy context and decision on input volume, reject volume and the volume making process. of the product, as well as including best practice on quality management. Such an initiative would improve visibility of quality across the industry, give transparent information on contamination to local authorities and industry, and increase confidence in the end product. The CoP could be made mandatory once lessons have been learned, in a similar way to the MRF code of practice. Prior to the CoP, more work needs to be done on estimating the amount of contamination in biowaste.

17 3 Making regulation smarter and control of odours at biowaste processing facilities”, which was developed by the Create a cross sector working group Composting Association in 2007. ESA will also work closely with the EA, and other trade The increasing complexity and diversity of the associations within the same group, to ensure organics recycling industry requires a coherent that the Best Available Technology for the regulatory approach. ESA therefore call on Defra biotreatment sector, as part of the Waste and the EA to relaunch the Biowaste Regulatory treatment BREF revision, properly addresses Forum in a new format. In this new format it public concerns with odours. must have a stronger, results-based focus, and a clear mandate to ensure a practicable approach Promote the EA/ESA Waste Placement to existing regulations and guidance from the EA, Scheme at biotreatment facilities the AHVLA and DCLG. A similar group was formed on regulatory issues with landfill gas, which ESA currently helps place a number of EA worked well. officers, put forward by the EA, at waste treatment sites to improve officers’ technical Update best practice on odour and practical understanding of these facilities. management ESA is committed to making more biotreatment facilities available for such placements for the EA One task for the cross sector working group and other regulators. ESA will encourage the EA mentioned above would be to help the REA to make use of these facilities. update “An Industry guide for the prevention

18 CIRCULAR ORGANICS: BIOWASTE IN A CIRCULAR ECONOMY Appendix 1 - Glossary

AD LGA Anaerobic digestion Local Government Association ADBA MBT Anaerobic Digestion and Biogas Association Mechanical biological treatment ADEPT NAWDO The Association of Directors of Environment, National Association of Waste Disposal Officers Economy, Planning & Transport NEWP AHVLA Natural Environment White Paper Animal Health and Veterinary Laboratories Agency NIEA BAT Northern Ireland Environment Agency Best Available Technology NNFCC Biowaste National Non-Food Crop Centre (The Bioeconomy Biodegradable garden and park waste, food Consultants) at the University of York and kitchen waste from households, restaurants, OAW caterers and retail premises and comparable Open Air Windrow waste from food processing plants ORG BIS The Organics Recycling Group Department for Business, Innovation & Skills Organic waste CLO Waste of animal or plant origin which, for Compost like output recovery purposes, can be decomposed by CfD micro-organisms, other larger soil-borne Contract for Difference organisms or enzymes Contaminated Land: Applications in Real PAS Environments (CL:AIRE) Publicly Available Specification by the British Independent not-for-profit organisation Standards Institution (BSI) C&I PES Commercial and industrial Payments for Ecosystem Services DECC QP Department of Energy and Climate Change Quality Protocol Defra RDF Department for Environment, Food and Rural Affairs Refuse Derived Fuel DfT REA Department for Transport Renewable Energy Association EA RHI Environment Agency Renewable Heat Incentive EfW RO Energy from Waste Renewables Obligation FAO rWFD Food and Agriculture Organization of the United Waste Framework Directive Nations SEPA FiTs Scottish Environment Protection Agency Feed-in Tariffs SOM GHG Separated organic materials Greenhouse gases SRF IVC Solid Recovered Fuel In-Vessel Composting WRAP LARAC Waste & Resources Action Programme Local Authority Recycling Advisory Committee WRATE LCA Waste and Resources Assessment Tool for the Life cycle assessment Environment

19 For more information about this report, please contact: Jakob Rindegren, Recycling Policy Adviser ([email protected]) Toni Waters, Communications Officer ([email protected]) Environmental Services Association This report has kindly been supported by the 154 Buckingham Palace Road, London SW1W 9TR Recycling Registration Service Telephone: 0207 824 8882 Printed on 100% recycled paper Web: www.esauk.org Twitter: ESA: @ESA__tweets / SESA: @SESA_tweets / WESA: @WESA_tweets September 2014