John Newson our lead waste campaigner along with our waste team have responded to Birmingham City Council’s future waste strategy on our behalf:

Objective 1. DISAGREE

Recycle or burn ?

There are two objectives being rolled together in the waste strategy document, and these have to be separated, since they are actually in competition with each other. Reduce, Reuse and Recycle is strongly supported by Birmingham Friends of the Earth as the best approach to waste, environmentally, economically and socially. However recovering energy from municipal waste by burning is to treat it as a “fuel”, although it lacks the characteristics of a fuel and cannot compete with cleaner, cheaper sources of energy. One does not recover the value of something by burning it to ashes, therefore incineration is a form of destruction and a huge leakage from the Circular Economy.

The present refuse collection system was designed to feed the incinerator at Tyseley in fulfilment of a 25 year contract with Veolia – if BCC continues to burn waste then you will be continuing the existing collection system that delivers 70% for disposal. If BCC wants to change to a much higher rate of recycling then that will require a redesign of the collection system aimed at minimising/phasing out the collection of mixed refuse which would in turn remove the fuel for the incinerator. “Collect to burn” and “collect to recycle” are not complementary approaches as suggested in objective 1, but would be in direct competition with each other.

The components of mixed refuse that actually burn are paper, card, wood, plastics, textiles, food and garden waste. If they are diverted to recycling by a well-designed Recycling Plan, then it will be the combustibles that are removed – and at some point the residual waste will not burn. Already oil or gas has to be injected to get to combustion, so municipal refuse only marginally a source of energy.

Continued mass burning of rubbish would require the failure of the recycling policy, or its postponement into the far future, which is not necessary. Change is long overdue since Birmingham is 330th in the recycling league of local authorities and remains in the lowest 10% in England. BFOE objected to the 1994 incinerator contract with Veolia, saying it would compete with and prevent the recycling of waste – and this has proved to be the outcome.

A choice has to be made. If BCC wants to change its message to households, from “throw everything in the bin and we shall dispose of it” to “please help to divert as much as possible into recycling because we cannot afford the disposal route any longer” then the decision should be made and communicated. People cannot respond to contradictory messages. The Future Waste Survey 2016 has already shown that they expect waste to be recycled.

Therefore objective 1 should be changed to We want Birmingham to reduce the amount of waste that is created, reusing and recycling what we can, so as to minimise both incineration and landfill.”

Objective 2. AGREE

Recycling Target

To recycle 70% of waste would be a dramatic improvement, which we would very much like to see actually achieved. Zero Waste is the direction of travel that the strategy should embrace, everything to have a secondary use. To get to 70% recycling would require a completely different system than the one that delivers 27% at present. The question is why wait until 2030 ? A different collection system would produce an immediate result. Birmingham has the lowest recycling rate 27% of any West Midlands authority, while Stratford on Avon is already at 60% and the highest achieving authority in England at 67% recycling. We want to see the Recycling Plan that will deliver a high recycling rate in Birmingham, with milestones and changes to deliver them.

Almost every waste has some use and some value, until it is mixed and contaminated when it becomes useless refuse. The basis for the system should be keeping wastes separate, so minimising what remains in the black bin. This is likely to involve repurposing the existing wheelie bins to get a better separation.

The proportion of food waste in the waste burned at Tyseley is 40% by weight. It smells because it is already beginning to rot when collected. BCC already collects food waste from every address in the city on a weekly basis, but it is mixed with the other black bin contents. Instead is element could be diverted by a separated collection from households. many authorities, such as Sandwell, collect the food waste in a separate container on the same vehicle that takes the mixed refuse, or the recycling. Increased separation does not have to mean more collection runs, vehicles or crew. Many of BCC’s vehicles are hired, so changing vehicles could be straightforward.

Food waste can be taken to an anaerobic digester or in-vessel composting plant whose gate fees are typically lower than incineration, because they simpler to maintain and operate, while producing useful products, such as gas, fertiliser or compost which can be sold. Even if BCC becomes the owner of the Tyseley plant in 2019 there will be gate fees to cover the cost of operation.

The remainder of the waste, having taken out the food waste, would be clean and dry and much easier to recycle. Our analysis of the highest performing local authorities show that separated food waste collection is strongly associated with their high recycling rate, because the principal contaminant has been removed.

Many households in Birmingham who compost food waste in a garden composter already find they have few items left as “residual” and these being clean do not need frequent collection. Modern mechanical sorting techniques at a Materials Recovery Facility have the potential to extract recyclables from mixed dry waste, leaving very little that cannot be used. The highest recycling authority is currently South Oxfordshire and they say 80% of that residual waste consists of recyclable material, which would leave only 10% as completely useless. This would suggest that a recycling rate well above 70% is obtainable by 2030 and we want to see some defined milestones and a plan to achieve them.

An alternative approach, popular in Wales, is manual kerbside sorting by the crew which delivers back to the depot material that can be directly sold for recycling. Newport is an example which says that it “costs less, creates more jobs and it better for the environment” than sorting mechanically. Some Welsh authorities are currently as high as 65% recycling rate, compared to Birmingham’s 27%.

Moving from “collect to burn” to “collect to sell” would improve the economics of the whole system, allowing incentives to be offered to householders to co-operate. BCC has trialled this some years ago and it was very effective. The incentive should be what will appeal to low income households, since they tend to lag the more affluent areas, for example, mobile phone credits, nectar points, bus tickets.

The Future Waste Strategy Survey in late 2015 showed Birmingham people do support incentives to recycle, and that public attitude is not a barrier to greater recycling, and in fact it is what residents and stakeholders said they expect. BFOE was easily able to collect 1400 signatures face-to-face from residents on a petition supporting food waste collection and increased recycling. Any plan to change the collection system will have to be clearly communicated to householders, learning the lessons of the wheelie bin roll out. Everyone should be clear about what is being asked of them and why. A new system has to be tailored to different housing types and household sizes around the city. There may be a system for the suburbs and a different one for the inner city and high rise blocks – examples exist in other authorities.

Objective 3. Waste Reduction DISAGREE

BFOE understands that Birmingham’s municipal waste tonnage has been falling by 2% a year, so a reduction of 10% by 2020 is likely to happen anyway. The council’s past waste strategies have been wrong in projecting an increased tonnage of waste. Society is becoming more resource efficient and less wasteful, with the internet having a big effect on paper use. We should question whether the recent population growth in Birmingham will continue, as the factors behind it are unlikely to be repeated, the expansion of higher education, EU migration, and a surge in the birth rate.

There should be a Waste Reduction Plan, whose basis would be that most waste has little or no value and is a cost to the council, so some spending on preventing waste can be justified. Organic waste can be prevented by home composting of food waste, garden waste etc. Community composting of garden waste can happen at suitable sites and we urge the council to identify the sites. Advice about this should be on a Recycling Birmingham website. Many items are surplus to the owner but usable to others so a Re-use Plan is wanted, learning from the success of The Re-Users at the Sutton Coldfield waste site. The website can show people how to swap, donate or sell items, with charities being involved in a city-wide system of recovery. That bulky waste items put out for the council are incinerated is scandalous when many low income families would like to buy such items, they are mostly furniture and electrical goods; a trial by CSV Environment some years ago found that 60% were usable and saleable.

Objective 4. Landfill DISAGREE

We do not see the alternatives as being landfill or incineration, when such a high proportion of waste can be composted or recycled, so should not be “residual”.

Eliminating landfill of waste is probably not possible, nor desirable. It is only biologically active waste that generates methane, a greenhouse gas, so ending that practice should be an objective, but not ending all landfill. Mixed waste can be bio-stabilised prior to landfill. Inert rock, glass, soil, rubble etc. carry a very low rate of tax, currently £2.60/tonne (General Guide to landfill tax’ HMRC). Plastic that is landfilled has its carbon kept out of the atmosphere. It may be recovered and used at a later date, what is called landfill mining.

Composting is Nature’s way of fixing carbon out of the air and building up soil fertility, therefore returning bio-wastes to the land should be an objective. Burning bio-waste is cutting the cycle of fertility, and in effect burning our future soil and food supply. We call on BCC to make composting or digesting all biological waste an objective for the waste strategy. This can be done in simple outdoor composting rows or boxes, but accelerated hot composting is used by many local authorities, which is called In Vessel Composting. Companies would be very interested in building such facilities if BCC can guarantee them a supply of bio-waste from households, public buildings, catering, park and gardens.

Anaerobic digestion is a route to recover methane from breakdown, keeping it out of the air and using as a fuel e.g. to generate electricity and waste heat. Smaller scale AD plants are available and sites for them need to be identified. Severn Trent has one at Curdworth, east of Birmingham, which can accept local authority food waste. Other useful products of AD are liquid fertiliser and waste heat. We have proposed using biogas to run buses, as happens in Bristol and Barcelona.

Such plants would well co-locate with urban food growing projects, such as the Salad City project. Connecting waste treatment to building up soil and growing food should be an objective of the waste strategy.

Objective 5. Carbon Reduction STRONGLY AGREE

BCC should identify ways that collecting waste should contribute to carbon reduction. This would include cutting the mileage covered by vehicles, both council vehicles and private cars taking waste to the council’s sites. The end of the incinerator contract is an opportunity to deal with wastes on a more localised basis and reduce movement of waste as much as possible. There are many companies within the city that buy separated waste and the council should be selling to them where possible, for example the paper mill at Nechells, but also metal and plastic recyclers.

The Strategy should have an objective for reducing carbon emissions from waste disposal. The largest single emitter of carbon dioxide in Birmingham is the Tyseley incinerator, which emitted 322,958 tonnes to the air in 2013, as reported by its owner to the Environment Agency. The impact of it starting up is like thousands of extra cars taking to the roads. To achieve its carbon reduction target Birmingham has a big problem controlling vehicle emissions, so running down and closing the incinerator which becomes the property of BCC in 2019 could be a huge opportunity for carbon reduction. We do not see how BCC’s stated aim to reduce carbon dioxide emissions on of 60% by 2026 can be achieved while burning the city’s refuse – or that of other cities.

The incinerator is of low efficiency compared to a power station, so only around 20% of the energy value is converted to electricity by our calculation, with 80% of the heat going into the air. This is the reality of “energy recovery”. Perhaps a quarter of the electricity produced will be used in running the plant, with more lost in transmitting it to consumers. The claim of Veolia that it supplies power to 41,000 Birmingham homes (1 in 10) seems very doubtful and needs to be carefully checkeded. The idea of capturing the waste heat and piping to where there is a demand runs up against facts such as that the incinerator cannot run all the time, and that buildings do not need heating in summer months.

The municipal waste at Tyseley comprises 65% biodegradable material, which is damp and of low calorific value, other fractions are incombustible, so around half of the heat at Tyseley comes just from burning plastic, made from oil, i.e. fossil fuel source, according to calculations done for BFOE. If organic waste is diverted in the future to composting or AD, and paper to recycling, then the plastic component, and hence the fossil carbon intensity, will increase further.

Electricity from Tyseley displaces electricity in the grid which is made from a mix of coal, gas, nuclear and renewables. Taking all these factors into account, our calculations suggest that the Tyseley plant produces as much fossil carbon as would a coal-fired power station and it is therefore making Birmingham’s electricity supply dirtier, not cleaner. It should not be called renewable, sustainable nor “green” electricity.

Most of the waste being burned there ought to be composted or recycled, so it should not be residual to those processes; therefore we do not accept that landfilling it is the alternative, and comparisons with methane gas released in landfills are not appropriate. A thorough analysis of the plant’s carbon footprint is required before any decisions are taken about its future.

Tyseley is in central Birmingham, where there are the highest air pollution levels, worst health statistics and highest social deprivation scores, so it is a social equity problem. Burning at Tyseley produces a cocktail of chemicals that are measured in the smokestack and reported to the Environment Agency. These include nitrogen oxides, hydrogen chloride and hydrogen fluoride, all of which are acidic and known irritants, mixed with fine particulates that can affect the lungs. The chemical reactions in the burner will produce further chemicals such as dioxins and it also releases metals such as lead, mercury, cadmium etc as reported to the Environment Agency, which are toxins. The levels averaged across a year may seem small, but this conceals pollution spikes when the plant starts up. It is not possible to prove that a raised incidence of lung disease is attributable to the Tyseley plant, but its emissions are adding to air pollution levels in inner Birmingham and these already exceed the EU safe levels. There are certainly costs to the Health Service from the rate of lung disease in Birmingham, and the Precautionary Principle should be used i.e to remove sources of air pollution wherever possible. As well as the risk to residents, the health of people working in the plant ought to be considered.

We do not believe that the plant is compatible with Birmingham’s aspiration to be a Clean Air City. BCC has responsibility for Public Health and we believe that any plans to continue mass incineration should be subject to a public health appraisal.

BFOE opposes any suggestion of bringing in rubbish on a large scale from outside the city to continue to burn and pollute the air. It would be a strange role for our local authority, which should be protecting the interests of citizens and spending its money on vital services.

The partnership with Veolia and their monopoly on the city’s waste end in 2018. The Council should ensure that no-one with a financial interest in particular waste solutions post 2018 has an undue influence on BCC’s Future Waste Strategy.

Objective 6. Priority to recycling AGREE

Changes to the composition of waste should be modelled in advance to show the effects of the strategy and the plans that will implement it.

Waste reduction would reduce the tonnage for disposal, as would separation of food waste, and the increased reuse and recycling. Some local authorities are already close to 30% for residual waste (Birmingham being 70%). If we include garden waste then most waste is compostable, and most of the remainder is recyclable. As compostable and recyclable elements are removed, the residue will be less and less combustible, and these trends can be predicted.

Value is destroyed every day by Birmingham’s low recycling performance. Nothing is improved by combustion. The items and materials burned have to be remanufacturing, wasting most of the energy embodied in them, so Energy Recovery should more accurately be called Energy Loss. This has a fincial cost, so our estimate of the value of the materials burned at Tyseley, taking the price of the lowest grade of waste paper, plastic, aluminium, textiles etc for recycling is £5 million a year.

The incinerator is not a cheap option. After 2018 the cost of repairing and maintaining a plant already 25 years old will fall on the new owner. Oil or gas must be bought in to make it burn. The ash has to be treated at a specialised plant, while toxic fly ash has to be disposed of. Above all, the need to feed the plant with rubbish keeps Birmingham’s Fleet and Waste teams collecting black bags every week from every address, when many authorities have already moved to fortnightly collection with consequent financial savings. The electricity generated by this process must be expensive and subsidised by the council taxpayers. We do not recommend this as part of the supply for a Birmingham Energy Company (subject of a recent consultation), since it would never be able to compete with modern power stations, but make the supply more costly and hence do nothing to encourage switching and “address fuel poverty” as is being claimed. District heating via heat pipes does work in the city centre, but Tyseley is the wrong location and uses the wrong “fuel” to supply waste heat to buildings.

Recycling, by contrast, generates financial receipts. All paper and card taken to the paper mill in Nechells is paid for and this covers the cost of collection, we understand. Aluminium alone is worth hundreds of pounds a tonne, making bins potentially “urban mines”. Organic waste delivered to AD plants typically incurs lower gate fees than at incinerators, so Wolverhampton Council takes separated food waste from households to an AD plant because it is the cheaper option. Many local authorities are finding that they can actually be paid for delivering even mixed dry recyclables to a Materials Recovery Facility, since these are getting more effective at recovering a wider variety of waste products which can be sold for recycling.

A higher rate of recycling would feed the local recycling sector, retaining value and sustaining jobs. It should be an objective of the Strategy to retain the economic benefits and to give local firms full opportunity to compete in using municipal waste, avoiding any single contract with a multi-national waste company. Social enterprises and charities should be involved in recovering value from the waste.

Objective 7. Appropriate technologies AGREE

Incineration of waste is a 100-year-old answer to Birmingham’s waste problem. The Tyseley plant was designed in the 1980s, but many options have been developed by the waste industry in the intervening decades. Because it is the largest authority in the country, Birmingham has a lot of power to demand and get the response and the investment that it wants from the waste industry, with competition to obtain best value succeeding Veolia’s monopoly. We support the idea of testing waste solutions on the market to see what offers are obtainable.

Most waste is bio-waste and anaerobic digesters are becoming smaller, cheaper and can fit on a variety of urban sites. We recommend a distributed pattern. Technology to sort materials has advanced greatly, hence even residual waste itself might be sorted using the latest “dirty MRF” and “wet MRF” equipment to give a very low residual rate. Hard plastics except plastic bottles cannot generally be recycled, but there are new processes for converting any plastic to oil, in use in Ireland and currently being trialled by Swindon Council.

It is essential not to sign contracts that foreclose these options or fix the waste stream or collection system around the assumption that waste will be incinerated in the future.

Objective 8. Separated collection of waste STRONGLY AGREE

BFOE believes strongly in the separate collection of food waste from households and businesses because the waste removes contamination, leaving dry items that can be recycled. This approach was supported by the 1400 people who signed our petition.

Our analysis of local authorities shows that all those with high recycling rates have separate food waste collection, for that reason. It is normal for example in Wales where all households have this service, so we do not accept that there would be significant public opposition or resistance if a scheme was properly explained and communicated. Food waste creates smell and health issues and requires a weekly collection, whereas dry items can be stored. People who compost food waste in the garden bin already find that they have very little residual waste, so the same principle can be applied to the whole city.

It is true that when people see their food waste in a receptacle they often buy and waste less, but there will always be inedible waste; peelings, tea bags etc. The aim is not to collect per se, but to remove the contamination, so prevention would be a good outcome. Similarly when people see dry clean items in the bag, then they may realise they should be in the recycling bin.

Neighbouring areas, such as Sandwell and Wolverhampton, use separate food containers which are fixed to the waste wagon, so no additional collection rounds are required. Other areas ask people to put their food waste into their garden waste bin, and this is all taken to an In Vessel Composter for treatment. Both methods could work in Birmingham. Lessons can be learned from neighbouring authorities about what system works best, for what housing types.

Having removed the food waste, many authorities accept a wider range of items in the recycling box than Birmingham; for example, drinks cartons, clothing and textiles, electrical goods, shoes. These may even justify some manual picking.

Nappies and other hygiene products are an element in household waste that may require separate treatment, there being already a specialised clinical waste incinerator at Tyseley.

Birmingham should plan for a steep reduction and phasing out of residual waste, down from the present hundreds of thousands of tonnes. Because it has a limited number of components this may be not as challenging as many people suppose; household waste is predominantly food and packaging, as is that in litter bins.

Any new collection system must be convenient to householders, easy to understand and well explained, preferably with an incentive to co-operate. We want to see an end to blaming citizens for their poorly-designed waste system.