Progress Towards Addressing the Ban
In order to understand the progress being made by local authorities towards addressing the ban, the Scottish Environment Protection Agency (SEPA) surveyed all Scottish local authorities in December 2017. Scottish waste managers also collated detailed information on each council's readiness, including current waste collection/processing/contractual arrangements, tonnage, forward plans for EfW processing and anticipated capacity gaps for possessing household waste in line with the ban. Interviews undertaken by Eunomia in September 2018 with Scottish local authorities and waste management operators provided further updates and clarification on top of the survey results, and also yielded information regarding the progress being made by the private sector to adapt to the ban.
Based on the surveys and interviews, local authorities were classified according to their 'state of readiness' into one of four categories.
- Rank 1: Policy Compliant – 14 authorities have, or will have, a policy compliant solution in place prior to the ban coming into effect. This equates to 744k tonnes (55.5%) of household residual waste landfilled based on 2017/18 waste flows.
- Rank 2: Secure Post Ban Solution, Uncertain Interim Solution – 3 authorities have procured a policy compliant long-term solution that won't be ready in time for the ban. However, no secure interim solution is in place. This equates to 99k tonnes (7.6%) of 2017/18 household residual waste.
- Rank 3: Uncertain Post Ban Solution, Secure Interim Solution – 6 authorities have short to medium term solutions in place but have an uncertain long-term solution or are currently in the early stages of procuring their solution. This equates to 177k tonnes (13.3%) of 2017/18 household residual waste.
- Rank 4: No solution – 9 authorities don't currently have policy compliant solutions in place, and are not yet procuring a solution. This equates to 315k tonnes (23.6%) of 2017/18 household residual waste.
The surveys indicate that, while slightly more than half of Scotland's household residual waste has a policy-compliant solution in place, there are risks for many authorities. This may result in some authorities facing difficulties in finding compliant solutions, or being exposed to higher costs.
The commercial and industrial waste collection market in Scotland is primarily served by a handful of large collection contractors, namely Biffa, Viridor and William Tracey. There are numerous smaller local enterprises operating at a regional level, with local authorities also participating in the market – non-household waste collected by councils is excluded from the local authority household waste figures listed above.
Interviews held with five commercial waste contractors in September 2018 suggest that few have developed specific plans to prepare for the ban. Where strategies are in development, they are primarily focussed on transporting waste, either to landfill or treatment infrastructure in Northern England or into thermal treatment capacity abroad. In areas of Scotland where this is likely to necessitate significant additional haulage, it can be expected to push up the overall cost of managing commercial and industrial residual waste.
A number of companies raised concerns about limited capacity south of the border to cope with additional waste from Scotland. Landfill capacity may well decline in the years prior to the implementation of the policy, as some sites may close earlier than expected as demand for landfill in England falls. The risks are likely to be greatest for smaller contractors that are not vertically integrated through collection, transfer and /or treatment and disposal services, as they may find it particularly hard to access capacity outside Scotland.
Some companies were concerned that the ban could result in some parts of the sector engaging in fraud. One possibility was that waste might be erroneously re-categorised from banned to non-banned EWCs as material passes through transfer station and pre-treatment infrastructure, so as to evade the ban.