Waste Management & Research (1985) 3, 28 9-302
WASTE MANAGEMENT IN NORTHERN EUROPE* Robert A. Arnottt (Received 28 January 1985)
Hazardous and municipal waste management in the F .R .G ., France, the U .K . and Denmark are reviewed from the point of view of U .S . practices . There are no significant differences in technology, but the continental system for total waste management as a public utility is novel . The need to minimize illegal dumpings, which, in the first instance, is always less expensive than high technology treatment and disposal, conflicts with the "polluter pays" principle . The latter is recognized as a public relations tool, but government subsidies are used extensively to retain a high fraction of the total wastes within the system . Key Words-Municipal waste, hazardous waste, incineration, landfills, F .R .G ., France, U .K ., Denmark .
1 . Overview of selected European waste management practices European waste management practices are as diverse as those in the U .S .A . and employ various levels of technology from direct landfilling of many industrial waste to the incineration of all available waste, even those which might be directly landfilled . The approach is highly variable from country to country and within certain countries, such as the F .R .G ., where there is a strong state (Länder) role in waste management regulation . The principal goal of this study was to undertake a country-by-country review of the prevailing waste practices emphasizing economic and other incentives for the development of more sophisticated management techniques, programs and disposal options . European Community and OECD roles in waste management were also reviewed . 1 .1 . France
Waste management practices in France are based on a centralized government system and two principal laws . Law number 76,663 of 19 July 1976 classifies establishments which must comply with regulations to protect the environment and covers the production and disposal of wastes . This law basically is tantamount to a construction permitting law by determining that certain establishments must have prior authorization before commencing operations . A second and perhaps more important law is Law number 75,633 of 15 July 1975 on disposal of wastes and recovery of material . This law covers all types of wastes and related activities such as collection, transportation, storage, processing and disposal . This law also obligates communities to provide for waste collection from domestic sources and smaller industries within their jurisdictions . Present waste disposal practices in France centre on the elimination of materials from * Based on a report "Non-Regulatory Aspects of European Waste Management" sponsored by the German Marshall Fund . t Colorado Department of Health, 4210 East 11th Ave ., Denver, Colorado 80220, U .S .A . 0734-242X/85/040289+ 14 $03 .00/0
© 1985 ISWA
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the waste stream through three principal processes : incineration, controlled landfilling or reuse . Present concerns in France centre on the provision of adequate facilities throughout the country for the disposal of hazardous wastes . Class I landfills, designed for industrial waste, currently number only 14 in France . While high technology systems are available for utilization in France, the regulations do not force all waste materials through treatment centres for treatment and disposal . Treatment centres are thus operating at a disadvantage because "polluters" are not willing to pay the necessary treatment costs and are not forced into the system as they are in certain Länder in Germany and in Denmark . The ministry of the environment develops and implements the waste policies in conjunction with other governmental agencies . Inasmuch as France has a centralized regulatory system, the state level ministry is extremely important in the development of waste management practices . Two agencies other than the environmental ministry, assume very important roles in the development of waste practices in France . These agencies are ANRED (Agence Nationale pour la Recuperation et ]'Elimination des Déchéts- the National Agency for Waste Recovery and Disposal) and the Agences Financieres de Bassin (Financial Agencies for River Basins) . ANRED is the agency most directly involved in waste management through the development of incentives in France . In this study of European waste management incentives, ANRED is a key agency since its mission is clearly to support the development and implementation of waste treatment recovery and disposal . This unique agency's charter includes the requirement to save energy and raw materials as well as to protect the environment . The French feel the agency has a direct role in the protection of the economic future of France as well as its environment . The principal activities of ANRED in recent years have been in the wood, paper and glass . agricultural, metal recovery and economic control areas . While this agency's budget is not large compared to the overall problem, its primary thrust is selecting activities to support which would impact the basic economy . One excellent example is the paper industry . Great emphasis has been placed on recovery of paper products for re-use as a way to reduce importation of raw pulp from the Scandanavian countries . Economic incentives through ANRED work two ways . Direct grants may be made to local authorities, farmers or small industries to provide sufficient incentives for the development and employment of newer technology with emphasis upon recovery and reuse of materials . The other fundamental approach of AN RED is low cost loans to facilities with loan pay back provisions dependent upon the success of the venture . Through this approach ANRED can be a contributor to very large investment programs . Some of these loan programs have had significant payback in the implementation of technology and in the recovery of the direct loan support . Another fundamental ANRED role which supports the development of hazardous waste innovation in France is acting as intermediary in projects by aiding in the local permitting process and by providing contacts with industries where mutually desirable results appear achievable . In this sense AN RED acts as a technical consultant for projects . A great deal can be learned in the U .S .A . from ANRED . It is a classic example of an agency whose organizational existence is to support the use of proper waste disposal technologies both through technical consultative support and through direct involvement in financing projects . At the same time ANRED serves a fundamental mission for the French economy by selecting to support those projects in which a national economic interest is present . The Basin authorities in France are also important waste management agencies . There are six such basins responsible for water management and pollution control . The Basin authorities generate significant income through the assessment of fees for drinking water
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and fees for water pollution discharges . The funds are then redistributed to finance pollution control within the basin . Waste management technologies are also supported . The Basin agencies provide direct financial support to ANRED for its waste mission, principally for innovative industrial waste stream management . They provide France a second entity involved in economic incentives for better waste management and also illustrates a successful multi-media approach to the development and implementation of waste management technologies . France clearly recognizes the interrelationship between water pollution and waste management through this approach . 1 .2 . United Kingdom Waste management practices in the U .K . are unique among the countries studied as a part of this internship . The central government has some authorities, principally under Part 1 of the Control of Pollution Act 1974, dealing with safe disposal of hazardous waste . The Central Government's role, however, is principally one of technical assistance and the development of guideline documents detailing good waste management practices . These guidance documents are simply that-guidance documents . They are not regulations or law . Principal regulatory control of waste management in the U .K . is a waste authority at the local level . This approach to waste management certainly decentralizes the regulatory aspects and gives all meaningful control to local government . Input from the public on waste management decisions is thus much more easily obtained . On the other hand, a very definite negative is the necessity for each local government and regulatory agency to maintain expertise to deal with all aspects of waste management . This resource question is very important in the U .K . where waste authorities generally have very limited resources and operate under serious constraints . The recent implementation of a Hazardous Wastes Inspectorate should markedly enhance the technical expertise available to the local authorities . Although this group, which is a part of the Department of the Environment, is non-statutory and without enforcement powers, one of its main missions is to provide advise to waste disposal authorites . Local authorities appear not to be "technology forcing" in nature and only the U .K . of the European countries visited, has clearly acknowledged co-disposal as an important waste management approach . This practice involves co-disposing of liquid industrial waste solutions with domestic solid waste . Proponents feel domestic solid waste will minimize or, better yet, eliminate any negative environmental impacts which the industrial liquids might produce because of their direct disposal . Co-disposal is widespread in the U .K . and is institutionally supported by the Department of the Environment and Harwell Laboratory, a very prestigious British institution whose principal historic function has been nuclear development . Harwell has a team whose sole activity is waste management technologies . The group actively advocates codisposal as a waste management practice and provides technical support for existing landfills, developing custom waste disposal situations based on precipitation chemistry . Other Harwell activities are modelling approaches to waste management systems, a very active literature abstracting service and emergency response to waste management problems . The modelling involves developing an economic assessment of the viable level of operation of a facility, such as an incinerator, before its construction . Harwell's technical support role is an example of the British approach to incentives in waste management . The government in the U .K . provides no economic or other incentive programs directed to waste management . Technical support by such entities as Harwell are the only viable governmental approach to waste management incentives .
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Although co-disposal is subject to ever increasing controls and greater research efforts . i t will be very interesting to follow this practice in the U .K . over the longer term . The U .S .A . does not allow this practice because of past difficulties with co-disposal sites . In Colorado co-disposal was actively practiced in the past at the Lowry Landfill . Because of real concerns about relying on soil chemistry as a treatment technique for industrial liquid wastes, the British "experiment" is important . Along with the local waste authorities approval and regulatory process, statutes in the U .K . require the regional water authorities to review and comment on waste management proposals . These authorities are the principal groundwater and surface water regulatory bodies in the U .K . They do, however, maintain a level of expertise on waste management issues . The water authorities alone, with their statutory obligation, have the right to appeal directly to the Secretary of the Environment if they cannot agree with or effect a compromise on the proposed license as developed by the waste authority . In general, the working relationships between these agencies is such that this appeal process has rarely if ever been utilized . The local waste authorities are also required to survey the waste needs of the community and to develop a 10-year minimum plan . The level of resources available to the local waste authorities, however, has resulted in the completion of few plans to date . Recent efforts to complete these plans should result in a greater number of plans available in the future . Given the decentralized approach to waste management, the lack of a strong resource base in the Department of Environment and the philosophy of the government towards economic and other incentives, it is very difficult to envision active encouragement of new waste disposal techniques in the commercial sector in the U .K . The incentives concept as practiced elsewhere in Europe is essentially non-existent in the U .K . In spite of this lack of incentives, the private sector has developed alternative technologies, including incinerators, for use in Britain on a limited scale . The U .K . waste management system places all effective decision making at the local level with the mandate to provide for necessary domestic waste disposal sites . The system provides no meaningful incentives within the common definition of that term : however, technical support is provided by the Department of Environment and also through Harwell Laboratories . The U .K .'s heavy reliance on co-disposal appears to deter the development and implementation of more sophisticated treatment techniques and will result in potential future environmental groundwater contamination problems . This is analogous to the practice of landfilling in the U .S .A . and elsewhere where groundwater contamination has occurred in spite of so-called "state-of-the-art" facilities . It is the "lowest common denominator" solution in terms of present cost . Despite these aspects of co-disposal, significant modifications in the co-disposal process have occurred over the past few years in response to previously determined inadequacies and at least one fatality . Co-disposal of many materials is now prohibited and other co-disposed materials are, in theory, strongly regulated to insure the appropriate chemical reaction quantities . 1 .3 . Denmark
Waste management in Denmark is accomplished principally through a national system . a unique approach in Europe but understandable considering the size and population of Denmark . Denmark has approximately 44,000 square kilometers and a population of 5 .1 million . It is roughly twice the size of the State of Massachusetts . This system focuses on the treatment of wastes at the Kommunekemi facility located at Nyborg in
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central Denmark . Kommunekemi, a corporation founded in 1971, is owned by the Danish municipalities . This ownership is appropriate, as municipalities have an obligation under Danish law to deal with waste generated within their geographic jurisdictions . The adequacy of this collection, treatment and disposal system is perhaps best understood when one understand that the objective of the Kommunekemi approach is to eliminate oil and chemical waste from throughout Denmark and to recycle products and materials where appropriate . In Denmark, as in other European counties, domestic waste is separated by legal definition from special waste . Special waste includes most materials which the U .S .A . considers hazardous waste . Municipalities in a country the size of Denmark could not reasonably meet their obligation without a common effort . The central treatment facility at Nyborg contains two incinerators as well as oil recovery and inorganic waste treatment systems . All wastes collected in Denmark are brought to this central location for appropriate processing . The residues from the waste treatment operations are deposited in a landfill approximately 15 miles from the central processing facility . This landfill has a limestone alkaline layer which, according to Kommunekemi's officials, acts as a efficient filter and barrier for heavy metal hydroxides . This landfill would not meet present U .S .A . standards . Oils which are processed at Kommunekemi are processed and upgraded to fuel oil quality and returned to the market place . Denmark has approximately 275 municipalities . The collection portion of their combined waste system, Kommunekemi, is most impressive, but the technology used at its central treatment facility cannot now be considered pioneering or state-of-the-art . Individual households can take hazardous materials to collection stations located in each municipality . At the stations the small hazardous waste quantities from all sources are combined and manifests completed . Manifests and the wastes are then transported to one of the 25 central transfer stations in Denmark . Industries and farms with larger quantities of special waste materials manifest and transport their wastes directly to these central transfer stations . At the stations common waste loads are combined and transported to Kommunenkemi for treatment . The attractiveness of the Danish system is this collection network where all waste from the smallest to the largest generator is collected and transported by the system operators to the treatment facility . The Danish waste system is most impressive due to its collection and management approach . The Danes have made a major commitment to waste management by providing upfront capitalization and a captive law requiring waste generated in Denmark to be brought to the central treatment facility unless granted generator treatment exemption . The vast majority of wastes are treated at the Kommunenkemi complex . This waste management concept is nowhere in Europe more throughly developed than in Denmark . The size of the country and the waste stream of approximately 63,000 tonnes per year (1980) make Kommunenkemi a reasonable prototype for an integrated total waste management system . Chemcontrol A/S, the technical arm of the Kommunenkemi system is also unique since the Danish government exports the agency's technology and management system throughout the world . This is a unique public/private organization whereby government employees are allowed to consult on private projects outside of Denmark with cost reimbursement to the government . The incineration and treatment facilities at Nyborg meet current reasonable standards but they cannot be considered state-of-the-art . Certain of these facilities have been operating approximately 10 years and were truely innovative when initially implemented . The Danish system, like many of the other high tech European systems, has rather high user charges compared to present American standards where landfilling is still a principal
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waste management approach . The Danish system is based on recovering all operating costs through charges to the waste generators . Treatment fees are greater than one thousand dollars per metric tonne for certain types of waste . In spite of these charges, the Danish system, like many other high technology systems in Europe does not receive sufficient revenues for capital financing and replacement of present waste treatment equipment, which may cause difficulties in future years . 1 .4 . West Germane
West Germany employs a federal approach in which basic guidelines and principles for legislatively achieving waste management goals are promulgated at the federal level . Federal waste management statutes in West Germany are passed by the legislature or Bundestag and the major central government role is implemented by the Ministry of Interior . A fundamental tenant of the West German approach is that the federal legislative directives are to be implemented at the Länder level, the German equivalent of American States . West German legislative approaches are flexible enough to allow individual Länder to employ differing approaches to achieve the waste management goals . The compentancy of the various Länder is assumed . This approach is most refreshing compared to the rigorous delegation requirements in U .S . Federal/State program relationships . West German legislation is very comprehensive and requires local authorities to provide for adequate waste management facilities for the treatment of waste streams generated within their geographic jurisdictions . Additionally, the West German legislation requires adequate planning for future waste management needs through the development of long range waste site plans . As comprehensive as these statutes are, achieving compliance with these requirements is difficult . Many of the Länder have not completed their long range plans despite adequate lead times provided in federal legislation . This is somewhat understandable, considering the difficulty of anticipating future waste streams and volumes, the dramatic changes presently occurring and the difficulty of public acceptance of a statewide plan which specifies the location of future landfill disposal sites . The Länder have met their obligation under federal law in differing ways . Certain Länder such as Hesse and Bavaria manage hazardous waste primarily through a corporation with significant state financial and operational involvement and support . In other Länder, such as Nordrhein-Westfalen, there are presently no state-operated or controlled commercial waste disposal sites . Waste generated by small firms or firms without self treatment and disposal must be taken to privately owned treatment and disposal sites, generally through governmental intervention . Two Länder within the F .R .G . deserve special mention . Hesse and Bavaria operate public/private corporations which are required to treat wastes originating within the Land . In Hesse, HIM (Hessische Industriemull, GMBH) operates incineration and treatment facilities at Biebesheim and has recently completed a new landfill disposal site at Mainflingen . HIM's activities are underwritten by the state of Hesse and as a result, elaborate waste treatment facilities are provided at a cost acceptable to the private user, member firms and outsiders alike . The Biebesheim installation contained the best incineration facilities observed in Europe, from an environmental control perspective . Hesse is a very industrialized area which produces significant quantities of waste and includes major chemical industry in the Frankfurt region . Biebesheim has yet to operate at sustained levels in which revenues offset all costs and, thus, demonstrate economic independence of He-P Tremendous costs are being
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underwritten by the state in order to allow continuous operation of the facility . The philosophy of the Hessian approach, however, is a very important one . There is strong public support for the state role in the management of hazardous wastes . A very elaborate system is operated in the Länd of Bavaria involving state/private ownership of facilities through GSB (Gesellshaft zur Beseitung von Sondermull in Bayern MbH) . GSB operates two integrated treatment/incinerator facilities, one at Schwabach and one at Ebenhausen/Gallenbach . An elaborate waste collection network is operated with the state of Bavaria assuming control of the waste at an early point and transporting the waste to the final treatment/disposal locations . The level of physical/chemical treatment of wastes (non-incineration) is especially high at Ebenhausen which annually treats 40,000 tons of waste at full capacity . The various incoming waste streams are segregated by type, and each type is custom processed through a batching mode . The wastewater from physical/chemical treatment is directed to a municipal treatment system after processing or is used in the scrubbing operations within the incinerator. Both Hesse and Bavaria are extraordinary management, treatment and disposal systems and represent, along with Denmark's system, the best that Europe has to offer . Unique among waste disposal sites in West Germany is the Kali and Salz facility at Herfa-Neurode . This privately owned and operated facility stores and disposes of waste from all the Länder in West Germany and other countries in Europe and America . It is located in the mined out sections of a salt mine near the East German border . The integrity of the system is very high as wastes are analysed, cataloged and verified to confirm generator analysis before disposal underground . The facility is immense, with over 50 miles of underground roadways, allowing waste to be segregated underground in certain areas . Areas of homogenous waste are sealed off making possible retrieval and recovery which has occurred in certain cases . The importance of this facility is that it is an alternative to permanent land disposal of the most toxic wastes and provides an environment in which the integrity of the waste can be maintained . The West German system relies heavily on attempts to minimize and recycle wastes where possible . In this context solid waste also received a great deal of attention in West Germany . One of the fundamental purpose of this study was a review of economic and other incentives for the management of domestic solid wastes in West Germany . At least three cabinet agencies, the Ministries of Interior, Research and Technology, and Commerce, are actively involved in providing incentives for solid waste management . The Ministry of Commerce operates a price support program for recycled oil which is gradually reduced as the practice becomes more institutionalized . The current support price is one Mark per liter of recycled oil . The F .R .G . has more than 100 oil recovery and recycling facilities, and approximately 90% of the oil in the market place is recycled and reusable . The Ministry of Research and Technology also supports recycling efforts, focusing on the development and implementation of innovative waste stream processes for both domestic solid waste and hazardous waste . Innovative systems are also supported by this Ministry . An example is financial support for a local solid waste facility in Nordrhein Westfalen with a system for source separation of domestic garbage and recycable materials and a facility which recovers paper, glass and, hopefully in the future, plastics . Government support of these activities plays a very strong role in their implementation throughout the F .R .G ., and represents an excellent example of the use of incentives to support better waste management systems . Lastly, the Ministry of Interior supports hazardous and solid waste projects and research into the development of new techniques through technology and capital funding .
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The combined budgets for these activities in the F .R .G . is millions of Marks per year . Throughout all Europe the most impressive direct subsidies for capital projects and research were observed in the F .R .G . West Germany is a very industrialized nation with a large number of chemical and other industries which produce tremendous quantities of special waste which must be managed according to West German law . In addition to the high technology facilities located throughout West Germany for the treatment and disposal of wastes, many corporations operate totally integrated private onsite waste treatment and disposal facilities . Their main approach is incineration . The facilities of BASF, Hoechst and Bayer are particularly impressive . In each of these operations, energy recovery and distruction of hazardous wastes are the most important goals . Collection stations are located throughout the plants visited for all recoverable or burnable materials which are then segregated according to type and waste stream . At Bayer and BASF waste streams with large quantities of combustible wastes are directly routed to incinerators . Both BASF and Bayer operate landfills which receive materials after treatment or incineration . Throughout West Germany and the rest of Europe . landfills are used for the final deposition of treated and untreated special waste streams . Most of these landfill sites have been in existence a number of years and were not selected with criteria currently used in most of the U .S .A . The process of developing new facilities in Europe is as difficult as in the U .S .A ., in spite of the general assumption that Europe is ahead of the U .S .A . in implementing waste treatment facilities . Europe will face tremendous public pressures in attempting to replace its existing landfills unless significant changes in public opinion occur . 2 . Summary European waste management facilities in the four countries studied appear to have much more government involvement in terms of subsidies and technical support than those in the U .S .A . The technologies of treatment and incineration employed in Europe are not beyond those available in the U .S .A . Thus the focus of a comparison of European and American waste disposal systems should not be on technology but rather on the "systems" approach to the management of waste . In Europe there is heavy emphasis on the "management" aspect of waste management . 3 . Discussion A major goal of this study was to review the use of both technical and financial governmental incentives to support waste management in Europe . There appears to be a prevailing philosophy in northern Europe that a law prescribing correct approaches for waste management is not very strong unless the government helps to provide facilities to allow individual waste generators to comply with the law . This is an important philosophical distinction between the concepts of waste management in the U .S .A . and in Europe and provides a framework within which incentives are realistic and acceptable . It should be noted, however, that incentives are not considered realistic for immediate environmental problems ; regulations are the necessary approach . For longer term problems and changes in direction incentives are very appropriate . It is also believed in parts of Europe that using regulations to achieve goals results in the "lowest common denominator" solution to a problem . Incentives and governmental involvement are believed to provide support for going beyond the minimal requirements of regulations .
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The management of domestic and industrial hazardous wastes in Europe is not identical from country to country and from area to area within a country . It is diverse and ranges from the use of available higher technologies to practices which have been discarded as unacceptable in America . This is an important conclusive given the existing American perceptions about the uniform high level of waste management throughout Europe . Likewise, the involvement of the government in the management of wastes ranges from partial ownership and direct involvement to a "hands off' approach with no or minimal central government involvement . The best systems observed during this study are truely outstanding and involve high technology both for incineration and physical/chemical treatment of inorganic and other waste streams . Some of these systems likewise are excellent from the viewpoint of management of the waste streams from the generator to the collection stations, pretreatment processes and other recycling or disposal activities . In the design, development and, in some cases, the direct management, these systems uniformly occur with the heavy involvement of the local and/or central government . The integrated systems approach to the management of waste in Europe clearly only results from government involvement . In all cases, it appears necessary to guarantee quasi-public corporations a virtual monopoly for the management of waste in an area in order to provide a sufficient market . There is a corollary between the operation of these management systems in Europe and the concept of the public utility in the U .S .A . The waste management approach practiced in Europe should be reviewed carefullly to determine its application in the U .S .A . This review should include the possibility of implementing the public utility approach to the management of wastes . The major reason for the high technology integrated systems in Europe is the "systems" approach to waste management . This approach includes a planning process . In Germany, for example, the Länder are required to prepare a needs assessment plan for a multi-year time-frame to assure that adequate waste management facilities will be available in the future . The "systems" concept of waste management also involves multiple collection stations located throughout a governmental jurisdiction . This allows generators to transport their wastes a relatively short distance to a collection station at which point the system becomes responsible for that waste . Costs are thus equalized, illegal disposal is minimized and generators are better served due to preplanning and the availability of collection locations . Utilizing the systems approach of Europe rather than simply allowing private enterprise to implement the most profitable segment of the waste stream without considering the needs of the total waste stream has merit . Many Europeans believe that the process of developing rules and enforcement procedures will not work without direct governmental support for cost effective total waste treatment systems . This philosophical concept has not been adopted in America . There would be considerable merit in implementing this system concept in the U .S .A . with a more complete long term analysis of waste management practices . For example, in air pollution a State implementation plan (SIP) process is used, and in water pollution the mandatory stream standards process is used . It would be very desirable to develop a waste planning approach in the U .S .A . similar to that used in West Germany with the implemention of total waste management systems including collection points appropriately located throughout a governmental jurisdiction . The concept of comprehensive planning and management of wastes in Europe is strongly supported by industry and government . It removes industry's obligation for development of private waste treatment and disposal options and places the burden on the system . Through clearly defined charges the system has incentives for producing separate and/or minimized waste streams and is capable of treating and handling wastes from all generators .
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The "pollutor pays" principle is often discussed in context with European waste management and is frequently mentioned by European industry . In spite of its advocates, the "pollutor pays" principle is not achieved in Europe due to significant government subsidies in certain countries or, in others, a waste management approach which clearly ignores future and many present costs . In all cases the "pollutor pays" principle appears to be a desired goal which has clearly not been achieved . One may ask whether this principle is an important aspect of a waste management program . It is obviously more important to have an adequate system for the total management of waste whether paid by government subsidy or totally by individual generators . The "polluter pays" principle in waste management appears to be of major importance to industry only as a public relations tool . Certain state-operated systems were very candid in admitting the role subsidies and incentives play in their systems and the unimportance of the "pollutor pays" concept . All systems uniformly supported incentives and subsidies which they believe to minimize the illegal disposal of waste which would result in greater governmental costs over the longer term . There is a widespread belief in certain areas of Europe, and a prevalent argument in the U .S .A . as well, that governmental involvement is desirable because higher costs for disposal would probably result in unacceptable disposal of waste outside the system . Those systems receiving government support appear to have decided that the incentive concept for maintaining a reasonable price for high technology treatment of wastes will minimize illegal disposal . This philosphy of preventing or minimizing illegal disposal appears to be the basis for elaborate collection systems and equalization of costs for disposal regardless of geographic location . Bavaria and Denmark in particular, which have many collection points with price equity, appear to have the highest level of support for the concept of incentives and development of a "system" . The Danes have gone to elaborate lengths to develop a company to export their system including technology to other parts of the world . The Danish approach includes state employees working on private sector activities outside Denmark with state reimbursement from Chemcontrol . In spite of the Danes worldwide marketing, the only aspects of their system deserving significant consideration in the U .S .A . is the concept of the collection network with a transportation system and the planning program to provide adequate waste management facilities throughout a geographic region . This broad "management" of wastes is the appeal of the Danish system . Although German law places governmental responsibility for waste m anagement . i n terms of facilities, collection systems, etc ., at the local level, it also provides local government with financial support . This financial support comes from both the federal and Länder governments . Bavaria alone provides DM 50,000,000 ($1 equals approximately DM 2 .60 1984) per year for waste management support . To encourage the appropriate methodology, Bavaria supports incineration at a level of approximately 50% while supporting landfilling proposals only at 10% . This support extends to domestic waste, which is principally a local government activity . European governments provide considerable incentives, both economic and technical, for the support of waste management . In addition to direct incentives most obvious in Hesse and Bavaria, the central West German Government, through The Ministry of Research and Technology, provides technological support for the development of new waste management techniques . The West German Government also provides incentives through the Ministry of Interior and supports the price of recycled oil through the Ministry of Commerce . Much can he learned from the European practice of providing upfront technical and economic incentives . Large industries in Europe, as in America . appear to be capable of managing their
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own waste with regulatory overview . Even though major innovative systems have been developed in Europe for high technology processing of wastes, Europe, like America, is undergoing fundamental changes in its waste streams . As waste handling charges for all treatment and disposal methods continue to increase reflecting actual costs, industry is making greater efforts to segregate and reuse waste streams early in a process . Historically, this was not a major practice since the economics of waste management allowed easy mixing and removal of wastes from the site . The present practice of early segregation of waste streams makes reuse, recycling and waste exchanges more reliable forms of waste management in Europe . Where disposal costs have remained artificially low, other waste management approaches than landfilling are not as effectively practiced . Major industry's philosophy (e .g . BASF and Hoechst) appears to be incineration of all combustible materials to avoid landfilling of untreated waste and to conserve landfill space . Also significant is the energy recovery aspects of incineration . BASF indicated that up to 75% of its incineration costs are recoverable through energy savings . Bayer's figure was much lower . These figures are not directly comparable since BASF does not consider capital and other important costs in its calculation . Nevertheless energy recovery is an important aspect . As overall costs for waste treatment at commercial firms has increased significantly the past several years, waste stream volumes have decreased significantly . The cost of waste treatment at commercial firms has increased due to higher technology waste stream treatment and the increase in external fuel costs for incineration . This has largely resulted from the tremendous decrease in the energy value of the waste provided by generators . Those facilities capable of on-site incineration or mixed fuel combustion are increasingly recovering energy and providing wastes with less heat value to be incinerated at the commercial facilities . This change in the waste stream poses a real dilemma for European incinerations presently under construction and/or not operating at full capacity . The volume of waste will probably continue to decrease in Europe . Industry is also attempting to minimize wastes in an effort to stabilize waste management costs . At BMW in Munich waste streams have been significantly reduced in an effort to maintain waste treatment and disposal costs . The individual unit prices for disposal and the treatment requirements are the biggest single deterrents to waste generation . Without adequate treatment regulations many generators would still seek the least expensive disposal option regardless of environmental consequence . As the waste management concept becomes more firmly ingrained in the minds of industrial managers and engineers, there is greater upfront analysis of waste generation . Waste generation costs are considered economic factors in produce development and waste management costs are charged back against production . All reasonable approaches are considered to minimize the per unit costs of waste management . More industries today are accepting waste production as a legitimate cost of doing business and are increasingly concerned about appropriate waste disposal . There is also a much greater recognition that necessary costs spared today have the strong probability of turning into greater future costs . Transfrontier waste movement is presently a very large issue in Europe . The Seveso incident in Italy in which dioxin wastes ultimately ended up in Paris and were then returned to the parent firm in Seveso is extremely important and of major public interest . The ultimate disposition of these wastes is unknown . Allowing wastes to move across borders without restrictions to the least acceptable waste treatment facility with the lowest costs is currently a major concern . The European Community is struggling with a proposed regulatory solution to this complex waste management issue . One of the proposals being debated in Europe is the concept of using the export approach to drive
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waste streams towards high technology facilities, resulting in transporting waste rather than transferring technology . Politically this would be extremely difficult ; however, the ability to send wastes across national boundaries to higher technology facilities may be desirable as this approach would sustain the existing higher technology facilities and offset the presently decreasing waste streams . Most Europeans contacted appear to advocate technology transfer rather than waste transfer . This issue will clearly require an increasing coordination and planning to preclude overcapacity in geographically selected areas or in Europe as a whole . Considering the present and future predicted waste stream the Federal Republic already appears to have an overcapacity of high technology waste treatment facilities in at least certain locations . Europeans are more highly motivated to recycle than are Americans . One senses a greater concern for the limited supply of raw materials and the finite availability of these materials within the European countries . This is probably a natural result of the lack of availability of industrial raw materials in Europe compared to the U .S .A . This is particularly true for petro-chemical and strategic metal feedstocks . The major industrial countries in Europe are major importers of raw materials and their economies are more allied to conservation of these raw materials . One or more European countries is strongly motivated to conserve oil, paper, metals and/or glass . As a result, reuse and recycling not only has an environmental impact but appeals to the public need to be a good citizen for the national economy . Very strong support for "economic" reuse and recycling occurs in France through ANRED where incentives for the development of waste management capabilities is strongly tied to national economic needs . The exception to this strong recycling attitude is Britain where there is no significant government support . The British attitude appears to be that recycling and reuse will survive on its own merits without government support if and only if it is economically reasonable relative to new raw materials . The reuse ethic is present in West Germany through the standardization of returnable bottles as well as the presence of containers throughout the country for glass recycling . Aluminium cans do not appear to be a significant market factor in this economy . West Germany also provides a strong government incentive for recovery of oil by supporting the price of recycled oil through the Ministry of Commerce . The outlook for recycling in certain Western European nations is quite positive and the use of government incentives, particularly in West Germany, has been significant in both developing technologies and in increasing the availability of recycling products . Continued public education and governmental involvement will be necessary and should pay increasing dividends in the future as raw materials become either more scarce and costly . On the whole, the European approach to waste management is very innovative at its best and not acceptable by present American Standards at its worst . The concepts of incentives and governmental support are much more highly developed in Europe than in the U .S .A . and are the true "technology" of European waste management . While the facilities do not appear more innovative than can presently be achieved in the U .S .A ., the concept of the management system, the multiple collection points and the role of the government in ensuring high technology waste management approaches is admirable and would greatly benefit the U .S .A . The concept of adequate preplanning for facility needs which is used in parts of Europe, is an approach which should also be implemented in America .
Waste management in northern Europe
Acknowledgements This working paper has been prepared under an ongoing German Marshall Fund of the United States environmental fellowship program . This program enables professional American environmentalists to spend two months in two or three European countries examining advanced environmental management practices of direct relevance to their own work . The State of Colorado provided the time to undertake this study . The Institute for European Environmental Policy provided logistic support and counselling and was instrumental in arranging appointments throughout Europe . Ms Marianne Ginsburg of the German Marshall Fund and Dr Konrad von Moltke and Ms Pascale Kromerek of the Institute for European Environmental Policy deserve special thanks . Ms Christina Serrano spent considerable time and effort in developing the manuscript for this report and Ms Ann Lockhart added clarity and conciseness through detailed review and editing . Appendix : selected major resources General Bundesministerium des Innern, Federal Republic of Germany (July 1983), A Study of the Hazardous Waste Activities in NATO Member Countries following the Completion of the Pilot Study, Final report, D 5300 Berlin, F .R .G . Commission of the European Communities (1983), Energy from Municipal Waste, 1980/1981, Summary Report, B 1049 Brussels, Belgium . Commission of the European Communities, Environment and Consumer Protection Service (October 1981), The Advantages of Secondary Resource Recovery-Final Report, B 1049 Brussels, Belgium . European Economic Community, Economic and Social Committee (June 1983), Waste Management in the European Community, B 1049 Brussels, Belgium . U .S . EPA (1983), Office of Technology Assessment, Technologies and Management Strategies for Hazardous Waste Control, Washington, D .C . Organization for Economic Co-Operation and Development (February 1983), Hazardous Waste Legislation in OECD Countries, Paris, France . The United Nations Environment Programme (1983) Industry and Environment Special IssueNumber 4, Industrial Hazardous Waste Management, Nairobi, Kenya . France France Agence Nationale pour la Recuperation et Elimination des Dechets (1982), Rapport D'Activite, ANRED Annual Report 1982, Paris, France . Ministere de L'Environnement, Cahiers Techniques de la Direction de la Prevention des Pollutions 1982, No 8, (French Technical document on industrial waste treatment), F92521 Neuillysur-Sein, France . Secretariat D'Etat A' L'Environnement ET A' LA Qualite de LaVie (1983), Nomenclature des dechets (French waste categorization document), F92521 Neuilly-sur-Sein, France . Germany Der Hessische Minister fur Landesentwicklung, Umwelt, Landwirtschaft und Forsten, Umweltachutz in Hessen (March 1982), Abfallbeseitigungs plan, Teilplan 1, Hausmull und Hausmullahnliche Abfalle, (Hesse domestic waste plan), D 6200 Weisbaden, F .R .G . Federal Environmental Agency, Federal Republic of Germany (March 1983), Abandoned Waste Disposal Sites Problems in the Republic of Germany-Status Report (Submitted to the 16th Meeting of the OECD Waste Management Policy Group), D 1000 Berlin, F .R .G . Federal Minister of the Interior (May 1982), Report on the Environmental Policy of the Federal Republic of Germany, D 5300 Berlin, F .R .G .
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United Kingdom Department of the Environment (1978), Co-operative Programme of Research on the Behaviour o/ Hazardous Wastes in Landfill Sites, London SWI 3PY, U .K . Harwell Laboratory, Waste Management Information Bureau, Waste Management Information Bulletin, Volume 20, Number 1 (January/February 1983), Harwell, Oxon, U .K . House of Lords (1981), Session 1980-81, Ist Report; Hazardous Waste Disposal, Volume I-Report, London, U .K . House of Lords (1983), Session 1983-84, 9th Report ; Trans/rontier Shipment of Hazardous Wastes (final revised preprint), London, U .K .