Our determined efforts aimed at amending the contents of the act on waste tax were not totally in vain, and even politicians seem to be able to improve on the proposals presented by public officials. However, I was nevertheless disturbed by the poor understanding of market mechanisms displayed by those involved in the preparation of the waste act. The impact of market forces is often referred to, but as regards the calculation of the cost impact of the waste tax, no attention was paid to this aspect.
Thus I wish to focus attention to the other side of the waste tax debate: if we wish to achieve the objectives set for the reduction of landfill waste, then instead of taxation we need to introduce completely different measures.
The notification procedure concerning the use of waste in earth construction must be expanded and relaxed
Forest industry by-products can be utilised in various ways, one of the most important of which is earth construction. For example, fly and bottom ash from peat and wood-based material are suitable for such use. Fly ash and bottom ash fall within the scope of the Government Decree concerning the recovery of certain wastes in earth construction (591/2006) and satisfy the requirements laid down therein. However, the limit values for leaching in the Decree are so strict that the use of fly ash in earth construction under the notification procedure has not been possible in practice.
The limit values issued based on the Decree should be based on a risk assessment, on the basis of which higher limit values could be used, or, correspondingly, values exceeding one or two of the current limit values by (for example) 50 per cent could be approved. At the same time, the number of fractions falling within the scope of the Decree should be expanded to cover fibre sludge generated in the de-inking of recyclable paper.
Flexibility and a proactive approach to be increased in the permit processes
Increasing waste recovery as targeted is also extremely challenging because in practice, the use of waste for earth construction always requires an environmental permit. Since only the landowner or the party carrying out operations on the site may apply for such a permit, the forest industry is rarely able to influence the opportunities for waste recovery.
The permit process currently takes some three to six months, which is too long considering contract schedules, and the process should be accelerated significantly. It should also be possible to obtain environmental permits for the utilisation of by-products on a material-specific basis throughout the area governed by a Centre for Economic Development, Transport and the Environment, for example, excluding natural conservation areas, ground water areas and other ecologically vulnerable sites. This would significantly increase awareness of waste recovery and interest in it among external parties.
Furthermore, it would not be a bad thing to introduce a statutory obligation to assess opportunities for waste recovery in projects falling within the scope of the EIA process, road and street planning and the permit procedures under the Environmental Protection Act and the Land Use and Building Act. This information could be used to guide the parties or to place them under a binding obligation to implement potential recovery measures.
More efficiency also in energy recovery
In addition to more efficient use in earth construction, the efficiency of energy recovery from waste can also be improved. The national interpretation of the Waste Incineration Regulation should be revised so that the regulation would not apply to the combustion of de-inking sludge. At the same time, the emissions trading classification of de-inking sludge should be revised to correspond to the classification of fibrous sludge.
All of the above measures would significantly increase the recovery rate of the forest industry’s waste fractions, which would also mean that their positive environmental impact would significantly exceed the steering effect of the waste tax. In addition, these solutions would not significantly increase the indirect cost of waste recovery and thus weaken the operating conditions of the forest industry.
Can we really afford not to implement these measures aimed at promoting waste recovery? The question also arises, was the sole purpose of the waste tax to generate revenues for the government after all?
Ari-Pekka Heikkilä
Environmental manager, Metsäliitto Cooperative