The Council Perspective

In the second of his article series, Angus Macpherson, managing director of the EnvironmentExchange, looks at the flurry of consultations resulting from the recently-published resources and waste strategy from the perspective of the local authority…

A pincer move by Defra and the Treasury to align the Government solution to Extended Producer Responsibility (EPR) for Packaging, Plastic Packaging in particular, and a shortfall in local authority funding may have eroded the complaint of lack of joined up Government. 

But, for some, the consequent result of 4 consultations, 3 regulatory impact assessments and 491 pages to read and respond to by 13 May (12 May for the Treasury), while applauded as a significant effort by all involved, may prove a little difficult to digest. 

This top level consideration of concepts is an unusual conglomeration ranging from tweaks to the current scheme, through better regulation of exports, to wholesale reform of the current producer responsibility system and the local authority collection system. 

The consultations are based upon the view – apparently, industry’s – that the current system of Packaging Recovery Notes (PRNs) is no longer fit for purpose. While it is acknowledged that the current system is not perfect, it is succeeding in achieving the targets that are requested of it – hence one may wonder whether the wholesale change proposed is truly necessary or whether a few tweaks in the right places might suffice.

While it is clear that the funds must have arrived at the right place to facilitate the achievement of packaging recycling targets, greater clarity in this area would assist all.

A key question asked by industry as the prices of PRNs increase is what is all the money that I am paying being spent on. Concurrently local authorities are wondering why they do not appear to be receiving any of that money at all, overlooking that they are receiving income paid by industry for their secondary raw materials and of the annually increasing collection and disposal costs, a significant element is the annual increase in landfill tax!

While it is clear that the funds must have arrived at the right place to facilitate the achievement of packaging recycling targets, greater clarity in this area would assist all.

Meanwhile, the consumer remains confused about what can or cannot be recycled and, where local authority areas meet, why the collection methods on one side of a street differ from those on the other. 

Not just the colour and size of the bins, although that does not help, but also why different materials are considered recyclable in one local authority but not another! Much of what is deemed not recyclable is plastic, which is not only ending up in the ocean but also the fastest growing packaging material. So why should materials which cannot be recycled not be banned?… and then there is litter!

So, what is the four pronged proposal. Firstly, to reduce confusion an agreed list of packaging materials for collection from every household; secondly a deposit scheme to increase the quality of the recyclate, secondary raw material, and reduce the quantity of litter; thirdly a tax on all plastic packaging that does not have a minimum recycled content, currently proposed at 30%, to increase the demand for plastic for recycling and finally a revised producer responsibility system that incorporates a financial penalty for using packaging that cannot be recycled and a direct funding  system for local authorities, while still achieving targets not only throughout the UK but also measured within each of the devolved nations. 

Local Authorities

What impact might the proposals have on the local authority? Consistent and simple messages about what can and cannot be recycled should reduce confusion and also increase quality as over enthusiastic householders no longer inadvertently add the wrong materials to kerb side recycling because it looks like it can be recycled. 

But nothing is simple and a whole lot of questions follow:

  • If what is deemed recyclable is restricted, will the local authority’s residual waste stream grow or shrink?
  • What is going to happen to those items that are not deemed recyclable?
  • How many waste streams will a local authority have to collect?
  • While it is good news that packaging producers are going to cover a local authority’s full net costs for packaging, who is going to pay for the rest? Will those costs increase?
  • Will the packaging producers’ funds be ring-fenced for waste management or will they just be allocated to the local authority’s budget?
  • How will producers pay local authorities and what justification will they request for that payment?
  • Could producers decide to by-pass local authorities and set up their own collection schemes? Is that what a deposit scheme is?
  • Why should local authorities increase packaging recycling when the packaging industry is going to cover its landfilling costs too?
  • How will householders react when they discover that their council tax is no longer being used for household collections? Ask for a decrease?
  • How will a local authority be able to influence a national communications campaign on recycling or litter?
  • Will a national campaign suit this local authority? What further changes might local authorities anticipate in its waste collection provision?
  • What impact will this have on litter in the local authority area and its collection costs?

Deposit schemes are a potential crowd pleaser. Politicians can stand smiling beside deposit return facilities, but local authorities look to lose income from secondary raw material sales. Anecdotal evidence from Oregon suggests that when in January 2018, the bottle deposit fee increased from 5 cents to 10 cents, the volume of PET in the kerb side mix dropped by 35 per cent. 

Not only a significant impact on a local authority’s costs but also the full net costs for packaging producers. Equally little if any research has been done on the cost benefits of investing funds into a new deposit scheme against an established kerb side collection scheme.

So, how might the local authority feel after all the proposed changes have come into place? Better funded because of producer contributions? A better place to live with more satisfied householders/electors because of better recycling rates? Frustrated by the loss of potential income streams to deposit schemes and the hoops required by producers to justify getting their funds?

Read Andrew’s article on “The Consumer Perspective” here.



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