Consistency in collection customer workshop
After the efforts of completing the consultation responses for Extended Producer Responsibility (EPR) and Deposit Return Schemes, we held an excellent customer session on Consistency in Collection (CIC) and its impacts on the waste management systems. At first look at costs, you might be drawn to think that consistency is the least important consultation, but a detailed read, systems map and impact assessment quickly suggests that it is far more important to success and outcome than simple numbers might suggest.
Understanding the proposed systems
Our first job was to map the existing system of waste production and management and then overlay DRS (the four options under consideration) and EPR (the five or six options under consideration), and see how the various proposals for consistency intersected, complemented or potentially conflicted with each other. A good example of interaction was the term ‘excessive cost’ in the Technically, Economically and Environmentally Practicable test (TEEP) and how it might relate to ‘efficient and effective’ under the EPR provisions. Which organisation, from national to local government, from householder to employer, scheme administrator or waste manager, is responsible for deciding what is ‘excessive’?
In the previous EPR consultation SUEZ recycling and recovery UK had worked through some municipal costings and published a table of potential costs which varied by a maximum of £60 per household for one collection type across multiple DNAs (types of LA, including factors such as rurality, deprivation), or a maximum of £25 per household across one DNA for the two modelled types of collection. Is £60 per household excessive? Not if the total EPR cost cascaded all to citizens would amount to just under £100 per household. Obviously, some of this £100 includes the costs of collection of packaging items and therefore the £60 and £100 are not additive but they give some scope to what government thinks might be acceptable and not excessive. Twenty-eight pence per day per person to help stop climate change and establish one world living may not sound an excessive investment in the future.
Money flows and new burdens funding
New burdens are defined as ‘any change in a central government policy or initiative that imposes a net cost on local government and could lead to an increase in council tax.’ This includes potentially £200M initial capital investment in food waste collections, around £100 million to cover transition costs and £2.2 billion to cover the minimum green waste collection service proposals. Although the consultation talks about funding transitions, it does not propose to make such payments until 2023, potentially delaying early opportunities to change as local authorities wait to ensure they get new burdens financial support. As a group we discussed these interactions and how they impact on investment timetables and service choices. New Burdens funding is also proposed to help local authorities where, for instance, zoning for business waste collections creates additional financial burdens.
The conversations then went to a deep dive into the application of TEEP. With TEEP guidance moving to statutory guidance and coming with sanctions or challenges to decisions being enabled (but not quantified), the purpose and effectiveness of current and future TEEP was a lively discussion.
Efficient and effective
Firstly, TEEP has a relationship with CORE items and efficient and effective in the EPR consultation, and secondly the choices around DRS can significantly change the quantities of plastic, glass and metal at the kerbside, dramatically impacting on service efficiency and revenues. We know that residual waste volume constraints (either through frequency or volume allowance or both) can have a dramatic impact on recycling performance and the proposals for two-weekly residual collections could well be challenged on the grounds of efficient and effective through the EPR system. So, the inter-relationship between EPR and DRS are fundamental choices that need to be made in consistency.
So where did all these discussions end? Well, we all agreed that there were far too many options and choices through EPR and DRS to truly be able to model what is likely to need to happen with consistency. What system of collection best matches TEEP, but also meets efficient and effective in EPR is still subject to debate – as was lack of enforcement on TEEP today which tends to force the market to provide services ‘of the lowest common denominator’ and not necessarily in line with governments intent. Making sure the consistency consultation outcome is fit for purpose is essential, not only for England’s recycling rate and circularity but also in ensuring that the systems are coordinated, complimentary and compound their respective benefits. A weak consistency agenda could well lead to uncertainty, a lack of coordination actions and an environment not supportive of investment or efficiency. Consistency is not the junior consultation, it’s actually a foundation that we all need to get right.