What do the Defra consultations mean for your waste strategy?

2 June 2021

With the three Defra consultations on extended producer responsibility (EPR), deposit return scheme (DRS) and collections consistency now released, local authorities have increasing clarity on the likely impacts of the Environment Bill on their future waste and recycling services. There’s never been a better time to review your Council’s waste strategy, but where do you start?

Evidence gathering

Waste strategies are long-term documents that set the strategic direction of a Council’s waste and recycling (and sometimes Streetscene) service over 10-15 years. For meaningful long-term planning, baseline data should be gathered to evidence why, how and where changes and improvements are needed. The best way to achieve this is to undertake a waste composition analysis; the results will starkly inform how effective your services are, where improvements are needed, and where to target future intervention measures, education and communication efforts.

Alongside a waste composition analysis, a review of relevant service data will unearth trends that need attention. Are costs escalating for particular material streams? Are residual waste arisings steadily increasing? Is the annual recycling rate only increasing because of garden waste tonnages, hiding the fact that dry recycling figures are plateauing? Reviewing historical data helps to look forward and set out how any issues found will be managed through the strategy.

Options appraisal and modelling

For most local authorities, consistency in collections is likely to require changes at the kerbside that need implementing in the short term. For all authorities, it will mean reviewing the impact on recycling composition from the introduction of a DRS. Defra modelling shows that just 7% of cans, plastic and glass bottles are likely to remain in the kerbside recycling stream following the introduction of an ‘all in’ DRS, if that’s the chosen way forward.

EPR will also affect the waste service in the short term, which strategies will need to reflect. This ‘polluter pays’ policy means that by 2023 packaging materials will be subject to EPR legislation and Councils will be required to collect all recyclable packaging to consistent minimum collection standards. By 2025, Defra will have consulted on expanding this to include textiles, bulky household waste, certain categories of construction and demolition waste, and tyres. This will change the way Councils collect and dispose of these material streams and new recycling services will undoubtedly be needed to support the drive up the waste hierarchy.

For 49% of English local authorities, consistency in collections will require the introduction of separate weekly food waste collections. For 60%, it could mean collecting cartons for the first time at the kerbside, as well as plastic film and metal tubes, such as those used for tomato puree. The consistency in collections consultation emphasises that materials should be collected separately. For 52% of local authorities this will require a review of their current comingled collection service to demonstrate it is “not technically or economically practicable to collect separately, or that there is no significant environmental benefit of doing so.” Whatever the scale of changes needed, conducting an options appraisal to inform a Technically Environmentally and Economically Practicable (TEEP) assessment is a key deliverable before a strategy review is undertaken.

Furthermore, if Councils are some way off achieving the national 65% recycling rate by 2035, as set out in the Circular Economy Package 2020, modelling the extent to which specific waste improvement activities will enable Councils to reach this target is critical in setting realistic targets and for strategy success. Modelling can detail a whole range of interventions to be delivered in the short, medium and long term; from modelling the impact of education and communication campaigns, to assessing the impact of introducing smaller residual bins. Whatever measures are agreed to meet strategic goals and targets, each of these should be detailed in the strategy as part of a rolling annual action plan for Council Officers (and their contractors) to deliver.

Communication, communication, communication

For a waste strategy to be effective, both cross-party Member support and a public consultation to garner support from residents is required. Open communications in the planning stages of the strategy is key.

Corporate Communications is also fundamental and should be engaged with as early as possible. Key considerations include planning the right time to launch the strategy, how this dovetails with other public consultations being held, and shaping the questions the consultation will ask and how the answers will be reflected in the strategy. How the public consultation will be delivered is also important to scope out in the planning stages. Writing a public consultation communications plan should be the first task in the planning stage to identify and scope how the consultation process will be run.

Target setting

Finally, all targets set in the strategy should be SMART.

Specific – What are your goals and why? It’s useful to include a range of goals across key areas such as cost, recycling rate, carbon and waste arisings. Keep each one simple and specific to each area.

Measurable – Modelling undertaken in the strategy planning stages will help set realistic targets and will show a year by which an improvement measure will yield a specific result.

Achievable – Ensure there is agreement between the portfolio holder, senior management, and others on how achievable each goal is. If you’ve some way to go to meet a goal, agree what is realistically achievable over the life of the strategy.

Relevant – Your goals should be relevant to the goals set out in the Corporate Plan and the Local Plan, as well as any other strategic documents which reference waste.

Time bound – Using modelling outputs to help, where possible, ensure every goal has a delivery date by the final year of the strategy. Ideally the strategy will run until 2035, in line with national waste and recycling target dates stipulated by Defra. However, if a key goal is to increase recycling rates but modelling demonstrates it’s unlikely that the national recycling rate of 65% target can be achieved by the Council within the strategy lifetime, set a goal of achieving a specified increase instead.

Despite the short term challenges the introduction of the Environment Bill may bring to local authorities, reviewing your waste strategy highlights at a local level all the opportunities there are to drive waste up the hierarchy and to challenge the status quo. Now is the time to review your services to understand the impact of future policy requirements. A strategy that embraces the upcoming changes will ensure opportunities are not missed to increase recycling rates and realise cost efficiencies.

At Resource Futures, we are working closely with local authorities to review and develop their waste management strategies. Please get in touch with Principal Consultant, Laura Snoulton, at laura.snoulton@resourcefutures.co.uk if you would like to discuss reviewing your waste strategy.