Memorandum from the Local Authority Recycling
Advisory Committee
My name is Andy Doran. I am the Vice Chair and
Policy Officer of the Local Authority Recycling Advisory Committee
(LARAC) and for whom I have been asked to submit evidence to this
Committee. LARAC seeks to represent the views of its 350+ member
authorities on issues of concern in local authority waste management
in particular with regard to recycling and waste minimisation.
Membership of LARAC is drawn from Unitary, Metropolitan, Waste
Collection and Waste Disposal Authorities. The views expressed
in this evidence are those of the LARAC membership, not those
of my authority.
In view of the range and type of statutory waste
management services provided by local authority professionals
the views of LARAC will be constrained to these main areas as
addressed by the scope of the Committee's inquiry and with a view
to the main areas of expertise of LARAC as set out above. In addressing
the concerns of this Committee this written evidence is structured
into the following sections:
— Waste strategy vision and direction;
— Recommendations for Government.
LARAC would of course be delighted to attend
the Committee and submit oral evidence to further substantiate
this written evidence.
1. WASTE STRATEGY VISION AND DIRECTION:
At a time when many European States are fully engaged on the agenda
of developing "Sustainable resource management strategies",
it is perhaps symptomatic of the failings of the UK that we are
still preoccupied with developing a sustainable waste management
approach that at best was poorly defined in the publication of
Waste Strategy 2000.
2. LARAC believes that over the two years
since the publication of Waste Strategy 2000, Government's overall
policy direction has remained confused supported as it is by the
waste hierarchy that encompasses a broad band of recovery options.
During the development of Waste Strategy 2000 Government appeared
to adopt a position of formal policy backing for energy from waste
recovery as a legitimate part of an integrated waste management
system. However, immediately upon publication of this strategy
there followed an apparent distancing from the policy by Government
Ministers. Such a stance is obviously unhelpful to local authority
professionals trying to steer waste developments in a sustainable
direction and confusing to the public.
3. LARAC believes that Government's current
vision is stymied by an obsession with performance management
when visionary thinking and strong leadership is required. Government
should be examining the evidence from European partners and developing
a forward thinking waste strategy based upon use of product taxes
(based on life cycle implications of that product), product reuse
schemes and high levels of disposal taxes. These need to be supported
by a wider regulatory package to "enforce" more participation
in private and public sector recovery schemes. LARAC does not
believe that the Government's approach of allowing the free-market
to determine the level of uptake in voluntary schemes has worked
and should be abandoned forthwith.
4. POLITICAL SUPPORT: This evidence has
already cited (Para 2) the political vacillations of Government
over their support for energy from waste as a recovery option.
On a wider scale there is an overall lack of senior political
support within Government for implementing the difficult decisions
that arise from taking a proactive stance to improving the UK's
performance in waste management terms. Whilst the continued support
of the Environment Minister is welcomed, it is not evident that
this support is shared by senior colleagues within the Cabinet,
such that Government spending decisions and reaction to industry
lobbies is sufficiently robust in support/defence of Waste Strategy
objectives. Without such overt political leadership and backing
the objectives of Waste Strategy 2000 are likely to go unmet and
this Government will continue tip-toeing rather striding down
a more sustainable path.
5. FUNDING FOR WASTE: The size and extent
of new funding to implement the Waste Strategy 2000 is still unclear.
Assurances in the Strategy that funding implications arising from
the Strategy would be considered in the Comprehensive Spending
Review are still largely unmet. Funds provided for the Waste and
Resources Action Programme (WRAP) are welcome and LARAC is confident
in the abilities of WRAP to deliver improvements in secondary
material markets as a result. However, whilst welcome the allocation
of the £140 million Recycling Fund can only be seen as a
palliative toward a larger and longer-term funding requirement
within local government waste and recycling services. This funding
allocated on a challenge basis and prioritised toward poor performing
authorities is only of a short-term nature and will do little
to ease the longer-term revenue funding requirements of these
and other local authorities. It is also equally possible that
such funding will do little toward sustained levels of recovery
within the household waste sector.
6. Similarly, despite serious concerns about
the historical lack of use of Landfill Tax Credit funding for
sustainable waste management, Government direction and legislation
is still required to enable a wider use of these funds to support
improvements in local authority waste minimisation and recycling
activities. LARAC welcomes the fact that the Government, in publishing
the results of a recent consultation exercise, appears to have
recognised the hitherto perverse effect of the Landfill Tax in
that local authorities (metropolitan, unitary or county regions)
are responsible for disposing of large volumes of waste (incurring
Landfill Tax) and yet have been largely barred from using the
Credits raised from the Tax. This is in effect a double whammy
that should be removed from any revised scheme.
7. A further problem for authorities in
implementing Waste Strategy objectives has been that allocations
of funding for waste within the Environmental Protective and Cultural
Services (EPCS) block of the Standard Spending Assessment (SSA)
have not kept pace with inflationary increases in this sector
and increases in waste volumes (see Para 11). Notwithstanding
the negative impact of the Landfill Tax on some authorities (see
Para 6) the trend for waste management and disposal prices has
been at an upward rate above the underlying level of inflation.
This position over a number of years has now left many authorities
with a significant gap between SSA grant levels and waste management
budgetary requirements. Inevitably, until this gap can be filled
achievement of Waste Strategy targets will be a local political
decision taken at the expense of a "lesser priority"
service.
8. For this reason LARAC has joined the
LGA and many individual authorities in calling for a separate
waste management sub-block within the EPCS allocation of the SSA.
Such a categorisation would, we believe, allow the true costs
of local authority waste management services to be transparent
and provide a surety that any additional funds forthcoming from
Government for waste management were guaranteed to reach their
destination and not be diverted to meet other legitimate service
pressures.
9. Finally with regard to funding, it needs
to be borne in mind that considerable new environmental regulation
has been introduced over the last 10 years, much of it without
concomitant new funding for local authorities to deliver these
requirements. Local authority resources in waste management and
to a lesser extent environmental management are at breaking point
due to this accumulated burden and due to inflationary deficits
as mentioned in Para 7. Unless Government accedes to the requests
for a separate waste management sub-block within the SSA (see
Para 8), unfounded incremental additions to local government environmental
services have the same sapping effect of funds available to waste
management services as funding below the level of real inflation
levels within the sector.
10. LARAC believes that since the publication
of Waste Strategy 2000 Government has not undertaken a realistic
financial assessment of the proposals within the Strategy or faced
up to the bold decisions required to allocate funding to deliver
the Strategy. It is our belief that in the highly pressured financial
environments that local authorities have become, strategies without
such accompanying funding will not survive as alternative budget
pressures can always take precedence.
11. WASTE MINIMISATION: The challenge of
uncoupling increased waste generation from increased economic
growth is proving a significant challenge for our global society.
Government's Waste Strategy 2000 offered considerable support
for the principles of waste minimisation, but little by way of
direct support. At the time of publication of Waste Strategy 2000
much was made of the piloting of householder incentive schemes,
however, little has progressed since that time. LARAC believes
that to date Government funding and support for waste minimisation
has been pitifully small and does not reflect the espoused priority
attached by Government to this as a policy goal.
12. In an effort to raise the public profile
and understanding of waste issues several authorities and organisations
including LARAC come together to support the National Waste Awareness
Initiative (Reth!nk Rubbish). However, three years on this programme
has still to secure any significant medium to long-term funding
and has not yet featured in Government spending plans. It is clear
that cultural change within UK society does not happen quickly
or cheaply and central Government needs to be at the forefront
(politically and financially) of promoting the values and actions
of a less wasteful society. In doing so it should recognise and
support the local implementation role provided by UK local authorities.
13. As the primary component of the waste
hierarchy waste awareness and waste minimisation need the wholehearted
support of Government to educate and inform the public of the
consequences of their actions and the opportunities to change
that behaviour. Government is ideally placed to support the development
of an initiative such as Reth!nk Rubbish in a similar fashion
to their broad environmental campaign "Are you doing your
bit?" which has sadly waned over the last year
14. LARAC strongly believes that only by
gaining a wider understanding of waste issues will the public
be able to engage and support the change programmes that are needed
to steer waste management in a more sustainable direction. Reference
has been made in previous Government literature for the need to
put waste on the same level as "Clunk-Click" or Drink
Driving campaigns. Therefore, LARAC strongly urges the Committee
to recommend Government financial involvement in a nation-wide
campaign such as Reth!nk Rubbish.
15. TARGETS: The introduction of recycling
targets for 2003-04 and the inclusion of performance targets for
recycling within the best value regime has been a strong challenge
to local authorities against the backdrop of funding pressures
highlighted earlier in this evidence (see Paras 5-10). These targets
in themselves are not bad things, but in some areas of the country
hinge upon the development of Joint Municipal Waste Management
Strategies. Guidance on the scope and content of such strategies
was published in March 2001. However, such strategies have still
to be enacted by legislation and lack the statutory backing that
would give local authorities the political impetus to push ahead
with implementation.
16. Additionally, Government has recently
issued guidance on potential pooling arrangements for targets
but with a woefully inadequate period of consultation to realistically
allow joint authority teams to submit pooling proposals. Furthermore,
in order to pool targets some authorities would have to shoulder
an extra burden over and above their current BVPI target. As many
will struggle to meet their own targets in the time left I think
it is unlikely that they could introduce any practical steps to
pool in time for next year's BVPI targets. A pooling approach
could have merit, but needs a longer timeframe and accompanying
freedoms and flexibilities to entice partnerships into considering
these alternative arrangements.
17. Given the nature of the Government's
BVPI target setting approach many authorities will struggle if
not fail to meet their forthcoming performance targets. Many authorities
are "treading water" at levels of 18-23% as they combat
increases in overall waste volumes and the financial effects of
trying to reach incrementally higher levels of recycling. In allocating
this funding Government appears to have ignored the law of diminishing
marginal returns, which means that authorities at the higher end
of recycling performance have to expend increased sums of money
per household to obtain a consequent increase in recycling levels.
18. To compound the matter, the Government
has recently allocated a disproportionate amount of the £140
million Recycling Fund to poor performing authorities thereby
leaving the higher performers in great danger of failing to achieve
their statutory targets.
19. The final comment with regard to targets
is that they should be assessed against a consistent background.
At the same time as bringing in statutory targets, Government
removed several elements from the definition of recycling (eg
household rubble). This leads to confusion amongst elected Members
and the public plus contributing to poor morale in local government
waste employees who see levels fall despite their considerable
efforts. Government needs to apply a consistent approach to defining
and monitoring waste targets.
20. REGULATORY FRAMEWORK: In much the same
way as local authorities have been given a stiff operational challenge
with weak financial backing, local authorities have also been
given a statutory obligation to meet targets with a largely voluntary
framework of legislation to deliver it. LARAC believes that unless
some somewhat radical changes are made to the current legislative
framework Waste Strategy objectives will not be met. Some of these
as outlined in Para 3 will switch the burden of compliance from
the public to the private purse through strongly applied and mandatory
producer responsibility. In the household sector local authorities
should be given stronger powers to compel the separation of waste
for recovery as well as the ability to penalise (or incentivise
the alternative) excessive disposal of recyclable wastes.
21. Landfill Tax needs to be significantly
increased (with differentials according to the hazardousness/
cost of managing the waste). The tax should however be cost neutral
to local authorities that could be compelled to demonstrate reinvestment
of foregone taxed sums in sustainable waste management schemes.
Alternatively, levels of tax could be restrained for household
waste to ensure that funds are not further eroded within local
government. Product taxes and reuse schemes could be introduced
to reduce the amount of waste entering the waste stream and engage
the public in actions to recover waste. This would hopefully raise
public awareness of consumption and disposal practices.
22. Additional changes to the local authority
regulatory framework could be to give local authorities a series
of earned autonomies such that local authorities can trade and
charge for certain services and thereby provide a more integrated
local waste management service. The Planning regime also needs
improvements such that waste-related planning decisions can be
treated objectively, fairly, but quickly. Currently planning decisions
are a major deterrent to the achievement of recycling and recovery
targets and in many cases are the weakest link in the operationalisation
of recovery schemes.
23. Government has recently been found wanting
with regard to the implementation of European legislation on ozone
depleting substances. LARAC would like to see Government take
a stronger role in forward planning with regard to emerging European
legislation (eg WEEE, ELV). This would not only benefit those
authorities charged with managing waste, but also support the
development of the UK environmental technology sector.
24. Finally, within the fiscal and regulatory
arena, is the issue of market development and public procurement,
which has been at the forefront of LARAC's views for many years.
However, despite mention in numerous White Papers, the topic has
failed to garner the mainstream support required to achieve a
step change in market conditions for recycled materials.
25. Government procurement of recycled contents
is patchy and support from this Committee would be welcomed. However,
the issue of public procurement affects all local government and
associated organisations. As such it should be tackled in a similarly
comprehensive fashion. Support for regional procurement programmes
could be considered perhaps co-ordinated by the Regional Development
Agencies who are able to catalyse activity from the local economy
and waste sectors
26. In summary it is disappointing to note
the lack of progress in waste management since the publication
of Waste Strategy 2000. LARAC believes that waste management decision-making
is still based on held beliefs rather than scientific or evidence-based
approaches. The planning system is under yet greater pressure
to deal with the land-use consequences of more sustainable waste
management and public understanding, market development and public
procurement are still in their relative infancy. The policy direction
is generally sound although there are some fundamental gaps as
detailed by this evidence. Within the waste industry and local
government in particular there is an understanding and will to
take on the challenges that delivering sustainable waste management
presents. However, all too often this can be stifled by inertia
brought about by an incongruous and inconsistent policy framework
established by Waste Strategy 2000 and associated documents.
27. RECOMMENDATIONS FOR GOVERNMENT: LARAC
recommends that Government take urgent steps to address the following
key areas of strategy development and implementation:
27.1 Develop a forward thinking waste strategy
based upon the concept of sustainable resource use to include;
the use of product taxes, reuse schemes and higher levels of disposal
taxes.
27.2 Adopt overt political leadership and
backing for the objectives of Government Waste Strategy.
27.3 Establish long-term, realistic and
sustainable sources of funding for local authority recovery programmes.
27.4 Consider a wider use of Landfill Tax
Credit funds to support improvements in local authority waste
minimisation and recycling activities.
27.5 Develop a separate waste management
sub-block within the EPCS allocation of the SSA.
27.6 Establish funding and support for waste
minimisation that reflects the priority attached by all parties
to this policy goal.
27.7 Provide Government financial support
for a nation-wide campaign such as Reth!nk Rubbish.
27.8 Consider revised pooling arrangements
supported over a longer timeframe and accompanied by appropriate
freedoms and flexibilities.
27.9 Significantly increase Landfill Tax
graduated according to the hazardousness of the waste.
27.10 Speed up the planning system for waste
management projects.
27.11 Allow local authorities more powers
and incentive mechanisms to "enforce" participation
in private and public sector recovery schemes and cap levels of
household waste generation.
October 2002
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