Waste Strategy: Implications for local authorities Contents

1Consistency of services

11.In the Waste Strategy, and in its responses to four subsequent consultations, the Government has set out proposals to require local authorities to provide more consistent waste collection and disposal services to their communities.15 These include proposals for greater consistency in the collection of dry recyclable materials, weekly food waste collections, free garden waste collections, a minimum frequency for residual waste collections, and a new Deposit Return Scheme. This chapter outlines the evidence we heard regarding the desirability of greater consistency in the waste services provided by local authorities. In particular, we consider whether the specific proposals put forward by the Government are seen as beneficial or, alternatively, an intrusion into the rights of local representatives to decide what is best for their communities. The financial implications of these proposals will be addressed in the second chapter of this report.

Consultation within Government and with local authorities

12.Before considering the desirability of greater consistency in waste collection and disposal services, we first wanted to address concerns which were raised with us regarding the extent to which key stakeholders were consulted in advance of the publication of the Government’s proposals.

13.Local authority representatives reported that they were not consulted on the financial implications, the achievability of the Government’s recycling estimates, or the desirability of the proposals made within the Waste Strategy. The Local Government Association said they had not been given sufficient opportunities to question the data that underpinned the proposals before they had been published by the Government:

Unfortunately, to date, there has not been enough opportunity for us to question what is a significant set of reforms. It would therefore be remiss of us to commit to a future where we might need to increase council tax charges to deliver on the proposals being implemented by central government.16

Similarly, the District Councils’ Network reported that councils had not been able to review the data used in the Government’s Impact Assessments:

We cannot be fully certain of the financial implications to councils as we cannot be assured of the detail used to inform the impact assessments. If individual authorities are allowed to see the data profiles used we can ascertain if all allowances have been considered and that the forecasts and proposed funding would be sufficient to roll out any change in services.17

14.On whether the Government’s recycling targets were achievable, the Local Government Association said they could not comment on the accuracy or deliverability of these targets as they had not been involved in the development of them. They called on the Waste and Resources Action Programme (WRAP)—a charity which had undertaken the analysis upon which the Government had based its proposals—to share their data:

It is our understanding that WRAP has helped to develop these targets based on their data sets. It would be very useful to us as a sector if WRAP would share this data with us so that we can work together to understand if councils are confident about being able to reach these targets.18

Dr Marcus Gover, Chief Executive of WRAP, defended his organisation’s analysis and said that most of its work had already been published online, while the rest was in the possession of the Government.19 He told us that, if local authorities wanted further information, it would be for the Government to share that with them.

Inter-departmental consultation

15.Questions were also raised as to whether there had been sufficient inter-departmental consultation prior to the publication of the Waste Strategy. Councillor Peter Fleming, representing the District Councils’ Network, told us that MHCLG had been ‘blindsided’ by the proposals:

It was clear that the Ministry [of Housing, Communities & Local Government] were not really aware of the work that was going on in the Department [of Environment, Food & Rural Affairs]. We, as a major part of this whole policy, were clearly as blindsided as the Ministry were on it, which means that we had no opportunity to take part in the impact assessments. We do not know what is and is not included. Until we do, frankly they are not really worth the paper they are written on [ … ] Both the Ministry and local government were fairly blindsided by all this.20

16.The then-Minister for Local Government strongly denied that the MHCLG had been blindsided by the proposals, describing this as an “unfair characterisation.”21 He told us that there had been detailed discussions between the two departments, particularly with regard to the new burdens process. On the extent of the consultation undertaken with local authorities, the then-Minister for the Environment told us she had held regular meetings with the Local Government Association and other local authority stakeholders, and expressed her view that these groups “cannot try to say that this has come as any surprise or that we have not been in discussion” regarding the Government’s plans for the waste sector.22

17.We are concerned by reports from local authority representatives that they were not sufficiently consulted in advance of the publication of the Government’s Waste Strategy, particularly around recycling targets, financial implications and the desirability of the proposed changes to waste management services.

18.Government departments should establish better processes for consultation with local authority representatives prior to the announcement of policy proposals which directly affect them. It is also important to ensure that, prior to the publication of new Government consultations, policy proposals have the full support of all the departments to which they are relevant.

Principle of choice and flexibility for local authorities

19.The Government proposes greater consistency in household and business waste collections in England, which they say are vital to reach their new recycling targets:

Government has set ambitious commitments for recycling in the Strategy, including to achieve a 65 per cent recycling rate by 2035 and to work towards sending no food waste to landfill by 2030. To do this, we need comprehensive waste management and recycling services [ … ] These outcomes are vital if England is to reach its ambitious targets to recycle more and to achieve zero avoidable waste by 2050.23

The Government said its proposals would “provide the right balance between supporting local decision making and ensuring best practice is embedded within local authority practice.”24

20.We heard support for greater consistency in waste collection services. Dr Sherilyn MacGregor, from the Sustainable Consumption Institute at the University of Manchester, told us that the local authorities will have higher rates of recycling if their systems are consistent, reliable and easy for consumers to access.25 She noted that standardisation of waste services, particularly the colour of bins and the types of materials that can be recycled, will improve recycling rates by reducing confusion caused by regular movement of residents between local authorities. Similarly, the Renewable Energy Association (REA) supported greater consistency in collections to reduce confusion for householders:

It is important that there is greater uniformity in the manner in which we collect recyclates, as this reduces confusion to the householder and will also improve participation rates. The REA believes that there should be an element of flexibility allowed to local authorities where the alternative proposed [ … ] can be demonstrated to produce as good or better recycling performance.26

What is collected vs. how it is collected

21.Several witnesses said that it was more important that there is consistency in what is collected rather than how it is collected. Lee Marshall from the Local Authority Recycling Advisory Committee (LARAC) said, “[Waste] does not necessarily have to be collected in exactly the same manner, in exactly the same container, as long as everyone has access to being able to recycle the same materials.”27 Similarly, Jacob Hayler from the Environmental Services Association (ESA) noted:

The two key dimensions are what you collect and then how you collect it. We would like to see consistency around what you collect, because that could really help with consumer engagement, improving communications, clearer labelling [ … ] In terms of how stuff is collected, there needs to be some degree of flexibility so councils can adapt things to their local circumstances.28

22.We heard evidence, particularly from local authority representatives, that the proposals for consistency within the Waste Strategy would take too much power away from local decision makers. For example, Councillor Fleming told us that central Government should not be dictating the level of detail proposed within the Waste Strategy:

We either trust local government to find the scheme that best serves the people who we serve, or we dictate it from the centre [ … ] It is clear from this strategy that they want one scheme to conquer all, which is a national scheme. You have taken local decision-making out of it. If that scheme works and if that scheme is brought in by a council that has political legitimacy at the ballot box, I do not believe that this place should be dictating how we collect rubbish.29

Calls to retain flexibility

23.The vast majority of the written evidence we received called for local authorities to retain flexibility in the waste management services they provide. LARAC told us there were normally good reasons for local authorities providing different waste collection and disposal services and the Government should not seek to standardise waste services:

Differences in approach between authorities are there for a reason and having one standard system across the whole UK would introduce inefficiencies to waste services and in some instances may be almost impossible to operate. Local authorities must contend with a variety of factors and implement waste and recycling systems accordingly. Services will be impacted for example according to demographics, waste composition and the availability and location of appropriate infrastructure.30

24.The Local Government Association explained that an effective waste management system was one which reflected housing type, geography, population density and social demographics and, as such, “the waste collection system which is needed in Tower Hamlets will be quite different to the one needed in Cornwall.”31 Ian Fielding from the Association of Directors of Environment, Planning and Transport (ADEPT) said they would also advocate against a single national approach to waste collection and disposal:

[ … ] we would advocate against a one-size-fits-all type of approach. A single system would not be the right way of doing it, certainly not nationally, and there are some good reasons for that. There are things like differences in demography, differences in geography, affluence and all these things that will impact on the best way of delivering a waste management service in a particular area.32

25.We agree that it is important to improve recycling rates in England and believes that it is right that the Government has set ambitious targets. It is also clear that, to achieve higher recycling rates, there needs to be greater consistency in what is collected by local authorities.

26.However, there is an important distinction between what is collected and how it is collected. At times, the Government’s Waste Strategy seeks to dictate from the centre that which would be better decided by local decision makers. While it is reasonable for the Government to determine which materials should be recycled, we believe that local authorities should retain as much flexibility as possible to determine how waste should be collected in their communities.

Prevention of waste

27.At this point in the report, it is important to note that our inquiry has focused on the Government’s proposals for the collection of waste. However, it is also right for the Government to consider how to prevent waste. This is clearly set out in the Waste Hierarchy, which gives priority to the prevention of waste, followed by preparation for re-use, recycling, other recovery and, finally, disposal.33 Indeed, the Government is clear on the importance of the prevention of waste, with one of the five strategic principles within the Waste Strategy addressing the need to “prevent waste from occurring in the first place.”34 It is a clear motivation, for example, for the Government’s proposals for an Extended Producer Responsibility (EPR) scheme.35

28.We heard that plastic waste was a particular concern for local authorities. Government statistics showed that the UK produced 1.53 million tonnes of plastic waste in 2016, an increase of 24 per cent since 2010 and 13 per cent since 2014.36 The Mayor of Hackney, Philip Glanville, representing the Local Government Association, told us that there were seven different types of plastic currently entering the waste stream, and that it was very difficult and costly for waste authorities to deal with such a wide variety.37 We note that the Government has set out proposals for a plastic packaging tax, which would apply to any plastic packaging with less than 30 per cent recycled content, alongside its proposals for an EPR scheme.38 Our colleagues on the Environment, Food and Rural Affairs Committee have also been undertaking an inquiry into plastic food and drink packaging, and we await the publication of their final report.39

29.While our report focuses on the Government’s proposals in respect of the collection of waste, the most effective strategy is to prevent as much waste as possible in the first place. The Government is right to make the prevention of waste one of its five strategic principles within the Waste Strategy; indeed, it should be its top priority.

30.There is too much unrecyclable plastic currently in use. We believe that the Government should mandate the use of recyclable plastics where alternatives are available. Local authorities should also be required to provide facilities for the collection and disposal of recyclable plastics. Further, the Government should commission research into alternatives to plastic packaging materials which currently cannot be recycled.

Dry Recyclables

31.As noted by the then-Minister for the Environment, the law already requires local authorities to collect certain recyclable materials where that is technically, economically or environmentally practicable (TEEP).40 Existing regulations require local authorities to collect at least two types of recyclable material and separately collect plastics, metal, paper and glass for recycling.41 However local authorities are able to determine locally which of these materials should be collected and can cite a ‘TEEP exemption’ where they do not believe a material is practicable to collect. As noted by the Government, this has led to differences between councils, with some collecting a smaller range of materials than their neighbours.42

32.The Government is therefore proposing that local authorities collect a more consistent set of materials for recycling.43 The then-Minister for the Environment was clear that the Government’s proposals around dry recycling had been made to ensure “that we have that consistency of material and we are not dictating how that material should be collected.”44 The Government’s consultation response, published in July 2019, confirmed that it would seek to amend legislation to require all English local authorities to collect at least the following dry materials from 2023:

Consistency in the collection of dry recyclable materials

33.The Government has said that “normally” dry materials would be collected in one of the following ways:

Alongside the proposals for residual waste, food waste and garden waste collections—outlined later in this chapter—the Government would, therefore, be requiring people to have either four bins (one for recycling, one for residual waste, food waste and garden waste), five bins (two for recycling) or six bins (three for recycling) inside or outside their homes. The Government has said that its preferred option would be for local authorities to adopt a six-bin multi-stream dry recycling system, which it claims would leave councils with a £679 million saving over the period from 2023 to 2035.47

34.We heard scepticism that people would want to store so many bins, particularly those in smaller properties or flats. Professor Gregson, from the University of Durham, suggested that even four bins in a flat would be challenging.48 Philip Glanville agreed, telling us that, in an inner-city location, it would be “impossible for most flats to have that segregation at the household.”49 He expressed his view that the Government should not be prescribing how local authorities collect dry recycling:

Dictating that level of detail from Whitehall simply does not make sense and is not the experience of local authorities that have been delivering, tweaking, changing and piloting their waste streams [ … ] There is no assessment that has been shared with the LGA, which the LGA has been able to test, that has proven that moving to six bins will see that increase in recycling rates [ … ] To have that set out from the centre, without a clear evidence base of why it would be better, is what we are disputing.50

Councillor Fleming agreed, telling us that the Government “need to keep all the options open for local authorities to find the best scheme for their local area.”51

35.However, Martin Curtois, representing the waste management company Veolia, told us that there were currently over a hundred different waste collection systems in operation around the country, and the Government was right to seek to reduce that to a choice of three systems.52 Similarly, Jacob Hayler from the ESA argued that the Government had proposed the right level of flexibility for dry recycling:

We think the three systems that were in the 2016 WRAP consistency framework should provide the degree of flexibility councils need. We would not like to see further restrictions—say, trying to go down to two or one system. With three you have enough, but fewer than three places too many constraints on councils.53

36.The Government is right to propose to retain flexibility for local authorities in how dry recyclables will be collected. However, we expect that most local authorities will not want to ask their residents to store six separate bins outside or inside their homes, particularly in urban areas where space is likely to be more limited. Even four receptacles—the minimum the Government is proposing—will be challenging in many circumstances.

Weekly food waste collections

37.The then-Minister for the Environment told us that, “where we want to be more insistent is the separate collection of food waste.”54 The Government has proposed that, from 2023, all local authorities be required to provide households with a free, separate, and weekly food waste collection.55 Currently, 51 per cent of councils collect food waste separately from residual waste, of which 35 per cent collect food waste separately on a weekly basis.56

38.The Government has highlighted what it believes would be the environmental benefits of providing separate food waste collections. They note that approximately 1.9 million tonnes of household food waste is sent to landfill each year, where it releases methane into the atmosphere.57 Separately collected food waste, by contrast, could be sent for composting or anaerobic digestion (AD), where it can be refined as biomethane and fed into the national gas grid, used to generate electricity, or used as a vehicle fuel or fertiliser. However, the National Association of Waste Disposal Officers (NAWDO) called on the Government to provide further information on the environmental benefits of introducing food waste collection for AD, as compared with the collection of food waste as part of residual waste for treatment by Energy for Waste incineration, rather than comparing against landfill, which is no longer the default residual waste management option.58

39.We heard mixed views as to whether the Government should require local authorities to provide weekly food waste collections. Jeremy Jacobs from the Renewable Energy Association said food waste “definitely should be collected weekly.”59 Similarly, Lee Marshall from LARAC told us that “we all broadly support” the Government’s food waste proposals, although he noted concerns around the adequacy of the funding for this service.60

40.Other witnesses, however, were less supportive of a consistent national approach to food waste collections. The Association of Directors of Environment, Planning and Transport (ADEPT) told us that the proposal would add significant additional cost and be complex to deliver, and argued that councils should be free to decide themselves on the balance of cost and benefit for separate food waste collections, depending on local circumstances.61 They said the proposal would not represent good value for money in all circumstances and should be assessed on a case-by-case basis. The ESA noted that there could also be challenges of participation, particularly in dense urban areas with a large number of flats.62

41.Further, several organisations noted that removing food waste from the residual waste stream could lead to local authorities not meeting long-term contractual requirements, including around Guaranteed Minimum Tonnages (GMT) or providing sufficient calorific content to run Energy from Waste incineration facilities.63 Councillor Fleming warned that these were expensive facilities, and the Government may be reluctant to subsidise those in the future if local authorities were no longer able to meet those costs on their own.64

42.The Government’s July 2019 consultation response confirmed that it would seek to legislate to ensure that every local authority provides householders with a separate food waste collection.65 However, the Government also noted that further consideration was needed with respect to local circumstances and they have committed to working with local authorities to consider how these should best be taken into account.

43.We do not feel that the Government has made a strong case for the implementation of separate weekly food waste collections. Our view is that the existing system, where waste collection processes are determined locally by people who know their areas best, and very few local authorities currently have weekly food waste collections, works perfectly well. There is also likely to be a very significant cost associated with the implementation of this proposal and local authorities have expressed concerns around funding for this service.

Fortnightly residual waste collections

44.The Government has proposed that alternate weekly collection of residual waste should be a minimum expectation for householders. Noting a manifesto commitment to support frequent and comprehensive rubbish and recycling collections, the Government said it wanted to:

[ … ] ensure that householders are not inconvenienced by being unable to get rid of putrescent or smelly waste weekly or having insufficient capacity to recycle or to remove residual waste [ … ] We think this approach provides the right balance between local decision making and providing a good level of service to householders.66

45.The Government’s proposal has been met with opposition from local authority representatives. LARAC told us that several authorities had decided to collect residual waste every three weeks because, “not only does this offer financial benefits, there are evidenced behavioural change benefits that show increases in recycling.”67 The Somerset Waste Partnership said they could demonstrate that moving residual waste collections to every three weeks would increase food waste collection by 20 per cent and dry recycling by 30 per cent.68

46.The evidence we received was clear that local authorities wanted to retain the right to determine the frequency of residual waste collections. The Local Government Association described the Government’s proposal as a “retrograde step” and said it showed that the Government was “not in touch with what needs to be delivered on the ground.”69 Councillor Fleming told us that it “has to be up to the local authority to decide the best method for residual waste”, while Philip Glanville, Mayor of Hackney, said:

There are good examples of fortnightly and three-weekly collection of residual waste. It is also then about investment required in food waste and recycling collections in between. All those decisions are best taken locally and have been iterations that people have gone through [ … ] To say by a certain date that it should be fortnightly or more frequently would just be an error.70

47.In the Government’s response to its consultation, it noted the strong opposition from local authorities to the proposal for fortnightly residual waste collections.71 The Government said it would work with local authorities and to prepare statutory guidance on minimum service standards for waste and recycling and give further consideration to the proposals for a minimum frequency of residual waste collection and prepare further analysis of costs and benefits.

48.The Government is wrong to insist that local authorities collect residual waste at least every two weeks. It should be for local decision makers, who are accountable to their communities through the ballot box, to determine the frequency of residual waste collections in their areas. The Government should not dictate from the centre that which is better determined at the local level. We are also persuaded of the potential benefits to recycling rates of less frequent residual waste collections.

Free garden waste collections

49.The Government has consulted on whether local authorities should be required to provide a free garden waste collection service.72 This, they told us, would bring environmental benefits, including a reduction in the level of garden waste entering the residual waste stream, where it would be sent to landfill or for incineration.73

Chasing tonnage

50.The then-Minister for the Environment was very open about why the Government was targeting garden waste; she told us, “It is about chasing tonnage; there is no doubt about that.”74 ‘Chasing tonnage’ refers to the practice of prioritising the collection of materials that are heavy in order to meet targets, and not necessarily because there would be significant environmental benefits of doing so. Garden waste is heavy, and the then-Minister admitted that the Government would struggle to meet its target of a 65 per cent recycling rate by 2035 without collecting garden waste. Indeed, Jacob Hayler, from the ESA, told us there was “no way we are going to reach the future targets if we do not have the contributions from [ … ] garden waste.”75 The Government estimated that a free garden waste collection service could see overall household recycling rates increase by 6 per cent compared to current levels.76

51.Several organisations criticised the Government for openly chasing tonnage. LARAC told us that the Government’s proposal “goes against the Waste Hierarchy and good environmental practice.”77 The Waste Hierarchy—which ranks waste management options according to what is best for the environment—would prioritise home composting above the collection and disposal of waste by local authorities, although the then-Minister for the Environment noted that composting still needed to be done carefully in order to limit carbon emissions.78 The Somerset Waste Partnership warned that, in Somerset alone, if residents were to stop home composting, an estimated 7,273 tonnes of garden waste might be diverted from the best environmental option to the household waste stream.79 Councillor Fleming, representing the District Councils Network, noted that this was the only area of the Waste Strategy where the Government seemed to be promoting a policy which ran contrary to the principles in the Waste Hierarchy:

It is interesting that the rest of the strategy looks at the waste hierarchy and yet, when it comes to garden waste, where you would want to be promoting composting, it is suddenly, “Provide a free service and collect it all.”80

Calls for local flexibility

52.We heard considerable opposition to the introduction of a free garden waste collection service from local authority representatives. Philip Glanville, representing the Local Government Association, told us that this was “not an area that should be dictated from the centre.”81 Similarly, Councillor Fleming said it made “very little sense” to ask local authorities who had already introduced a chargeable service to stop charging and provide the service for free.82 He noted the significant logistical challenges arising from the proposal, telling us that it would be very difficult for every council to attempt to procure staff, machinery and resources to collect green waste for free during an undefined growing season, all at the same time.83

Subsidising wealthier homeowners

53.The proposal for free collections was also criticised for being unfair on residents who did not have gardens, with some arguing that poorer residents would effectively be subsidising wealthier homeowners with gardens. This was a point made by Professor Gregson, who told us she would not be supportive of a free service.84 The District Councils’ Network argued that a system which saw “a vast majority of residents subsidising a scheme they cannot receive” would not be viable.85 The National Association of Waste Disposal Officers (NAWDO) told us that there was little evidence of garden waste being diverted to residual waste where charging had been introduced—suggesting that a garden waste service did not need to be free in order to be effective.86

Value for money

54.Several organisations raised concerns around the financial implications of the policy. The Somerset Waste Partnership reported that, in Somerset, 4,750 tonnes of garden waste was put into the residual waste stream each year, compared to an estimated £6 million cost of providing a free collection service.87 Consequently, the policy could cost over £1,200 per tonne to capture all of the garden waste that was currently put into residual waste:

We believe that this isn’t good value for money, is disproportionate, is inequitable, and through discouraging home composting it is not environmentally the right thing to do.88

They also warned that the proposal could threaten the long-term viability of recycling centres, for which garden waste was one of the top two reasons why people used them.89 The then-Minister for the Environment told us she did not believe that this would be the case, although she admitted this was based on her perception as opposed to any data she had received.90

55.The Government’s July 2019 consultation response noted many of the criticisms that we heard in our evidence and said that Ministers would give further consideration to the costs and benefits of this measure before making a final decision on whether garden waste collections should be free of charge, or whether charging should be a matter for local decision making.91

56.The Government should not require local authorities to implement a free garden waste collection service. The current system, where most local authorities provide a chargeable service to households that want it, works perfectly well. While a free service might improve the Government’s recycling statistics, the environmental benefits are less clear. This is another area in which the Government should not seek to dictate from the centre.

Deposit Return Scheme

57.The Government has proposed to introduce a Deposit Return Scheme (DRS) for single-use drinks containers through a new Environment Bill, confirming this in its consultation response in July 2019.92 In a DRS, consumers are charged a deposit when they buy a drink in a single-use container, which could then be redeemed when the container is returned. The Government’s consultation document noted that local authorities would be affected by any future DRS scheme, both in terms of lost income as high-value recyclates are removed from the waste stream, but also opportunities to increase revenues through the redemption of deposits:

A DRS may move higher-value recyclable materials away from local authority collections, which will reduce both their income from the sale of these materials as well as their costs of managing these materials [ … ] We also anticipate that where consumers choose not to return their drinks containers to a designated DRS return point, DRS material would end up in kerbside collections, and the deposit value would fall to local authorities, should they choose to redeem it. We are considering a funding formula whereby local authorities could be paid the deposit amount on drinks containers [ … ] without having to physically return them via a designated return point.93

58.The Government has proposed two options for a DRS: an ‘all-in’ model, which would not place any restriction on the size of drinks containers; or an ‘on-the-go’ model, which would be restricted to smaller containers sold for consumption outside the home. In July, the then-Secretary of State for Environment, Food and Rural Affairs, Rt Hon. Michael Gove MP, revealed his preference for an all-in system:

The Government’s waste reduction partner, WRAP, have persuasively argued that the deeper that deposit return schemes drill into the value chain–extending to cover full life cycle costs under producer responsibility, and an ‘all in’ standard–the clearer the financial and social signal will be to recycle. We need to work with business to make deposit return schemes as effective as possible and I believe an ‘all-in’ model will give consumers the greatest possible incentive to recycle.94

The Government’s consultation response noted that a majority (59 per cent) of respondents also stated a preference for the all-in model, although it said that a final decision on the nature of the DRS scheme, including the material and drinks to be included in scope, would be developed using further evidence and through ongoing engagement with stakeholders.95

Calls for a deferral of the scheme

59.While some organisations, such as the Campaign to Protect Rural England (CPRE), told us they were supportive of the Government’s proposals for a DRS, several witnesses called on the Government to defer its implementation until after the Extended Producer Responsibility (EPR) scheme and other consistency proposals had been implemented.96 The Somerset Waste Partnership described the implementation of a DRS alongside the other proposals as “too much, too soon” and was likely to result in duplication and unnecessary additional costs.97 LARAC noted the “potentially big changes” the Government had proposed and called on the Government to first establish their impact before introducing another significant change to the system.98

60.We heard particular concerns around the potential costs to local authorities were a DRS to result in higher-value recyclates being removed from council waste collections, which they are often required to provide through their contracts waste management companies. Cathy Cook from the London Waste and Recycling Board (LWARB) outlined some of the financial risks to local authorities:

Some of the financial risks that we have looked at are things like the higher-quality materials possibly going into the DRS deposit points rather than the kerbside, which would generally make a lot of the collections less efficient, possibly with vehicles carrying less material, still having to go to each of the properties but not collecting as much. There is the possibility of some people looking through bins and trying to get good-quality materials out to get deposits back from some of the reverse vending machines and this sort of thing.99

61.We heard that the loss of income to local authorities was unlikely to be offset by operational efficiencies. Cathy Cook expressed her view that it could be harder for local authorities to agree good contracts if they were not able to collect good-quality materials.100 At the same time, as noted by Gurbaksh Badhan from NAWDO, costs would be maintained: “You still have to go out, you still have to go and clean the street and you still have to send people out, so those costs will still be in the system. There is no ability to offset that.”101

62.Some witnesses told us that a DRS should not go ahead at all. Ian Fielding from ADEPT argued that the Government had failed to make the business case for a DRS, with an over-reliance on “unproven analysis” with regard to the potential reduction in littering:

The case for a DRS within the Government’s consultation seems to be predicated largely on avoiding litter [ … ] The Government have recognised that there is a need to do a lot more work on this. We do not believe that they have effectively proven the business case for a DRS. If a DRS is going to be rolled out and implemented, it does not seem sensible to include those materials that are not prevalent in litter to any large degree.102

63.Were a scheme to go ahead, there was no consistent view expressed by our witnesses as to a preferred option. We heard calls for an ‘all-in’ system from LWARB and NAWDO, who argued that it was the simplest proposal and would avoid confusion for the consumer.103 Others, including Veolia, ADEPT and LARAC, argued for an ‘on-the-go’ system, telling us that it would be a more manageable system that would have less of a negative effect on local authority collection services.104

64.Some witnesses suggested that a DRS should focus on different materials entirely. The ESA told us that a DRS should be introduced for things that were not already widely recycled, such as coffee cups and batteries.105 Otherwise, they argued, it would be “taking a key revenue stream away from local authorities, and would add more cost to the system” by putting in place machines to capture material that is already recycled at a lower cost.

65.We do not agree with the Government’s intention to take forward its proposals for a Deposit Return Scheme (DRS) through an upcoming Environment Bill. Instead, the Government should listen to local authorities and defer the implementation of a Deposit Return Scheme (DRS) for the time being. We heard significant concerns about the financial implications arising from a DRS and the Government should not add further complexity and uncertainty into the system, given the significant changes it is already proposing.


15 Our Waste, Our Resources: A Strategy for England, Department for Environment, Food & Rural Affairs, December 2018, and Consistency in recycling collections in England: executive summary and government response; Packaging waste: changing the UK producer responsibility system for packaging waste; Introducing a Deposit Return Scheme (DRS) for drinks containers (bottles and cans); Plastic packaging tax, Department for Environment, Food & Rural Affairs, 23 July 2019

16 Local Government Association (IWS0024), para 2.3

17 District Councils’ Network (IWS0010)

18 Local Government Association (IWS0024), para 4.3

19 Q19–21 (Dr Marcus Gover, WRAP)

20 Q144/Q160 (Councillor Peter Fleming, District Councils’ Network)

21 Q169 (Rishi Sunak MP, then-Minister for Local Government)

22 Q168 (Dr Thérèse Coffey MP, former-Parliamentary Under-Secretary of State for the Environment)

23 DEFRA (IWS0028), para 39

24 DEFRA (IWS0028), para 40

25 Dr Sherilyn MacGregor (IWS0013)

26 Renewable Energy Association (IWS0026), para 16

27 Q101 (Lee Marshall, Local Authority Recycling Advisory Committee)

28 Q69 (Jacob Hayler, Environmental Services Association)

29 Q148–9 (Councillor Peter Fleming, District Councils’ Network)

30 Local Authority Recycling Advisory Committee (IWS0017), para 26

31 Local Government Association (IWS0024), para 6.4

32 Q101 (Ian Fielding, Association of Directors of Environment, Planning and Transport)

33 Guidance on applying the waste hierarchy, Department for Environment, Food & Rural Affairs, 15 June 2011

34 Our Waste, Our Resources: A Strategy for England, Department for Environment, Food & Rural Affairs, December 2018, page 17

35 Our Waste, Our Resources: A Strategy for England, Department for Environment, Food & Rural Affairs, December 2018, page 29

36 Plastic Waste, House of Commons Library, 17 June 2019, page 5

37 Q147–8 (Mayor Philip Glanville, Local Government Association)

38 Plastic packaging tax: consultation, Department for Environment, Food & Rural Affairs, 18 February 2019

39 Plastic food and drink packaging inquiry, Environment, Food and Rural Affairs Committee

40 Q171 (Dr Thérèse Coffey MP, former-Parliamentary Under-Secretary of State for the Environment)

41 DEFRA (IWS0028), para 19

42 DEFRA (IWS0028), para 19

43 Consultation on Consistency in Household and Business Recycling Collections in England, Department for Environment, Food & Rural Affairs, 18 February 2019

44 Q171 (Dr Thérèse Coffey MP, Parliamentary Under-Secretary of State for the Environment)

45 Consistency in recycling collections in England: executive summary and government response; Department for Environment, Food & Rural Affairs, 23 July 2019

46 Consultation on Consistency in Household and Business Recycling Collections in England, Department for Environment, Food & Rural Affairs, 18 February 2019, page 9

47 DEFRA (IWS0028), paras 10–11

48 Q29 (Professor Gregson, University of Durham, and Dr Marcus Gover, WRAP)

49 Q150 (Mayor Philip Glanville, Local Government Association)

50 Q150–1 (Mayor Philip Glanville, Local Government Association)

51 Q151 (Councillor Peter Fleming, District Councils’ Network)

52 Q69 (Martin Curtois, Veolia)

53 Q69 (Jacob Hayler, Environmental Services Association)

54 Q176 (Dr Thérèse Coffey MP, former-Parliamentary Under-Secretary of State for the Environment)

55 Consultation on Consistency in Household and Business Recycling Collections in England, Department for Environment, Food & Rural Affairs, 18 February 2019

56 Consultation on Consistency in Household and Business Recycling Collections in England, Department for Environment, Food & Rural Affairs, 18 February 2019, page 26

57 DEFRA (IWS0028), paras 24

58 National Association of Waste Disposal Officers (IWS0032), para 1.6

59 Q70 (Jeremy Jacobs, Renewable Energy Association)

60 Q103 (Lee Marshall, Local Authority Recycling Advisory Committee)

61 Association of Directors of Environment, Economy, Planning and Transport (IWS0025), para 29

62 Environmental Services Association (IWS0019), para 10

63 For example, Local Authority Recycling Advisory Committee (IWS0017), para 25, and Q156 (Councillor Peter Fleming, District Councils’ Network)

64 Q156 (Councillor Peter Fleming, District Councils’ Network)

65 Consistency in recycling collections in England: executive summary and government response; Department for Environment, Food & Rural Affairs, 23 July 2019, para 3.1.2

66 DEFRA (IWS0028), para 34

67 Local Authority Recycling Advisory Committee (IWS0017), para 5

68 Somerset Waste Partnership (IWS0012), para 2.1

69 Local Government Association (IWS0024), para 6.6

70 For example, Q152 (Councillor Peter Fleming, District Councils’ Network, and Mayor Philip Glanville, Local Government Association)

71 Consistency in recycling collections in England: executive summary and government response; Department for Environment, Food & Rural Affairs, 23 July 2019, para 3.1.3

72 Consultation on Consistency in Household and Business Recycling Collections in England, Department for Environment, Food & Rural Affairs, 18 February 2019, page 29

73 Consultation on Consistency in Household and Business Recycling Collections in England, Department for Environment, Food & Rural Affairs, 18 February 2019, page 29

74 Q189 (Dr Thérèse Coffey MP, former-Parliamentary Under-Secretary of State for the Environment)

75 Q71 (Jacob Hayler, Environmental Services Association)

76 DEFRA (IWS0028), para 30

77 Local Authority Recycling Advisory Committee (IWS0017), para 18

78 Q191 (Dr Thérèse Coffey MP, former-Parliamentary Under-Secretary of State for the Environment)

79 Somerset Waste Partnership (IWS0012), para 3.1

80 Q153 (Councillor Peter Fleming, District Councils’ Network)

81 Q153 (Mayor Philip Glanville, Local Government Association)

82 Q153 (Councillor Peter Fleming, District Councils’ Network)

83 Q143 (Councillor Peter Fleming, District Councils’ Network)

84 Q42 (Professor Gregson, University of Durham)

85 District Councils’ Network (IWS0010)

86 National Association of Waste Disposal Officers (IWS0032), para 1.6

87 Somerset Waste Partnership (IWS0012), para 2.3

88 Somerset Waste Partnership (IWS0012), para 2.3

89 Somerset Waste Partnership (IWS0012), para 2.3

90 Q192–3 (Dr Thérèse Coffey MP, Parliamentary Under-Secretary of State for the Environment)

91 Consistency in recycling collections in England: executive summary and government response; Department for Environment, Food & Rural Affairs, 23 July 2019, para 3.1.2

92 Introducing a Deposit Return Scheme (DRS) for drinks containers (bottles and cans), Department for Environment, Food & Rural Affairs, 23 July 2019

93 Introducing a Deposit Return Scheme (DRS) in England, Wales and Northern Ireland, Department for Environment, Food & Rural Affairs, 18 February 2019, page 7

94 Rt. Hon. Michael Gove MP, Secretary of State for Environment, Food and Rural Affairs, Kew Gardens, 16 July 2019

95 Introducing a Deposit Return Scheme (DRS) for drinks containers (bottles and cans), Department for Environment, Food & Rural Affairs, 23 July 2019, para 38

96 Letter from Tom Fyans, Deputy Chief Executive, Campaign to Protect Rural England, 5 July 2019

97 Somerset Waste Partnership (IWS0012), Executive Summary

98 Local Authority Recycling Advisory Committee (IWS0017), para 13

99 Q126 (Cathy Cook, London Waste and Recycling Board)

100 Q127 (Cathy Cook, London Waste and Recycling Board)

101 Q128 (Gurbaksh Badhan, National Association of Waste Disposal Officers)

102 Q123 (Ian Fielding, Association of Directors of Environment, Economy, Planning and Transport)

103 Q124 (Gurbaksh Badhan, National Association of Waste Disposal Officers) and Q126 (Cathy Cook, London Waste and Recycling Board)

104 Veolia (IWS0021) and Q121–3 (Ian Fielding, Association of Directors of Environment, Economy, Planning and Transport, and Lee Marshall, Local Authority Recycling Advisory Committee)

105 Environmental Services Association (IWS0019), para 9




Published: 5 September 2019