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Waste Strategy: Implications for local authorities: Government Response to the Committee’s Nineteenth Report of Session 2017–19

First Special Report

The Housing, Communities and Local Government Committee published its Nineteenth Report of Session 2017–19, Waste Strategy: Implications for local authorities [HC 2071], on 5 September 2019, as House of Commons Paper HC 2071. The response from the Government was received on 17 March 2020 and is appended below.

Appendix: Government Response

Executive Summary

The government thanks the Committee for its report on the Waste Strategy and its implications for local authorities. In the 25 Year Environment Plan, the government pledged to leave the environment in a better condition for the next generation. Key to this is moving towards a circular economy to keep resources in use for as long as possible while reducing waste and reliance on primary materials. The recently published Environment Bill carries forward this commitment and proposes measures that will help to achieve these ambitions. This includes measures to ensure all households and businesses are able to recycle the same materials and powers to ensure producers take full responsibility for packaging placed on the market and to introduce a deposit return scheme.

In all this, the government recognises the central and important role that local authorities play in delivering our circular economy at a local level. Local authorities provide essential local services to manage, treat and recycle household waste, turning it into new resources. Local decision making is key to determining the best arrangements for collecting waste and recycling; while ensuring cost effective treatment.

As the Committee notes, the government has a clear role to play and must set the national framework for waste management in line with principles such as the waste hierarchy (i.e. seeking to prevent waste, then preparation for reuse, recycling, recovery or finally as a last resort disposal (for example to landfill)). The government must also take the lead on setting sustainability goals, ensuring we are able to meet international obligations to reduce carbon emissions or national targets for recycling and reducing waste to landfill. Without a national framework we will not achieve our long term goal for net zero carbon emissions by 2050 or reduce the impact of waste on the environment.

We agree with the Committee’s comments that there is a balance to be struck between local decision making and what the government sees as necessary to increase the quantity and quality of recycling. However we disagree with the Committee’s conclusion that Government’s Resources and Waste Strategy has sought to dictate from the centre what is best decided at local level. Our consultations on producer responsibility and consistency, alongside discussions with local government and industry stakeholders demonstrated that there is support from producers, the public and local authorities for central government to take a lead. There is also support for having all local authorities in England collect the same range of materials from households and provide for separate food waste collection. In our approach we have been clear that local decision making is key to effectively implementing these reforms. It should also be noted that in recent decades, the requirements of EU Directives have imposed top-down requirements on local councils, and regulated how they provide local waste services. Parliament has also previously legislated directly (e.g. the Household Waste Recycling Act 2003) to set minimum requirements on household recycling.

The government continues to believe that local authorities are best placed to understand local challenges and to deliver services at local level. However, not all local authorities provide the same level of service or collect the same range of materials. This means that producers are not able to definitively label all packaging as collected for recycling so householders are not always clear on what materials can be recycled locally from looking at packaging. In addition whilst there is much potential to recycle food waste only a third of local authorities have regular separate food waste collections. The costs of establishing a collection have in particular been highlighted by local authorities that want to introduce these services but face difficulty in making the initial investment. In order to address these concerns and to increase recycling of these materials, the government has seen it necessary to propose legislation to establish a consistent approach for the materials collected and to support action to expand separate collection of food waste. The government has also made clear that it will ensure the costs of these new duties on local authorities are properly funded.

We will continue to work closely with local authorities to implement reforms. The government is committed to funding the new burdens on local government in line with the New Burdens Doctrine and Defra will work with MHCLG. The Committee is right that there is a distinction between what is collected and how it is collected and the government believes that it has got the balance right. In developing the next phase of the consultation we will ensure local authorities are able to take account of local circumstances when delivering local services whilst also complying with their statutory duties. The government has also met regularly with the Local Government Association (LGA) to discuss these issues.

We respond to the points made by the committee on these policies below.

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. (Paragraph 18)

The government is satisfied that the proposals were extensively discussed with stakeholders prior to announcement and also that other Departments were adequately consulted and agreed on the published consultation documents.

The government engaged in extensive consultation with local authorities and stakeholders prior to the release of our consultations on consistency in recycling, extended producer responsibility reforms for packaging (EPR) and whether to introduce a deposit return scheme for drinks containers (DRS) in February 2019. This engagement built on extensive formal and informal consultation that took place before and after the launch of our Resources and Waste Strategy 2018 and the development of policies in 2018. A representative from local government was also seconded to the policy team in Defra to support work on developing the Resources and Waste Strategy. Policy on consistency in recycling has been in development since 2015 when then Defra Ministers asked WRAP to work with an industry advisory group which included representatives from the LGA and local government bodies to develop a voluntary framework for consistency in recycling. This was published as a “Framework for Greater Consistency in Recycling Collections” in 2016. This publication was supported by an evidence document that outlined the initial modelling of the proposals. The actions in the framework were developed through the advisory body over 2016/17 and 17/18.

During the development of the recent consultation document, officials met with local government and industry representatives to set out options for introducing consistency and to discuss policy proposals. An overview of the modelling approach, based on the approach taken in the original “Framework for Greater Consistency” was also shared in advance of consultation. During the consultation period itself officials met with the local government Association and with local authorities to share the analysis and to provide greater transparency on the details of the modelling. We are continuing this engagement to ensure our final proposals continue to take into account local authority views.

All government policy proposals are subject to collective agreement and clearance; without this it cannot become government policy. The consultation proposals formed part of the Resources and Waste Strategy which was extensively discussed with other government departments. These departments included the Ministry for Housing, Communities and Local Government and Her Majesty’s Treasury as well as the Department for Business, Energy and Industrial Strategy. Advice from MHCLG on the application of new burdens and local decision making was taken into account during the development of the Resources and Waste Strategy, as well as the consultation document on consistency in recycling. The final Resources and Waste Strategy and the three policies consulted upon in 2019 were all subject to standard Cabinet Committee clearance procedures. This obtained cross government support for the Strategy and approval to consult on the proposals for EPR, DRS and greater consistency in recycling.

Over the 12 weeks that stakeholders were given to respond to our consultations, we received 1,713 responses for our consultation on consistency (241 from local authorities and their representative bodies), 679 responses for the extended producer responsibility consultation and 208,269 for our consultation on a deposit return scheme including campaign responses. All three consultations received significantly more responses than many previous consultations published by Defra, this level of participation from the public and from stakeholders is in part due to our high level of engagement prior to and during the consultation period. The response to our consultation on consistency shows a high level of support for our proposals from stakeholders across the board, including from local authorities. We have made clear that through the application of new burdens doctrine, local authorities will have the cost arising from new statutory duties covered. This would include both transition and on-going costs and would avoid undue pressure on other services. Our future consultations (in 2020) will build on the feedback we have received and policy decisions will be taken in light of this.

There will be further consultation on secondary legislation and guidance in relation to proposed changes on consistency In light of the committee’s comments we will review arrangements to engage with the LGA and local government representatives to ensure they are fully consulted on the development and implementation of proposals. This work has already begun and we will continue to engage with the LGA and MHCLG to provide assurances about the approach taken to assessing costs to local government and in ensuring new burdens principles are applied. We will also continue to build on engagement across Whitehall and with the sector to ensure policies are developed effectively.

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. (Paragraph 26)

Dry Recycling Collection and Local Decision Making

The government is pleased that the committee agrees with the importance of recycling and the need to improve recycling rates in England. We are also pleased that the Committee agrees with the need to set ambitious targets and to have consistency in what is collected by local authorities, if we hope to achieve higher levels of recycling as part of a comprehensive waste collection service for households.

We disagree that the Resources and Waste Strategy seeks to dictate what is better left to local decision making. The government has been clear that we believe local authorities are best placed to understand their local circumstances. Having said that, local authorities will be required to collect glass, metal, plastic, paper and card, food waste and garden waste for recycling, as set out in the Environment Bill. There will be no exemptions from collecting the core materials. Our available evidence shows that collecting recyclable materials separately is the best way to improve quality and that local authorities should follow this approach as a first principle. This is why current legislation requires waste collectors to separately collect glass, paper, plastic and metal except where this is not necessary to achieve high quality or it is not technically, environmentally or economically practicable to collect these separately. This approach is carried through in the Environment Bill measures on separate collection. This will support high quality recycling which attracts higher value on recycling markets.

Importantly though, the requirements of separate collection in the Environment Bill recognise that local circumstances will mean that some local authorities are not able to separate dry materials in every circumstance. There may be local technical, environmental or economic conditions that require a mixed collection to deliver the best service locally, within the framework set by law, we will produce statutory guidance to assist local authorities on this.

Separate Food waste Collection

The government notes the Committee’s views on separate food waste collection. The government believes that the first step in reducing food waste should be prevention and has supported measures to reduce food waste in the home and in the supply chain for many years. However there will always be some level of unavoidable food waste which if not collected separately would potentially go to landfill or otherwise be lost from the opportunity to recycle usefully through either anaerobic digestion or composting.

Separate collection of food waste in England has increased every year since 2010 as has the tonnage collected which was 386,000 tonnes in 2017. There is however potential to collect much more unavoidable food waste from households and to have this recycled to produce biomethane and digestate which can be spread to land in accordance with good practice guidance on land spreading. Our recent consultation on consistency estimated that over 1.3m tonnes of unavoidable food waste could be recycled if all households had a separate food waste collection.

Currently, 51% of local authorities in England collect food waste separately from residual waste. Of these local authorities, 35% collect food waste separately on a weekly basis, 12% collect food waste mixed with garden waste, usually on a fortnightly basis and the remaining 4% operate both systems depending on local circumstances. Our analysis shows that if all local authorities provided at least kerbside properties with a separate food waste collection service, this would increase the amount of food waste collected by 1.35 million tonnes by 2029 and reduce greenhouse gas emissions by an estimated 1.25 million tonnes a year. This would increase the household recycling rate in England by 5% points. WRAP has estimated that UK food waste sent to anaerobic digestion (AD) produces 1,000 GWh, enough to power 1 million homes for over one month.

The waste hierarchy as set out in the Waste (England and Wales) Regulations 2011 requires everyone handling waste materials or products to follow the principles of prevention, preparation for reuse, recycling, recovery and disposal. The government has published guidance and supporting evidence on the waste hierarchy.1 This has shown that anaerobic digestion of food waste delivers the greatest carbon benefits for recycling compared to food waste going to energy recovery. The government supports anaerobic digestion as it represents the best environmental outcome for the treatment of unavoidable food waste. On a like for like basis AD is more efficient for energy production and for its optimum value produces bio- methane, heat and fertiliser. In addition where food waste is collected separately the quality of dry recycling collected improves.

Our consultation stage impact assessment estimates an investment of £180 million—£260 million would be needed to roll out separate food waste collection from households across England. These costs would cover additional bins, vehicles, transportation of food waste to AD sites and free caddy liners. Given the additional costs involved in separate food waste collection the government is committed to funding the new burdens on local government in line with the New Burdens Doctrine and will ensure that local authorities are resourced to meet new costs arising from this policy including upfront transition costs and ongoing operational costs.

We therefore believe that there is indeed a strong case for separate collection of food waste for treatment through anaerobic digestion. This supports other government policies to decarbonise energy production and to reduce reliance on fossil fuels. This is also borne out by our consultation in 2019, which demonstrated that there was a high level of support for the measure from the vast majority of stakeholders including over 60% of local authority respondents. As stated previously we recognise that there are local considerations to be taken into account on delivery. We want to work with local authorities that currently do not collect food waste or have a mixed food and garden waste collection to help them to introduce separate collections where practicable. This will be done as part of our implementation of consistency reforms.

Frequency of Waste Collections

Since 2010, the government has taken a series of steps to support frequent and comprehensive rubbish and recycling collections. This has included scrapping plans for new taxes on household waste collections; putting new rules in place to stop the issuing of unfair fines for minor breaches of rules on bin collections; supporting local incentives and rewards for recycling, and banning charges for responsibly disposing of household rubbish at local civic amenity sites. The government has actively encouraged a comprehensive weekly service.2

Councils will get access to £2.9bn of extra funding available to them in 2020/21 for core services, including waste services and also measures to support recycling reward schemes. Not all local authorities provide the same level of service or collect the same range of materials. Through the introduction of our proposals we aim to have consistency across local authorities in what is collected for recycling to reduce confusion over what can and cannot be recycled both in the home and at work.

As food waste and dry recycling collections increase, one would expect the amount of residual waste collected to reduce. Since 2001 residual waste has fallen; but reductions in the level of residual waste then led many local authorities to review the frequency of residual collections and reduce them. This has led to widespread public concern and controversy about households receiving a reduced collection service, which is a particular problem for large families, and for households without outside bin storage. There is a particular concern that a small number of local authorities have also moved to three weekly collections of residual waste. Since 2010, the government has recognised these concerns.

Decisions on frequency of collection are rightly for local authorities to make and we do not propose to dictate this centrally (though since 2010, the government has removed guidance which recommended that councils introduce fortnightly collections, and supported weekly collections). But there is also a balance to be made with ensuring householders have access to regular collection services and in particular have “smelly” waste removed frequently.

This is why the Environment Bill proposes that food waste should be separately collected for recycling at least weekly. This will ensure that all local authorities provide a minimum weekly service for food waste, and thus directly address local residents’ concerns about the harm to local amenity and public health from this rubbish not being collected frequently. Defra will consult in 2020 on including advice on frequency of collections in proposed statutory guidance.

In the Resources and Waste Strategy the government has also made clear that householders should not be charged at civic amenity sites in relation to depositing waste from small scale DIY construction activities and that it will take steps to clarify this through a review of the Controlled Waste Regulations.

Garden Waste Collection

The government notes the comments received by the committee regarding the provision of free garden waste collections. We also note the Committee’s recommendation that government should not require local authorities to implement free garden waste collection services. Government’s view is that a free service would remain the best approach to delivering environmental benefits overall, but as stated in our response to the consultation we are giving further consideration to the overall cost and benefits of this proposal and available evidence on the effectiveness of different service arrangements before making a decision on how best to proceed.

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. (Paragraph 30)

Waste Prevention

The government welcomes the Committee’s support for waste prevention. Our Resources & Waste Strategy sets out our ambition to move towards a circular economy, meaning that we keep resources in use for as long as possible, extracting maximum value from them. According to current evidence, the most efficient way to use resources is by preventing them from becoming waste in the first place, which is why waste prevention sits at the highest tier of the waste hierarchy and why action to prevent waste should be preferred before recycling and recovery.

Producer Responsibility and Increasing Plastics Recycling

The Environment Bill will allow the government to introduce a number of measures to encourage companies to use plastics that can be more easily recycled but it is not our intention to require the use of recyclable plastics. In general, government’s preferred approach is to help companies make the right choice rather than mandate the use of certain materials or ban materials outright unless there are good reasons to do so, as is the case with microbeads and certain other single use plastics where we are proposing to introduce restrictions.

Our proposals for extended producer responsibility for packaging include a requirement on producers to cover the costs of managing packaging once it becomes waste. The fees that producers pay will be structured to incentivise the use of recyclable packaging and discourage the use of packaging that cannot be recycled. In other words producers will pay more for packaging that cannot be recycled. We have also proposed that all packaging that can be recycled and is collected for recycling will be labelled as such to help people to recycle more and to reduce confusion over what can and can’t be recycled.

To further stimulate the secondary markets for recycled plastics the Chancellor announced, in the 2018 Budget, a tax on plastic packaging placed on the market with less than 30% recycled content. It is proposed that this will take effect from April 2022. The tax will be designed to create an economic incentive for businesses to use recycled material in the production of plastic packaging, which will increase demand for recycled plastic and in turn stimulate increased levels of recycling and collection of plastic waste, diverting it away from landfill or incineration. We are also working to ensure that plastic packaging is recycled responsibly through a deposit return scheme.

Our proposal for local authorities to collect a core set of dry recyclables addresses the Committee’s recommendation that local authorities should be required to provide facilities for the collection and disposal of recyclable plastics. In regard to plastic packaging we will work with local government and producers to agree the core set of plastic packaging materials to be collected through household collection services. This will include the types of plastic packaging formats to be collected. Local authorities will receive additional funding for collecting and managing this packaging waste. The government will be exploring options for how funding through the producer responsibility scheme can be used to cover these costs.

Innovation in Packaging Design

The government welcomes innovations that have a positive impact on the environment and incentivises business-led technology innovation through the UK’s innovation agency, Innovate UK. Innovate UK’s role is to fund business-led innovation through the allocation of competitively awarded grants, delivered through competitions. In March last year the government set aside £20 million for research and development managed through the Plastics Research and Innovation Fund. A further £10 million was committed in the Autumn Budget for continued and additional plastics research and development, along with £10 million to pioneer innovative approaches to boosting recycling and reducing litter.

The government has also announced £60 million of funding through the Industrial Strategy Challenge Fund, alongside a £150m investment from industry, towards the development of smart, sustainable plastic packaging, which will aim to make the UK a world-leader in sustainable packaging for consumer products. The aim of this challenge fund is to prompt and facilitate innovation in the development of new polymers and packaging solutions that minimise environmental impact and are sustainable and viable economically. The government has also published a call for evidence on the development of standards or certification criteria for bio-based, biodegradable, and compostable plastics to better understand their effects on the environment and our current waste system.

Deposit return scheme for drinks containers

The government notes the Committee’s comments made regarding the introduction of a deposit return scheme (DRS) and also their recommendation that implementation should be deferred. The government remains minded to introduce a deposit return scheme for drinks containers from 2023, subject to further evidence and analysis. We have committed to reviewing the inclusion of drinks containers up to 3L in volume. The specific details of a DRS, including the material and drinks to be included in scope, will be developed further and will be presented in a second consultation in 2020. Following the second consultation, a DRS could be implemented from 2023.

Our ambition would be to introduce a DRS earlier if feasible; we want a timetable that is bold but realistic, implementing an effective, cost-efficient scheme that works coherently across the UK. We consulted with the Welsh government and on behalf of Northern Ireland. Scottish government consulted in 2018 and announced final proposals for a DRS for Scotland in early May 2019. We will continue to work with the devolved administrations to accomplish a coherent UK-wide approach.

Defra are considering two options for a DRS relating to size of containers. An ‘all in’ DRS would include drinks container of any size. An ‘on the go’ DRS would include drinks containers smaller than 750mls and would exclude multipacks. We will consult again on a DRS in 2020, and set out whether this will be an ‘all in’ or an ‘onthego’ scheme. We also published a consultation impact assessment for the introduction of a DRS for drinks containers alongside our consultation. Initial estimates show that this measure will impose costs on businesses, with the net cost estimated at around £665 million per year for the ‘all-in’ option. However, the introduction of a scheme is expected to have environmental benefits by increasing recycling and reducing littering of drinks containers that are in-scope. The GHG emissions reduction associated with this are 2.9Mt of CO2e over the ten-year appraisal period. The Net Present Value of a DRS for drinks containers is estimated in the initial IA to be more than £2 billion over the appraisal period for the ‘all-in’ option, and £250m for the ‘on-the-go’ option.

We recognise the concerns raised by local authorities that some of the material local authorities currently collect will be diverted to a deposit return scheme for drinks containers. This is expected to have an impact on waste collection and disposal costs and mean that this material can no longer be sold to reprocessors by local authorities to generate revenue. However, under the reformed packaging producer responsibility system, packaging producers will be responsible for the costs of dealing with the packaging waste they produce. Therefore, the identified kerbside costs and benefits are expected to fall to packaging producers rather than placing a burden on local authorities. We are also considering, in relation to a deposit return scheme for drinks containers, a funding formula whereby local authorities could be paid the deposit amount on drinks containers collected at kerbside without having to physically return them via a designated return point.

We recommend, therefore, that the Government commits to undertaking a review of funding levels at least every two years, providing top-up funding to local authorities if this becomes necessary. The process by which EPR funding will be passed on to local authorities requires greater clarity, but must be transparent and fair. (Paragraph 77)

We welcome that the Committee is supportive of the government’s proposals for introducing an extended producer responsibility scheme for packaging. In the summary of responses to the consultation published on 23 July 2019 we stated that we would be undertaking further work to determine the basis for allocating producer funding to local authorities and how this funding would be distributed. There are various approaches that could be taken and the practicalities of how this funding would be distributed. The arrangements for doing so would largely depend on the final governance arrangement for the packaging EPR scheme and the mechanism for raising fees from producers. In undertaking this further work we will continue to engage with local government and producers and also across government to scope options. The government agrees, and made clear in the consultation document that we expect the process of raising costs from producers and allocating funding to local authorities to be transparent and fair to both local authorities and to producers.

The costs to be recovered from producers and hence the fees they pay, would need to be kept under review to account for changing factors. These could include changes in the quantity and types of packaging placed on the market, investment in collection services to enable new recyclable packaging formats to be collected for recycling, prices for recovered materials and improvements in collection efficiencies. We will bring forward our final proposals for an extended producer responsibility scheme for packaging for consultation in 2020.

As stated above, the government is committed to funding the new burdens on local government arising from these reforms in line with the New Burdens Doctrine . We will work with MHCLG to refine our understanding of costs of new burdens.

The Government should invite the Local Government Association and other council representatives to review the data that informed their funding estimates, publish these and commit to providing any additional funding that is deemed to be required. (Paragraph 87)

As stated above the government is working with the Local Government Association and other representatives of local government and industry to review data and modelling approaches used to assess costs of collections. This work is on-going and will be used to inform consultations on our final proposals for consistency in recycling and on packaging producer responsibility in 2020. The government has stated both in the Resources and Waste Strategy and in its consultation on Consistency in Recycling that it is committed to funding the new burdens on local government in line with the New Burdens Doctrine. Guidance on applying new burdens has been published and this will be followed to assess new burdens.3

Private sector contractors should commit to covering the cost of these contract amendments, but where this cannot be agreed, the Government should commit to cover, in full, any additional costs incurred by local authorities as a consequence of contract renegotiations arising from the Waste Strategy. (Paragraph 98)

We will work closely with local authorities to decide how best to introduce these proposals from 2023 taking into consideration commitments from pre-existing contracts, infrastructure and fleet capabilities. Where contracts may be affected by changes in law we would want to work with parties to resolve concerns and to ensure new duties can be incorporated effectively. We note that during the Committee’s evidence sessions waste operators were concerned to take a pragmatic approach to support implementation of changes. We recognise that the proposals will mean new duties for local government. The additional burden presented by these will be appraised in line with New Burdens Doctrine and costs of new duties will be funded, including support needed for financial, communications, contractual and technical consequences of new measures.

The Government should work closely with the industry to ensure that England has the right recycling infrastructure in the right places, and that this is provided at a reasonable cost. The Government should also commit to covering any costs arising from the need for new infrastructure, which end up being passed on to local authorities through more expensive contracts. (Paragraph 103)

In the Resources and Waste Strategy the government stated that “we cannot increase resource efficiency without the right waste infrastructure”. Recycling infrastructure is key to this and we agree with the need to have the right infrastructure in the right places and at reasonable cost.

Through the Resources and Waste Strategy the government has committed to taking actions which will help stimulate private investment in reprocessing and recycling infrastructure. We want to significantly increase UK capacity by both increasing investors’ confidence and improving the competitiveness of UK reprocessing through:

We will do this through the policies we have consulted on such as Extended Producer Responsibility (EPR) and Deposit Return Schemes (DRS) for drinks containers. This would help to guarantee that waste products have a value at end of life, increase the quality and quantity of materials available to recyclers, and stimulate demand for secondary materials.

The National Infrastructure Commission (NIC) was established in 2015 to provide the government with impartial, expert advice on major long-term infrastructure challenges. The NIC published their first National Infrastructure Assessment (NIA) in July 2018, which set out their assessment of the UK’s long-term infrastructure needs. The NIA made over 60 recommendations to the government based on extensive consultation. A number of key recommendations concerned waste and recycling and these are listed below.

National Infrastructure Commission Recommendations

As announced at Budget 2018, the government is planning to respond in full to all of the NIA recommendations through a National Infrastructure Strategy. Infrastructure is essential for jobs, growth and productivity and the National Infrastructure Strategy will be a key part of the Government’s ongoing plans to support the UK economy.

Defra will continue to engage with industry and local authorities to explain government policy and invite feedback. We have drawn attention to the investment needs for recycling and reprocessing infrastructure in particular through the Resources & Waste Strategy and Green Finance Strategy. Local authorities are responsible for waste planning at a local level. The National Planning Policy on Waste says, for example, that:

Defra will work with MHCLG to ensure that the Waste Management Plan for England and the National Planning Policy for Waste and its supporting planning practice guidance reflects the policies set out in the RWS.

Specific measures taken by government that are already supporting the creation of new recycling infrastructure include:

The Government should undertake a review of whether the existing models of delivery and governance for the management of waste in two-tier areas continue to be appropriate. The Government should include this in its programme of Waste Strategy consultations that are due to take place over the next 12 months. (Paragraph 122)

We sought views on greater partnership working between local authorities in our recent consultation on consistency. Our discussions with LA representatives indicate that LAs would be open to greater collaboration. However, there is a preference for partnerships formed by LAs themselves, rather than government mandated partnership.

As we stated in our Resources and Waste Strategy, household waste management arrangements are complex. Around 350 local authorities in England have responsibility for collection and/or disposal of household waste. About 90 of these authorities are responsible for both collection and disposal (Unitary Authorities). The remainder are ‘two-tier’ authorities where a waste disposal authority (WDA) is responsible for disposing of waste collected by smaller district authorities (waste collection authorities, WCAs). Both WRAP and Local Partnerships through Defra’s Waste Infrastructure Delivery Programme (WIDP) have demonstrated that efficiencies and improvements can be made through greater joint working between two-tier authorities.5 The government has also previously published guidance on procurement saving opportunities from joint working and sharing resources, to help deliver savings whilst still providing comprehensive and frequent waste and recycling collections.6 Better sharing of assets for handling household and commercial waste would drive down treatment costs and could lower the gate fees paid by local authorities.

Feedback from stakeholders in our recent consultation included suggestions on incentives or financial support to develop partnership or the pooling of resources. Stakeholders also suggested that existing partnerships should be assessed, with the visibility of these partnerships enhanced and opportunities to share best practice highlighted. There was also support for the development of centralised standards and practices for collaboration and partnership, including a space for sharing knowledge, experience and expertise.

We will work closely with Ministry of Housing, Communities and Local Government (MHCLG) who led on local authority governance to identify where improvements can be made to current two-tier working arrangements. We will also work with local government and with WRAP and Local Partnerships (a joint LGA and government body) to support greater collaborative working across authority boundaries where this can drive improvements in services and deliver economic and environmental benefits.

1 https://www.gov.uk/government/publications/guidance-on-applying-the-waste-hierarchy

2 https://www.gov.uk/government/publications/guidance-on-weekly-rubbish-collections

3 https://www.gov.uk/government/publications/new-burdens-doctrine-guidance-for-government-departments

4 Municipal waste is household waste and waste from businesses and public bodies that is household-like (an office for example, where the main waste types will be food, plastic packaging, paper, etc., similar to a household).

5 http://localpartnerships.org.uk/wp-content/uploads/2017/05/Delivering-Efficiencies-in-Waste-Services-in-the-East-of-England.pdf

6 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/418767/150320_Waste_Goods_Procurement_Savings_Opportunities_final.pdf



Published: 19 May 2020