Waste Prevention Team
Defra
Area 2B
Nobel House
17 Smith Square
London
SW1P 3JR
23rd September 2013.
Dear Sir,
Consultation on the Waste Prevention Programme for England
I am writing to present the LARAC response to the above Consultation, which is
contained below, and may I thank you for the opportunity to respond.
The responses to your questions are sent on behalf of the Local Authority Recycling
Advisory Committee (LARAC). LARAC is an association of around 75% of local
authorities across England, Scotland, Wales and Northern Ireland whose membership
of waste management and recycling professional’s co-ordinate and operate waste
management services. Membership is drawn from all types of authority including
statutory Waste Collection (WCA), Waste Disposal (WDA) and Unitary.
Our response has been peer reviewed by members of LARAC’s policy team and
executive committee. LARAC members have also been invited to comment on the
consultation through the members’ discussion forum on our website. All contributions
received have been taken into account in drafting the response below.
Our members welcome this proposal as well as any other initiative which seeks to
improve the quality of recyclable material and where possible avoid the need to export
materials for recycling abroad.
If you have any queries on this response then please contact me at
andrew.bird@newcastle-staffs.gov.uk or telephone 01782 742510.
Yours faithfully,
Andrew Bird
LARAC Policy Team
LARAC PO Box 28 Knighton LD8 2WA
01544 267860 larac@btinternet.com www.larac.org.uk
SUMMARY OF CONSULTATION QUESTIONS
Question 1. – Do you broadly agree with the proposed role for Government?
No LARAC does not agree with the proposed role of government.
We are disappointed with the proposals as we feel they lack real leadership and vision.
Effective and sustainable approaches in reducing waste is a complex and multi-faceted topic,
which requires vision, commitment, action plans and policy instruments, and this is what LARAC
feels should be the responsibility of Government. Mention is widely made in the document about
the work of WRAP in playing a major role in making this plan effective, a statement made after
government have severely cut funding to the organisation.
No one wants to see over bureaucratic and unnecessary red tape and legislation, however it
has to be recognised that the vast increase in performance in recycling and significant reduction
in the volumes of waste going to landfill over the past ten years would not have been achieved
without targets and taxation policies applied in the right area. It is disappointing that the plan
makes no mention of green taxes, plastic bag taxes, or most importantly extending producer
responsibility. It is however refreshing that an announcement has been made about charging for
carrier bags, but not until 2015.
LARAC’s concern in England is that we are now starting to see an increase in the amount of
residual waste being disposed of and recycling rates stagnating, which will only serve to make
effective waste prevention even more difficult to achieve.
In essence the commitment given by government to waste prevention in this plan, unlike those
of the devolved governments, is merely a ‘tick box’ exercise with no SMART objectives, to do
the minimum necessary to fulfill its obligation to meet the requirements of article 29 of the
revised Waste Framework Directive.
Question 2. – Do you broadly agree with the proposed role for Business?
In principle, yes LARAC agrees there is a significant role for business to play in achieving
effective waste prevention measures. However while mention is made of successful initiatives
such as the Ellen McArther foundation model and providing more information to consumers,
there is no robust indication or plan on how this is to be achieved.
There are of course a number of best practice examples of businesses driving effective waste
prevention initiatives, however it is LARAC’s experience that such examples of best practice are
not easily spread within the business community, even when advice is available free of charge.
Some small businesses find it hard to find the time or resources to research best practice.
Ultimately a business will do what is best for them in a competitive market, on numerous
occasions LARAC has been told that there is no such thing as excess packaging which in the
light of the success of the Courtauld Commitment clearly isn’t true. Business has not had to
become more efficient because the inherent inefficiencies of their processes (i.e. the waste)
when they are paid for by others – often the local authority.
LARAC PO Box 28 Knighton LD8 2WA
01544 267860 larac@btinternet.com www.larac.org.uk
Major strides have been achieved when WRAP (who after all are funded by the public) has got
everyone to work together, a very good example being the Courtauld Commitment. This kind of
voluntary agreement does however need to be underpinned with a threat of legislation being
bought in if voluntary targets cannot be agreed.
Again it is interesting again that much is made of the work WRAP undertakes with businesses,
and the role they will play in this plan, but this is against a background of severe cuts in their
funding, which will surely reduce their ability to be as effective.
Question 3. – Do you broadly agree with the proposed role for Local Authorities?
Yes LARAC agrees that Local Authorities have a major role to play in waste prevention,
however current activities only touch the surface of what could and needs to be achieved, and
while initiatives such as furniture and Waste Electrical equipment re-use are very worthy
causes, it is food waste where significant tonnage remains in the residual waste stream.
There is naturally evidence of good practice being undertaken by local authorities, a number of
which LARAC highlighted in its response to DEFRA’s recent call for evidence on the subject.
However Local Authorities continue to face difficult times financially and in particular where
waste services are concerned our attempts to deal positively in increasing recycling and
reducing residual waste are continually undermined by the government itself. Negative
comments about council newsletters, door steppers being labeled as bin police or bin snoops
and the huge reductions in the funding for Love Food Hate Waste campaigns are just some
examples of the current undermining of government over the last three years.
The other area that has not been explored in this plan is ensuring that the service offered for the
collection of waste and recycling assists in waste prevention – for example charging for garden
waste collections, the frequency of collections, strict rules about not collecting side waste or
overflowing bins. Unfortunately, again, many of these initiatives have been subject to
unfortunate comments from the government – as have any attempts to try to enforce these
waste prevention policies.
It would appear that with residual waste tonnages starting to increase again, Local Authorities
will need to find ways to reduce waste without government help and guidance, due to the
significant additional budgetary pressure on rising disposal costs. The danger is this will not be
achieved in a consistent way that an effective national policy approach would achieve.
Question 4. – Do you broadly agree with the proposed role for Other Organisations and
individuals?
Yes, LARAC agrees there is an important role for other organisations and individuals, although
one of the key issues has been missed which is many of these community based organisations
received funding from councils (grants, re-use credits etc.) that have since been cut.
LARAC PO Box 28 Knighton LD8 2WA
01544 267860 larac@btinternet.com www.larac.org.uk
The role of the individual in the process of waste generation is so significant that it deserves
more than just one paragraph in this document. There needs to be more detailed policy on just
how a coordinated approach to reducing food waste for example, can be achieved when WRAP
and local authorities who deliver it at a local level have had their budgets cut. There are ample
opportunities for the messages of love food hate waste to be disseminated by a range of
organisations (food, cookery, health, financial planning) but these partnerships need to be
supported by government with more than just fluffy words.
The same is true of the statement about consumers; they are the most important element in this
whole process, and vital to a growing economy. Again a few words of examples, which are
actually already happening is not enough, and somewhat ‘old hat’. What is needed is a move
away from waste focused thinking, changing consumer habits will go a long way in delivering
prevention of waste.
LARAC PO Box 28 Knighton LD8 2WA
01544 267860 larac@btinternet.com www.larac.org.uk