SWR12

Legislation Committee No 1

Response to the Consultation on the Proposed Shipment of Waste for Recovery (Community Involvement in Arrangements) (Wales) Measure

CSS (Wales) Waste Group

CSS (Wales) Waste Group Response on the Shipment of Waste for Recovery Measure

Background to CSS Wales) Waste Group

For over 120 years, from its origins as the County Surveyors’ Society, CSS has been providing the leadership and expertise required to tackle some of the country’s most pressing issues. The CSS represents local authority chief officers who operate at the strategic tier of local government, and are closely involved in crucial transport, waste management, environment, planning, energy and economic development issues.

The CSS (Wales) Waste Group is a sub group of the main CSS within Wales. The group was formed in 2007 to represent Local Authorities in relation to all relevant waste management issues and to liaise with other waste management organisations/bodies operating in Wales and the UK.

Our response has been prepared around the specific questions highlighted in the consultation paper.

Consultation Response

Q1 - Is there a need for an Assembly Measure in relation to community involvement in local authorities’ arrangements for dealing with recyclate?

The CSS believes that it is essential to engage with local communities in encouraging their buy in to the need to divert waste from landfill and to require waste to be handled in a more sustainable way.

This measure could potentially damage public confidence in recycling at a time that community buy in is essential. The measure raises the prospect that Local Authorities could be challenged for the use of reprocessors outside of Wales and the UK. This could raise problems where local facilities do not exist. As Local Authorities would not be able to deliver new local reprocessing facilities, despite public expectation that one should be sourced, recycling would lose credibility.  

The CSS believes that general awareness activities through organisations such as Waste Awareness Wales and WRAP would be more effective in delivering community involvement. The focus should be on what happens to the recycled materials and what end products are produced rather that focus on end destinations. We believe that this would better demonstrate the principles of sustainability to local communities.

Q2 - What are your views on the key provisions set out in the proposed Measure?

It is believed that the information required to be provided by Local Authorities will prove difficult and that significant resources will need to be diverted from front line recycling to chase reprocessors to provide the required information. As mentioned in responses during the previous consultation, Local Authorities have little powers to gather the required information. To be more effective the requirement should be placed on the reprocessors to provide this information rather than on LA’s to request it. Additionally where waste is mixed by a broker and material sent to a number of final destinations this will further complicate the issues of identifying the actual final destination and the need to apportion the waste between the potential final destinations. Whilst the proposed regulations do provide an opportunity to highlight these difficulties in the return, the community is likely to view this as a failing of Local Authorities to provide detailed information or perceived control rather than lack of transparency with a reprocessor.

The suggested publication of a statement on an Authorities website is viewed as ineffective. Waste Data Flow is used by all authorities to track waste movements. It would be more effective that the information is entered into WDF. The information could then be collated at a national level through the Environment Agency and a national report issued. This would ensure consistency of reporting and, if combined with other reports such as the Landfill Allowance Scheme Annual Report, provide additional background information on waste management.

The requirement for Local Authorities to invite representations from the public will increase the resources needed to investigate and reply to individual queries. Additionally, it is agreed that representations should be considered for future arrangements. However this consideration would need to be balanced against those residents who have not made any representations. It would be difficult to do this without additional communication methods being employed. These could include tools such as roadshow events, liaison groups and community group visits.

Q3 - Do the above provisions provide the most appropriate means for ensuring community involvement in local authorities’ arrangements for dealing with recyclate?

We do not believe that the measure will best deliver community engagement. As mentioned in Q1 this could be achieved through more effective general awareness activities. The focus should be on what happens to the recycled materials and what end products are produced rather that focus on end destinations. This would provide valuable feedback to residents to demonstrate that their recycling does make a difference. This could then be linked to issues relating to markets for recycled products.

Q4 - What are the practical and financial implications of putting these provisions in place?

Under the proposed regulations there will be a significant additional burden imposed on Local Authorities. This will include a significant amount of time required to chase additional information on the final destinations and also in producing reports on every waste transfer and providing responses to representations. Additionally, the extra information required to be provided by reprocessors will increase their costs which will be passed on in less favourable rates to LA’s. We agree with the views of the WLGA highlighted in last year’s response that these increases would result in approximately £25,000 per authority of additional costs (equivalent to 1 FTE).

Q5 - Will the proposed Measure achieve its overall purpose and aims, i.e. toengender greater transparency and openness in the way that Welsh local authorities deal with recyclate; for residents to encourage local authorities to use recycling facilities nearer to the source of the recyclate than those further away; and increased interest, and possibly participation, in recycling?

The measure is unlikely to deliver its overall purpose and aim. Whilst the aims of increasing transparency is laudable, the practical difficulties of obtaining the information may make it seem as if authorities are not being open. To address this issue the responsibility of providing this information should be directed at the reprocessors. To report the information tools such as WDF already exists to record such information and should be developed further.

There is a huge amount of change underway in Wales on how we are handling our waste. We need to encourage residents to fully engage to meet future targets. We believe that the focus should be on supporting new collection infrastructure to increase capture and participation and the development of local infrastructure and local recycling markets. By focusing on final destinations, this could reduce the effectiveness of other awareness activities and increase apathy in recycling and reduce the capacity of Local Authorities to meet future waste targets.