Here we are again! But there's an elephant in the room ....

Hi, it is us again. Hopefully, you are not sick of us yet and when it comes to information about the DRS and EPR consultations there is no such thing as too much information.

By the time you read this we will have held (or maybe even holding) a webinar outlining the main points of both consultations and you will have already received two briefing notes along with an invitation to book on workshops.

Whilst LARAC has been involved in a great number of stakeholder meetings in past 18 months it is still a different situation when the consultations are finally out, and you have to really start thinking about how you will respond to them. And even though much in them was as we expected there are one or two things in there that we were not. One is in the EPR consultation where there is a presumption that local authorities will continue to take responsibility for material sales and have the income. In stakeholder meetings there was broad agreement on the local authority side that producers were best placed to maximise income from materials sales, so we have something to ponder there.

In the DRS consultation we are still being asked if an “all in” or “on the go” scheme is preferred and the emergence of a “digital DRS” is an interesting development. Surely a DRS based on the existing kerbside infrastructure is a win for all involved, especially the consumer. The worry is that the rush to get DRS implemented means that the emerging technology will not be given a chance to prove itself and that would be shame. But we will no doubt be making that point in our own consultation response, as I am sure will lots of you.

Another surprise was the fact it was not a full 12-week consultation period. It may not sound much but that one and a half weeks that it has been reduced by makes a big difference to what we had planned. We have done our best to condense the programme of activities where possible, but it means we might not get our draft responses to you our members as far ahead of the submission deadline as we wanted. We know that you must go through internal sign off processes and these can be quite considerable if Councillors are involved. But again, we will do what we can to help you and get the information to you when you need it.

So that just leaves the elephant in the room. Or rather the consultation not in the room. The delay on the release of the consistency consultation is worrying and frustrating. DRS and EPR cross over so much with consistency they cannot be looked at in isolation from each other, but that is what we are in danger of having to do. When it does get released we will provide you with all the information you need, but it really does needlessly complicate what is already a detailed and in depth process.
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