July Policy Update:
The following consultations were responded to:
-Consultation on environmental targets for England
This consultation proposes at least one target in each of four priority areas is set for: air, water, biodiversity, and resource efficiency and waste reduction. LARAC only responded to the targets for resource efficiency and waste reduction.
We have concerns that the Government’s intention to reclassify small quantities of DIY waste delivered into HWRC sites as household waste (see below) will skew the data for this target, as this will add mineral wastes into LACW data, but the target specifically proposes to exclude mineral wastes from collected data. We also believe that the target is better expressed per household rather than per head of population as statutory kerbside collection schemes are designed around household not individuals. We also believe that a lack of reliable quality data for business waste collections should not be an excuse for a lighter reporting regime for commercial collections.
Our consultation response can be viewed here
-Consultation on preventing charges for DIY waste at household waste recycling centres and call for evidence on booking systems at household waste recycling centres (England)
This consultation supports a Government position that householders should not be charged to dispose of DIY waste and proposes changes to allow householders to deposit DIY waste for free at HWRC sites.
LARAC is concerned that the proposal will increase the volumes of DIY and construction waste received at HWRC sites and this is contrary to the statutory duty to apply the waste hierarchy and the priorities to reduce or then reuse. We also believe that many of the specified wastes cannot be generated other than by professional tradespersons, which would mean that such wastes must be classified as commercial. The insufficient controls proposed will increase the potential for challenging behaviour against site staff. Whilst LARAC members do not agree that such wastes should be re-classified as household waste, if this happens then one in three believe the only workable control will be the use of a booking system. LARAC is of the opinion that this policy directly contradicts other proposed policies on the review of the registration of waste carriers, brokers and dealers, and the new digital waste tracking system.
Our consultation response can be viewed here
The following consultations are live and in the process of preparing a LARAC response:
-Consultation on Scotland’s Circular Economy Bill
This consultation has proposals for a Route Map to deliver a circular economy in Scotland and on proposals for legislation in a Circular Economy Bill. The Ministerial Forward states “A circular approach to our economy, where we move from a "take, make and dispose" model to one where we keep materials in use, is imperative if we are to tackle the climate and nature crises. The Route Map sets out how we intend to deliver our system-wide, comprehensive vision for Scotland's Circular Economy. It outlines the tangible actions the Scottish Government and others must take to accelerate progress, and the tools we will put in place to enable everyone to play their part. Our proposals for legislation will provide us with the powers we need to do so.”
The consultation link is here: Consultation and the closing date is 22nd August 2022.
-Persistent Organic Pollutants (POPs)
LARAC recently became aware that the Environment Agency would be writing to all local authorities about the implementation of compliance with the Stockholm Convention on managing POPs. Representatives of the waste management sector have been in engagement with Defra officials and Environment Agency (EA) representatives for some time in seeking a proportionate and effective solution to this matter. The requirements are that all POPs domestic seating waste is being collected separately and incinerated and that beyond that point enforcement activity will commence. Although this requirement has been headlined for some time, the Domestic Soft Seating Working Group has been operating under clear Terms of Reference restricting the sharing of information beyond the group, and therefore it has not been possible for Local Authorities representatives to share details.
A short briefing is available here and we are in contact with the EA on practical steps that must be taken when collecting bulky items and storage within transfer stations.
