Following a notably short consultation period, the DEFRA discussion on consistency in household recycling in England closed last week and many respondents will be relieved to clear this task from their to-do-list. However, for local authority Waste Managers, the closure of the consultation period marks the start of a longer and more significant piece of work.
The consultation was an opportunity for public sector and waste industry stakeholders to provide their views on the policy proposals, including mandatory household food waste collections. As this consultation was the second round, the policy documents and context presented in the introduction were a more significant part of the discussion and provide a clear signal on DEFRA’s intentions and detail on specific policies.
Food waste recycling mandatory for local authorities?
It is evident that weekly food waste recycling will be a requirement for all authorities from 2024. The weekly nature is embedded within the Environment Bill, which has almost completed its passage through parliament, with other aspects of service design being subjects in the secondary legislation that will follow the Resources and Waste Strategy.
The policy proposals visibly favour source segregated presentation of household food waste and that effectively prescribes the collection approach. But following our active participation in the consultation, including meetings with the DEFRA team responsible for household and organics policy, it is also clear to us that there will be opportunities for local authorities to consider alternative approaches such as co-mingled collections in some circumstances where they may be appropriate. These conditions could include authorities with an existing co-mingled service with high performance, or authorities where demographical factors make a source segregated collection technically challenging and/or unnecessarily expensive.
Response to DEFRAs waste sector food collections
In our consultation response to DEFRA, our consultancy expressed our belief that individual local authority Waste Officers need to be empowered by the strategy to determine the most suitable food waste recycling service for their authority area. This is a view which is also supported by several of our clients and industry organisations such as LARAC. It is understood that further guidance on Technically, Economically and Environmentally Practicable (TEEP) exceptions will be released as statutory guidance for further consultation in early 2022.
Is time running out for local authorities to act?
So where does the closure of the consultation, and the prospect of further engagement on the policy detail leave the waste sector on food waste collections? With little time to act is the answer. Waiting until mid-2022 for final policy proposals to be confirmed will give local authorities less than two years to test market options, develop a strategy, gain governance approvals, and then design, procure, and mobilise services. When considering the time required for tasks such as soft market testing, navigating governance procedures, and running a competitive procurement for collection and/or waste treatment services, along with lead time on vehicles and containers, it is clear that action is required well before mid-2022.
One perceived risk of starting the strategy and evaluation piece ahead of the final legislation being confirmed, is that the policy changes in some significant way. Given the limited options for organics collections, the strong policy preference, and the expectation of TEEP, this risk is significantly minimised for food waste recycling collections.
Indeed, it makes sense for local authorities to start developing their organic waste strategy now and begin by seeking to understand their options and begin to secure the resource elements needed. Those that do act now will be more likely to meet the 2024 implementation deadline.
Join us for our Webinar on organic waste collections
We are hosting a free webinar for local authorities where we will offer guidance on options for collecting food waste and the session will include an opportunity for questions and answers on policy proposals. To book your place on the webinar taking place on Wednesday 8 September 2021 email your details to Mark Richmond at Mark.Richmond@WRM-Ltd.co.uk.