Steve Palfrey, Chair of the Waste Group for the Association of Directors of Environment, Economy, Planning & Transport (ADEPT), talks about the government’s recent consultation on DIY waste and booking systems at household waste recycling centres (HWRC).
In April 2022, the government published a consultation around household waste recycling centres (HWRC), proposing changes that would prevent councils from charging for DIY waste delivered by householders. The government believes that this will reduce the risk of fly-tipping. The consultation is also seeking views on the impact of booking systems at HWRCs.
One of ADEPT’s key concerns is the lack of an evidence-based approach – the consultation takes the view that council policies are resulting in fly-tipping. However, the evidence does not support this. In fact, a recent comprehensive, nationwide report by WRAP investigated the relationship between fly-tipping rates and HWRC charging and, using existing published data, they: ‘found no evidence of an association between fly-tipping and charging at HWRCs’. They found the only variable that does impact on rates is deprivation in urban and rural areas. In addition, the report identified that only five per cent of fly-tips contain DIY waste – so stopping charges for DIY waste will not stop fly-tipping.
Another key concern is that this proposal is out of step with Government’s own principles, as recently published in their draft environmental principles policy statement. One of their five key points is the ‘polluter pays’ principle, which links responsibility to the producer of the pollution to fund its effective management. In this consultation about HWRC charges, however, the government is going against this principle – it instead proposes that all council taxpayers pick up the burden of funding the waste costs for those who are renovating their properties. This will add to the cost-of-living crisis for everyone, rather than the cost falling to those who choose to renovate their properties.
The policy proposals themselves are also impractical to implement in a number of ways. They outline four criteria on how waste can be classified as DIY waste, including two which aim to differentiate between waste from construction and demolition activities undertaken by the householder and works undertaken for them by commercial contractors. In reality, once it gets to a HWRC, it would be impossible to determine which of these the waste derives from. It would operate on a matter of trust, with the potential to be a constant point of conflict between staff and site users, and an opportunity for abuse of the system.
The other criteria relate to the amount of permissible waste and the stipulation that waste is not taken to the centre on a regular basis (300 litres, no more than once a week). For these criteria to be meaningful, councils would need a booking and checking system in place, imposing additional responsibilities on councils to provide this service. Again, the criteria are impractical and would lead to conflict on site and be open to abuse.
ADEPT is concerned that removing charges for DIY waste would also bring about some unexpected consequences. For example, it could lead to an increase in rogue operators who would take waste away from households and fail to dispose of it correctly, as well as providing them with a ‘free’ route to operate a building waste disposal service.
The cost implications of this policy proposal are also of serious concern to the association. The consultation states that councils should be taking this waste anyway, without any charge and that there will not be any new money to support the change. However, since the austerity programme began in 2010, councils have seen their budgets shrink by 40% – so it is little surprise that most councils have introduced their charges for DIY waste over the past ten years.
The consultation is also seeking evidence on the implications of introducing a booking system at HWRCs. ADEPT is pleased to note that the government is proposing to adopt an evidence-based approach on this aspect of local service design. Introduced as a result of social distancing responsibilities and the national lockdown, around 50 per cent of councils brought in a booking system, allowing the public to book a slot at their local centre. In many areas, these booking systems remain. They have proven to be very popular with the public as booking spreads demand more evenly, reduces congestion on site and reduces queues around sites, therefore reducing emissions and improving air quality.
We are confident that the evidence will speak for itself around booking systems. However, we have serious concerns around removing the option of charging fees for DIY waste. In this instance, the government is not taking an evidence-based approach and is not following their own strategy. Dropping fees based on the criteria proposed would be difficult to implement, would impose the burden of cost on the public sector and therefore all taxpayers and, additionally, is likely to encourage more crime in the waste industry. ADEPT believes that councils are best placed to determine how best to manage recycling centre provision in their areas.
ADEPT is currently preparing a formal response to the consultation, due for submission on 4th July.
Photos by Nareeta Martin and Vivianne Lemay