Comment

Consulting the days away

And they’re out! Those consultations that have the potential to shape how packaging and municipal waste are managed are finally in full public view. So, ‘where’s the beef?’, or maybe, in a carbon-constrained world, where’s the marinated cauliflower steak?

The first thing to say is that it’s great to see that there are some genuinely transformative proposals being consulted upon in the consultations on extended producer responsibility (EPR) a plastics tax, a deposit return scheme (DRS) and consistent collections. It also makes good sense for the package to be consulted on in the round, recognising the linked nature of the measures. This is about changing a system that’s been stuck for some time, and is riddled with all sorts of problems that badly need sorting out.

Consulting the days away
Dominic Hogg.
This aside, my slight gripe, after reading the whole lot, is that we have some way to go before the system emerges as a clear and – hopefully – coherent whole. Indeed, there’s another bout of consultation to follow on from this one, at least on producer responsibility and the plastics tax.

Each of the four separate documents allude, at various points, to the linkages to the other policies being consulted upon in the other three. The problem, though, is that the consultation isn’t really integrated: answers to the myriad questions that one’s asked to respond to in one document depend on what the outcome might be in each of the others. The benefits of the simultaneous consultation – that we could have consulted on the design of a system – have not been seized. Too much has been left wide open and it’s as though no one is prepared to make a decision.

The lack of system thinking in the package as a whole is reflected in a few areas:

  • The extent to which modulation, or the refundable deposit/charge scheme need to do ‘heavy lifting’ will depend on the level at which the tax is set (and how it is structured);
  • The ‘on-the-go only’ variant of a DRS is still in play, even though full net cost recovery from producers, and full funding of local authority collections, is established as a key principle. There’s even the credibility-destroying (for Michael Gove) suggestion of no DRS at all;
  • The proposal of formula-based payments to local authorities hardly supports the idea of retaining competition in the compliance space;
  • The decision to label packaging as either recyclable or non-recyclable, and to use incentives to drive out non-recyclable packaging, sits uneasily with the discussion about how collection systems might evolve to cover a widening range of packaging types. The definition of ‘recyclable’ will become highly-charged to the extent that it triggers a high charge or extreme form of modulated fee; and
  • The consultation on consistency is – ironically – inconsistent with that on producer responsibility, beverage cartons being considered central to the core packaging materials to be collected by local authorities in the latter, but their inclusion being consulted upon in the former. No package will want to be excluded from the system if that leads to being labelled ‘unrecyclable’, and hence, to a large tax being slapped on the package.

There is (a lot) more.

All in all, though, there’s plenty to work with here. The broad definition of full net cost recovery and the potential shift to a single point of compliance, should, along with the other measures, transform the management of packaging and other waste collected by local authorities, as well as from commercial premises. But we’re short on system thinking and I’m not left with a feeling of confidence that the coherence we really need will emerge from the consultations. There are 300 or so questions across the four documents: would it not have been better to have set out clearly the contours of the system and to consult on the package as a whole, and only in those areas where it was meaningful to consider options? We now face another 100 questions at the next phase. When, I’m left asking, do we stop consulting and actually decide to do something?  In the meantime, good luck to the person analysing the responses to this lot.