Consultation time ticks on, are you ready and are you willing to share?

12th April 2019 Posted by

Posted by Dr Adam Read.

Dr Adam Read, External Affairs Director, SUEZ reccyling and recovery UKTime really does fly in our sector right now, and I would rather be busy than idle.

But it only seems a blink of an eye since my last blog which focused on the then ‘new’ Defra and HM Treasury consultations which I firmly believe will reshape the sector like nothing before.

So many facets of the sector will change in the next five years due to the Extended Producer Responsibility (EPR), deposit return (DRS), consistent collections and 30% recycled content tax proposals that we are all digesting.

Some of the big questions which arise from the consultations from my perspective are:

  • Which EPR model will we adopt and how will it be governed?
  • How will we ensure that money flows through the system from producers to those collecting, harvesting, segregating, and refining the materials?
  • How will benchmark payments be set for collections and processing to drive efficiency? Producers won’t want to pay for ineffective systems that are ultimately too expensive.
  • How will the transition to consistent collections be funded and over what period?
  • Will on pack levelling clearly identify the cost associated with the packaging and the modulated fee or deposit to help inform consumer decisions?
  • Will packaging targeted through DRS be included under EPR, and what guarantees do we have about expected performance and delivery?
  • Can food waste be collected and treated with garden waste, and will that conform to the new policy agenda?
  • Is it OK if we don’t meet any of our recycling targets as a nation until 2035 because of the time lag on the policies and funding and the impact of the new definition of recycling on our existing rates?

With so much proposed reform and change, there is inevitable concern and some degree of risk. We cannot afford to get this wrong, which is why it is so important that we are actively engaging in the consultations. We need to hold government to account, share new data that might inform forthcoming policy decisions and help build consensus about what is the right path, approach and system to deliver resource productivity, circular economy principles and sustainable resource management to 2030 and beyond.

So with seven weeks gone and only five left, are you doing enough to get on top of the documents, their proposals and the implications for your organisation, your customers, your services and the sector as a whole?

Sharing is a key component of this consultation period

I have continued to attend workshops, join meetings and take part in a number of webinars in the last five weeks so help share my thoughts (and those of my colleagues at SUEZ) about the consultations, the key issues, the points of interactions between the different documents, and the robustness (or not) of the evidence used in the impact assessments.

I really enjoy the opportunity to present a contractor perspective on consistency, DRS or EPR and to hear the discussions of others in the value chain, from consumers, brands and retailers, to local authorities, reprocessors and compliance schemes.

The real value of these workshops is the interaction, peer-to-peer learning and ability to ‘soft test’ ideas in a relaxed environment with others who are going through exactly the same degree of pain, terror, worry, or stress (please select the one that most applies).

I have been involved in workshops and events focused on the consultations that have involved over 400 delegates (some of whom have been at multiple events, but most haven’t). These have included a session with local partnerships and our treatment and disposal clients, SUEZ-run workshops, two CIWM workshops and many more.

There has been no shortage of opportunities to get involved in the debate, to see what experts are thinking, to hear directly from Defra on the priorities, and to build some momentum around your own consultation response.

WRAP and LARAC have both been running regional workshops focused on issues likely to impact local authorities, while many of the key stakeholders have put on their own sessions and surgeries. In particular, I have thoroughly enjoyed sessions by EcoSurety and the Renewable Energy Association in the last week or two. So I hope you all feel you have had a chance to not only immerse yourselves in the documents, but to discuss issues at one or more of these sessions…

But, if you haven’t, or if you still think some discussion might be useful (if only for your sanity) then an opportunity should arise in the next two or three weeks.

In need of a helping hand

I am fortunate that my role with SUEZ is dedicated to consultations, stakeholder engagement, policy influencing and that I have a number of colleagues who also have part of their role dedicated to planning for change, understanding the policy environment and stakeholder engagement. Reading, understanding and interpreting the consultations has been a team effort thus far. But I know you are not all so lucky, and are having to squeeze reading the 450 pages and answering the 250 plus questions in around your policy, operations and customer facing roles.

Because of the obvious need to help the sector cut through the reams of documentation and focus on the key issues, and because of our role as a partner and long-term contractor with both public and private sector customers, we have sponsored the development of the Resources & Waste Policy Impact Calculator.

Created by Anthesis, with data and funding support from SUEZ, LARAC, Project Integra and the Kent Resource Partnership, the calculator is available to download and provides a user-friendly interface to help local authorities estimate the potential implications of the different DRS scenarios and full net cost recovery Extended Producer Responsibility (EPR) proposals on their individual services.

In the last two weeks there has been a huge level of interest in the calculator and the early feedback is that it is helping authorities to work through the proposal and the ramifications for their local services, materials slows and costs.

Yet that isn’t the last of our contributions to the live consultation debates, as next week we plan to launch a new short report ‘Unpackaging Producer Responsibility Two’ which takes a closer look at the proposals in the current consultations (in particular the governance models for EPR) and the principles we outlined for a gold standard EPR scheme in Unpacking Producer Responsibility back in September 2018.

Our work to date suggests that none of the proposed governance models will deliver what the government wants. So rather than being forced to pick one of the four models, we are identifying the best bits from each that we feel could be put together in a hybrid system. We expect this report will be another opportunity for us all to test our thinking about the proposals, and promote further dialogue about what the new system must have in order to be a success.

Good luck and blank out some time in your diary over the next few weeks to do the consultations justice – the sector needs you and your insights.

This blog was  originally published on on 11 April 2019.

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