The proposed targets:
- Reduce residual waste (excluding major mineral wastes) kg per capita by 50 per cent by 2042 from 2019 levels. It is proposed that this will be measured as a reduction from the 2019 level, which is estimated to be approximately 560 kg per capita
- We are exploring how we might measure this as a ratio of economic output (gross domestic product) in money value to raw material consumption (excluding fossil energy carriers) estimated by material weight (i.e. gross domestic product divided by raw material consumption).
Do you agree or disagree with the proposed scope of the residual waste target being ‘all residual waste excluding major mineral wastes’?
Disagree
The exclusion of major mineral wastes significantly reduces the ambition of the target. Mineral waste, consisting of waste from construction and demolition such as bricks and concrete plus mineral waste from mining and other activities, was the largest category of waste in the UK at 84 million tonnes. Household waste made up 12 per cent of all waste generated, by contrast. Defra acknowledge that the lack of data is one of the reasons for excluding major mineral waste, and this data gap needs to be addressed.
Do you agree or disagree that our proposed method of measuring the target metric is appropriate?
Agree
Measuring the volume of waste sent through various disposal routes can be easily understood and this is already collected as part of household waste and recycling statistics. Dividing this figure by the amount of people in the population allows for progress to be tracked over time. Defra may wish to consider whether this is best done per person or by household, noting that many councils base their analysis of waste data on households.
Do you agree or disagree that local authorities should have a legal requirement to report this waste data, similar to the previous legal requirement they had until 2020?
Disagree. The local authority sector provides waste data as part of national statistics. It is already recognised that data collection systems need to be reformed to support the implementation of Extended Producer Responsibility for packaging and through reforms to waste tracking systems. Defra must consider the opportunity to streamline data collection systems and reduce the burden on councils.
The big gaps in data are to be found in other sectors, notably business waste and construction and demolition waste. The focus should be on bringing all sectors up to the same standard of data collection.
Do you agree or disagree with the level of ambition proposed for a waste reduction target?
Agree.
It is right that Defra has set a high level of ambition the target for reducing residual waste. The strategy for achieving the target needs work, however. Defra must have a clear focus on waste prevention, as reducing waste in the first place has the best environmental outcome. The consultation sets out how Government will work with local government to increase recycling, but there are gaps in the strategy for reducing waste, for example in dealing with municipal offensive waste items that frequently end up in the household residual waste bin e.g., nappies, hygiene products, and incontinence pads. As household waste is only 12 per cent of the total waste generated, Defra needs a clear strategy for ensuring that other sectors are making an equally strong contribution to the waste reduction target.
Do you agree or disagree with our proposed metric for considering resource productivity?
Expressing resource productivity in a simple metric is very difficult. Defra’s thinking is at an early stage and there is not enough information for the LGA to be able to comment. In view of this Defra may wish to propose some interim targets that can be easily measured.
Of the possible policy interventions described, which do you think will be most effective to meet a resource productivity target? Please specify whether these policies would be most effective if implemented nationally or regionally, and whether measures should be product or sector-specific.
The LGA supports all the measures proposed: extended producer responsibility schemes, eco-design measures on producers and better information on consumers. All of these are levers that will support a more circular economy.
Defra should consider what more could be done to reduce the pressure on scarce natural resources, for example by helping people move away from a linear model of consumption and disposal to models based on leasing and renting. We welcome further information on next steps.
Target proposals for air quality
The proposed targets:
- Annual Mean Concentration Target (‘concentration target’) – a target of 10 micrograms per cubic metre (µg m-3) to be met across England by 2040.
- Population Exposure Reduction Target (‘exposure reduction target’) – a 35 per cent reduction in population exposure by 2040 (compared to a base year of 2018).
Questions
Do you agree or disagree with the level of ambition proposed for a PM2.5 concentration target?
Disagree
The government needs to be more ambitious in the timescale of improvements. Government must provide the support to help local authorities provide healthier air for communities faster than proposed. The government should aim to hit the WHO’s 2005 aim for its AMCT of PM2.5 of 10 micrograms per cubic metre by 2030 instead. This shorter timescale is required to incentivise central government to furnish local authorities with the powers, resources and wider support to take immediate action to reduce domestic combustion, monitor and enforce compliance in industry and reduce road transport as a source of PM2.5.
Whatever target is settled upon, local authorities will need the long-term funding and support to make use of the enforcement powers set out in the Environment Act and the DfT’s ambitions for Local Transport Plans.
Do you agree or disagree with the level of ambition proposed for a population exposure reduction target?
Disagree
A more ambitious concentration target should be the backstop for a more ambitious exposure reduction target that is more directly focused on improving public health. The government should aim to make these improvements by 2030 alongside background concentrations. Local authorities with the most acute public health problems caused by poor air quality must receive greater resources to take appropriate measures to improve public health equitably. The government should aim to hit the WHO’s 2005 aim for its AMCT of PM2.5 of 10 micrograms per cubic metre by 2030 instead. This level of ambition is required for central government to furnish local authorities with the powers, resources and wider support to take immediate action to reduce domestic combustion and road transport as sources of PM2.5.
Whatever target is settled upon, local authorities will need the long-term funding and support to make use of the enforcement powers set out in the Environment Act and the DfT’s ambitions for Local Transport Plans.