LGA response to Consultation on Waste Prevention Plan for England, 2021

About the LGA

The Local Government Association (LGA) is the national voice of local government. We are a politically-led, cross party membership organisation, representing councils from England and Wales. Our role is to support, promote and improve local government, and raise national awareness of the work of councils. Our ultimate ambition is to support councils to deliver local solutions to national problems.

Summary

​​​​​​The LGA welcomes the opportunity to continue to contribute to the consultations on resources and waste reforms, first set out in the Government’s Resources and Waste Strategy.

The LGA supports the ambition for an increase in recycling rates. As the Resources and Waste Strategy notes councils have a good story to tell on the growth in recycling, which has been maintained at its current level of around 45 per cent in recent years even though central government funding for councils has reduced by £15bn, nearly 60 per cent, since 2010. The local government sector is ready to take on the challenge of improving recycling levels and the overall waste service it provides to its residents. Our work in understanding the reforms continues and we are grateful for the engagement with Defra.

The LGA has been calling for waste prevention to be given equal priority with strategies to increase recycling. Avoiding waste in the first place is the best environmental outcome. We welcome the development of the waste prevention programme and the focus on reducing greenhouse gas emissions, reducing pressure on our natural environment, safeguarding resource security, creating jobs and increasing growth and the aim to move our economy from a current linear model to one that is truly circular. This aim needs to be front and centre for all government departmental policy and delivery.

Consultation Questions

Question: Do you agree or disagree with our choice of impacts and outcomes as the right goals for us to be aiming to achieve?

b. Agree

The impacts chosen (products reused, repaired and remanufactured, more extensive sharing economy and greater use of secondary materials) are the correct impacts but consideration needs to be given to the business models that will enable this such as renting and leasing and how they interact with the impacts.

The outcomes (eco-designed products on the market, consumers make informed decisions and products are collected at end of first life for reuse, accessible reuse and repair services and Information on availability of secondary materials) are the correct outcomes but should be considered through the lens of the user.

The current linear economy is simple and a circular economy alternative needs to be equally simple. In the current system you decide what you want, buy it then when you are finished with it you dispose of it. A circular economy model must facilitate a simple and straight forward end-of-life transaction if the model is to be accepted by the consumer and the carbon benefits of a circular economy are to be achieved.

Question: Do you agree or disagree that our policy approach covers all the areas for action that are needed?

b. Agree

The policy approach incorporating these three broad themes of products and design, systems and Information and data look to cover most of the life cycle of a product. 

It is unclear what is meant by ‘encouraging greater transparency by local authorities and businesses’ but we agree that the flow of information from trusted sources will be essential if the economy is to move to one that is more circular. 

Chapter 2: Designing out Waste: Ecodesign, Extended Producer Responsibility and Consumer Information

Question: Do you agree or disagree that the measures described are likely to achieve the overall aim set out at the beginning of this chapter?

b. Agree

The measures described for designing out waste will go some way to achieving the aim. We welcome the commitment to address the design of products such as nappies and car seats. Producers need to take more responsibility, as councils are left with the problem and cost of disposing of these items.

The ambition to extend product life needs to be properly thought through from the perspective of the consumer. Products with a longer life are likely to have multiple owners and therefore this needs to be considered at the design stage. If products are being repaired and components are being replaced, do all the components need to be purchased from the original producer? And where is the price guarantee? If components can be sourced elsewhere, which producer is responsible? 

Chapter 3: Reuse, Repair, Refill, Remanufacture - local services and facilities

Question: Do you agree or disagree that the measures described are likely to achieve the overall aim set out at the beginning of this chapter?

b. Agree

There are excellent examples of local authorities facilitating reuse and repair, reducing waste, avoiding fly-tipping and providing training and jobs. Often this is done directly or in partnership with not-for-profit organisations.

Case study: Groundwork London is a charity that has been working with boroughs and housing associations for a number of years to reduce waste, improve skills and alleviate poverty. The programmes they undertake include REPURPOSE, working with estates on repairing and refurbishing furniture. REPURPOSE currently has two active locations, one of which is in Islington and linked to a reuse shop. The benefits of the loops include reduced fly tipping, avoided waste disposal costs, avoided carbon dioxide emissions and training, employment and volunteering opportunities. Groundwork initially piloted the programme with EU funding on five estates across London. Over the two-year period of the programme it;

  • removed 6868 items from the waste stream
  • repaired over 1717 items in furniture workshops
  • produced over 3400 items of low-cost furniture for low income and vulnerable families
  • provided local volunteering and employment for 79 volunteers
  • created 25 jobs
  • engaged 3416 residents
  • created over £2.1m in social value (HACT)

Chapter 4: Data and Information - from industrial symbiosis to research & innovation

Question: Do you agree or disagree that the measures described are likely to achieve the overall aim set out at the beginning of this chapter?

b. Agree

Work has already been undertaken in this area, with varying levels of success, through the National Industrial Symbiosis Program (NISP) and Buildings As Material Banks (BAMB). We encourage Government to take the time to learn from these and other programmes before engaging in new programmes.

We encourage Government to implement a nationwide electronic system for tracking waste as soon as possible. This not only paves the way for material passports and material inventories but a could also contribute to a reduction in fly tipping.

Chapter 5: Construction

Question: Do you agree or disagree that the measures described are likely to achieve the overall aim set out at the beginning of this chapter?

b. Agree

The measures described go some way to achieve the aim of the Waste Prevention Plan, but more options should also be considered. Offsite construction can have multiple benefits not just for waste avoidance by reducing offcut waste and oversupply but also productivity. Modern methods of construction that reduce the need for mineral extraction should be further encouraged and incentivised. Modular construction and designing for disassembly and reuse are two approaches that can significantly reduce the amount of raw materials required. More research into new materials and methods of construction should also be prioritised such as the role of 3D printing and the utility of materials such as graphene.

More should be considered around how use and adaptability can be encouraged in the construction sector. This should not be at the expense of quality or energy efficiency and should not undermine housing standards, but instead enable the transition of a building to an efficient and effective alternative use.

Any additional role local authorities may be required to take through the planning function will need to be fully funded in terms of training and the increased levels of resources required.

Chapter 6: Textiles

Question: Do you agree or disagree that the measures described are likely to achieve the overall aim set out at the beginning of this chapter?

b. Agree

In addition to the measures described that generally lend towards improving the sustainability of the current linear approach to fashion and textiles we would encourage government to consider how it can support and encourage emerging opportunities for renting, leasing and subscription services for fashion.

Chapter 7: Furniture

Question: Do you agree or disagree that the measures described are likely to achieve the overall aim set out at the beginning of this chapter?

b. Agree

The measures described go some way to achieving the overall aim of the Waste Prevention Program.  We support the proposal for “bulky” waste (consisting largely of furniture and furnishings) to be subject to an extended producer responsibility scheme.

Defra could go further and consider measures to prevent large amounts of office furniture being disposed of at the end of an office lease. Lease agreements often require the space to be returned void of furniture and furnishings which often leads to perfectly good office furniture being disposed of. New tenants auditing a prospective office space prior to a previous tenant’s departure could mitigate much of this material loss

Chapter 8 Electrical and Electronic Products

Question: Do you agree or disagree that the measures described are likely to achieve the overall aim set out at the beginning of this chapter?

b. Agree

The measures described go some way to achieve the overall aim but fall short of measures to develop skills and training required to create an affordable repair workforce. Local authority HWRCs can extract materials but often the cost of repair and testing make the activity prohibitive.

Further education establishments should be supported and encouraged to offer entry level Science, Technology, Engineering and Maths (STEM) qualifications to build a skills base for electronic equipment repair.

Chapter 9: Road Vehicles

Question: Do you agree or disagree that the measures described are likely to achieve the overall aim set out at the beginning of this chapter?

b. Agree

The measures described go some way to achieve the overall aim, but more focus should be placed on avoiding road use in favour of walking and cycling. Encouraging 15-minute centres, car free roads and cycle routes that are separate from car and lorry use can significantly reduce car use.

Further consideration should be given to encouraging innovative business models such as leasing tyres.

Chapter 10 Packaging, plastics and single use items

Question: Do you agree or disagree that the measures described are likely to achieve the overall aim set out at the beginning of this chapter?

b. Agree

The measures described go some way to achieve the overall aim of the Waste Prevention Program. The work of the Plastic Pact and the impending introduction of the plastic tax will further tackle the urgent issue of single use and hard to recycle plastic but one big risk remaining is the infrastructure required to recycle plastic in the UK.

Chapter 11: Food

Question: Do you agree or disagree that the measures described are likely to achieve the overall aim set out at the beginning of this chapter?

b. Agree

The measures described go some way to achieving the overall aim, but further support and guidance is needed to help households and businesses to reduce food waste and save money.

Avoidable food waste has a financial impact on the householder or business that has produced it. WRAP’s Love Food Hate Waste campaign provides good advice to householders but similar resources for businesses are harder to come by. WRAP estimate that food waste from the hospitality and food service accounts for 12% of UK food waste with a value of £3.2 billion[1].

Food Save, run by the Mayor of London and the Sustainable Restaurant Association provided resources and support to food and hospitality services businesses. Investment in such a program can reduce carbon dioxide emissions and save businesses a significant amount of money

Chapter 12 Monitoring and Evaluation

Question: Do you agree or disagree with the described approach to monitoring and evaluation of this Waste Prevention Programme?

a. Strongly agree

Lifecycle CO2 emissions are an important metric if government is to properly align resource management and climate change action. Understanding the benefits of reuse using this metric is essential if the leasing, sharing and reuse sectors are to be fully recognised for their contribution to tackling climate change.