Consultation on exemptions and statutory guidance for Simpler Recycling in England – North London Waste Authority Response
Link to consultation: https://consult.defra.gov.uk/waste-and-recycling/5576d1f1/
Closing date: 20 November 2023
Q6. Do you agree with the provision of an exemption to allow for the co-collection of paper and card, plastic, metal and glass in one bin without needing a written assessment?
x Agree (please explain why you agree)
☐ Disagree (please explain why you disagree)
☐ Unsure (please explain why you are unsure)
NLWA would welcome this exemption. We strongly agree that an exemption should be unconditional, as local authorities are best placed to make local decisions. As stated in our previous response, it is already the case that all north London’s boroughs successfully recycle dry recycling materials through existing mixed dry recycling collections and MRF facilities. This method of collection enables operational efficiency, simplicity for the residents (circa – two million), storage of containers, impacts on the street scene, depot space and MRF and treatment infrastructure.
Q7. Do you agree with the provision of an exemption to allow for the co-collection of food and garden waste in one bin without needing a written assessment?
x Agree (please explain why you agree)
☐ Disagree (please explain why you disagree)
☐ Unsure (please explain why you are unsure)
As per the answer to Q6, NLWA welcomes this exemption. We strongly agree that an exemption should be unconditional, as local authorities are best placed to make local decisions, as demonstrated across the north London boroughs.
Q8. The guidance advises that waste collection authorities should build flexibility into their contracts to ensure materials can be added/removed to the recyclable waste streams as new recycling technologies develop. Do you agree or disagree with the content of this section?
x Agree
☐ Disagree
☐ Unsure
If you disagree, please select one of the following to best describe why:
☐ Further content should be added (please explain why further content should be
added)
☐ Content should be removed (please explain why content should be removed)
x Other (please explain)
NLWA agrees flexibility should be built into contracts to enable continuous improvement and value for money. However, blanket flexibility would not be feasibly practicable, therefore any requirements should safeguard against any additional costs or unnecessary burden on both the client and the contractor. Full consideration needs to be given to the operational and contractual relationships between collection authorities and disposal authorities, including end market availability, cost implications, and necessary time to make the changes.
Q9. Do you agree or disagree with the contents of the list above (below), detailing the materials that are out of scope of the recyclable waste streams?
x Agree
☐ Disagree
☐ Unsure
If you disagree, please select one of the following to best describe why:
☐ Materials should be added (please specify which materials)
☐ Materials should be removed (please specify which materials)
☐ Other (please explain)
Q10. Guidance is provided regarding the requirement to collect dry recycling from premises and the use of communal bins. Do you agree or disagree with the content of this section?
x Agree
☐ Disagree
☐ Unsure
If you disagree, please select one of the following to best describe why:
☐ Further content should be added (please explain why further content should be
added)
☐ Content should be removed (please explain why content should be removed)
☐ Other (please explain)
NLWA agrees that all properties should have a recycling provision that’s appropriate for the property type. Local authorities are best placed to decide what is the best solution for their localities which often have differing challenges, and all collections need to be practical and effective for their residents. Local authorities should have the ultimate decision-making power to ensure this.
Q11. Is there any additional guidance that would be useful regarding the provision of caddy liners?
x Yes (please explain what additional guidance would be useful)
☐ No
☐ Unsure (please explain why you are unsure)
While it is known that the provision of caddy liners can increase household participation in food waste recycling, we do not believe that a blanket introduction of caddy liners would enable the best environmental outcome. The high cost of this is prohibitive to many collection authorities who have increasingly stretched budgets. If a collection authority is mandated to provide caddy liners, the costs need to be covered through the new burdens funding associated with the new food waste collection requirements.
Consideration needs to be given to the end processor, and the material of the caddy liner. Caddy liners do help with participation, but whether or not they help or hinder the benefits of a food waste service will depend on the treatment facilities. With in-vessel composting facilities (IVC) they breakdown more effectively but with anaerobic digestion (AD), which is the preferred method outlined in the guidance, they are seen as a barrier and are extracted with other packaging, which defeats the objective of using them above plastic or paper bags.
Q12. Guidance is provided regarding the requirement to collect food waste from premises and the use of communal bins. Do you agree or disagree with the content of this section?
x Agree
☐ Disagree
☐ Unsure
If you disagree, please select one of the following to best describe why:
x Further content should be added (please explain why further content should be
added)
☐ Content should be removed (please explain why content should be removed)
☐ Other (please explain why)
NLWA welcomes the flexibility of being able to co-collect food and garden waste and the ability to apply a charge for the collection of garden waste. It also welcomes the flexibility around communal onsite bins. This reinforces the point NLWA has made previously, that local authorities are best placed to make local decisions on how waste and recycling is collected.
Q13. The guidance provides advice on the collection frequency of garden waste. Do you agree or disagree with the advice on collection frequency of garden waste?
☐ Agree
x Disagree
☐ Unsure
If you disagree, please select one of the following to best describe why:
☐ Further content should be added (please explain why further content should be
added)
x Content should be removed (please explain why content should be removed)
☐ Other (please explain why)
NLWA disagrees with the proposed recommended garden waste collection frequency. Collection authorities are best placed to determine the frequency and duration of garden waste collections based on the needs of local residents.
Q14. The guidance outlines that anaerobic digestion is the preferred method for treating food waste, where suitable, but composting is also permitted. Do you agree or disagree with the content of this section?
x Agree
☐ Disagree
☐ Unsure
If you disagree, please select one of the following to best describe why:
☐ Further content should be added (please explain why further content should be
added)
☐ Content should be removed (please explain why content should be removed)
☐ Other (please explain why)
NLWA supports the use of both AD and composting for the treatment of organics, and currently uses AD facilities for its collected food waste. However, it should be noted that market capacity for AD may not exist in certain areas and the purpose of this section of guidance is unclear. NLWA believes
that the preferred treatment option should lead to the best environmental outcome for that area, taking into consideration all factors from collection to treatment. It should also be recognised that operators of AD facilities regularly discourage the use of caddy liners as this causes issues with their operations.
Q15. The guidance outlines a backstop on the frequency of collection of residual waste, to protect householders’ local amenity. Do you agree or disagree with the content of this section?
☐ Agree
x Disagree
☐ Unsure
If you disagree, please select one of the following to best describe why:
☐ Further content should be added (please explain why further content should be
added)
x Content should be removed (please explain why content should be removed)
☐ Other (please explain why)
NLWA disagrees with this proposal. Setting a minimum frequency for residual waste collections does not take into consideration local circumstances. Organic waste makes up 33% of north London’s residual waste stream, and as a result the provision of weekly food waste collections will both decrease putrescent or odorous waste, residual waste as a whole, and increase the capture rate of recyclable waste. Furthermore, where there is a specific need (i.e. medical etc.), authorities can and do make arrangements for more frequent collections.
The blanket minimum frequency requirement also doesn’t take into consideration the operational nuances of local areas, and it removes the flexibility for local authorities to operate the most cost effective and efficient service for their residents. Any specific statutory requirement that requires change should be funded through the new burdens process.
Collection authorities are best placed to decide how they collect waste and recycling locally, and there is evidence to suggest that reducing the frequency of residual waste collections can improve resident participation in recycling, increase recycling rates, and reduce residual per kilogram per household.
Restricting the frequency of residual waste collections could negatively impact local authorities’ ability to achieve the government’s target to halve residual waste levels by 2040. The decision on collection frequency for residual waste should therefore sit with the collection authority. For a comprehensive list of supporting evidence, please see LARAC’s response to this consultation.
