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ALG TEC Executive Sub-Committee
Defra
recycling
consultation
Report by:
Jared Boow
Date:
9 February 2006
Contact
Officer:
Jared Boow
Telephone:
020 7934 9951
Summary:
Recommendation
s:
targetsItem
No:
Job
title:
Emai
l:
10
Principal Environment
Policy Officer
[email protected]
In October 2005, DEFRA issued a consultation
document on options for local authority statutory
performance standards on recycling and composting
in 2007/08. An ALG officer response was made to
Defra, and Member endorsement of those comments
is now sought.
Members are recommended to:

Agree the ALG officer response to Defra’s
Options
for
local
authority
statutory
performance
standards
on
recycling
and
composting in 2007/08.
Local
authority
statutory
performance
recycling and composting Consultation
standards
on
1. Defra issued the ‘Options for local authority statutory
performance standards on recycling and composting in
2007/08’ document for consultation in November 2005,
requiring responses by January 2006.
ALG TEC Executive Sub-Committee
Defra recycling targets consultation
66
Agenda Item 10
09 February 2006
Background:
2. The Government’s Waste Strategy 2000 set targets to
recycle or compost at least 25% of household waste by
2005 rising to at least 30% by 2010 and at least 33% by
2015. The Government also has a Public Service Agreement
(PSA) target to “achieve 25% recycling or composting of
household waste by 2005/06 with further improvement by
2007/08”.
To ensure that all local authorities
contributed to achieving the PSA target and national
recycling
targets,
the
Government
set
statutory
performance standards for recycling and composting in
2003/04 and 2005/06 for each local authority in England.
These standards when combined were designed to deliver
the national targets of 17% in 2003/04 and 25% in
2005/06. The individual local authority targets were set
as part of the existing Best Value framework which
requires local authorities to set challenging targets to
improve waste management services.
3. Four options are presented by Defra in their consultation
regarding
setting
future
recycling
and
composting
targets. These are:
Option 1: do nothing;
Option 2:
set statutory performance standards in
2007/08 for recycling and composting for all
local authorities equal to the level of
their targets in 2005/06;
Option 3: set statutory performance standards for
recycling and composting in 2007/08 for all
local authorities equal to the level of
their targets in 2005/06 except for those
local authorities with a target of 18% in
2005/06 who would be required to raise their
performance to 20%; and
Option 4: setting statutory performance standards for
recycling and composting in 2007/08 as in
option three and including the removal of
the 30% cap on the highest recycling targets
which was imposed in December 2004.
These options are further expanded on in Appendix A.
ALG Officer Response:
ALG TEC Executive Sub-Committee
Defra recycling targets consultation
67
Agenda Item 10
09 February 2006
4. Six boroughs and the North London Waste Authority
provided comments to inform the ALG’s response, which was
sent to Defra on 27 January 2006.
This paper seeks to
inform ALG TEC of the officer response sent to Defra, and
gain endorsement of this (please see Appendix B for the
officer response).
5. On the balance of the responses received, boroughs are
generally in agreement that out of the options presented,
Option 3 is preferred. Retention of the 30% cap on the
best performing boroughs still allows progress beyond
this target, but without the potential to be penalised
for failing to meet the higher targets that Option 4
would require.
Option 3 also allows the lowest
performers to be set slightly higher targets to bring
those boroughs more into line with others, and creates a
more level playing field for the Landfill Allowance
Trading Scheme.
Financial Implications
6. All of the options available have financial implications
for boroughs:
 Option 1 may superficially appear to allow savings if
compulsory targets are scrapped.
However, other
drivers, such as increasing landfill tax and LATS
targets mean that landfill diversion will still be
required, and at this time, recycling and composting
are two of the most cost effective approaches to
achieving this.
 Option 2 may appear less onerous for lower performing
boroughs, but again, the requirement to increasingly
divert waste away from landfill in the future means
that recycling rates are likely to have to reach such
levels anyway.
 Option 3 is similar to Option 2. However, it requires
the lowest performing boroughs to reach 20% rather
than the current target of 18%.
Due to future
diversion targets, the financial implications may be
similar to option 2.
 Option 4 may be more costly to boroughs in terms of
penalties, if higher targets set above the 30% cap are
then not achieved.
Legal Implications
ALG TEC Executive Sub-Committee
Defra recycling targets consultation
68
Agenda Item 10
09 February 2006
7. None.
Equalities Implications
8. None.
Appendices
9. Appendix A: Extracts from Defra consultation paper on
recycling targets.
Appendix B: ALG officer response to Defra recycling
targets consultation.
ALG TEC Executive Sub-Committee
Defra recycling targets consultation
69
Agenda Item 10
09 February 2006
APPENDIX A: Excerpts* from Defra’s recycling consultation
document “Options for local authority statutory performance
standards on recycling and composting in 2007/08”.
(*for the full text, please go to the following internet
link: http://www.defra.gov.uk/corporate/consult/recyclingcomposting/consultation.pdf )
1.
SCOPE OF THE CONSULTATION
Background
1.1
Statutory Performance Standards (recycling targets) for recycling and
composting have formed an important component of the Government’s
plans to improve waste management in England. The overall challenge
remains to break the link between economic growth and the amount of
waste produced and to drive the management of waste up the waste
hierarchy of reduction, re-use, recycling and composting, and energy
recovery.
1.2
First set in 2000, the current targets for all English local authorities run
until 31st March 2006 and are designed to deliver the Waste Strategy 2000
headline target to recycle or compost at least 25% of household waste by
2005. Further national targets have been set in Waste Strategy 2000
rising to at least 30% by 2010 and at least 33% by 2015. Since 2000 there
has been a considerable amount of progress by local authorities in pursuit
of these targets and numerous developments in Government policy,
including but not limited to the Landfill Tax Escalator and implementation
of the Landfill Allowance Trading Scheme (LATS). In light of this progress
and in order to ensure continued progress on recycling and composting in
England, this consultation proposes future targets for recycling and
composting of household waste for 2007/08.
What is covered by the paper.
1.3
This paper outlines a basic proposal for the extension of the existing
Statutory Performance Standards to the year 2007/08. It does not
propose any targets are set for the year 2006/07 as local authorities need
sufficient time to plan for new targets. Consideration is also given within
the proposals to increasing the Statutory Performance Standards for those
local authorities with the lowest levels of recycling and composting in
2005/06 and removing the cap on the highest performers set in December
2004 at 30% for 2005/06. This consultation paper does not discuss
ALG TEC Executive Sub-Committee
Defra recycling targets consultation
70
Agenda Item 10
09 February 2006
recycling and composting targets beyond 2007/08. The current review of
Waste Strategy 2000 is considering a number of measures for the future
direction of local authority and wider waste streams including the role of
statutory targets. A progress report on the review is planned to be
published by Defra by the end of this year which will include consideration
of the form and focus of any future targets.
1.4
Four basic options are outlined in this consultation:
Option 1:
Option 2:
Option 3:
Option 4:
do nothing;
set statutory performance standards in 2007/08 for recycling and
composting for all local authorities equal to the level of their targets
in 2005/06;
set statutory performance standards for recycling and composting
in 2007/08 for all local authorities equal to the level of their targets
in 2005/06 except for those local authorities with a target of 18% in
2005/06 who would be required to raise their performance to 20%;
and
setting statutory performance standards for recycling and
composting in 2007/08 as in option three and including the removal
of the 30% cap on the highest recycling targets which was imposed
in December 2004.
The merits and demerits of these options are outlined in the consultation and
further in the associated Regulatory Impact Assessment.
OPTION ONE – Do Nothing:
4.4
The option exists to set no further statutory performance standards for
local authorities beyond 2005/06 which would offer the freedom to local
authorities to perform at the standard deemed to be the most appropriate
to their local circumstances as set out within the context of their local
municipal waste management strategy and (for Waste Disposal
Authorities) the requirements of the LATS.
4.5
While some authorities will continue to maintain or increase recycling as a
result of local priorities or to meet LATS targets others may not plan their
programmes in accordance with the waste hierarchy. There is also the
potential as indicated in paragraph 3.10 that without statutory recycling
and composting targets for Waste Collection Authorities after 2005/06 and
in the face of other local budgetary pressures there is a risk that some
local authorities may decouple from the successful partnership working
currently being progressed in two-tier local authorities.
ALG TEC Executive Sub-Committee
Defra recycling targets consultation
71
Agenda Item 10
09 February 2006
4.6
The “do nothing” approach does not give any assurance that levels of
recycling and composting will ensure continued progress towards our
national recycling targets. There is a very significant risk that this could
lead to failure to meet the EU stringent landfill reduction targets. It could
also lead to very variable levels of service provision across England. This
could undermine the government’s attempts to increase participation in
recycling activities since the evidence shows that easy access to recycling
opportunities is essential to changing behaviour.
4.7
Modelling indicates that the “do nothing” option could deliver recycling
rates up to 27.1 per cent. However, the modelling is based on the
theoretical assumption of optimal joint working in two tier areas,
responding to the drivers (at the waste disposal authority level) of landfill
tax and LATS. Therefore there is a risk that in reality this level of
performance will not be realised in the absence of future recycling targets
for all local authorities, which would also put at risk maintaining the
trajectory towards the first Landfill Directive target in 2009/10 4.8 In light
of this the “do nothing” option is not the preferred option of Government.
OPTION TWO - Maintaining the level of recycling performance at 2005/06
levels:
4.9
This option is to set statutory performance standards for recycling and
composting in 2007/08 for all local authorities equal to the level of their
targets in 2005/06. This essentially acts to freeze the current targets for all
local authorities and requires the maintenance of performance at the same
level in 2007/08. (Individual local authorities retain the discretion whether
to perform above the level of their statutory performance standard.) These
targets would be measured in the same way as the 2003/04 and 2005/06
targets by combining the data sources from Best Value Performance
Indicators 82a and 82b. A list of the proposed new statutory targets for all
local authorities created by this option is shown in Annex B.
4.10
Any local authority that fails to reach its 2005/06 target in the year 2005/06
will therefore be required to attain it by 2007/08 (in 2003/04 43 per cent of
local authorities failed to reach their target) and can expect to be subject
to some form of engagement or intervention by Government following the
announcement of 2005/06 performance. (See comments in paragraph
4.22 regarding Defra’s proposals for engagement and intervention in poor
performing recycling authorities).
4.11
This option has the advantages that it will ensure continued progress
towards national recycling targets, Modelling indicates that this option
would deliver a national recycling and composting rate of approximately
28.5 per cent in 2007/08.
ALG TEC Executive Sub-Committee
Defra recycling targets consultation
72
Agenda Item 10
09 February 2006
4.12
The option also has the advantage of ensuring that Waste Collection
Authorities (in two tier areas) will have obligations that encourage them to
continue working in partnership with their Waste Disposal Authorities. It
will also ensure that a certain level of service provision for recycling is
provided throughout England and will maintain the focus for achievement
for the 43 per cent of local authorities who failed to achieve their 2003/04
targets. This proposal should also help to ensure that LATS targets are
met across the country as we progress towards the EU target in 2010.
4.13
It should be noted that the last Spending Review (SR04) increased the
EPCS block to fund, amongst other things, local authorities achieving their
2005/06 performance standards on recycling waste with continuing
improvements thereafter on a small scale. Therefore, the extension of the
existing targets regime as proposed in this option is seen as the minimum
needed to ensure that all local authorities continue to play their part in
meeting the government’s objectives and European obligations.
OPTION THREE - Maintaining the level of recycling performance at 2005/06
levels and increasing the floor level of recycling to 20 per cent:
4.14
This proposal would have the same effect as Option Two in that all local
authorities would be set statutory performance standards for recycling and
composting equal to the level of targets set in 2005/06 with the exception
that the existing ‘floor level’ of recycling performance (the lowest level of
statutory performance standard in 2005/06) is increased from 18 per cent
to 20 per cent for 2007/08. This would have the effect of increasing the
statutory performance standard for the 143 local authorities whose current
2005/06 targets is 18 per cent or less.
4.15
This option would have similar advantages to Option 2. In addition it would
ensure greater progress towards our national recycling targets. Modelling
estimates on this proposal suggest that the effect of increasing the floor
level of performance will be to increase the national recycling and
composting rate to 28.65 per cent in 2007/08.
4.16
This option also has the advantage of focussing on improving poor
performance by requiring the local authorities with the lowest level of
targets to go some small way to closing the gap on those local authorities
at the top end of the performance league. It will also help to ensure a more
even level of service provision across the country.
4.17
This proposal aims to continue the forward momentum on recycling and
composting in England and to require in particular those local authorities
with the lowest performance to improve with respect to the rest. It also
ALG TEC Executive Sub-Committee
Defra recycling targets consultation
73
Agenda Item 10
09 February 2006
does not place unfunded burdens on local authorities. As such this is the
Government’s preferred option.
OPTION FOUR - Maintaining the level of recycling performance at 2005/06
levels, increasing the floor level of recycling to 20 per cent and removing
the 30 per cent cap from those authorities originally given targets in excess
of 30 per cent:
4.18
In December 2004 Government announced that Statutory Performance
Standards for recycling and composting of household waste would be
capped at 30 per cent in 2005/06 in recognition of the fact that, while
many local authorities were able to deliver and sustain very high levels of
recycling, in some circumstances local authorities were unable to deliver
this degree of step change in the time available, or could only do so at
disproportionate short-term cost.
4.19
In proposing new statutory performance standards for 2007/08,
consideration has been given to removing this cap. This would have the
effect of reinstating the original individual performance standards in the
range of 31-40 per cent for the 104 local authorities whose targets were
reset to 30 per cent. A list of those local authorities that under this option
would receive new Statutory Performance Standards in 2007/08 in excess
of 30 per cent is attached in Annex D. Such an approach would no doubt
be seen as a confusing signal to those authorities directly effected. While
adding just over 1 per cent to the national recycling rate (taking it to 29.7
per cent), this option would cost an additional £48m (2005/06 prices).
Given the previous options put us well on the way to meeting the national
target of 30 per cent in 2010 and our EU Landfill Directive obligations in
2009/10, this brings forward increased performance and financial cost
before it is necessary and before local authorities will have had sufficient
time to plan to implement such a step change efficiently. Therefore, this
option is not the preferred option of Government.
ALG TEC Executive Sub-Committee
Defra recycling targets consultation
74
Agenda Item 10
09 February 2006
APPENDIX B: ALG officer response to Defra recycling targets
consultation.
Defra consultation- Options for local
authority statutory performance standards
on recycling and composting in 2007/08
Contact
Officer:
Date:
Telephone:
Jared Boow
Job
title
:
25 January 2006
020 7934
Email
9951
:
Principal Environment
Policy Officer
[email protected]
1. The Association of London Government (ALG) welcomes the
chance
to
submit
a
written
response
to
Defra’s
consultation on options for local authority statutory
performance standards on recycling and composting in
2007/08.
2. The following comments represent the views of London
boroughs, many of whom will have also made individual
responses to Defra. Please note that due to the timing
of the consultation, this is an officer-level response.
Officers will therefore seek ALG Transport & Environment
Committee (TEC) endorsement of these comments in early
February 2006, and will forward this endorsement or any
amendments made by TEC to Defra.
3. Boroughs are generally in agreement that out of the
options presented, Option 3 is preferred.
Retention of
the 30% cap on the best performing boroughs still allows
progress beyond this target, but without the potential to
be penalised for failing to meet the higher targets that
Option 4 would require. Option 3 also allows the lowest
performers to be set slightly higher targets to bring
those boroughs more into line with others, and creates a
more level playing field for the Landfill Allowance
Trading Scheme.
Three boroughs with the lower target
have also already reached 18% in 2004/05, while trends
indicate at least six more boroughs are likely to achieve
it by 2005/06. Therefore, a slightly raised rate to 20%
for 2007/08 will help to continue this impetus.
ALG TEC Executive Sub-Committee
Defra recycling targets consultation
75
Agenda Item 10
09 February 2006
4. Boroughs agree that those failing to meet their Statutory
Performance Standards should expect to receive some form
of engagement or intervention from Government. However,
Government must also recognise that poor performance may
be for a variety of reasons, which may often be outside
the immediate control of the borough.
Low performance
may not reflect the resources and processes that boroughs
have put in place; therefore any intervention must
account for this and not take the form of punitive
measures which are likely to only further inhibit
improvements in performance.
5. Current and 2007/08 targets originate from historic
performance in 1998/99, and not the potential of
individual boroughs to recycle.
It is therefore
suggested that Government needs to revisit how future
targets are set, including incorporating criteria such
as:
the
type
of
authority
(i.e.,
rural,
urban,
metropolitan and inner city); the number of higher rise
properties in the authority; and the average size and
number of gardens in the authority.
6. Further to this, the potential level of investment
required to push recycling and composting figures even
higher
at
the
top
end
of
the
scale
could
be
disproportionate to the returns achieved, in comparison
with changing the focus to diverting waste from landfill
(which
obviously
still
incorporates
recycling
and
composting at the top of the waste hierarchy). In terms
of setting targets for future years therefore, boroughs
suggest that Government needs to look beyond recycling
and composting targets and move towards a wider
perspective.
This would for example, incorporate the
Landfill Allowance Trading Scheme, and take into account
the performance of boroughs that have invested in
technologies which divert waste away from landfill, in
line with the European Landfill Directive. In addition,
Defra’s Waste Performance and Efficiency Grant (WPEG)
still has two years to run. Future target setting would
therefore be better informed if the benefits made from
investments under this programme were taken into account.
7. The review of the Mayor’s powers could see changes
regarding who is responsible for certain waste sites and
assets, which could affect borough recycling figures.
Future target setting therefore needs to take into
ALG TEC Executive Sub-Committee
Defra recycling targets consultation
76
Agenda Item 10
09 February 2006
account
any
changes
to
waste
governance
and
infrastructure which could impact negatively on boroughs’
ability to achieve Government targets.
8. Boroughs have also suggested that, as recycling rates
continue to improve, Government could more usefully
employ its efforts towards improving national and
regional markets for recyclables, so as to create more
‘room’ for recycling and make it more economic at the
margin, rather than constantly raising the bar on
targets.
Yours sincerely,
Jared Boow
Principal Environment Policy Officer
ALG TEC Executive Sub-Committee
Defra recycling targets consultation
77
Agenda Item 10
09 February 2006