Councils concerned over cost of complying with WFD

Council recycling officers have warned that the government appears to have “seriously under-estimated” the amount it will cost local authorities to comply with the requirements of the revised Waste Framework Directive.

In its response to a government consultation on implementing the Directive in the UK (see letsrecycle.com story), which closed last week (September 16), the Local Authority Recycling Advisory Committee (LARAC) claimed that the cost to councils of meeting the legislation's goals for recycling and the waste hierarchy were “very uncertain” and would vary “widely” from one council to the next.

And, the organisation also said it had doubts over the government's “wait and see” approach to reaching the Directive's target for 50% of household waste to be recycled by 2020, claiming that factors such as financial constraints on councils could actually lead to recycling rates stalling or even reducing.

LARAC explained that its particular concerns over the cost to councils related to article 4 of the Directive – the legally binding waste hierarchy, article 11 – recycling targets and requirements – and article 28 – a requirement to establish waste management plans.

Cost estimates

“Cost estimates on public authorities that are given in the Impact Assessment appear to be conservative and of limited meaning or benefit when severe financial constraints are being placed on local authorities,” it said.

“Because of what we believe are wide variations in the costs to individual local authorities of complying with new regulations and guidance, there is considerably uncertainty in what these costs will be over England and Wales,” it added.

LARAC acknowledged that it could not provide a better way of estimating the costs than that used in the consultation, but said that the assessments could “scarcely merit” being called ‘ballpark' figures, “let alone be used as evidence for policy”.

In particular, it takes issue with the consultation's claim that additional costs in relation to developing waste management plans are expected to be “minimal” and would cost a maximum of £304,000 between the 152 local planning authorities.

Instead, it points towards the cost of providing regular and continuing surveys of commercial waste arisings, information on non-local authority ‘municipal wastes' and costs in relation to reviewing existing waste management strategies to meet the requirements of article 28.

LARAC said: “Costs of reviewing, amending and, in some cases, re-writing municipal waste management strategies will vary from local authority to local authority.

“For some the additional cost will be negligible, for others it will amount to tens of thousands of pounds. We believe the cost estimates given in the IA are, overall, too low,” it added.

Recycling targets

In terms of reaching the Directive's 50% recycling goal, LARAC said that the “wait and see” approach favoured by the government “may not be wholly appropriate”, claiming that Defra had not taken a number of factors fully into account.

These included:

• the move away from recycling being driven by imposed targets for councils, something LARAC said the new government's ‘localism' agenda will accelerate;
• the “main effect” of the landfill tax escalator is to drive waste treatment technology, not separate recycling collections;
• waste policy not being “articulated” with drivers encouraging councils to reduce carbon emissions, such as the Carbon Reduction Commitment, which LARAC believes is now a stronger driver for councils than the need to increase recycling;
• the potential for communities secretary Eric Pickles' promise to end council “non-jobs” to impact on waste. LARAC explained: “The fact that he explicitly mentioned communications and waste strategy officers means that this can only damage the excellent work that local authorities have carried out over the last five years, in conjunction with WRAP, bringing about the cultural change and wide public awareness of the need to increase recycling”;
• Mr Pickles' call for the withdrawal of Audit Commission guidance on fortnightly collections (see letsrecycle.com story) would have an “undetermined but clearly detrimental” effect on recycling rates;
• Financial constraints on councils could see recycling provision reduced when costs exceed gains.

LARAC concluded that, if the household waste recycling target set by the Directive is to be reached, these issues must be addressed on a “shorter timescale” than that suggested in the consultation.

The results of the consultation are expected to feed into the final regulations that will come into force on December 12 2010 to implement the Directive in England and Wales.