18 May 2018

Commercialisation and HWRCs

Brian Mayne and John Woodruff from the Resource Efficiency & Waste Management team at Ricardo Energy & Environment look at the options for commercialisation of HWRCs


Against a backdrop of China’s Operation Sword, austerity and Brexit, local authorities are under ever-increasing  financial pressure to adopt a commercial and entrepreneurial approach to generating income while continuing to deliver high quality and efficient customer-focused services. 

One service that has been developed over recent years is the introduction of charges for commercial waste at household waste and recycling centres (HWRCs), which not only provides economic benefits but improves local services to small businesses as well as protecting the provision of HWRCs for residents.

Councils have introduced a range of ways they can charge traders including:

  • Pay by weight
  • Pay by container, item or volume
  • Pre-payment of sacks
  • Subscription

Often these charges are linked to benefits whereby the customer pays less if they separate their waste – often separated recyclable materials are charged at a lower rate than mixed loads.  Unsorted loads, whether they’re made up of recyclable materials or not, normally attract a higher rate resulting in better quality recyclate with additional economic and environmental impacts.

HWRCs

A range of approaches are taken by local authorities to the operation of HWRCs

There are a number of additional benefits to Local Authorities in taking this approach at HWRCs including:

  1. Developing staff by providing an opportunity for them to acquire commercial skills which can be transferred to other opportunities internally;
  2. Increasing the opportunity to reuse and recycle;
  3. Providing small businesses with a local accessible service to dispose of their waste correctly;
  4. Improving control of commercial waste at HWRCs, with a reduced quantity of material being disposed of by traders under the guise of household waste.
  5. Incentivising businesses to separate their recyclables to reduce costs and

Generating revenue which can support non-statutory services that would otherwise be stopped or reduced due to lack of funding.

This commercialisation of HWRCs hasn’t stopped at trade waste however, as Councils have introduced or sought to introduce charges to residents for the use of HWRCs to dispose of DIY-type waste from home renovations (soil, rubble, plasterboard, carpets, or kitchen or bathroom fittings), which has been contentious to say the least.

Interpretation

These charges have been introduced due to the difficulty in interpreting Section 51 of the EPA (1990), which sets out the duty for Waste Disposal Authorities (WDAs) to provide a facility for residents in their area to dispose of household waste free of charge. Confusingly, whilst construction and demolition waste from households is not defined as household waste for the purposes of the EPA, DIY waste is classed as household waste if it results from work a householder would normally carry out, according to WRAP’s HWRC Guide, last updated in January 2016.

The Guide also accepts that this interpretation may differ depending on the householder’s ability to perform certain home improvement tasks, and ‘if a householder employs the services of a trades person to perform domestic tasks consideration must be given the classification of the resultant waste.’

In addition, the litter strategy, which was jointly compiled by the Department for Communities and Local Government (DCLG), the Department for Environment, Food and Rural Affairs (Defra) and the Department for Transport (DfT), claims that charges for waste disposal at HWRCs ‘can make disposing of waste more difficult’. The government noted: “There is a long-established precedent of free access for local residents to deposit household waste at household waste recycling centres (HWRCs) and this is now reflected in Regulations brought into force in 2015 – the Local Authorities (Prohibition of Charging Residents to Deposit Household Waste) Order – which prohibits councils from charging residents for the use of HWRCs either at the point of entry, exit or disposal.

Clarity

Due to the lack of clarity over the legality of charging the public, many local authorities have gone ahead and introduced and continue to charge for DIY-type waste. A survey by the National Association of Waste Disposal Officer (NAWDO) members was carried out last year and of the 55 responses received, covering 421 HWRCs, 18 were charging, with 2 more introducing charges since and a further 8 considering the option. The main reasons for introducing charges were to keep the sites open at current levels and generate some much needed income to enable service levels to be maintained.

The predominant materials attracting a charge were hardcore, rubble, soil & stones, pipes, guttering, ceramics and breeze blocks.  However, materials such as doors, kitchen units, wooden/laminate flooring, sinks and windows illustrate the difficulty of defining where DIY stops and construction & demolition begins.

THE MAIN REASONS FOR INTRODUCING CHARGES WERE TO KEEP THE SITES OPEN AT CURRENT LEVELS AND GENERATE SOME MUCH NEEDED INCOME TO ENABLE SERVICE LEVELS TO BE MAINTAINED.

The government has pledged to work with WRAP to review current guidance to ‘ensure this reflects changes in the law and to make clear what can and cannot be charged for at HWRCs – including in respect of DIY waste’. This revised guidance, will also explore ways of managing HWRC services to facilitate access for local householders and small businesses ‘at proportionate cost’.

Since WDAs are only required to provide a free-of-charge facility for ‘residents in their area’, some authorities make a charge for non-residents to use the site, regardless of the material delivered.

Pilot scheme

Meanwhile Hampshire County Council has taken charging a step further, as it has lobbied Government to allow it to pilot a pay-as-you-go scheme at their HWRCs. According to the Council charging the public a £1 per visit fee could raise up to £4m. This type of approach is in line with the LARAC call for research into how a ‘discretionary direct charging system’ – which sees householders paying a fee for disposal of waste – could be implemented in the UK.

There is no doubt that HWRCs play an important part in providing valuable reuse, recycling and waste management services to all sectors of the local community. However, financial pressures stretching local-authority budgets are resulting in local authorities taking decisions to reduce hours and even close sites.  Creative and innovative solutions around charging at these sites offer an opportunity to improve, expand and sustain a network of accessible sites which will provide much needed economic, social and environmental benefits.

Brian will be speaking at this year’s edition of the letsrecycle.com National Civic Amenity Site Conference on the 7th June in Leicester where delegates can discover how to improve performance, maintain good service levels and hear practical guidance on how to achieve the most from a civic amenity site.

AUTHORS

Mayne

Brian Mayne is Ricardo Energy & Environment’s Regional Director (Wales) for waste management and resource efficiency.

He is a fellow of the Chartered Institution of Wastes Management and Chartered Environmentalist. Brian is responsible for project direction and management, business development and technical delivery across a range of resource efficiency areas for Ricardo Energy and Environment. He has a background in strategy policy and operational management at a senior level within local government. He has delivered presentations, workshops, seminars, papers and case studies on the commercialisation of public realm services throughout the UK.

John Woodruff is a Principal Consultant in Waste Operations at Ricardo Energy & Environment.

He has 30 years’ experience in the waste industry, initially as a contractor working to local authorities, and then working in local government for 16 years. John has extensive direct experience of waste collection, management, disposal and recycling, both as a contractor and a client manager and is well versed in designing, evaluating and negotiating service developments, operational efficiencies, the roll-out of new services and methodologies and the redevelopment of HWRC and WTS facilities to enable flexibility in handling varied material streams.

1COMMENTS

Councils should be focused on much needed profit not revenue. This simple slip in terminology is the reason why councils should stick to their main skill set rather than chasing revenue. This will end up in traders being undercharged, private companies losing work / jobs and the councils generating losses that they either hide in their budgets or fail to recognise in the first place as losses. Unfortunately, in my experience, councils seeking to commercialise really ends up with the tax payers subsidising local traders at the expense of the professional waste sector.

Posted by Billy Bin on May 18, 2018

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