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Why DEFRA’s waste consultations matter; we are ALL stakeholders now!

Just before Christmas, DEFRA published its long-awaited mega-strategy for the sustainable use of resources and the management of waste. It was obviously the season of goodwill for it attracted almost universal acclaim for finally addressing long-standing ‘wicked issues’ that previous Governments had chosen to avoid. No wonder Michael Gove was purring with self-satisfaction.

Such criticism as surfaced from environmental campaigners was not about the content of the 150-page document. The problem with Our Waste, Our Resources: a Strategy for England, they claim is not the direction of travel, but the speed of the journey. It will take too long to change behaviour. So much will depend upon the pace and progress of DEFRA’s consultations.

And there are a great many consultations. To its credit, the department has published a timetable for its strategy:

Over the years, we have rarely uncovered a systematic plan of this nature; for that the Department must be congratulated. For those in the industry, it is as clear a road map as you can get in an uncertain world. Except that this is not just for local authorities, for recycling contractors or builders of energy from waste plants. Everybody who makes anything, who packages anything, or who consumes anything is affected.

Just consider the four consultations announced last week: –

  • A deposit return scheme for drinks containers, intended to improve the recycling rates for the 14 billion plastic drinks bottles, 9 billion drinks cans and 5 billion glass bottles used in the UK each year.
  • A reformed UK packaging producer responsibility system to incentivise the recyclability of packaging, tighter compliance monitoring and enforcement including of export regulations; and makes it easier for consumers to recycle packaging materials.
  • Consistency in Household and Business Recycling Collections in England requiring local authorities to collect a core set of dry recyclable materials and to introduce separate food waste collections and free garden waste collections.
  • Plastic packaging tax seeking views on the design of a brand new tax on the production and import of plastic packaging that doesn’t include at least 30% recycled content.

If these sound straightforward or uncontroversial, beware. They are not, and the Government knows it. Reforming grotesque over-packaging practices and their supply chains will engage the business community – not necessarily constructively. And standardising waste collection means backtracking on the Localism theory introduced as part of Government cost-cutting. (Only a third of English Councils have separate food waste collections!). ‘Fast fashion’ may be popular – but will consumers easily renounce their enthusiasm for cheap textiles. Will business relish the prospect of paying more for waste materials to be collected and recycled? We may all be stakeholders, but there are plenty who will find something or another inconvenient … or worse.

They are hefty documents. The Producer packaging one is 125 pages, the Consistent collections and Deposit Return papers come in lighter at 63 and 68 pages respectively and the Plastic packaging tax weighs in at a paltry 42 pages – rather restrained for a consultation jointly run with the Treasury. When there was a ‘call for evidence’ on this subject last year, 162,000 responses were made. How many will participate this time around?

So, here are three observations: –

(1) Whatever is said about other Government departments, DEFRA – under Michael Gove, at least seems to have committed itself lock-stock-and-barrel to a consultation-led policy-making approach. It would be churlish to criticise. The consultation papers themselves are well researched and the consultations – at first glance appear to be fair and relatively open-minded. It is also extremely helpful to place them in a broader framework – the December paper. It does not entirely escape overlaps and duplications but avoids the piecemeal policy-making we see elsewhere in Whitehall where the relationship between one policy domain and another seems to be overlooked as departmental silos battle it out. One senses that DEFRA is about to quietly secure the reverse an almost decade-long squeeze on local council funding for waste management that has seen recycling rates stagnate in England whilst they have soared in Wales.

Politically, Gove has little choice. His portfolio includes many of the more intractable problems which a post-BREXIT Government would have to tackle including farming and fishing where consultations have already been launched. He owns the air pollution problem, key aspects of climate change management and knows that promising a ‘Green BREXIT’ was one route to persuading the defeated liberal elite Remainers that it might not be so bad after all. Whatever the motivation, those who believe in evidence-based policy-making and a consultation-led informed dialogue should applaud his approach.

 

(2) But what kind of debates will we have? Many of the issues raised in these consultations go far beyond the obvious and require consumers – all of us – to change behaviours as well as producers, distributors, transportation and public bodies all to spend more and become more regulated – two things that fly in the face of many people’s philosophical and practical preferences. It is one of the reasons why the Americans find it so hard to tackle climate change! Academic experts in this field know this well, and in these massive consultations, we see an attempt to soften up the public for tough decisions ahead. Put simply, to carry out its 25-year plan for the Environment the Government – indeed any Government would need to carry people with it. Politicians remember how the fuel price escalator had to be abandoned for lack of popular support. They also know how damaging it is to back the wrong horse as they did by promoting the use of diesel cars. This is truly a case study for the Politics of Consultation

Can it be enough just to launch consultation papers and wait for responses to be submitted … mostly online? Clearly timing, simultaneously with the BREXIT hiatus crowds out other issues, so we won’t see many public events. But are there sufficient attempts being made to have deliberative sessions with the large number of stakeholder types that matter? And can we not involve civil society more – whether it is the Women’s Institutes, youth bodies or local community councils?  A bureaucratic below-the-radar series of consultations just plays into the hands of big business or the trade associations, and we understand that Greenpeace’s greatest fear is that that powerful commercial interests can yet frustrate and delay even the more popular proposals.

 

(3) Will anyone listen? So far; so good. The consultations have been launched but there will be a tendency to drown in the detail with a danger possibly that the most important decision-points will not attract enough coverage in the BREXIT-dominated media. People and organisations who care will need to do far more than offer a response. A consultation is, in effect an invitation to debate issues of importance and too many – even political activists are sadly unaware of their rights as consultees. Old-fashioned skills of political campaigning still matter – even in the days of social media. A key task is just to raise awareness. Tell people that these issues are out there for public discussion, and that a large number of options seem genuinely not to have been pre-determined.

Governments frequently find themselves torn between providing too firm a lead in policy-making – with the result that they are castigated for having pre-determined the outcome or leaving too much for debate and appear lacking in drive or direction. In these DEFRA consultations, there are signs of both, but much of the subject-matter will lend themselves to grassroots mobilisation (- one thinks of garden waste disposal …. sorry) and environmental campaigning. The recycling of fridges may be a specialist subject but is probably more likely to be discussed at one’s local pub than many more obscure items of political policy!

In summary, here are a set of public consultations that matter, with more (eg on Food waste) to follow soon. For its own reputation as well as for sound policy-making, the consultations need to be handled well by DEFRA. There needs to be scrutiny, and this especially applies when Ministers start considering the evidence. The Institute will be watching, but we urge all members, supporters and newsletter readers also to watch what happens in this space.

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