Amongst the backdrop of a lack of money in Councils generally, waste management services have an additional set of challenges related to new policy, retaining new payment streams and cost liabilities. This second of a two part blog sets out key topics that are relevant for most of our client Councils (items 1-3 are in the preceding part of this blog), and potential solutions (the priority order will be bespoke to the Council).

4 - The Emissions Trading Scheme (ETS) liability – this will affect most forms of waste disposal to a greater or lesser degree (post 2028) as there is usually a significant combustion (Energy from Waste, EfW) aspect to disposal of residual waste in England. Generating energy from residual municipal waste has become a comparatively more carbon intensive process over time (as the electricity grid becomes cleaner, through more renewables). The ETS therefore brings this technology within its remit, hence the additional cost burden coming down the track to Councils in 2028. This liability can be mitigated by extracting more plastics from the waste, and potentially also more textiles, nappies and small waste electricals (which will also contain fossil carbon, and therefore be subject to ETS if burnt). The ‘effectiveness’ of materials separation / diversion (see the first part of this blog, item 2) will also help mitigate these liabilities, and the four other methods of limiting ETS exposure are:

• using a non ETS residual waste treatment option (although landfill should be avoided and Landfill Tax should be increased to make residual waste disposal more costly than treatment);
• pre-treating residual waste to further remove plastics prior to combustion (e.g. a residual waste MRF);
• using a facility with Carbon Capture & Storage (CCS), and;
• using a facility with District Heating.

Future waste treatment procurements should have consideration to alternative technologies and reducing fossil carbon in residual waste. Existing long term operations will require exploring options with the contractor running the treatment / disposal operation to help address these cost liabilities.

5 - Local Government Reorganisation – this provides the opportunity to rethink operations and seek to generate efficiencies across both services and infrastructure when organising across a different Council geography. There is the potential for rationalisation of management with Waste Collection Authority and Waste Disposal Authority being combined into Unitary Authorities, but also to target investment to increase waste reduction, behaviour change and recycling effectiveness, efficiency and to reduce liabilities on the ETS and EPR aspects. A review of the ‘new’ operations and infrastructure can set out a list of priority areas to help address all 6 aspects covered in these two blogs.

6 - Simpler Recycling (SR) – Whilst subject to new burdens funding to a degree, there are significant planning, procurement, communications and mobilisation costs around any change in service, and for some Councils Simpler Recycling is a massive change, whilst for others it is business as usual. There are almost 50% of Councils in England that don’t currently collect food waste, but will need to begin collecting and procuring the treatment of household food waste from April 2026. A much higher % don’t separately collect plastic film but will need to from April 2027 (this could be expanded for WEEE and textiles in future years). There is also a need to offer services to households that may have previously had a more limited service (such as flats above shops), and there is good practice and technical solutions for this (see previous FRM blogs this month). There are differential impacts on Councils as to whether they have an active commercial waste collection (see item 3, from the first part of this blog), which should already be in compliance with the SR Regs. Planning new collection and recycling / treatment services require a review of the service and consideration of alternative options prior to setting out a business case and moving into implementation. Householders need engaging with regarding these changes and then suitable communications regarding ‘how and when and why’ they should be using the services.

See part 1 of this blog for the other three main challenges and solutions – Efficiency, Effectiveness and Revenue Generation! We have an experienced, specialist team of Chartered professionals who can support on any of the above, either as a flexible critical friend or a friendly team to deliver specific tasks, we have worked with over 130 Councils on waste consultancy. See www.frithrm.com for details or email paul@frithrm.com or call 01746 552423 for a chat.