Clash of the hierarchies

The long awaited details of DCLG’s £250m Weekly Collection Support Scheme were announced last week in the form of a prospectus for local authority applicants. For all the undoubted effort that has gone into trying to reconcile respect for the waste hierarchy with Eric Pickles’ vision of every Briton living unmenaced by 8-day old chicken tikka masala, the end result would appear to be a bit half-baked.

The application process itself is rather unclear. While authorities ‘should’ submit expressions of interest by 16^th March, doing so is not apparently a precondition of putting in an outline bid in May. A bigger issue lies with the multi-criteria analysis (MCA) that will be used to evaluate applications.

While Pickles assured the Communities and Local Government Select Committee that the scheme would be implemented ‘without sacrificing recycling’, a focus on weekly refuse collection was always going to come into tension with the demands of the waste hierarchy.  After all, the available evidence suggests that schemes with weekly black bag collections typically result in more waste and lower recycling rates than less frequent residual collections. So how does the prospectus square the circle? The short answer is that it simply ignores the waste hierarchy, giving it not a single mention. The longer answer is more interesting.

Core sampling

One of the ‘core criteria’ against which bids are to be evaluated is ‘quantifiable environmental benefits’, based on the ‘carbon impact’ of the project resulting from anticipated changes in waste arisings and management routes. This would therefore seem to favour bids that will prevent waste, increase recycling and bring about a reduction in the level of residual waste.  So far, so good.

Another core criterion is cost-effectiveness. This again would appear to favour schemes that lead to a reduction in residual waste, given the high and increasing cost of its subsequent treatment and/or disposal. However, what is meant by cost-effectiveness is not readily discernible, as no denominator is stated. Is it the cost per tonne of carbon dioxide avoided? Is it the cost per tonne of waste diverted from landfill? Neither, it seems. Projects just have to ‘demonstrate a cost effective means of achieving their proposed aims’, aims which will most likely vary between bids.

Even among vocal opponents of the Scheme, there has been a warm welcome for the decision to allow separate food waste collections to qualify for funding. This too, would seem entirely consistent with the waste hierarchy. However, a third core criterion relating to ‘collection pattern committed to’ appears to greatly limit this concession. The food waste option is placed on the bottom rung of a new weekly collection ‘comprehensiveness’ hierarchy. In order of priority, this favours:

• a weekly residual collection alongside a weekly recyclables collection;
• a weekly residual collection alongside a fortnightly recyclables collection;
• adding a weekly food waste (or organic) collection to a fortnightly collection of residual household waste.

In determining comprehensiveness, DCLG will also take account of the number of households that will receive a weekly collection.

Authorities proposing separate food waste collections also have to pass the additional hurdle of confirming that they have credible support from local people. The prospectus states that this could include qualitative or quantitative feedback from residents – but does not clarify whether public support must be for the weekly food waste collection, the fortnightly residual, or both. While Eric Pickles’ introduction says that ‘at the heart of localism is choice’, it appears it is only ‘wrong for council officials to not even bother to ask local people what they think and want’ if they propose to deviate from the preferred path of weekly refuse collection.

Eric Pickles

The last of the core criteria is the innovation ‘wildcard’. Bids will be assessed on how innovative their approach is – and to assist authorities’ thinking, DCLG helpfully provide ‘examples of innovative service design that will help bids score more highly’. Top of the pile is reward schemes, although tackling the problem of ‘bin blight’ also gets a mention. Presumably, reducing the frequency with which bins are set out wouldn’t cut the innovation mustard.

Weighting game

While the core criteria for the MCA have been announced, one critical element of the evaluation process remains under wraps – and won’t be finalised until all the bids are in.  During the evaluation, the DCLG policy team will assign weightings to the criteria and adjust these weightings to ‘sense-check’ the effect this has on how bids are ranked. They will choose weightings that ensure that, when taken as a whole, the package of successful bids ‘maximises cost effectiveness, satisfies the aggregate environmental tests, and demonstrates a reasonable spread of successful bids (noting factors such as type of bids, geographical spread, and the number of households or local authorities)’.

Of course this means that local authorities will, to some extent, be bidding blind. Should they focus on delivering an environmental benefit, even if this makes the scheme more expensive? Should they try to do something innovative, even if it can’t be made available to everyone? And should they bother even looking at adding weekly food waste collections to fortnightly refuse, given its place in the collection hierarchy and the extra democratic hurdle that must be passed in the short time available?

At the Select Committee, when Heidi Alexander asked Eric Pickles whether the fund would be open to food waste collections, he suggested she ‘would be pleased with the scheme’. If she has analysed the prospectus in detail it would be great to hear just how pleased she is.