If you are reading this on the Wednesday this LARAC Online comes out, you are 21 working days into the 61 days of the consultation period. That is 34% of the way through. So, it would appear time flies when you are not having fun as well. If it had been only an eight week consultation period, then that would mean we would be over half way through and given the workloads involved so far it shows LARAC was right to call for the full 12 weeks.
We have had a good response to the online survey of the membership, and we are looking through those at the moment to see how they inform the first drafts that we have now completed. We also have the five workshops coming up over the next week or so when again we will get members views on the consultations, the key areas of concern and support, and what the stances they want to take are. At the risk of slipping into management jargon we want the workshops to be a two-way process. They will be important in testing and refining the stances LARAC has adopted at this stage, but we also believe that participants will get information and ideas that will then inform their own responses. That is the intention anyway so we will see how we get on.
We know from talking to people and attending a couple of events that the focus for most of you is the consistency consultation and on the face of it that makes sense. But for me the EPR one is almost more important. Without the concept of full net cost recover under EPR I think the Government would have not been able to bring the consistency proposals forward. The definition of full cost recovery seems broad in the EPR consultation document and we need to fight to make sure it is kept like that. Also, there is no mention of recovering collection costs of packaging that is in residual waste, just recovery of disposal costs of packaging that is in residual waste. It may just be an oversight and the intention is that collection is also covered, but if we don’t point it out and just assume then there is always a danger it gets missed.
The consultation documents say it anyway, but it is becoming obvious that these are just the first in a series of consultations that will get more detailed as we go along. But again, we have to be careful that we have not raised issues now because we think they will come up later, but then find they don’t, and we have missed a key opportunity.
That means a lot of work now, to get full, informed and comprehensive responses back to these key consultations. Given they will potentially shape local authority waste services for a generation its an effort we should do our utmost to make.
