Deposit Return Schemes and Destinations update

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Efforts continue to try and highlight that the almost inevitable introduction of a Deposit Return Scheme (DRS) for many or all types of drinks containers could be far more problematic than they might first appear, especially, for those places like popular destinations, major towns and Cities where, “on the go”, drinks containers are distributed in quantity from a wide variety of outlets.  Nothing much has changed since my last flag waving exercise, other than of course the Secretary of State, The Prime Minister and much of the rest of the Cabinet.  These changes could mean that an DRS isn’t adopted quite as soon or to the same degree as it might have done under Michael Gove’s leadership at Defra. However, that’s supposition not supported by any declared changes in policy direction that I am aware of.

Personally, and professionally, I still have no doubt that a DRS is needed to help stem a tide of disposable, single use items of all types and materials and not just in tourism and leisure.  So why am I still nervous about the impending introduction of a DRS and its potential impacts on the visitor economy and place making? In short, the more I look at the problem the more I realise just how easy it could be to get this badly wrong, either in an effort to appease public concern, or because of a reluctance to burden business or more likely a fudged mashup somewhere between the two.  The harder I look, the more I am forced to conclude that the better a DRS is for recycling and waste management the worse it is likely to be for business interests and vice versa. I also believe that destinations need the DRS to work well in both areas; hence my concern and desire to get others to understand and articulate it.

What looks from outside like a simple linear, one dimensional issue of collecting together and “recycling” more of what we use, is in practice far from simple. It is a multi-dimensional, dynamic, self-competing set of problems involving among other things: encouragement for reduction/discouragement of use, initial capture, recovery and centralisation, transportation (at every stage), sorting, resorting, cleaning and storage (at various stages), identification and maintenance of viable markets for a wide variety of different materials collected, conveniently located reprocessing and remanufacture facilities, sufficient processing and remanufacturing capacity and, ultimately, a viable market for both the recycled new raw materials and for any new products, produced with them. If any step in that long process faulters then the whole DRS and other parallel recycling models, effectively starts to fail. What’s the point of recycling if it isn’t then recycled?

UK capacity and the continued viability of exporting recycled or recyclable plastics, in particular, are already questionable areas and that is before we endeavour to capture and process far more plastic, glass, paper and metal containers through a UK based DRS.  Moreover, we are not operating in isolation.  Other developed countries are also trying to recycle far more, while developing nations are increasingly resisting the import of other nation’s waste, including recyclables, some (much?) of which have previously proved to be too contaminated for viable use and ended up being dumped, buried or burnt, totally defeating the original intent.

To add to these practicalities, a workable DRS also involves putting a not insubstantial, artificial monitory value in the UK on literally billions of otherwise, individually worthless items, produced in both the UK and abroad. The best estimates puts the UK’s annual consumption of plastic single use bottles, alone at 13bn, making an all-in scheme for plastic bottle a £1.3bn affair assuming a modest 10p deposit, and that’s before you start considering some or all of the other billions of glass, metal and card drinks containers and potentially paper and plastic drinks cups also in annual circulation that are potential subject to the DRS.  The financial scale will almost certainly necessitate some form of rigorous control across the supply and recovery chains from the point that it is eventually decided to apply the deposit to the point where it is decided to stop  redeeming it and the items are deemed to have returned to their waste value only. Conceivably the deposit could be left as a simple transaction between the retailer and customer only, at which point it starts to beg questions around how does that approach act to influence critical improvements in recycling within the waste chain from the retailer back to remanufacturing?  Getting more of the empties back in to the hands of some or all of the original retailers is surely only the first step in a very long chain of events?

Where it is decided that the extra value starts and ends and whether that value is applied to all identical containers or just those sold in certain circumstance, radically changes the nature and/or impact of the scheme.  How that value is identified, for example, via different bar coding will also impact on manufacturing, distribution and wholesales practices.  Does the beer bottle bought at the supermarket attract the same treatment as an apparently identical bottle bought and usually but not always consumed in a pub or restaurant? If it doesn’t then what are the implications of that major exemption and many potential others for setting up an otherwise seamless national scheme?  Giving individually worthless items an artificial value opens up the potential for all manner and scale of enterprise, some of it, potential undesirable, like individuals “bin dipping”. It could very easily negatively alter the financial modelling underpinning existing public and other recycling operations (or, if so designed, strengthen them?).  Moreover, if the financial aspects of the chosen scheme are not absolutely water tight, it could present multiple opportunities for abuse at any or all levels, from individuals making pocket money, to multi-million-pound fraud.

Understanding how the whole DRS process will work from start to finish and how it holistically impacts on our local business partners and their customer, and on the public services and public space is more than just important.  Unless we proactively influence the shape and detail of the scheme and its processes well beyond those that directly involve our retailer, their customer and the public services and public realm we could be gifted a solution, that doesn’t meet the peculiarities and typically scale of our destinations major industry’s needs.

The scale of the DRS undertaking itself means that a national, one size fits all approach is the most likely outcome, and such approaches seldom sit well with a transient visitor heavy economy.   For example, a system that charges a deposit at all points of sale but is predominantly redeemable at major, usually out of town, supermarkets (a strongly hinted at option) may work for many communities and for local residents but it would hardly meet the needs of the visitors, the visitor economy and their predominantly on the go consumption.  Unless of course it is viewed as a new form of visitor, environmental tax? A tax that Councils try, as best they can, to collect via public litter bins and the drinks container deposited in them in quantity for want of any convenient refund provision.  This assumes that the scheme includes provision for Councils and/or other organisations a mechanism for claim back the deposit without taking the empties back to the retail refund points themselves!

How this might all work in practice and what options there are for other enterprising activities that might emerge to intercept or recover containers from the public waste stream before the Council can benefit are endless.  The involvement of private enterprise, officially approved or otherwise, in itself may be no bad thing? However, simply allowing the market to dictate how the DRS functions in anyone location, doesn’t auger well for the provision of good quality environmental management and place making, especially in those places that have to maintain a good environment and environmental standards in order to attract and maintain visitor volumes.

Over the summer Defra should be working towards the production of various major environmental consultations including that on the introduction of an DRS in England Wales and Northern Ireland (Scotland are working on their own scheme).  Whether, the change of Secretary of State will make any difference to the nature style and timing remains to be seen.  Michael Gove appeared to be extremely pro the concept, keen to introduce it next year and he publicly professed a personal preference for widest possible application of an DRS for all types of containers, of all materials and of all sizes (the “all-in” approach). His successor’s views aren’t yet so clear, nor is the impact on Defra’s workloads and priorities of the Cabinet’s renew focus on preparing for Brexit and/or a no deal Brexit on 31 October 2019.

I hope the note, if a little long, is still a useful thought piece.  Another will follow shortly that aims to illustrate that seemingly good ideas around single use plastics and environmental policy issues are a potential minefield. A minefield, that I understand, an increasing number of destination managers are being invited to venture into in the pursuit of local environmental, quick wins that demonstrate responsive local policy making.

MacDonalds and their decision to replace plastic straws with a paper-based alternative (along with many other corporate players) is, I think, a really good example of the law of unintended consequence and of a potential worrying trend towards, what in practice can be smokescreen, headline environmental policies that don’t necessarily address root causes and that can intentionally or unintentionally leave a range of other potentially far bigger problems unresolved.  If MacDonalds’ well-intentioned actions can backfire and leave them publicly  exposed, then so can most, if not all other’s well intended actions.  More detail to follow.

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