40. Do you agree that all retailers selling in-scope drinks containers should be obligated to host a return point, whether it is an all-in or on-the-go (OTG) deposit return scheme?
Neither agree nor disagree. Retailers vary significantly in size small retailers on high streets, street corners or villages will struggle to accommodate large quantities of returns. With an increase in on-line supermarket shopping and many households short of storage, a scenario whereby units are bought via and online supermarket, and returns are taken daily to the local shop, unfairly penalises the small business.
41. Given the proposed extensive distribution and availability of return points for consumers to return bottles to, do you think customers would be likely to experience delays / inconveniences in returning drinks containers?
Not a straight-forward question. Delays are already experienced at retailers without a DRS so therefore, adding in another action, would only increase the delay already being experienced
42. Do you have a preference, based on the 3 options described, on what the schemes approach to online takeback obligations should be? We welcome views from stakeholders on who this obligation should apply to, including if there should be an exception for smaller retailers or low volume sales.
None of the proposed options are ideal. Things to be considered are; how can the item best be recycled and what is the carbon and environmental quality implication of each option. An option that increases the size or type of vehicle being used is counterintuitive and therefore more consideration of the options needs to take place.
43. Do you agree with the proposed criteria for the calculation of the handling fee?
Neither agree nor disagree
The handling fee could be further used to incentivise other low carbon, environmental or social behaviours such as encouraging the use of electric vehicles, energy efficient equipment and buildings. However there is a risk that some retailers may lose out where costs are not paid on actuals, and as such some sort of appeals procedure should be allowed for – to ensure that the intention is fully respected that any retailer should be compensated for ‘any costs incurred in hosting a return point’.
44. Please tick which exemptions you agree should be included under the scheme:
Close proximity and Breach of safety
45. Please can you provide any evidence on how many small and micro sized retail businesses we might likely expect to apply for an exemption to hosting a return point, on the grounds of either close proximity to another return point or on the compromise of safety considerations?
No evidence to submit
46. Do you think obligations should be placed on retailers exempted from hosting a return point to display specific information informing consumers of their exemption?
Signage to demonstrate they don't host a return point and signage to signpost consumers to the nearest return point
47. Do you agree with our rationale for not requiring retailers exempted on the basis of a breach of safety not to be required to signpost to another retailer?
Yes. For anti-competitive reasons set out in the consultation document
48. How long do you think exemptions should be granted for until a review date is required to ensure the exemption is still required?
3 years
49. Do you think the scheme could benefit from technological solutions being incorporated as a method of return, alongside reverse vending machines and manual return points?
Yes
50. How could a digital deposit return scheme solution be integrated into existing waste collection infrastructure?
Using existing waste collection infrastructure, provided by the local authorities and waste management companies, to deliver DRS inherently feels like an unnecessary expense. If the household and business collection services are good enough to deliver high quality recycling then why the expense of a DRS system?
51. What are the potential fraud control measures a digital deposit return scheme could bring?
There are two significant risks with digital DRS. 1. Inclusion – society as a whole is not equal when it comes to digitisation. Sections of society do not have access to the technology required for various reasons and therefore it is not a service that is accessible to all. 2. For those that can access the service, there is a question about data. Who holds what data and what is its intended use? Until the issue of equality and data security are resolved. Local authority collection systems being used to facilitate this function is not acceptable.
52. Do you think a digital deposit return scheme could ensure the same level of material quality in the returns compared to a tradition return to retail model, given containers may not be returned via a reverse vending machine or manual return point where there is likely to be a greater scrutiny on quality of the container before being accepted?
One of the reasons given for a DRS is to improve the quality of recyclable material that is being presented at kerbside. If kerbside collections are facilitating DRS then the quality of the material coming through this route will be the same. The LGA feels that kerbside collections deliver good quality, value for money recycling services. It is a redistribution of that cost to the producers that is the key requirement.
53. If the digital deposit return scheme system can be integrated into the existing waste collection infrastructure would its implementation and running costs be lower?
The digital return scheme systems running costs would be lower. The existing waste collection infrastructure running costs would be the same or higher, depending on who audits the consumers behaviour. This is a question of who pays the running costs. In this scenario a digital DRS becomes an incentive scheme.
54. Do you support the proposal to introduce a new permitted development right for reverse vending machines, to support the ease of implementation for the scheme?
Do you have any amendments or additional parameters you would propose are reflected in the permitted development right?
The LGA does not support permitted development rights (PDR). PDR removes local planning authorities’ ability to make the appropriate long-term decisions for their infrastructure and services, Only a locally-led planning system in which councils and the communities they represent have a say over the way places develop will ensure the delivery of high-quality affordable homes with the necessary infrastructure to create sustainable, resilient places for current and future generations.
PDR can cause significant environmental issues such as surface water flooding and in this case, damage the streetscape. The LGA’s preferred option would be for the DMO to fund planning posts that could work with local authorities to develop supplementary planning guidance for reverse vending machines.
However, if Government did continue the PDR route, these amendments or additional parameters should be included.
- Should exclude conservation areas
- Suitable locations should be specified (supermarket car parks, retail parks, retail arcades)
- Size limit
- Maintenance and cleaning requirement
- Ensure access both to, and past, for people with disabilities.
- A prior approval process with a deemed consent if no response from the LPA may be a better option than a pure PDR.
- There may be potential issues regarding loss of car parking on smaller scale retail sites.
- Appropriate amendments to the advertisement regulations should be made to give deemed consent for any necessary signage.
- A condition requiring redundant machines to be removed when no longer being used.