27 April 2020
Cyflwyno i' r ymgynghoriad Llywodraeth Cymraeg a'r Economi Gylchol
Wales Green Party Response to Circular Economy Consultation
WALES GREEN PARTY
The Gate, Keppoch Street,Cardiff, CF24 5TR
A GREEN VISION FOR A CIRCULAR ECONOMY
The circular economy in Wales should be a central part of a greener, resource efficient and climate-resilient economy, supporting the Wellbeing of citizens including a healthy and flourishing natural environment. Commitments to Circular Economy should help to bring transformative change through a holistic and participatory approach involving civil society, government and business towards a more resilient and more equal society. The Circular Economy agenda has the potential to deliver a major shift in the way our future economies and societies could be organised and managed. The need for such changes is very clear since the COVID pandemic, which has pushed us to recognise the real essentials for our communities and societies, including well-supported care and social welfare systems.
Our answers to the consultation questions are intended to highlight these wider issues of social and economic change and to flag up areas where ambition needs to be strengthened. In this we also draw on responses from civil society and local authority experts from regional consultation sessions. We also draw upon a number of excellent other submissions to this consultation from other organisations:
Circular Economy Wales (CEW)
Zero Waste Wales (ZWW)
Cardiff Community Energy (CCE)
COMPLETING THE STRATEGY
The Welsh Government Strategy document provides valuable insights, but it does not yet present a sufficiently complete picture to gain public understanding and support, or to generate transformative social impact. Our view is that the document does not really present a full strategy as it fails to state the conditions under which a Circular Economy could really flourish. It is necessary to build on the good work done in the past – but working from the concept of ‘Beyond Recycling’ downplays the fact that Circular Economy demands a change in goals for the economy as a whole. As noted by many consultation participants, a Circular Economy can only really exist if we move towards an economy that supports Wellbeing for people and planet – not growth at any cost and GDP. A related point from consultation participants was that we need to develop methods, tools, and scenarios for learning and engagement towards a ‘Circularity Culture’. Such an approach needs to work with learning, and with the Arts, through to changed business models and economic practices. Lastly, the contribution of governance to Circular Economy requires democratic innovation involving greater civil participation in helping ensure that public money is used for public benefit – for example more support for the social business start-ups and coordination in this area. We support CEW in calling for a major independent social business organisation to lead in Circular Economy in Wales, to serve communities, government, for-profit and not-for-profits.
RESPONSE TO THE WELSH GOVERNMENT CONSULTATION ON A CIRCULAR ECONOMY STRATEGY, ‘BEYOND RECYCLING’
Question 1: Are the suggested actions the best way to help us recycle more?
This question continues to presume that the responsibility for waste will continue to be that of government. New business models and legislation are moving towards concepts of leasing many goods with the responsibility of recycling staying with the producer. The current recycling settlement highlights one of the worst aspects of economic developments since the financial crisis of 2008 – Privatise gains and socialise costs. This model needs to be questioned and changed it is still ‘end-of-pipe’ and fails to address the root causes of the enormous waste in our societies.
In addition consultation participants pointed to the changes in the legal landscape underway in areas such as climate change (Heathrow Airport; Bristol Airport). In this changing landscape it was felt that the Welsh Government should be pushing for a more ambitious review of legal issues to do with waste and advocating for wider measures to be put in place supporting ‘Right to Repair’ and other such measures that address the production process earlier at the design level.
This is one area where the limited nature of the ‘Beyond Recycling’ approach can be seen – as this does not include the serious questions of agricultural waste and pollution. We recommend that Natural Resources Wales should work together with any coordinating body to build in agricultural waste into the strategy and to also outline ways that this can be diminished by changes in farming practices etc. The Circular Economy should form part of the criteria in assessing public benefit in any new farming support system in Wales with an emphasis on helping farmers do the right thing.
We are in broad agreement with the points made in the ZW response to this question. We would emphasise community learning through local Circularity hubs rather than enforcement as the key aim should be to help people do the right thing and support local innovation. We agree with ZW that there is a need to take special measures concerning critical raw materials. (See Q 20 for points about Critical Resources and Circular Economy).
We are in broad agreement with the points made in the CEW response to this question. Putting people and communities at the heart of a Circular Economy is vital. However we also need to develop and deploy the range of expertise and new thinking in our Welsh HE and Research sectors. Brokering the understanding and strategies across these different kinds of knowledge could be a key role for any coordinating organisation. For example, research is needed to draw on the wider knowledge base on Circular Economy worldwide in order that sharing of examples and experience can result in rapid developments that are needed.
Question 2: Should recycling arrangements across Wales be consistent?
YES. We support the responses provided by CCE. A coordinated all-Wales response is needed. We are in broad agreement with the responses provided by CEW. A participatory process need to be engaged to determine the best way to develop and fund a social enterprise focused on enabling the Circular Economy in Wales, learning from the experience of successful social business in Wales and elsewhere. We are in broad agreement with the response from ZW and suggest that this learning could be promoted by Local Circularity hubs who will be able to draw on their knowledge of the people and the area issues.
Question 3: Are the suggested actions in this theme the right ones? If not, why? What other actions could we consider to achieve the aims of the strategy?
We welcome these actions as a short term part of any strategy. However we would propose the following additions.
Re-think the model of responsibility for waste in production more generally as outlined above. Consider giving localities more legal powers to address particular waste nuisances such as large amounts of take-away food containers etc.
Include agricultural waste into the strategy as outlined above.
We agree with ZW that an all-Wales strategic body should be formed. We also agree with CEW that this should be a social business but would add that this should be developed through consultation with stakeholders and experienced social businesses.
We are in broad agreement with the points made by ZW regarding the timeline and ambition and also the necessity to transition as fast as possible away from incineration as a ‘solution’ to waste.
Question 4: What actions could we take to further promote the work on prevention and re-use that occur in our communities?
We are in broad agreement with the responses from CEW, particularly with the need to embed the ‘waste hierarchy’ in any strategy – Re-design, Re-use and Recycle as a last resort.
We also agree with CEW in their emphasis on the leadership role to be taken by social economy actors and that the Welsh Government should support the proposal to create an overarching support and coordination social business for the Circular Economy in Wales.
We would add that this coordinating body should help create and support local Circularity hubs as themselves independent social businesses with income derived partly from delivering learning in the community and fostering innovation in social and for-profit economy for Circularity.
We are in broad agreement with the responses from ZW – especially the need to recognise and draw on the experience and social learning of the existing social business in Wales. This includes the need to develop working relationships and exchange of information with local authorities.
Question 5: Do you agree we should develop and expand the work we do in schools on waste prevention and re-use?
The existing ESDGC curriculum can be expanded and developed to further cover information about Circularity in natural processes, biomimicry and the need for Circular Economy. This can be linked to Global Citizenship and the relationships between being a good local citizen and being a good global citizen. This includes understanding and support for the WG commitment to stop exporting waste to other countries.
We are in broad agreement with the response from CEW that schools should have in place systems for re-use. Creative projects in Circular Economy innovation should also be encouraged and linked to community service aspects.
We also broadly support the suggestions in the ZW response for the review and broadening of the Eco-Schools agenda.
Question 6: What do you think are the key steps that we need to take to further reduce avoidable food waste?
We are in broad agreement with the points made by CEW. The linkages between the composting and use of food waste and regenerative agriculture need to be made. Soil loss and depletion is a big issue in Wales and indeed worldwide. Heavy agricultural machinery, along with floods is destroying soil structure and our soil is travelling down our rivers to be lost in the ocean. This has links to the important question of food security and resilience, likely to be under stress in the economic downturn following COVID (let alone a potential ‘hard’ Brexit and its economically disastrous effects). Again, this strategy needs to be linked to wider agricultural strategies for protecting and enhancing soils.
We are broadly in agreement with the comments from ZW, with their emphasis on the value of community initiatives in recycling food. There is already a food crisis in poorer communities in Wales and it is important to ensure that any surplus is used by those in need.
Question 7: Are the suggested actions in this theme the right ones? If not, why? What other actions could we consider to achieve the aims of the strategy?
The actions proposed are all valuable. However there is a need to develop a more strategic overview to show how they can be made more complementary and add up to more than the sum of the parts. There is a lack of details as to HOW some of these actions will be supported and through what mechanisms.
We agree with the comments from ZW that SROI (social return on investment) is a good measure, however this needs to link more with the objectives of a regenerating and flourishing biodiversity in Wales, supporting human health and wellbeing for current and future generations.
We are in broad agreement with the points made by CEW that devolving management of Circular Economy to social business could help facilitate locally informed action that could result in better outcomes for Reuse. The Circular Economy Fund needs to become a diversified set of financial support mechanisms in order to provide a more thorough and strategic set rather than one instrument.
Question 8: Are the materials we have listed ones we should focus attention on?
The emphasis on wood is largely welcome provided it can be sourced from plantations that maximise carbon storage and biodiversity. There needs to be more emphasis on scarce resources and the problems of composite materials. These topics need to be addressed at source, but effective recycling should mean that valuable materials stay in Wales and can make supplies more resilient as global demand for rare resources grows.
Question 9: Are design changes in products using the materials listed an area to focus on?
YES. We agree with ZW that the WG needs to develop a research-informed set of design changes that guidance and legislation work towards as opportunities arise. We agree with CEW that extended producer responsibility is desirable and achievable. This is one area that participants in the consultation events clearly identified for more ambitious action by the Welsh Government, along with the need to overcome the culture of risk aversion in seeking to develop stronger measures in law and regulation.
Circular Economy requires not just individual product redesign but the REDESIGN OF PRODUCTION PROCESSES ACROSS DIFFERENT ENTERPRISES. This in turn needs overviews and the ability to work with a range of different actors: communities, business in the for-profit and not-for-profit (social) sectors, local government to identify place based opportunities and strategies. This kind of activity and communications can involve research efforts (modelling material flows etc) and social innovation across business barriers. This kind of effort overlaps with the planning system (see Question 22 below).
Question 10: Are the suggested actions in this theme the right ones? If not, why? What other actions could we consider to achieve the aims of the strategy? Are there other materials we could focus on and why?
The actions proposed are valuable but require more detail as to how they will be achieved and through what strategic instruments.
We support the additional suggestions made by CEW for mattresses, micro reprocessing and paint reuse.
Question 11: Is our focus on improving resource efficient procurement within the Public Service a priority area?
We agree that public money should be spent on procurement that helps deliver public benefit, both directly and in the wider sense of supporting a resource efficient economy. However, narrow constructions of ‘efficiency’ will not suffice. What is needed is a shift to procurement that strengthens the social, ecological, and resource resilience of the Welsh economy. This requires a more joined-up approach in the context of climate emergency and the need for mitigation and adaptation.
We agree with ZW that the power of Welsh public money should be used to help develop the market viability of production that contributes to an all-round more sustainable economy and the climate emergency.
Question 12: Is our focus on materials used and resource efficiency in construction a primary consideration to implement for the future?
Planning Policy Wales (PPW) https://gov.wales/sites/default/files/publications/2018-12/planning-policy-wales-edition-10.pdf has many references to how the planning system should support a move to a Circular Economy by embedding these principles into design choices, site selection, infrastructure provision, making use of existing buildings, and providing more sustainable transport networks and settlement patterns, as well as reducing waste and recycling building materials. Planning for a circular economy would recognise inter relationships between the built and natural environment. All these considerations should be a crucial part of preparing Local Development Plans (LDPs) and making decisions on planning applications. There is also reference to training in construction and design industries.
Construction is a key area for improvement and we are in broad agreement with the proposals from CEW for an overall Circular Economy social business to collaborate with the existing work done by Construction Excellence Wales. In addition we propose local Circularity hubs that can liaise with local social enterprise in Circular Economy and provide awareness-raising, networking and local place-based innovation.
We agree with ZW that the synergies of horticulture, silviculture and apiculture should be linked to a national forest project, developed in conjunction with communities and stakeholders.
Question 13: Are the suggested actions in this theme the right ones? If not, why? What other actions could we consider to achieve the aims of the strategy?
In general we welcome the suggested actions. We consider that Public Service Boards could liaise with the proposed Circularity hubs to improve communication, ambition and generate new ideas and initiatives.
We broadly agree with CEW that funding mechanisms based on public benefit should be developed to support Circularity social businesses and the initial need for a central fund.
Question 14: Is our continued business support to make them more resource efficient a priority action?
We agree with ZW that Circularity social business needs support from an overall body and that education is a priority area. We propose that local and societal learning be undertaken by local Circularity hubs that can liaise with schools. Further, we agree that incineration as ‘solution’ should be phased out and that they disincentivise better waste measures.
We agree with CEW that the Circular Economy Fund needs to be re-thought in the light of the importance of social business and new forms of cooperation needed for a more thorough Circular Economy strategy.
Question 15: How would you view starting a Zero Waste Town area?
Zero Waste towns have a great record and should be supported. However, the comments from ZW raise an important point that to adjust the waste responsibility picture and bring in more community & producer responsibility will change LA job structures and roles. Therefore there is a need for a wider discussion on how to transition to a new set of roles and relationships in a just manner.
We agree with CEW that consultation with previous initiatives will be essential to any success. See below Question 22 for more comments on leveraging the consultation process itself in this regard.
Question 16: Are the suggested actions in this theme the right ones? If not, why? What other actions could we consider to achieve the aims of the strategy?
The actions are welcome. However we do agree with ZW that the social sector is a central player in this and should be supported financially and politically to help engage with communities and develop new structures that do not rely on end-of-pipe disposal with LAs picking up the waste responsibility. A cross-sectoral dialogue and engagement was begun in the consultations on this strategy and could be extended – see Question 22. WE agree overall with the CLEANSTREAM approach that CEW supports.
EW have some good suggestions for delivery-based financial support to the social sector and more inclusive ways of accounting for benefit. The additional points from CEW about a need for a deeper understanding and model of Circular Economy is also welcome. The Green Party view is that will need to be linked to a re-purposing of the goals of economy to wellbeing. After the COVID economic and social shock we will need a new social contract that can deliver security, but that moves away from short-term consumerism towards a more resilient economy for all. This has to be the background for any realistic Circular Economy strategy.
Question 17: Are the initiative actions mentioned here those we should aim to provide supporting infrastructure for?
We have proposed that supporting infrastructure (in terms of policies, revenue opportunities, and so on; but also in terms of collection and processing infrastructure) should be reconsidered to support the development of the mixed economy that can help make Circular Economy a reality. In this we also agree with CEW that
Dwr Cymru is a successful model that could well be adapted to a Circular Economy lead body as a social business.
We agree with ZW that Circular Economy means re-thinking learning in schools and in communities, and we would add, across research expertise and local knowledge.
Question 18: How can we work regionally to ensure resource efficient decision making?
We propose that local Circularity hubs can be the basis for Regional working, together in partnership with civil organisations, LAs and social and for-profit business as supported by ZW. These actors could together form Regional partnerships.
We agree with CEW that permanent communication networks need to be developed.
Question 19: Are the suggested actions in this theme the right ones? If not, why? What other actions could we consider to achieve the aims of the strategy?
The suggested actions are welcome but have the major flaw of currently excluding and/or downplaying community and social business sectors. Add these in and the actions will change and become more cross-sectoral.
We agree with ZW that an all –Wales strategy is needed but consider that this would be best served by a lead body that is itself a social business on the Dwr Cymru model as suggested by CEW. NB this model is the envy of many countries and regions and is the origin of much good practice that can be adapted.
Question 20: We would like to know your views on the effects that our proposals in this document would have on the Welsh language, specifically on opportunities for people to use Welsh and on treating the Welsh language no less favourably than English. What effects do you think there would be? How could positive effects be increased, or negative effects be mitigated?
We consider, along with ZW, that if the Welsh government tried to increase community cohesion while encouraging more recycling through a circular economy then effects on the Welsh Language can be positive. This would align with the local Circularity hub proposal. In this case not only are we encouraging learners of the language to communicate more with other learners and Welsh speakers we are potentially encouraging people who currently don't speak Welsh to give it a go.
We consider that there is a need to investigate Welsh expressions and concepts that might express Circular Economy in a uniquely Welsh way and that here is one avenue for involving the Arts and Welsh Language Creative community.
We broadly agree with CEW that there is a strong relationship between maintaining cultural life and diversity of expression and putting in place a more resilient economic model – centrally including Circular Economy.
Question 21: Please also explain how you believe the proposed strategy could be formulated or changed so as to have positive effects or increased positive effects on opportunities for people to use the Welsh language and on treating the Welsh language no less favourably than the English language, and no adverse effects on opportunities for people to use the Welsh language and on treating the Welsh language no less favourably than the English language.
Similarly with the example proposed by ZW of Curitiba, if we can increase the opportunities for local engagement, learning and action by supporting local Circularity hubs. A strong overall message on Circular Economy and common recycling approaches can be made more locally meaningful and relevant by local organisations, embedded in the community.
Engage with Welsh Language creative communities to develop Welsh language cultural expression to communicate Circular Economy in the Welsh Language and through the Arts more generally.
Question 22: We have asked a number of specific questions. If you have any related issues which we have not specifically addressed, please use this space to address them
The consultation is very welcome and timely. Generally the information provided was interesting and informative. It is difficult to get the different levels of information right for a very mixed group of people and organisations involved. The comments below are intended to help improve the strategy and events going forward to help make the proposals a reality and to raise the level of ambition.
Concepts and information
1. What is Circular Economy? And/or what Should Circular Economy be? This needs to be stated. Our suggestion: A radically systemic and symbiotic ecology of livelihoods generating ecological and public value, responding to both resource limits and wellbeing goals for people and planet.
2. The consultation did not directly draw on the latest thinking internationally on CE (not referenced in the document at any rate) and this meant there was a limitation on the concept used – and consequently a lack of attention to the links needed to other areas of policy. Both these points were raised by participants in the consultations. Main areas overlooked:
a) In stating that the main problem is WASTE the background of RESOURCE depletion and more effective resource use was not really a factor considered fully. In fact resource limits are, and will become, bigger drivers of recycling and will increasingly impact business. Thus there is a business case to be assembled for up-front investment by the WG to help get a head start as a leading recycling economy.
b) One of the areas lacking (as is generally the case with areas that are considered to be ‘technical’ – was the whole issue of cultural perceptions and values associated with waste and recycling. Some participants mentioned ‘education’ and awareness raising –but cultural perceptions of jobs in the waste industry are generally negative and need to be the subject of a cultural campaign. Circular Economy heroes are out there waiting for public recognition and new language and imagery that talks of a better future.
c) Changes in business models and cooperation will need to be supported to help change an overly fragmented (and fragile) economy to something more integrated in new ways. Relationships will need to be formed that are not solely of actors in a market.
d) This point needs to be connected to RESILIENT economies that can withstand shocks and ADAPT FORWARD to the future. What links will be made with the ‘Foundation Economy’ thinking – especially in the wake of the COVID pandemic?
e) The relationship of the agricultural & food sector to the whole topic of waste, recycling & pollution. The different sectors may well need to come into closer relationship as we move towards a Circular Economy. There will be some symbiosis between agricultural ‘waste’ and other products and processes, in addition to the waste & pollution reduction in the agricultural sector that can be achieved. Natural Resources Wales therefore should be involved in this process.
f) The question of the increased use of complex materials and the extreme difficulty of recycling this kind of waste (eg microprocessors) needs to be specifically addressed.
3. Perhaps the conceptual framing of the Strategy and the consultation as ‘Beyond Recycling’ could be seen as contributing a sense of lack of ambition – and of course leaves open the question: ‘How FAR beyond?’ and ‘How FAST?’ Participants in the consultation generally wanted more ambition. Tying the discussion to recycling had the benefit that many people have experience to bring from recycling efforts – but they also brought understanding of the more systemic blocks to making recycling work. These points should have been more systematically captured.
4. There was some comment from participants in consultation meetings that more insight into the STRATEGY proposed for a thoroughly Circular Economy would have been good …for example how this fits with ECONOMIC and WELL-BEING frameworks. There was no analysis of exactly what could be enablers and what are currently blockers from Westminster for example. Alliances with other areas such as Scotland could be developed on this basis.
5. There is a sense that the whole strategy based on voluntary change from producers needs to change gear and involve both ‘carrots and sticks’. The main criterion for this should be assessment of the PUBLIC VALUE to be promoted by any measure, including supporting and extending biodiversity as a key public good, culturally, psychologically and as a contributor to public physical health.
Making Consultation Processes and Public Money work for the Community: multi-purpose events
6. The Welsh Government has rightly used public money and resources for a widespread consultation with meetings held in different regional areas. Some of the spend could have been leveraged to develop local/regional networks to help empower the civil society groups that were there. There was no structured opportunity for networking amongst participants at the consultations other than the people on a particular table. This was a wasted opportunity particularly in the light of the recognition that civil society and community groups are very necessary and important partners in making these ideas happen. These consultations could be the basis for local and regional partnerships.
7. All the community groups, social and other businesses and local authority experts present and engaged in these consultations have knowledge, experience and insight to offer. Another outcome from the consultation to help leverage public money spent would be to work with researchers to help gather information and develop networks. The relevant research communities in Wales could have been involved to help make the links between expertise and practice that are needed to really get stuff done. This should be an action point for further events.
A big gap in the draft circular economy document is a failure to recognise the importance of planning in implementing a circular economy. At a very basic level, the proposed recycling hubs aren’t going to happen unless they get planning permission. The idea of zero carbon cities is being considered and even implemented in other countries and, is being supported by appropriate planning policies https://www.ellenmacarthurfoundation.org/assets/downloads/The-circular-economy-opportunity-for-urban-industrial-innovation-in-China_19-9-18_1.pdf In the light of this, we would have expected something in the final Circular Economy document to explain the relationship with land use planning
We also support CCE in recommending consideration of off-site construction as there is evidence that this can reduce waste and transport impacts.
Additions to Recycling
We support the points made by CCE about the inclusion of steel and UPV window frames and doors.
In addition we support the focus on looking at new materials likely to come into the picture of Reuse: electric vehicle batteries, photovoltaic panels, wind turbine blades.