Consultation outcome

Annex 1: Detailed summary of consultation responses

Updated 1 October 2024

This annex sets out the responses we received to our consultation on charge proposal for materials facilities.

Questions are set out in the same format as they were presented on the consultation website and response form.

Within the consultation, each question asked for a specific choice as well as providing a free text box for comments. The consultation questions for material facilities operations were divided into several topics: 

• about you and consultation feedback
• proposal to increase the annual additional subsistence charge
• proposal to change the billing approach
• economic context 
• additional comments about the charging proposals

We received 14 responses through the consultations website and response form. We did not receive any emails or letters with comments relating to the consultation. 

About you

Within the consultations website and response form, we included an ‘about you’ section to provide us with an understanding of who responded and to help us better analyse the consultation feedback.

For the 14 responses (11 online and 3 using our response form), we asked if you were giving a personal response as an individual or providing a response on behalf of an organisation. You said: 

• responding as an individual – 3 
• responding on behalf of an organisation or group – 11
• other – 0
• no answer given – 0

If you responded on behalf of an organisation, we asked you to give us the name of the organisation. These responses are reported in Annex 2.

For those responding as organisations, we also asked you to specify which of the following options was applicable. You said: 

• you are responding as an existing material facility – 7
• you believe your organisation will be a materials facility under the new regulations for materials facilities which are due to come into force on 1 October 2024 – 2 (these 2 responses were both noted on the response form and in each case the option ‘responding as an existing material facility’ had also been selected) 
• not applicable – 1
• other – 5
• no answer given – 1

If you selected ‘other’ we asked you to explain your area of interest, you said:

• owner of a joint venture whom operates a materials recycling facility.
• responding as an existing materials facility and also as a business that has sites that will newly be materials facilities under the new regulations
• the Environmental Services Association is the trade association which represents the resources and waste sector.
• we have existing facilities as well as newly in scope Materials Facilities.
• we partner with our district councils who collect recycling and are interested in the changes

We asked how you found out about this consultation, you said:

• from us – 10
• from another organisation, group or trade association you are a member of – 3
• press article – 0
• social media, for example Facebook – 0
• through a meeting you attended – 1
• other – 0

Consultation questions

Proposal to increase the annual additional subsistence charge for a materials facility operation

Question 1: To what extent do you agree or disagree with the proposed change to the additional annual subsistence charge for a materials facility operation?

You said:

• strongly agree – 0
• agree – 3
• neither agree nor disagree – 1
• disagree – 6
• strongly disagree – 4
• do not know – 0
• not applicable – 0
• did not answer – 0

Of the 14 responses we received to this question, all respondees included additional comments. We have analysed these comments to identify the main themes raised in response to this question and the number of times each was mentioned.

Customer impact (10):

• wider economic issues – 3
• all or some charges too high – 2
• impact on customers (economic) – 2
• timing or phase the introduction of charges – 2
• increased regulatory burden (red tape) – 1

Business approach (5):

• charge management – 3
• likelihood of more unregulated activity – 2

Service provided by us (4):

• be more transparent – 3
• poor (or declining) service – 1

Agree proposals (3):

• qualified support for proposal – 1
• supports proposals (no objections) – 2

Other (3):

• customer challenging information – 2
• other issue – 1

Charge scheme design (2):

• other suggestion for proposal – 2

Protect environment (2):

• better or effective regulation – 2

Consultation design (1):

• misinterpretation from lack of clarity – 1

Proposal to change the billing approach for the additional subsistence charge for a materials facilities operation

Question 2: To what extent do you agree or disagree with the proposed change to our approach to billing for the additional subsistence charge for operators of materials facilities?

You said:

• strongly agree – 0
• agree – 8
• neither agree nor disagree – 3
• disagree – 2
• strongly disagree – 0
• do not know – 0
• not applicable – 1
• did not answer – 0

Of the 14 responses we received to this question, 10 included additional comments. We have analysed these comments to identify the main themes raised in response to this question and the number of times each was mentioned:

Agree proposals (8):

• qualified support for proposal – 5
• supports proposals (no objections) – 3

Business approach (3):

• competent or efficient management – 3

Customer impact (1):

• impact on customers (economic) – 1

Economic impact

Question 3: To what extent do you agree or disagree with our view of the economic impact? 

You said:

• strongly agree – 0
• agree – 4
• neither agree nor disagree – 2
• disagree – 4
• strongly disagree – 3
• do not know – 0
• not applicable – 1
• did not answer – 0

Of the 14 responses we received to this question, 9 included additional comments. We have analysed these comments to identify the main themes raised in response to this question and the number of times each was mentioned.

Customer impact (8):

• impact on customers (economic) – 4
• underestimated economic impact – 3
• increased regulatory burden (red tape) – 1

Charge scheme design (5):

• charging and permitting policy – 5

Agree proposals (1):

• supports proposal (no objections noted) – 1

Consultation design (1):

• insufficient information – 1

Other (1):

• customer challenging information – 1

We were particularly interested to know if you thought our proposed charges adversely impacted small and medium sized enterprise (SME) operators in any way. If as an SME operator, you have any evidence of likely adverse impacts, please share these with us. 

Of the 14 responses we received to this question, 9 included additional comments. We have analysed these comments to identify the main themes raised in response to this question and the number of times each was mentioned.

Customer impact (4):

• impact on customers (economic) – 4

Agree proposals (1):

• supports proposal (no objections noted) – 1

Business approach (1):

• likelihood of more unregulated activity – 1

Consultation design (1):

• insufficient information – 1

Protect environment (1):

• better or effective regulation – 1

Question 4: Do you have any comments about our proposals for additional subsistence charges for materials facility operations?

Of the 14 responses we received to this question, 7 included additional comments. We have analysed these comments to identify the main themes raised in response to this question and the number of times each was mentioned.

Consultation design (2):

• presentation or information too confusing – 2

Customer impact (2):

• increased regulatory burden (red tape) – 1
• timing or phase the introduction of charges – 1

Agree proposals (1):

• supports proposal (no objections noted) – 1

Charge scheme design (1):

• charging and permitting policy – 1

Protect environment (1):

• better or effective regulation – 1