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Arc21 Response

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Arc21 Response Appendix 1 ITEM 9 - APPENDIX B Consultation on Proposals for a Charge on Single Use Carrier Bags Introduction arc21 is a collaborative legal public sector entity embracing eleven Councils located along the Eastern Region of Northern Ireland which covers 25% of the land base, populated by approximately 57% of the national population and accounts for approximately 54% of the national municipal waste ( as currently defined) arisings. The establishment of arc21 together with its functionality is enshrined in legislation with the original provision being The Local Government (Constituting a Joint Committee a Body Corporate) Order (NI) 2004. In essence, it is primarily responsible for activities associated with the production, ongoing development and implementation of a Waste Management Plan within the Eastern Region Area. The eleven constituent Councils of arc21 are Antrim Borough Council, Ards Borough Council, Ballymena Borough Council, Belfast City Council, Castlereagh Borough Council, Carrickfergus Borough Council, Down District Council, Larne Borough Council, Lisburn City Council, Newtownabbey Borough Council and North Down Borough Council. Report arc21 welcomes the opportunity to respond to this consultation. Prior to addressing the specific questions posed in the consultation, arc21 would make the following comments. This response is submitted in the context of the commitment made by the Assembly Executive Committee in March 2011 that the following provisos will apply: a charge on single use carrier bags will be introduced no later than 1 April 2013; sellers will be obliged to pass on the charge to customers; and sellers will be obliged to forward the revenue generated by the minimum charge to the Department. The consultation paper makes reference to the fact that work is underway to complete an economic appraisal which will identify costs and benefits of the proposed arrangements. It is unfortunate that this has not been completed with the results forming part of the consultation process as the information contained therein could influence the response of stakeholders. This is particularly pertinent given that the consultation paper does state that “the proposed charge will need to raise at least £4million to restore the deficit in the Department’s annual budget. arc21 recognises that although single use bags make up a very small proportion of the municipal waste stream i.e. less than 1%, the introduction of such a charge represents a symbolic measure designed to have a wider impact. 1. What are your views on the Department’s proposals in relation to which sellers should be subject to the charge? It is proposed to introduce similar provisions to that applicable in Wales i.e. all sellers of goods including companies, individual retailers and the not for profit sector. This will affect a wide range of businesses e.g. retails outlets, charity shops mobile traders and service providers. It would also cover circumstances where carrier bags are needed to enable the goods to be delivered e.g. supermarket deliveries ordered over the internet. arc21 is content with these proposals. 2. What do you think is an appropriate minimum charge for single use carrier bags – and why? This is an issue more appropriately addressed by individual Councils in their submission. 3. Are there any types of carrier bags which should be exempt from the charge? If so, on what grounds? arc21 supports the view that the provision should cover a wide range of types of single carrier bags including those made from paper, plastic, part plastic and degradable plastic. The consultation paper suggests that the exemptions in Wales e.g. hygiene (bags which act as primary packaging for goods intended for human or animal consumption) and patient safety and confidentiality (bags which are used solely for NHS prescriptions) would not be replicated in the Northern Ireland provisions. The reasons outlined in the consultation relate to simplicity and consistency of approach which has obvious attractions and as such appears to be reasonable. In Wales the charge does not apply to single use carrier bags used for promotional items and free items such as catalogues, samples and leaflets where no sale of goods take place. Applying the same reasoning as above, no exemption should apply in these circumstances for Northern Ireland. However, in the interests of clarity, arc21 wishes to ensure that biodegradable compostable liners which are specifically designed for use with kitchen caddies in Council Organic Waste collection schemes are not captured by the proposals. These schemes help to divert organic material from landfill to more sustainable treatment facilities. The use of these liners is seen as an important component of the scheme to encourage householders to fully participate in the service provided by Councils. This comment is submitted as these liners are sometimes referred to as bags, clearly have a single use and arc21 wishes to ensure the provisions do not apply in this case. 4. Do you think that multiple use carrier bags should be included in any levy? At this stage, arc21 is not persuaded that extending the scope of the levy to multiple use bags is appropriate. 5. What information should sellers have to keep in relation to the carrier bag charge? arc21 would advocate that the principle of keeping the regulatory burden on businesses as light as possible should be applied. Accordingly the information should be limited to that necessary to clearly establish the quantity of single bag usage. This would consist of basic stock control records. 6. Should sellers have to publish their records? At this stage, arc21 is not persuaded that it is necessary to require sellers to publish their records. 7. Have you any views on which organisation should administer the carrier bag charging scheme in Northern Ireland? The consultation paper advises that it is likely to take some time to complete an assessment of the available options. It would have been helpful if this work had been completed and the information incorporated into the consultation. arc21 would suggest that any agent(s) appointed to administer the charging scheme should have an existing regional operational remit. 8. Have you any views on the required arrangements to enforce the carrier bag charging scheme in Northern Ireland? The consultation paper proposes that the appointed administrator will be given the power to enforce all aspects of the new arrangements with civil sanctions in the form of a fixed monetary penalty (up to £5,000) or a discretionary requirement. arc21 is content with the proposed arrangements. 9. Have you any comments on the Department’s preliminary conclusions in relation to equality screening, human rights or rural proofing? arc21 has no comments. ___________ arc21 August 2011.
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