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| Proposal | Pros | Cons
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1. Sustainability
Foundation | - this is a new source of funding for sustainability of at least"
20 million per annum, but not in the first few years of operation (three years?)
- it is an annual fund secured by a levy on the industry
- the proposed Board of Trustees to manage the Foundation includes non-governmental representatives and is not QPA controlled.
| - it is still comparatively a small fund
- a large number of positive commitments" are included_too many commitments risk funds being insufficiently targeted. Key objects" will get at least 10 per cent of the Foundation money, but that is only 2m for biodiversity and education, for example
- recycled and secondary aggregates are just one of many competing objects" and should receive more attention than this
- rehabilitation of orphan quarries may not be cheap, and it may be beyond the Foundation to address these meaningfully, depending on cost
- the Foundation does not provide a means of reducing demandper se
- it is not clear whether the Foundation will be voluntary, contractural or statutory. There could be difficulties in ensuring compliance and the potential sanctions are minimal
- there is a risk of free rider behaviour, both in the QPA itself and companies outside the QPA
- the industry itself identifies potential conflict between its desire for local" projects and the Government's desire for long-term solutions to the problems of the industry
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2. Sustainability
indicators | - these will be useful for environmental monitoring of QPA members activities and the effectiveness of the measures proposed
| - indicators do not, in themselves, deliver environmental benefits and improvements
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3. Environmental
Impact
Assessment
| - commitment to go beyond the requirements of the new EIA Regulations is welcome
- commitment to apply this to old minerals permissions is also welcome
| - it is only just voluntary as 1999 EIA Regulations require EA for all quarries bar those under 25 hectares. This means that many quarries require EIA anyway
- the QPA are only going to undertake EIAs where requested by MPAs" to do so. The commitment should be an unambiguous one of EIA for all mineral applications
- the Wensley Quarry case means EIA is most likely going to apply to old permissions
- the proposed best practice guide for members may be unnecessary as best practice guides on EIA already exist_its usefulness depends on its proposed content. Generally quality of EIA depends on the adequacy of scoping and skills and expertise of the consultants used.
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| 4. Recycling | - a major weakness of New Deal was the lack of commitment to increase the supply of recycled aggregates. Recognition of need to optimise use of recycled and secondary materials and to use aggregate resources efficiently is welcome
- commitment to invest at least"
20 million per annum for the next five years in new and improved aggregate recycling capacity
- joint BRE/QPA bid to operate Aggregates Advisory Service
- work to produce more efficient demolition materials database
- discussions with Highways Agency regarding specifications
- recycled aggregates excluded from sustainability fund levy
| - existing trend is a gradually increasing investment in recycled aggregates. A dynamic incentive is needed to increase the rate of investment, rather than a fixed annual target, and it is needed beyond the five year period
- can the 20 million pa achieve the same impact as the market signal sent by an aggregate tax?
- progressive firms in the industry are already committed to investment in recycling. For instance Tarmac since 1997 have established 10 recycled aggregate facilities and they intend to establish a wide network" of such facilities
- costings for establishing such operations are not available, due to commercial confidentiality, but are not cheap. The
20 million may include already planned expansion
- there is no guarantee that the BRE/QPA bid will be successful
- assessment of the cost doesn't include financial benefits of recycling, in terms of reduced primary material use and a reduction in landfill
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5. Environmental
management
systems
| - commitment to ISO 14001 accreditation in all QPA companies by end of 2002 (c 900 sites)
- only 947 certificates have been granted in UK to date so this is a significant commitment
- guidance commissioned on Environmental Management Systems for SMEs
- QPA training programme
| - as an environmentally responsible industry they should be moving towards this anyway
- seven of top eight QPA companies have already started ISO 14001
- EMAS is a better system to adopt
- QPA costing disregards efficiency savings
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| 6. National Parks | - new 5th commitment_not to enter into new agreements to operate third parties' dormant sites_added to previous four-point commitment towards National Parks
| - the commitment to National Parks has loopholes and is less demanding than advice in MPG6
- to date implementation has been slow with only one permission surrendered in 12 months
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| 7. SSSIs and wider landscape | - finance fundamental research into the relationship between quarrying activities past and present and SSSIs"_an SSSI database
| - they should have had such a database before now
- new permissions, and old mineral permission in particular, continue to damage and threaten SSSIs
- should make a commitment to SSSIs similar, but stronger, to the one they have made on National Parks
- this proposal does not include the wider landscape
- the section on SSSIs shows lack of real understanding of the issues
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| 8. Transport | - drawn up haulage code of practice
- registration with the FTA well driven" scheme
- each QPA member will have a transport plan_eg. routing and access
- contracts of hauliers will carry mandatory use of low sulphur fuels clause within three years
| - welcome, but this is part of good quarry management and should be in place already
- the haulage COP has already been drawn up
- transport plans should address mode of transport, as well as more local issues of routing
- Government introduced a preferential duty rate for Ultra Low Sulphur Diesel in August 1997, which means ULSD is now 3p per litre cheaper than ordinary diesel. This has resulted in rapidly increasing ULSD consumption. Given this and the uptake of ISO 14001 this commitment reflects business as usual"
- the QPA cannot enforce a mandatory scheme on its members as a representative trade association
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| 9. Training | - commitment to 50 per cent of workforce having health, safety and environmental competence training to NVQ 2-4 standard by 2004, plus other environmental training (EPIC) by 2001/2
| - the industry should aspire to this already as part of effective quarry management and arguably a higher target by 2004
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| 10. Enforcement fees | - significant increase in planning fee to aid monitoring and enforcement (c.10p per tonne)-
| - welcome commitment, but accepts, by implication, that some of their operators are not complying with extant planning conditions
- estimated contribution of
22m pa would reduce when firms achieve ISO 14001
- proposed linked discount for firms with ISO 14001 is not acceptable, as ISO 14001 accreditation is not a guarantee of good planning performance, for example
- proposal relies on Government regulation, albeit with active support from QPA
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11. Air pollution
control | - propose that air pollution controls are extended to sand and gravel production and processing
- propose to discuss and agree with Government a sectoral commitment to meeting Kyoto climate change targets
| - both require Government action, albeit supported by a QPA commitment
- energy reduction targets have been adopted by many firms across many sectors. Achieving these targets brings financial rewards through energy efficiency gains. Several QPA members already have energy reduction targets. The climate change levy will see even greater use of, and more challenging, targets. Firms adopting ISO 14001 are very likely to introduce such targets. Therefore, the broad commitment to energy reduction targets does not represent a significant improvement.
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