Annex 3
ENVIRONMENT AGENCY PUBLIC INVOLVEMENT IN
INDUSTRIAL LICENCE APPLICATIONS
BLUE CIRCLE CEMENT WORKS, WESTBURY
BACKGROUND
Blue Circle operates a cement works in the Wiltshire
town of Westbury. Travellers on the London-Penzance railway line
pass the site. Traditionally coal has been used to fire the kilns,
but the company came forward with a proposal to use tyres as a
substitute fuel for coal. Immediately a series of potential pros
and cons came to the fore. On the one hand the potential for environmental
gain (ie tyres burnt rather than landfilled; better emission standards
than coal); while on the other hand there were community concerns
over a range of issues from health effects to black smoke.
Blue Circle had carried out two tyre burning
trials in 1996. These had been approved by the Agency with little
other than the legally required narrow formal consultation on
the company's applications. At this stage the Agency had a very
low profile. A local pressure group "The Air That We Breathe"
had been established and held a major public meeting at the end
of the second trial. Friends of the Earth were on the top table,
the Agency in the audience. The situation was made even more difficult
by the company, who had tried to "sit-on" some poor
emission figures in the second trial. As a result there was a
low level of public confidence in the process. It was not considered
transparent.
It was clear to everyone involved in the Agency
that it was time to get to grips with the issue. The first step
was to make it clear to the company and the public that the Agency
was not happy with the first two trials and that we would not,
at this stage, look favourably on an application for permission
to burn tyres on a permanent basis. As a result the company announced
its intention to apply for permission to hold a third trial. The
Agency immediately resolved that any such application would be
dealt with using enhanced communication and consultation techniques.
The objectives were: to clearly communicate
our regulatory action; to be open and transparent and to engage
and listen to the community.
The success criteria were: to build understanding
of the Agency and its role; to enhance our decision-making and
regulation and to win and build trust.
CONSULTATION PROCESS
The company applied to carry out a third trial
during 1997. The Agency responded with its new approach. As in
all situations the Agency needed to work on: Who are the audiences?
What are the messages? How to communicate? Above all the Agency
had to "know the community". It was soon recognised
that there was a good mix of audiences and messages and that a
good mix of communication tools would be needed and so a strategy
was developed that had three key strands: (a) Face-to-face meetings
with key stakeholder organisations; (b) Two public meetings (one
at start of process; one near end); (c) Active use of media. The
following concentrates on public meetings and the surgery.
THE PUBLIC
MEETINGS
The first meeting underlined the dangers if
you have not built up a good relationship with and understanding
of the community. The Agency was criticised for the date clashing
with another local event; the choice of venue; the start time;
and poor publicity.
Nevertheless there were many gains including
the fact we were holding a meeting at all. The meeting was well
managed and well chaired (good female chairs seem to be particularly
effective). Agency speakers were good—clear and non-technical.
The main gap between public expectation and Agency delivery was
on the issue of health. There was clear frustration from the audience
who wanted health answers. Unfortunately the various health bodies
were not in attendance. However the Agency got strong credit by
firmly promising to take up the issues with the health organisations
including the Department of Health. So overall a big step forward
but still lessons to learn.
For the second public meeting various organisational
shortcomings were discussed with local interests and addressed.
As a result it was ensured that the date didn't clash, a preferred
venue was booked, the meeting started at a later time and the
event was publicised via a door to door flyer.
The meeting was again well managed and another
building block in gaining confidence from the community. One initiative
did backfire. The meeting was to discuss our "minded to"
decision and it was felt that it would aid discussion on the night
if we publicised our views in advance. However, local perception
was that the Agency "had made up its mind" and deliberately
publicised our views in advance to put people off from coming
to the meeting. Nothing could have been further from the truth
but it taught that perception is reality.
THE SURGERY
The Agency did finally give the trial the go-ahead
with several stringent conditions reflecting issues of concern
raised during the consultation. The trial started but after a
short time the company broke the licence conditions. The Agency
immediately stopped the trial. This was a further vital step in
winning local confidence in our role as the "green police".
The key lesson here was that enhanced communications and consultation
have to be backed up by strong regulatory action.
After a lengthy time the Agency finally allowed
the trial to restart. A local authority committee asked for a
further public meeting and the Agency considered this request
carefully. In the end the Agency offered (and this was gratefully
accepted) to hold a public surgery where individual members of
the public (or groups) could book slots to raise issues with officers.
A surgery was decided on at this stage because it was felt to
be more appropriate. There had already been two public meetings
and there was a danger of meeting fatigue. The surgery offered
very individual concerns to be raised in a face-to-face personal
forum. It was well used and generally approved of.
CONCLUSIONS
In carrying out this process we have proactively
managed the process; raised the profile of the Agency; built better
relationships with the community and key stakeholders and lifted
internal morale. The key lessons learnt were the need to build
a long-term relationship with the community; it does take resources
(but better to proactively use these than be forced to do so anyway
but reactively); once the process has started you need to stay
involved and there are positive gains all round.
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