Letter from Biffa Waste Services Ltd to
the Department of Trade & Industry 23 August 2001
RE: EC
REGULATION 2037/2000—DOMESTIC
INDUSTRIAL AND
COMMERCIAL REFRIGERATION
EQUIPMENT
Thanks for the opportunity to support the round-table
session on 21 August. Whilst the issues are fresh in my mind I
thought you might find the following key points from a Biffa perspective
of use. I will circulate this electronically to all other attendees
and interested parties once you confirm a complete listing.
— There is no shortage of interest
in the market place in terms of preparedness to invest in the
necessary collection and reprocessing infrastructure. Biffa is
keen to undertake such investment as part of a far wider forward
strategy to develop strategically located warehouses and reprocessing
centres for a wide range of materials in the waste stream which
will require more specialist approaches in coming years and decades.
These include electrical and electronic equipment as well as fluorescent
lamps, hazardous waste streams, insecticides, pesticides and automotive
equipment alongside the more mundane non hazardous materials such
as packaging and aggregates.
— Pre-requisites for such investment
are:
(a) Clear undertakings from the Environment
Agency, DEFRA and other relevant parties with regard to the specification
of reprocessing equipment. In the absence of such assurances,
companies like us are not in a position to tender and install
equipment which may subsequently be confirmed as non compliant.
Even when plant specifications are agreed by Government it is
important that tolerance standards are not too wide—otherwise
operators of less efficient plants can generally operate to a
lower cost base which will then prejudice operators of state of
the art equipment.
(b) There must be a clear definition
of who pays and where the market is located. Given the tight time
constraints I have already written to a range of potential customers
in the public and private sector but they are unlikely to come
to a decision until central government makes its mind up with
regard to funding methodology. The Annex outlines some of the
current possibilities which might operate in isolation or combination.
(c) There need to be clear assurances
from DEFRA, Environment Agency and others with regard to a consistent
regulatory regime—particularly in respect of accelerated
planning and licensing conditions coupled to absolute guarantees
on enforcement against those continuing to handle fridges via
non compliant routes (ie those operating today).
Those with an interest in this area seek assurances
on some or all of the above three aspects. Given the time constraints
I suggest that the German specification for plant operation be
adopted without question—they have much greater experience
and there is no opportunity for a cumbersome British reinvention
of the wheel.
The next priority is to decide on the appropriate
funding mechanism and establish a process were pricing transparency
is achieved—particularly in relation to operational differences
in efficiency between the different branded technologies. In the
short term it is likely that these costs will land on the public
purse but I for one would be more than happy to support DEFRA/DTI
discussions with the Treasury and/or Office of Fair Trading.
Some months ago we have already submitted operating
standards to the Agency for type approval but, thus far, I have
yet to receive a response.
I trust this clarifies matters from our perspective—please
let me know if I can be of further assistance. Needless to say
I look forward to confirmation of the next stages.
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