Select Committee on Environment, Food and Rural Affairs Minutes of Evidence

Correspondence from Biffa Waste Services in Response to notes by M B Recycling Ltd 27 September 2001

  As a follow up Michael Baker's informative note on the technical reprocessing aspects I write to affirm Biffa's full support that any new UK standard must be to the highest possible level available in the market place. It is our understanding that there is sufficient technological choice for total mass loss emissions of 3per cent or less to be achieved and we would certainly be very much against introducing standards which do not reflect these types of overall net losses.

  Technology specifics apart we would assume that any plants processing refrigerated equipment would be subject to total mass balance evaluation—with all processed units being subject to a rigorous audit procedure with inputs weighed on entry into the site and all net exports of processed materials also subject to mass balance reporting as part of an IPPC type framework. This may not be possible in 2002 but should form part of the objectives of any standards code being developed for operators.

  Clearly such systems can be bypassed but such risks are overcome on landfill sites by full video observation seven days a week, 24 hours a day of entry routes into sites. These video records can then be subject to random viewing the by the regulator during site audits—both inbound and outbound. Such levels of control would be necessary to satisfy any contractual arrangements whether the contracting party is the Treasury, local government, manufacturers or a shared responsibility type supply chain organisation.

  If technologies which do not satisfy the standards which Michael Baker sets out as contained within the E DIN framework then they should at least be subject to full mass balance assessment. In reality market distortions between this inferior type of equipment and those with lower CFC losses can be adjusted by introducing a CFC trading framework. This is outlined in the attachment which is my letter to Michael Meacher of 30 July. The effect of such measures is to level the economic playing field and make investment in sub standard equipment uneconomic because users would have to procure tradeable permits from the more efficient processors—in effect rebalancing the market place. This latter measure should not be necessary however—why don't we just go to the simplicity of adopting the Best Practicable Environmental Option (BPEO) when we have the opportunity? To do anything less would simply be a fudge and lay us open to accusations of ineptitude from the great British public.

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