APPENDIX 9
Memorandum from the Environmental Industries
Commission
Thank you for the opportunity to take part in
this inquiry.
INTRODUCTION
The Environmental Industries Commission (EIC)
was launched in 1995 to give the environmental technology and
services industry a strong and effective voice with Government.
With over 240 Member companies—over 100
of which are involved in sustainable waste management—EIC
has grown to be the largest trade association in Europe for the
environmental technology and services industry. It enjoys the
support of leading politicians from all three major parties, industrialists,
trade union leaders, environmentalists and academics.
Our Integrated Waste Management and Contaminated
Land Working Groups contain many Members supplying technologies
and processes that provide alternatives to landfill for hazardous
and non-hazardous wastes. Among the many barriers to the development
of these technologies is the fact that fly-tipping and other illegal
disposal methods are, in many areas, inexpensive and relatively
convenient. Our response, therefore, concentrates on this area.
FLY-TIPPING
There are a large number of important, and very
welcome, new pieces of legislation that will have the effect of
either banning, or raising the price of, disposal of waste in
landfill sites. These include:
The Landfill Directive: From July 2004 this
Directive will effectively reduce from about 200 to about 10 the
number of merchant landfills accepting hazardous waste, meaning
both the cost per tonne and the average distance to the nearest
disposal site will increase dramatically.
Waste Acceptance Criteria: The Landfill Directive
also introduces waste acceptance criteria in July 2005 which will
put further restrictions on the types of waste that can be stored
in non-hazardous landfills, and put an extra burden of testing
(with associated costs) on all waste.
ELV and WEEE Directives: This Directive will
make it more difficult and expensive for owners of end of life
vehicles and electrical and electronic equipment to dispose of
them.
The increase in the barriers and costs of disposal
provide an obvious incentive for an increase in fly-tipping of
waste on a commercial scale. For example the recent House of Commons
Environment, Food and Rural Affairs Committee on "End of
Life Vehicles Directive and Waste Electrical and Electronic Equipment
Directive" concludes that "it does seem likely that
there will be problems of abandoned waste as a result of the way
in which the ELV Directive is to be implemented. However the Government
does not appear to be planning any significant extra resources
for local authorities or the Environment Agency to control fly-tipping".
As well as the direct problem that fly-tipping
causes this lack of focus on enforcement undermines the willingness
of the environmental technology industry to invest in developing
new waste prevention and recycling solutions as they are concerned
the market for these solutions will be reduced by fly-tipping.
This is being reflected currently in the lack of development of
alternative treatment methods of hazardous waste in advance of
the drastic cut in landfill capacity for this waste in July of
this year.
EIC therefore recommends that the Government
fund the Environment Agency to co-ordinate a greatly increased
programme to combat fly-tipping. One potential source of funds
for this is to allow the Agency to keep fine income arising from
prosecutions of fly-tippers.
March 2004
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