Conclusions and recommendations
1. We
strongly recommend that the Government ensure that, as soon as
possible, it issues clear guidance to the recycling industry about
exactly what is expected of it, in order that it can make decisions
to investment in new facilities. If it fails to do so it will
exacerbate the potential problems associated with these Directives
- such as, in the case of the ELV Directive, an increase in the
number of abandoned cars. We further recommend that over time
the Government continue to update its guidance, and take steps
to communicate its wishes clearly to stakeholders. (Paragraph
14)
2. The evidence we
have received makes us seriously question the 'own marque' approach
to funding the disposal of end of life vehicles after 2007. The
objective should be to ensure that complying with the ELV Directive
is as straightforward as possible. We urge the Government urgently
to re-examine whether that objective will best be achieved by
encouraging consolidation and concentration in the dismantling
sector, as the 'own marque' approach seems likely to do. (Paragraph
17)
3. Therefore, we recommend
that the Government look again at the funds it has made available
to local authorities for dealing with abandoned vehicles, specify
in response to this report exactly what these sums are and how
they have been allocated and distributed, and ensure that they
are adequate to deal with increased abandonment up to 2007. (Paragraph
21)
4. We are concerned
that an 'own marque' approach will mean that it is more difficult
for local authorities to deal with the problems of abandonment,
since they will not simply be able to use a single contractor
to deal with any and all abandoned vehicles. We invite the Government
to reflect on the issue, and to explain exactly how in practice
local authorities will deal with abandoned vehicles after 2007.
(Paragraph 22)
5. We believe that
civic amenity sites have a crucial role to play in ensuring that
waste electrical and electronic equipment can be collected separately
from the rest of the municipal waste stream. We recommend that
the current network of civic amenity sites be expanded, so that
such sites are easily accessible to all. We recommend further
development of those sites which already exist. In order to facilitate
these recommendations we also recommend that the Government find
ways to streamline the process of gaining and amending waste management
licences for civic amenity sites, and of gaining and amending
planning permission. (Paragraph 24)
6. We urge the Government
to ensure that the Environment Agency is adequately resourced
to deal both with the requirements of implementation of the Directives
and with their consequences, and to identify in its response to
this report exactly how much additional resource has been or will
be allocated to the Agency for this purpose. (Paragraph 26)
7. Although we understand
the argument made by the Government, we are concerned that excluding
printer cartridges from the WEEE Directive will not encourage
their sustainable re-use. We invite the Government to think again
about the matter. (Paragraph 27)
8. Nevertheless, we
recommend that Defra re-examine the workload placed on its specialist
staff, including its lawyers, to ensure that they are not being
asked to do too much, and that they are thus able to act efficiently
and effectively. (Paragraph 29)
9. Before embarking
on the negotiation of Directives such as the ELV and WEEE Directives
the Departments involved should review whether they have available
the specialist skills and other resources needed to do so effectively.
The Government should not agree to this sort of European legislation
without a clear understanding of all of its ramifications. (Paragraph
30)
10. We strongly recommend
that Defra (and other Government Departments such as the Department
of Trade and Industry) take steps to develop its understanding
of the waste and recycling sector. We urge it to institute a programme
of seconding outside experts into the Department to help with
the negotiation and implementation of European legislation, and
a programme of seconding officials out to work for short periods
in the waste and recycling industry. (Paragraph 31)
11. We reiterate the
recommendation made by the Better Regulation Taskforce that the
Environment Agency should be directly involved at an early stage
in the negotiation of European environmental legislation. We further
recommend that the Government consider involving others, such
as representatives of the waste and recycling industry, also at
an early stage in the process. (Paragraph 32)
12. We support the
recommendations of the Better Regulation Taskforce, and urge the
Government to ensure (a) that a clear 'lead' Department is designated
for each piece of environmental legislation, and (b) that a project
management approach to the implementation of legislation is adopted.
Doing so would go some way to avoiding a repeat of the confusion
and lack of clarity which has afflicted the stakeholders of these
two Directives. (Paragraph 34)
13. But 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. That
said, for the moment the prospects for a 'smooth' transposition
of the WEEE Directive do seem brighter. We nevertheless urge the
Government to take steps, beginning with the recommendations of
this report, to ensure that it remains in control of the process
of implementing these Directives. (Paragraph 35)
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