Supplementary memorandum submitted by
the Quarry Products Association Northern Ireland
Thank you for your letter of 2 February seeking
the views of the Quarry Products Association NI (QPANI) on the
Code of Practice and Compliance Framework document produced by
the Department of Environment Northern Ireland (DOENI).
As you may be aware it was the QPANI who put
forward the idea and the first draft of an Environmental Code
and presented it to the Treasury in February 2003. This initiative
was industry driven and wherein, we believe, lies its strength.
On 26 January 2003 QPANI representatives met
with Customs and Excise, DOENI and the Department of Finance officials
to discuss progress on the application to the EU for state aid
approval for the further derogation on aggregates tax in Northern
Ireland. In what was as a workmanlike meeting Customs officials
informed the Association that the application to the EU had been
made immediately after the Christmas break. Everyone was now hopeful
that the approval will come in time for introduction on 1 April
2004.
QPANI informed the Government officials that
at present the Association was conducting a survey of members
on the possible impact of the Code of Good Environmental Practice
and Compliance Scheme. To date all responses have been positive
although there are a number of technical issues relating to blasting
and some clarification being sought as to timetables and auditing
procedures. These issues, and any other areas of concern, will
be raised by QPANI in what will be a very comprehensive response
to the current consultation paper. The consultation process closes
on 5 March 2004.
Our views to date are as follows:
1. CODE OF
GOOD ENVIRONMENTAL
PRACTICE
Aggregates are amongst the essentials of life,
as important to us in their own way as the food from our farms.
Aggregates can only be won where nature has placed them. Through
their products, quarries give us places to live, places
to work, places to play and much more. They literally underpin
our society. Quarrying does, however, have environmental implications.
Recognising this, the Northern Ireland industry aims to adopt
a responsible approach to its work and a considerate attitude
to its neighbours.
The Industry in Northern Ireland is an integral
part of the Community and with this in mind formulated this Code
of Good Environmental Practice that will be a guideline for companies
and a reassurance to the Community that quarrying can and will
be carried out in a environmentally responsible manner.
This Code of Good Environmental Practice deals
with the environmental effects of surface mineral working and
keeping emissions within acceptable limits without imposing unreasonable
burdens on the minerals operator. The Quarry Products Association
NI believe that the Code sets out procedures that all companies
involved in aggregate extraction should adhere to for the following
reasons:
1. Protect the Environment.
2. Improve Health and Safety
3. Good Environmental Practice makes good
commercial sense.
4. It will improve the perception that many
have of the industry.
5. Improved employee morale.
6. Reduced labour turnover.
7. It will improve the chances of success
in planning applications.
8. Operating Quarries can double up as highly
important environmental sites.
9. Quarres with good environmental practice
can encourage nature/wildlife.
2. THE COMPLIANCE
FRAMEWORK
The implementation of the scheme is based on
the conduct of compliance audits of all quarry and aggregates
operations within Northern Ireland which choose to join it. The
Association believe, and have made our views known to both Customs
and Excise and DOENI, that in many areas of the compliance scheme,
we do not need to redesign the wheel. There are a number of Government
agencies that regulate the quarry industry in Northern Ireland
— Planning Service—minerals unit.
— Industrial Pollution Inspectorate.
— Health and Safety Executive.
QPANI would suggest that all of these agencies
should communicate through some sort of database to facilitate
the collation of data relating to compliance on the relevant issues.
Planning Service would, we suggest, take the lead by the planning
conditions that they set on each operation and compliance to those
conditions can easily be assessed. The other agencies' compliance
figures can also be assessed annually and be collected together
to form the basis of an overall compliance figure for a company.
In the response to the DOENI Consultation Paper
on the Code and Compliance Scheme there are a number of technical
issues relating to blasting and some clarification being sought
as to timetables and auditing procedures. These issues, and any
other areas of concern, will be raised by the QPANI in what will
be a very comprehensive response to the current consultation paper.
The consultation process closes on 5 March 2004.
Overall the Quarry Products Association NI is
happy with the proposed compliance scheme and view it as fair,
rewards good practice and promotes continuous improvement. The
adoption of this scheme however must go hand in hand with beefed
up enforcement and increased penalties for illegal quarry operators
if people are to see the benefit of joining the scheme and adopting
the Code.
The QPANI will also be making a strong argument
to have compliance with the Code linked to the right to supply
Government Contracts with materials, Government Departments should
be ensuring that a products they procure come from legitimate
companies who carry out their operations in a safe and environmentally
responsible way.
Our Association believes that this incentive-based
system will work more effectively in the application of any laws
than the use of regulatory power.
3. PARTIAL REGULATORY
IMPACT ASSESSMENT
The impact of doing nothing (ie continued phasing
in of the aggregates tax) is in our view not an option. The reasons
for this have been highlighted in our two previous submissions
to the Committee.
The compliance scheme however aims to provide
a system for improvement in environmental performance across the
industry without significantly affecting the existing economics
of the industry. Without implementation of the Code environmental
performance is unlikely to improve significantly across the industry.
It could even lead to a reduction in environmental performance
in order to reduce costs to cope with the aggregate tax and more
importantly competition from illegal operators selling stone without
VAT and the aggregate tax. QPANI believe that impIementation of
the Code will provide direction to the industry and significantly
raise the awareness of environmental issues.
The implementation of the Code and Compliance
scheme is, at this stage, the best option. As we have stated above
it is fair, promotes best practice and encourages continuous improvement.
OPANI believe that in order to achieve as high a compliance rate
and adoption of the Code as possible Government need to assist
organisations such as QPANI in educating and informing the smaller
micro size companies on best practice and where to go in order
to receive support and grant aid.
There are a number of ways this support could
be delivered and there is existing grant aid and support programmes
such as that delivered by Invest NI.
Invest Northern Ireland delivers a range of
initiatives to help Northern Ireland companies improve environmental
and business performance. Support programmes offered include:
Environmental Audit Support Scheme (EASS)
All businesses can benefit from minimising their
environmental impacts in an integrated way. Many use formal Environmental
Management Systems (EMS) such as ISO 14001. The EASS, a financial
assistance scheme, can help businesses take the first step towards
developing an EMS by providing 66.66% grant, up to a maximum of
£5,000, towards the cost of carrying out an environmental
audit or baseline review of environmental performance.
Environmental Enquiry Point (EEP)
Invest Northern Ireland delivers a range of
initiatives to help Northern Ireland companies improve environmental
and business performance. Support programmes offered include:
Green Technology Initiative (GTI)
This scheme, which provides interest free loans
of up to £50,000, aims to help Northern Ireland businesses
implement environmental technologies and reduce operating costs.
The scheme supports projects requiring capital investment, thereby
helping to promote the local, environmental technology sector.
Water and Effluent Advice Centre
The centre offers impartial, authoritative
advice, information and consultancy services in the field of water
conservation and effluent treatment. Free services to Northern
Ireland companies include on-site assessments of water usage and
effluent disposal practices and advice on measures required to
reduce the cost of water and/or effluent treatment.
Analysis and testing of water and effluents
can also be undertaken on a fee-paying basis.
Envirowise
Invest NI is a contact point for Envirowise,
a Government-funded programme which helps companies to cut costs
by increasing efficiency and reducing waste at source. Envirowise
publishes guides and case studies of best practice in action.
Smaller companies can benefit from a one-day fast track waste
minimisation visit from an Envirowise advisor. www.envirowise.gov.uk
or Sam McCloskey 028 9070 6000.
Biowise
This national programme aims to help companies
reduce business costs, improve product quality and/or reduce environmental
impact through the use of Biotechnology. The programme offers
free, independent and practical advice in a range of formats including
publications and seminars. www.biowise.gov.uk or Diane
Moore 028 9070 6000.
Northern Ireland Waste Exchange Bureau (NIWEB)
NIWEB, supported by Invest NI, is an internet-based
trading site for the exchange of wastes. The service is free to
all Northern Ireland businesses and facilitates the cost-effective
sourcing and supply of waste and redundant material normally destined
for landfill. Visit www.niweb.net for more information.
The Quarry Products Association NI have also
produced a guidance document for our smaller companies on how
to take the first steps on setting up an Environmental Management
System, see attached.
It is essential that Government assist the industry
by helping raise the awareness of smaller companies about the
availability of these support programmes.
If this additional assistance is not offered
there is a serious risk that schemes will fail through lack of
proper information and preparation at the outset and of course
the actual cost of delivering the improvements will still be borne
by the operator concerned.
The requirement for all operators to achieve
certification to a recognised Environmental Management Standard
is we believe premature and too big a step for much of the industry
to take at present. However QPANI view the adoption of a third
party accredited environmental management scheme as a process
that will evolve and become part of Government procurement policy
as each Department moves towards accreditation to an EMS themselves.
For example Water Service in Northern Ireland have achieved accreditation
to 1SO 14001 and other Departments, we are informed, will follow
their example. As part of any Environmental Management System
your procurement and waste disposal policy are audited. It therefore
is the view that rather than Government Officials running around
acting as policemen to check where materials are coming from or
going to the Department should be buying materials and services
from third party accredited companies. That third party accreditation
is the guarantee to Government that products and services are
being procured from and disposed of to legal sources.
QUARRY PRODUCTS
ASSOCIATION NI PROPOSAL
ON THE
DEVELOPMENT OF
A RECYCLED
AGGREGATES INDUSTRY
IN NORTHERN
IRELAND
The issue of Recycled and Secondary aggregates
is not a straightforward one as unfortunately it is not within
the gift of the quarry industry alone to deliver a substantial
increase in the use of these materials. The general view within
the industry is that we stand ready and willing to embrace and
fully participate in the development of markets for recycled and
secondary aggregates in Northern Ireland. The industry realises
that the development of such markets will complement our core
products, not threaten them, and at the same time the quarry industry
will play their part in utilising a waste stream that presently
goes to landfill, of which we are running out rapidly in the Province.
The Symonds Report, recently commissioned by
Customs and Excise, estimates that at present the total production
of recycled aggregate in Northern Ireland to be no more than 280,000
tonnes, 1.2% of total aggregate production. They estimate, although
this is based on pro rata figures that the total in NI
could be in the region of 1.28 million tonnes, 5.5% of total aggregate
production.
The Symonds Report highlighted the lack of regulation
of the landfill sector in Northern Ireland. Observation in NI
shows that there are unlicensed and uncontrolled waste disposal
sites to which predominantly inert construction, demolition and
excavation waste is taken. In section 6.31 page 46 of the Symonds
Report they set out four tests of whether a country or region
has a prospect of developing an aggregate recycling industry.
Having studied these four tests QPANI are more than confident
that Northern Ireland potentially stands on the threshold of developing
an effective aggregates recycling industry.
The Second major barrier to recycling is Government
procurement. In Northern Ireland Government agencies and Departments
purchase approximately 50%-55% of all products produced by the
quarry products sector. QPANI are aware of, and have been involved
in, high level discussions on the role of procurement in developing
an aggregate recycling industry in Northern Ireland. The active
participation of organisations like WRAP (Waste Resource Action
Programme) will help facilitate and encourage this ongoing development.
At present QPANI have a number of members who
have taken the proactive step of putting in place recycling facilities
at their quarries. To date there has not been much payback for
them due to the problems and barriers I have mentioned above.
However I have no doubt as markets develop their investment will
be rewarded. Indeed QPANI are confident that many others will
follow their example and put in place facilities to handle C and
D waste from their local communities.
The Association's firm belief is that with proper
regulation and the new landfill directive construction companies
will, rather than pay £30-£40 landfill tax, approach
their local quarry which has the space and the equipment to process
C and D waste into a valuable recycled aggregate for a cost of
a fraction of landfill tax.
Combined Quarry and Recycling centres are, in
the QPANI view, the most cost effective and environmentally friendly
option. We see the options as follows:
Northern lreland Recycling, What can be done?
Work in partnership with client bodies to:
— Secure construction waste stream.
— Develop recycling centres.
— Develop genuine partnerships with
government bodies to take recycling to a higher level.
Recycling Alternatives—(Construction Waste):
— On site reprocessing and use.
— Stand alone recycling centres.
— Combined quarry and recycling centres.
Recycling Alternatives—(On site recycling):
— Most environmentally effective.
— No transport requirement.
— Successfully carried out in NI. Already.
HOWEVER,
— Does not recover added value raw
materials.
— Virtually no opportunities outside
Belfast and Londonderry.
Stand Alone Recycling Centres:
— Increases truck movements.
— Duplication of effort (processing/overheads).
— Increases CO2 emissions.
— Not cost effective (reflected in
high prices which does not attract potential clients.)
Combined Quarry/Recycling Centres:
— Minimises transport movements.
— Reduces CO2 emissions.
— No duplication of infrastructure/overheads.
— Compliance with stringent Environmental
legislation.
— Allows recovery/reuse of high value
materials such as macadams (bitumen).
— Attractive to end-users due to efficiency
of transport and labour management.
As you can see the Combined Quarry/Recycling
Centres along with on site recycling are the best environmental
options.
Following ongoing discussions in London between
the Highways Agency, WRAP, QPA and the Environment Agency there
are hopeful signs that one of the major barriers to developing
a viable recycled and secondary aggregates industry in Northern
Ireland will be removed. An announcement from the Environment
Agency is imminent to the effect that where clean C and D waste
is processed inline with the factory and production control as
set down in the new European Aggregates standard for recycled
aggregates and the operator provides related data that their enforcement
officials will view the material as "recovered". This
step will remove recovered material from duty of care and waste
licensing requirements. The Association welcomes this positive
move and have already had discussions with DOENI to ensure that
local waste licensing enforcement officials adopt a similar stance.
It is vitally important that HM Treasury and
the Northern Ireland Affairs Committee use their undoubted influence
with Environmental Policy Division within the DOENI to ensure
that a pragmatic view is taken as regards recycling of Construction
and Demolition Waste in order to remove barriers to the creation
of a viable recycled aggregate industry in Northern Ireland.
QPANI fully support the promotion and development
of a recycled aggregates industry that will complement the core
products of the sector. As the Code of Good Practice Compliance
scheme is developed we suggest that targets are put in place for
utilising C and D Waste. We believe that given the existing levels
of recycling estimated in the Symonds report and the potential
level that could be acheived we would propose that a target should
be set for individual quarries to have achieved a level of use
of C and D Waste of 5% of their annual extraction figures by the
end of the three-year derogation. This information for the use
of C and D Waste could be gathered in the annual minerals statement
currently collected by the Geological Survey for Northern Ireland
for DETINI.
In relation to the level of consultation with
the aggregates industry and its representative bodies the Quarry
Products Association NI are delighted with the openness and co-operation
the Economic Secretaries officials have shown. As Regional Manager
of QPANI I would like to mention in particular the work that Kris
Komanski, Andy Biscombe and Dave Fitzgerald have done in co-ordinating
the work between Customs, DOENI, DFPNI and the industry representatives
in Northern Ireland. This level of partnership between industry
and Government to solve an evident problem can we hope be a template
for the future.
8 February 2004
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