Select Committee on Northern Ireland Affairs Minutes of Evidence


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.

    —  Water Management Unit.

    —  Industrial Pollution Inspectorate.

    —  Customs and Excise.

    —  Health and Safety Executive.

    —  Waste Management Unit

  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:

    —  Change specifications.

    —  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,

    —  Very limited scope.

    —  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.

    —  Cost effective.

    —  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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