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UNCORRECTED TRANSCRIPT OF ORAL EVIDENCE To be published as HC 637-vi House of COMMONS MINUTES OF EVIDENCE TAKEN BEFORE NORTHERN IRELAND AFFAIRS (NORTHERN IRELAND AFFAIRS SUB-COMMITTEE) The Senate Chamber, Parliament Buildings, Stormont, Belfast
WASTE MANAGEMENT STRATEGY IN NORTHERN IRELAND
Tuesday 26 October 2004 MR STEVE ASTON, MS PAT CORKER, MR NOEL SCOTT and MR BRENDAN O'NEILL MR PAUL WALSH, MR GORDON BEST and MR BILL WEIR Evidence heard in Public Questions 273 - 316
USE OF THE TRANSCRIPT
Oral Evidence Taken before the Northern Ireland Affairs Sub-Committee on Tuesday 26 October 2004 Members present Mr Tony Clarke, in the Chair Mr Stephen Hepburn Mr Iain Luke Mr Eddie McGrady ________________ Memoranda submitted by Department of the Environment
Examination of Witnesses
Witnesses: Mr Steve Aston, Grade 6, Environment and Heritage Service (EHS), Ms Pat Corker, Principal Scientific Officer, EHS, Mr Noel Scott, Grade 7, DoE Planning Service, and Mr Brendan O'Neill, Grade 6 Director of Policy, Procurement Service, DFP, Department of the Environment, examined. Q273 Chairman: Ms Corker, gentlemen, you are very welcome. Thank you for taking the time to give evidence. The committee is about halfway through its inquiry into waste management and we are already discovering lots of interesting facts. There one or two debates ensuing as to whether or not Northern Ireland will or will not meet its obligations. I wonder if I could start the questioning this morning by asking you to what extent you think that Northern Ireland has a strategy for waste which is independent of that which would be required to deliver compliance with EU directives. We all know that we have those EU directives to meet but how much would you say you have a strategy which is independent of what is required? Mr Aston: Good morning. My name is Steven Aston. I am the Head of Waste Management and Contaminated Land for the Department of Environment placed within the Environment and Heritage Service. The question asks to what extent we are independent of a strategy for European compliance. I think there are elements of the strategy which develop issues in waste management which will assist Northern Ireland plc in having a better economy, a better environment and better participation in the delivery of that. Having said that, if we were to become too independent of the central targets for compliance we would possibly add too much burden to the industries which seek to comply. If we look at the things with which we have to comply, beginning with the Landfill Directive, there are pretty tough targets already in place. When we add to that directive limits on WEEE, ELV, batteries to come and also packaging waste, having a strategy which is aligned with compliance as a first step is highly appropriate. Where I think we have gone that little bit further is in looking to a longer term picture, not only to make people and businesses aware of what needs to be done and can be done and how they might do it, but also in particular to look at education and behavioural change (these are very long term issues), which are beginning to show real promise in terms of resource efficiency rather than waste management. Q274 Chairman: It is now four years on from publication of the strategy. In terms of progress are you ahead of where you thought you would be, behind where you thought you would be or on target? Mr Aston: We gave in our written evidence a long list of achievements. I would like to draw from that what I call successes and failures which seem to predominate. Both are qualified, so the short answer to your question is that in some areas we are ahead of where we thought we would be and in other areas we are certainly not. That is a gentle way of expressing failure but I want to remind everyone that we are in the first phase and the review we are undertaking is very much part of ensuring (in pilots' terms) that when we look out of the window we are on the track that we set ourselves towards compliance and that centre of excellence. On the success side I think that the building of the strategy was tremendously successful. We started off with a steering group comprising SOLACE (the Society of Local Authority Chief Executives), the CBI and Friends of the Earth. They said what the scope should be. We had the review by the Advisory Group, an independent group, again comprising NGOs, businesses and professionals, and they gave us 104 recommendations for change. We took on board 98 and then we went on to the Waste Management Advisory Board. The consensus was marvellous and I think that was important. We had people signed up to the promise of policy. With regard to progress on delivery, I am not sure that all those - and I am very careful in my use of the word "all" - who signed, and that includes government, delivered what they promised, so that was a qualified success. I also think the partnerships were tremendous. We had gone through a period where from 1978 we had all 26 local authorities under a statutory obligation to deliver waste disposal plans and only 14 managed it in 20 years to a situation where not only did all of the district councils work together in forming partnerships but they also delivered very useful plans, the key instrument of implementation of the strategy, in very strong partnerships. That was a great foundation. It is still qualified because I think they would like us to develop that more. I also think the Wake Up to Waste campaign was remarkably successful. Its difficulty was that it built expectation that people's behaviour would change as much as their awareness did. It is much longer term; think most people would recognise that. Failures? Greening government was right up there. We were going to green government because it was a good leadership step. I do not think we have done but later on I think we will discover that the latent action is very strong and very positive. In terms of other areas, data has always been a real problem for us. That is another area which has not worked. We are behind on some areas but that is the purpose of the review: to make sure we recognise and react to that. Q275 Chairman: I have a couple of questions in respect of the review and just to clear up some issues surrounding targets. The strategy declared at the first strategy review point in 2003, once further analysis of waste arisings and consultation had established that they were achievable, the targets would become mandatory. Has that happened? Mr Aston: The review is incomplete but de facto some have become mandatory because the directives have come into play. When we began with our targets, and they began with a whole range of primary and secondary targets, some of them were aspirational, they were marked very clearly as provisional, but they were building towards compliance, primarily with the Landfill Directive but also cognisant of the future change for the directives I have already mentioned, so we now have ELV and WEEE framing targets, we have packaging targets and they are specific and mandatory. The deeper question here is, does setting mandatory targets work as drivers? The answer is yes. You have to qualify that and that refers to your original question: do you want industry to go further? We then pose the question: what is the benefit? When we talk with our colleagues in Invest Northern Ireland they want businesses to come to Northern Ireland and make it a successful place to work. If we set too high a standard which is beyond what they would find elsewhere they may not come unless there is a specific advantage. That is a qualifying issue. In other areas where we have failed - and I have talked about green government - one of the targets was ten per cent paper reduction by the year 2002. That introduced two things. The first was, what was our benchmark against which we could measure this? We did not have one. That is across all targets on the issue of data. Secondly, what was the response of government? What we currently have is an adopted action plan which talks not just about ten per cent in 2002 but 50 per cent over the next five years and reduction, reuse and recycling. Without the mandatory framework it has been reframed or reset. We have reacted very strongly. Q276 Chairman: You have set targets for 2005 and 2010. The targets for 2010 I assume you would meet during the year 2009-2010, so the targets for 2005 you will be looking to meet in the year 2004-2005? Mr Aston: Yes, I think that is what they are set for. On household recycling, the 25 per cent target, I said to someone the other day that Northern Ireland's performance is a little bit like the horse Sea Biscuit in the recent American film. We start off as rather small with a big challenge but at the moment (and I think I am allowed to say this) we are just passing Scotland on the household side and we are drawing alongside Wales. By the end of 2005 our indicators and data sets coming back from local authorities on quarterly returns suggest that we will achieve the 25 per cent by the end of 2005. Q277 Chairman: We have received some criticism that a lot of the targets within the strategy are not supported by touchable, concrete measures. They seem very aspirational but some people have given us evidence to suggest that their fear is that we have targets but there are no concrete measures or policies in place that will assist us to achieve them. Can you point in the direction of anything concrete in terms of policy that we can present to those critics to say, "Yes, it is not just an aspiration. There are concrete measures in place that we are taking which will enable us to achieve those targets"? Mr Aston: Yes. Much of the action that has taken place gets lost in observation. May I deal with the criticism in broad terms first of all? What is missing from the original strategy (and is one of the purposes behind the review) is concrete action plans. Everyone would like government to have an action plan. We will see that action plan in the revised strategy where we set timetables, specific measures and observable movement in recycling and reclamation - the things that we do. But government cannot do it all despite its massive budget. It can show leadership; it must do that, but it is getting an equivalent action plan from the key stakeholder groups that is important. The same groups that signed up to the strategy and helped build it with the recommendations need to take steps. We have got a recent example of that with the Construction Federation industry where we are dealing with construction, demolition and excavation waste where, using the BPEO technique; they are looking at targets of approaching 40 per cent by 2010 for on-site recovery, again bringing it back to the point of production, following another principle. We are looking at specific education, awareness and behavioural targets in our new plans and programmes. We have taken tremendous steps forward in linking up north and south of the island with those campaigns but it is specific things that we have achieved in terms of targets. We note that the household recycling target is working well. We note that the introduction of the Northern Ireland Landfill Allowance Scheme, which frames the directive, is very specific as a scheme, so there are some concrete targets. There need to be more. What we need to be wary of is that they are focused on the sectors that themselves need to respond and that it is not simply government sending out a wish list which it cannot control. Q278 Chairman: You mentioned earlier on Invest Northern Ireland, and forgive me if I misquote you but I think you said we have to be careful not to create a disadvantage. Is there any evidence that would suggest that better resource management, better waste management, damages competitiveness because surely what we should be doing is looking at how we can encourage new business into Northern Ireland because of our waste management strategy and because of the way that the state plans for better resource management? Is there not a difficulty there that if we say that this is a bad thing, that we have to be careful that it does not damage investment, we may miss an opportunity to present waste management in a totally different light? Mr Aston: You quote me absolutely accurately. You interpret me in a slightly different way. What we have to recognise is the synergy between what is good for business in Northern Ireland and inward investment and what is good for Northern Ireland in terms of its environmental compliance and quality of life issues. One of the drivers for Invest Northern Ireland is to have a competitive industry to bring increased employment, jobs, that element of sustainable development, and also to export goods. The synergy that we have is that by focusing on resource management, by making it better, easier and simpler for the producers of waste to spend less in producing waste and more on the production processes, in other words to make them efficient, we will benefit industry and in benefiting industry with our systems, with our techniques, we will export that expertise. That is one angle of how we are working together. We have slightly different drivers but they come together very clearly in exactly the way you describe. Q279 Chairman: It is a difficult sector to monitor, is it not? How are we going to find out whether or not targets are being met in the industrial and commercial sector in respect of the amount going to landfill? How are we doing that at the moment? Mr Aston: There are two elements there. First of all, one of the actions that has taken place in terms of Invest Northern Ireland is strong support for - and we know we have the Waste Management Industry Fund - environmental auditing of companies. In the last few years they have run through, I think, 107 companies, getting better practice in place, better expertise. From our point of view we have set up a scheme called Net Regulations in conjunction with the Environment Agency and SEPA, and this approaches 80 per cent of SMEs via the web with clear information on compliance, so they are specific actions in the sector. Your question related to how we are going to measure success. We walk into a particular difficulty there on the adequacy of data. If we take commercial and industrial waste, we already have a figure for that on a survey from 2002, but we immediately would question that base line data of 660,000 tonnes simply because it is an extrapolation from questionnaires. It could be that our targets, which are set as secondary targets and primary targets, are obeyed because the second survey gives us a result but we are not confident in the first survey. This is where there needs to be a major shift. We have done that in that we are going to do a new survey with commerce and industry, construction and demolition, and that will be done by interview, but we still pose the question: are those people whom we interview at company level sufficiently aware of the waste that they generate? That moves us on to a much bolder step and I think an essential one. We have under our duty of care across the UK this "keep, describe and transfer" requirement and responsibility. We think that needs to be extended to keep records and provide on a self-assessment basis annualised returns. The parallel model for this is the Health and Safety at Work Act 1974 which committee members may recollected stated that if you had more than five employees you had to have a health and safety policy. From that has grown a tremendous exchange and improvement in welfare and protection. We think the environment requires the same because periodic data sets, however well we do them, are just that: periodic. They do not improve the information sufficiently, set the benchmark, nor do they change the culture that the producer will remain responsible. Q280 Mr McGrady: I would like to ask some questions regarding the planning situation. In your evidence to the committee you say that meeting the 2005 targets is dependent upon composting facilities being in place. Yet our inquiry has highlighted that planning for waste management facilities has been notoriously slow. Your figures show that the process would take an average of a year and sometimes much more than that. How would you anticipate reducing the time for determination of applications in order to meet your targets? Mr Aston: I will begin and then introduce Mr Scott to give the direct planning perspective. The notoriety in terms of determination that you describe the position as is one that applies across the UK. Waste management facilities, whether we are talking about salt mines in the north of England for special waste or incinerators in London, take years and years, and one of our difficulties is following due process and winning technical arguments does not always win hearts and minds. One of the things that we were determined to do in Northern Ireland - and I am not suggesting that we have been completely successful - was to build from a base of consensus. No other strategy as far as I am aware was built in the same way that the Northern Ireland strategy was in terms of contact with people and businesses and the use of an independent forum to judge it. We also built into that this best practicable environmental option, another model for rational selection which I think will come up later, to ensure that people were involved in the selection of a facility. One of the things that has held up most planning applications is the department taking an active rather than a seemingly passive role. We did not want the strategic choices to be determined by a plethora of landfills being granted prior to the adoption of formal waste management plans because we had suffered in the past from what had been cheap and cheerful options. What we wanted was a balance of facilities that presented compliance opportunities as well as competitive opportunities to deliver the targets we talked about earlier. We waited until a strategy was published, the BPEO applied through adopted plans, and the publication of Planning Policy Note number 11. That in one particular case led to the permission at Drummee which came out of SWaMP (the Southern Waste Management Plan). This was a landfill. They clearly said that this particular site, for all the reasons they set out in the plan, was the best option at that time as part of the menu. Some of that notoriety that you referred to has been a positive step to hold back and make the right decision, but there are clear issues of confidence for those people coming to new tendering processes and new applications for which we will be looking for new processes such as composting. I will let Mr Scott explain the detailed planning background to that. Mr Scott: I am Noel Scott, Head of Special Studies Section, Planning Service. We deal with waste applications throughout Northern Ireland. Just to pick up on Steve's point about the hold on major landfill applications, our view of that is that that was a positive contribution. That was DoE acting as one and saying that we were committed to the Waste Strategy and waste plans at a very early stage. Effectively those major sites started the process in December 2002 and we are now at a stage - I think this week - where we hope to move two of the four outstanding applications to our Planning and Management Board and then on to the minister for decision. In relation to other applications - and the other applications are just as important in terms of diversion away from landfill - we recognise that there are difficulties in the process. For example, some consultees are particularly under-resourced and that is recognised, but a factor that exacerbates that situation is the poor quality of a number of applications and the lack of applicants using the scoping and screening processes involved in environmental impact assessment before submission of applications. I looked at some of the figures we supplied to you and this means that we approved 78 applications over the four years. On average they took about 11 months to determine. That was from date of validation to decision, but in fact they were in the system longer than that. There was a process of getting the applications up to speed, getting them shaken out so that there was sufficient information to actively process them. That took on average five weeks, but about 40 applications were validated on the day they were received. If you take those out you have a three-month delay and that feeds into the consultee problem because if you receive an application you then have to ask the consultees, "Does it need a statement?". You need to make a determination, so they are involved in that. You then receive the environmental statement. Frequently it is inadequate. The consultees are involved again but they are involved not in one run; they are involved in two or three runs through the system. Poor applications, coupled with a lack of resource in terms of consultees, combine to cause problems. The Planning Service at the moment is involved in a major review of process, the first in 30 years. It is focused on legislation, on procedures, on achieving speedier decisions. At its core we have attracted four million pounds for e-planning. There are programme dates for that. The e-planning has to be in place by the end of 2005. That will provide the ability to make planning applications and pay fees on the net. It will also involve consultation on the net with internal consultees and with councils. The e-planning will also involve advertisement of council schedules, add lists, etc, diverting a lot of work that comes through the divisional planning office at the moment onto the net, we hope, and releasing staff to work on more fruitful areas. Those processes are in place. We are looking in that process at use class changes, permitted development changes, fees and validation. All of these issues together I suggest will result in a more effective streamlined process that produces decisions. In terms of validation, within the next six months we are going to take a line that applications that cannot be processed will be returned to applicants. We are not doing that at the moment. We are dealing with complex cases and therefore there is a degree of latitude. We try and get applications up and running, but where they definitely are insufficient they will be returned. There are plans in hand to do that within the next six months. I should say that those plans may be delayed because of the need to switch resources. The decision was taken a week ago to re-allocate resources because of a 20 per cent increase in planning applications on top of a 20 per cent increase last year, but that affects timing, not the introduction of that process. We will also by 2005 have guidance on the system on the e-net and in our offices to allow people to make preliminary inquiries, to come in and talk to us about their applications, and we will encourage people to get involved in scoping and screening before applications are made. The consultee resource issue we are also seeking to address positively. There are steps in hand within this modernising planning programme to charge the full fee for the consultation process and to allocate that resource to the consultees. They will produce audited annual accounts showing what they have done with the money so that we will be able to decrease or increase the level of payment to reflect the workload. That action on validation, the action on fees to resource consultees, should help to change the situation. It is within the context of modernising planning where the whole approach is to change the image that planning has away from being an obstacle to being a positive contributor to the whole process. Q281 Mr McGrady: That was a very detailed reply to what I thought was a rather simple question. We appreciate that, of course. You did refer to the announcement last week that the minister had diverted some 50 personnel from general planning to individual planning applications for single dwellings. Surely that is an indication not of review in planning but of chaos in planning, where the area plans have all been suspended bar one, to my knowledge, and that we do not have an adequate planning situation in the six counties now at all? Because of that and what you have said, does that not mean that you need a radical review of where you are at in meeting your target of 2005, which is only next year? For instance, do you see that a regional level body would be better at dealing with this situation? The ultimate decision is regional but if that is the case is that not remote from the local input that is necessary, essential and desirable? What assessment have you made of dealing with planning on a day-to-day basis, which from a member of the community's point of view is absolutely chaotic? Mr Scott: I appreciate that there are no signs of change out there perhaps apart from announcements, but within the agency there is radical change going on. We will be electronic in 2005. What I am suggesting is that there may be some slippage in some of the proposals and times. That is all within a framework where all this will be done nevertheless by the end of 2005. In terms of managing waste, my team is not affected by any of these resource allocations or moves. We are well resourced and that has happened progressively over the last two or three years. I was responsible for minerals; I am not now. My team was responsible for enforcement; it is not now. My team was responsible for waste water treatment works, and there are hundreds of those; it is not now. We have become much more narrowly focused on achieving results on waste and while there may be delays in the short term in terms of the validation I spoke about, that too will be achieved by the end of 2005. These things are in hand and there will be changes and there will be positive outcomes. Q282 Mr McGrady: Taking this into consideration and your own suggestion to us, you will already be struggling to meet the 2005 targets, particularly for diversion of biodegradable municipal waste away from landfill. We come up to a crunch barrier in 2010 when the first Landfill Directive hits home. With the lack of facilities being progressed at a sufficient rate are you looking at this point of 2010 to see if you are going to fulfil your targets there, because I do not think you are going to fulfil the targets for 2005 in spite of the assurances you have tried to give me? Mr Aston: If I may answer Mr McGrady's question, it is another succinct question but a very deep one. We are convinced, according to the data given to us by local authorities, that we will meet the 25 per cent target. The concerning one on the horizon must be the 2010 target, and in fact the one beyond that which is 2013, in terms of compliance. Despite these delays, which started off this line of questioning, we have had no significant applications for new facilities and that is an issue. What has been described is the department focusing down to ensure that it can deal with those expeditiously when they come. The other aspect is that the review of the strategy is moving in the direction of convergence of the existing waste management plans, two of which, you will be aware, are under review at the moment because they do not cover the period to which you refer. The idea of converging the plans and looking at a Northern Ireland-wide examination of what the best options are is precisely to ensure that we do have the right infrastructure in place and indeed goes back to the basic issue of compliance that the Framework Directive sets out, "Thou shalt have a regional network". The purpose of the review is to make sure that the very things that you identify are physically in place by 2010. Q283 Mr McGrady: In your introduction, Mr Aston, you did mention that awful mnemonic the BPEO. In your evidence to us you state that the PPS 11 places an onus on the applicant to demonstrate both a need and a BPEO. You indicate that there is some tension between these two requirements, in other words, between the more strategic BPEO determination and the site-specific BPEO assessments required for planning applications. Is that not taking the whole thing even further away from the local context, local understanding and local participation? Mr Aston: There is always that danger but let me begin with an introduction to a reply and then ask Ms Corker to explain a bit further where we are going. One of the things we have tried to do is get a very clear strategy for Northern Ireland. One of the great advantages we had was to look at what had happened in England, Wales and Scotland, and we believe that what we have is rather better. I can say this in this chamber; perhaps in Westminster I would be a bit more timorous. What we have is a strategy which has great potential and the review of that strategy is about making sure we deliver what was already set out. The framework itself is quite good. The second thing was to have a clear plan, and that has progressed very well with the waste management plans from local authorities. The clear process, which is the third element and the one you, understandably and quite rightly, carefully tried to enunciate, the best practicable environmental option, is a difficult one because it is a strategic tool. It is in its simplest terms a rational beauty competition, if that is not a mixture of terms. The idea is to make a selection that fits. You start off at a strategic level with a ration of processes: how much landfill might we need, how much composting, how much in-vessel digestion, other physical processes to deliver better waste management. If we said, for example, that 30 per cent of what we needed was landfill or 30 per cent was waste to energy, what then do you select as the best facility, the best location? This idea of selection of what is the best environmental, economic and value model still applies but the concept gets a little difficult when you get down to the individual site. At any stage you are always choosing, and I think that what has happened is trying to make that practical at the local level, but also in building BPEO we have gone across the whole of Northern Ireland and I will turn to Ms Corker who will explain some of the meetings that she has been holding recently beyond the existing guidance. Q284 Chairman: Before Ms Corker does that, I noticed on the BBC this morning there was a very interesting article on English grammar and I am confused now as to whether or not we are talking about best practicable or best practisable. Mr Aston: Best practicable option. Q285 Chairman: I think earlier on we heard the term "best practisable" in terms of what was best practice rather than what was practicable. I am confused. Mr Aston: I am sure that was my enunciation. Forgive me. Mr McGrady: Do not confuse the issue any more! Q286 Chairman: My apologies. Ms Corker? Ms Corker: Good morning; I am Pat Corker, the Waste Strategy Development Manager in the Waste and Contaminated Land Unit of the department. I think there is a lot of confusion about what BPEO is and what it is trying to achieve. The first thing you have to get a feel for is that it is a tool and it is about making robust technical, environmental and economic decisions. That is why BPEO was introduced within the strategy: to help frame us towards our goals. The purpose of the Northern Ireland-wide BPEO, which we are now looking at with a number of councils, is to provide a clear process and framework for decision-making, and we were looking at this in response to the strategy review findings which indicated that a number of the councils were confused about what it was trying to deliver and they wanted a clearer steer from the department. The BPEO cascades down from the strategic level, which is embodied in the Waste Strategy (which as Mr Aston said is about the proportion of landfill and other facilities that we might want), to the sub-regional plan level which is much more location-specific and then down to guide the decision-making at the local level. It is trying to do this in a consistent way. It is intended therefore to ensure consistency in local choices and provide confidence to the public that the choices which are made will represent the best solution. This is essential because everyone needs that confidence. We spoke about the planning process and the delays in the planning process, but contractors and business which are going to come in and deliver these facilities all need confidence that the planning process is not going to be endless but will meet our needs for delivering the integrated network of facilities, and that has to complement the community. There is an awful lot of consultation required because you do not want to get to the point where you have made a technically robust decision at the high level but the local population will not buy into it at the final level. The whole purpose of BPEO is to try and take a step-wise approach and make it as robust as possible so that when you get down to the local decision-making level there are fewer places to go. You will get a number of objections; you will not eliminate them completely, but the robustness of the tool will help cascade down and inform the decisions. An example of that is through the Drummee process where, having followed that process through the Waste Strategy and the waste management plans for a particular landfill site, it did release the planning decision. What we are trying to do with the Northern Ireland-wide BPEO is perhaps extend that across and harmonise all three plans so that we can get those robust decisions right through the process. We have recently held a workshop. We formed an expert group to try and refine the scenarios and the options that you might want to look at. Because it is such a complex process, because there are such a lot of different balancing factors from the environment and the economic and social perspectives, it is quite a difficult concept. We have therefore formed a group which has brought forward some more detailed options and it was those options we then took forward with the councils to look at the pros and cons and progressively refine the scenarios and the options that we needed. That is making good progress and we hope to have firm guidance and a firm steer by the end of the year on what is that strategic-wide option for Northern Ireland and that will then cascade down into the review of the plans and the local level. Mr McGrady: Chairman, this is a very educative process for the likes of me and I would like to read all that you say in order perhaps to understand it a bit better. If anything further arises perhaps we could ask for further explanation in writing because time is short. Thank you very much indeed. Chairman: I do agree. The general message is that whatever our inquiry we tend to cross swords with planning in Northern Ireland. Yesterday we were talking about the lack of action on publication of PPS 12 and today we are talking about the implications of PPS 11. I do hope that at some stage a message will come across that our efforts can often be frustrated through a lack of co-ordination between what is happening in the planning process and what needs to happen in practice - or what is practicable. Q287 Mr Luke: I will move from theoretical planning to financial planning for my series of questions. You mentioned that Scotland is the leader in this but you have obviously at least come up to their level and will perhaps have surpassed that now. In your evidence to the committee I do not think there is any clear explanation of what financial resources are needed for the implementation of the waste management plans in the Province. You do mention that over the next three years some £42.4 million will be needed by the regional groups to implement their action plans. The Waste Management Advisory Board, in the evidence we took from them, estimated that they would need three billion pounds over the next 20 years to get the plan up and running and put the infrastructure in place, and some five million pounds over the next five years to kick-start that process. Do you agree with the board's figures? Mr Aston: No. Mr Luke: Can you give us an explanation? Q288 Chairman: Your other answers have been far longer than that. Mr Aston: I think there is a great difficulty, whether you look at the Waste Management Advisory Board figures or whether you look at Defra figures, in estimating the impacts and costs of dealing with waste management. The variance in competence and range is enormous and it is a key challenge. One of the issues about the Northern Ireland-wide BPEO is to establish very clearly what we think the capital costs will be for Northern Ireland to put an infrastructure in place that will deliver over that period, but that is a capital expenditure cost. If I can break it down a little into the four areas of cost to help the analysis, we have the one I have referred to, capital infrastructure costs. The macro-infrastructure costs range, we think, from £250 million to establish new high-tech plant and landfills and other bits and pieces to maybe up to £400-£450 million. There are also the micro-infrastructure costs which relate to the implementation action plans of the local authorities. We think our payment of that is roughly 45 per cent by grant-in-aid over the period, in accordance with their figures. The second is market development, which is a key driver in terms of pulling the material through. We can regulate, we can provide infrastructure, but we need market development to pull things through in terms of reprocessing. That has been led by WRAP and provides leverage and confidence. The estimate for that figure is not determined yet but we do know we would benefit from things like the Shotton plant, which is a £300 million capital investment, but we would benefit directly. For our development and demonstration projects and research we link up through the Scotland and Northern Ireland Forum for Environmental Research (SNIFFER) and we also will link up in terms of information and results with the new technology fund currently running for demonstration in England, Wales and Scotland. Northern Ireland companies can still bid for that. We have education and awareness. We have put five million into that in very global terms. We also do direct support to NGOs on MCAMS(?), landfill tax credit schemes for Bryson House and others in Northern Ireland. The big unknown in terms of cost, which we will come to later, is illegal activity. Much of the Environment and Heritage Service's work is predicated on environmental receipts. The enforcement activity does not bring us any receipts at all; it brings us a huge burden in cost which we will touch on later. That analysis still gravitates to the capital infrastructure and the operational infrastructure, and the figures are enormous. Going back to INI, the investment in the environmental sector, incorporating waste, has grown in the last three years by 81 per cent to £82 million and overall turnover to £191 million. These are large figures but until we get a handle on it we cannot easily rationalise the next question in terms of procurement and financial support, and there are different models for that but we do not think it will be a direct grant-in-aid. We think it is going to be PPP/PFI joint venture. Before seeking those partnerships or new rules of engagement we need to crystallise the figure because the variants at the moment give me and the department less confidence rather than more. Q289 Mr Luke: You mentioned the estimate of something like £400 million for the infrastructure investment alone. Taking the governmental financial processes, what bids have you put in to the Treasury to help you finance the work over the next few years? Mr Aston: On illegal enforcement we have a major bid in; not major in terms of that statistic but we have a bid for £2.5 million on that element of the cost. On the infrastructure costs, which you are directly questioning, that has been taken up with our joint working with the Strategic Investment Board for Northern Ireland which is setting up a plan over the next ten years. We are finalising that process now and that will be the basis of the bid for more money. Whether we can hope to match the sudden leap forward in cash that Scotland has demonstrated I do not know but we need to start with a pure and understood and shared consensus as to what the figure is to deliver. It reverts, interestingly, back to the very first question: do we deliver more than simple compliance? Do we go beyond that because we are covering a period of 2010, and how do we fund education and information because they are expensive in the short term but the long term benefits are incalculably strong and beneficial for the community? It is expensive work. Q290 Mr Luke: Obviously, Scotland's progress is helped by a devolved government system which can target these things. You have picked up an issue which is something we have talked about previously. You see the way forward as working through PPP/PFI bids and joint ventures. The way that works is that you have to have some sort of focus on long term spending. The current arrangements where local government has to spend its money in a year and there is no ability to roll that money over financial years I assume is a major obstacle to that kind of partnership. Mr Aston: It is and it is not the only obstacle. The concern that local authorities have expressed over the current grant-in-aid system, which is modelled on the Welsh system, is that it is very difficult to apply because there is not a continuous guarantee of funds. That has to change. We have already run PFI projects here on water treatment works, on hospitals and on schools, and we will come on to procurement shortly, but there are models that exist. The bigger question behind that is with whom do you partner? We have a coalition of district councils producing plans and implementation action plans and we have extended the powers to the arc21 group and they now have a chief executive, but we need probably to go beyond that. The whole question of a single authority as a procurement authority for a Northern Ireland-wide plan suddenly comes to the fore. That brings in a second order question, which politicians quite rightly would say is a first order question: the review of public administration. We have these knock-on effects and the real spanner in the process is the fact that the review of public administration may not occur until 2008/2009 and the committee's accurate questioning is: what are you going to put in place for 2010? It is that sequence rather than are we going to create a PPP, because whoever you partner with I do not think anyone wants to partner with 26 local authorities. I am not aware of any example across Europe where someone has done that, although I stand to be corrected. It is another very challenging question about how we deliver the planning mechanisms in terms of permissions and the financial mechanism in terms of adequate provision to transfer risk and create confidence amongst investors. Q291 Mr Luke: You mentioned in one of your earlier responses to me that you believe that the government would seek to supply 45 per cent of the support for local authorities and grant-in-aid to implement investment strategies. Mr Aston: I hope I was more careful than that. If you add up the figures produced by the district councils, there are two sets of figures. The first set is in their waste management plans. The second set is in the implementation action plans. I think the second was a slightly more accurate and lower figure than the first one and came out at round about £90 million. I think when we look at our grant support to the current grant scheme that if you add it up over the same period it will approach somewhere between 42 and 45 per cent of support; this is for their current implementation action plans. I do not think, and I would not be correct to suggest, that we are going to take that as a base line level of support. I am not even convinced that despite Scotland's enormous boost to the waste management industry its final capital figure will extend to a 45 per cent level of support for change; I do not know. It is not something we think as a model will work for the major infrastructure. The deepest question of all here is, can we produce a strategy over a period which gives investors confidence? Much of what we do in the waste management industry across the UK is about leverage. The WRAP does not support every single project. It provides a degree of credibility and accreditation and some money which gives sufficient confidence for venture capitalists and banks to invest. That is in a sense the name of the game of the long term strategy: investment by others, not government just handing over money to support things. Q292 Mr Luke: Do you think that the ten million pounds which the Waste Management Advisory Board points to in the waste management grant scheme has been sufficient to meet these needs? Mr Aston: Absolutely, because it is meeting the needs identified by the implementation action plans. The second answer is, absolutely not, because it is there to cover many of the other things. We have carried out a number of surveys on waste, half a dozen or more, which are expensive. We have carried out a number of developments on waste data flow, for example. We have a project going on at the moment where we are working across the UK. We have a huge investment. We have gone in central government terms within my own team from a level of funding of round about two and a half to three million at the time of launching the strategy to over £21 million and still we want more because there are so many more things to do. The strict answer to your question is that the plans asked for a sum of money and the grant aid was more than enough. If we overdo it, if we overpay, where is the pressure on a local authority or a householder or a business to wake up to waste? Q293 Mr Luke: Obviously, this is a negotiation and we are uncertain about what the final figure is. Something that looks quite probable is that the local authorities will have to increase their contributions and raise their rates to make sure that they have money in place to meet these costs. Do you think that is an acceptable form of taxation for local citizens to meet? We are talking about long term projects. Would it be useful to let local authorities know now or very soon what they can expect to spend over the next three years? Mr Aston: I think it would be useful to let them know and one of the hiccups in the system is our not being able to guarantee that. We must deal with that and if we go to PFI/PPP that is inevitable. Unquestionably we must deal with that. Your first question was a much trickier one in these sensitive times when we know that water rates are being charged, we know that household rates are going up, but I am afraid the answer is yes. Every other service that is provided to households is a paid-for service. There is no question in my mind that at some stage we have to look at this most carefully to encourage and incentivise people to segregate their waste and to pay attention to the products they buy. It is an essential part of how our policies work or do not work. We have had a fabulous public response to the efforts of district councils to provide second bins, to the Wake Up to Waste campaign. I think people want more and they deserve more but it will still be driven by the avoidance of cost. In other words, if you participate and you recycle there may be no charge, for example, on a recycle bin, but there may be quite a high charge for a contaminated recycle bin to be treated the same or for waste which you are not prepared to compost. This is highly politically charged, not only locally but generally across the UK. I also think that for logical analysts it is an inevitability. If we separate away from the "polluter pays" principle and say that that is okay at a certain level, and take it from the householder, we take away the very generation of education and participation and I do not think we can afford to do that. Q294 Mr Luke: We talked earlier about the planning process. Would you agree that there is a difficulty in putting financial planning in place and estimating over a period of time because of the nature of planning in general, because when you put in planning applications to get specific schemes on the go there is no certainty that it is going to be delivered in a certain time and these things make it difficult to plan long term financially? Mr Aston: I would agree there is a challenge and I put it in those Civil Service terms because it is a challenge rather than a simple difficulty. If we take the financial planning we need to move to significant support because we have a stable and clear policy and we have the mechanism and the vires with perhaps a single authority or a cluster of authorities to procure. On the development planning permission side there are a number of different models. We constantly fall into the trap of wanting to supply a waste-to-energy plant or a murph or a composter. What we need to think about is whether or not we should publicly acquire sites on which the technology may change and work in conjunction with Invest Northern Ireland and others to have multidisciplinary centres where energy can be used, where material can be used. It is a much bigger picture than just this one-off selection of a site or a process, and that is how deep the second question is. In our discussions yesterday we were concerned about the development planning side. In our practice yesterday I was very convinced by Mr Scott's evidence of the changes that the Planning Service is putting in place. I think there is a genuine recognition of a need to change and provide that confidence. If we go back a decade, Belfast City Council were very forward-thinking in trying to run a competition to supply capacity. They demanded of their tenderers that they all had planning permission and every one of them went to public inquiry in sequence and it completely jammed the planning process and the tender failed for that reason amongst others. The reverse is happening now where perhaps not enough tenders are coming forward because people are nervous of the planning process delivery. We have to take charge of that. That is one of the key leadership issues for government. Q295 Mr Hepburn: Do you think there has been a lack of leadership in respect of the strategy and, if so, what do you think government, or indeed the department, could have done to avoid this? Mr Aston: I would like give a simple "yes" but I think it is important I give a qualified "yes". If I simply say that there has been a lack of leadership because the government has not done all that it said it would do, lost in that answer is a recognition of all that it has done. Whilst I am not trying to give a Life of Brian description of all of our achievements it is important to reflect that we are as part of the UK well ahead of our colleagues in terms of European compliance. We are the only part of the UK that is not being chased because Northern Ireland decided it would take a binary approach: the department would produce a strategy as soon as possible, and it did, and we would produce plans which implemented that strategy, which district councils did. That was a huge success. The level of guidance we have produced is phenomenal and has been a huge success, and even in our response to regulations we were, as I mentioned earlier, some way behind. Over the last few years we have had something like 45 pieces of legislation introduced by our policy arm in the department. We have had to implement ten sets of new regulations within the Environment and Heritage Service and we have gone from 15 people to over 100, amongst whom we have 50 graduates, 30 postgraduates and approaching 200 years of real time experience because our appointments have been made by open competition. In that sense and in the task force we have led on education, Wake Up to Education, leadership, yes, is good, it is strong, but it is not good enough. We accept and acknowledge some of the criticisms. The dilemma in accepting that is the Spartacus routine. The department gets up and makes a declaration and every other stakeholder points at us and says, "Yes, that is Spartacus up there". We have not had the response we had on the strategy where other people have acknowledged things that they might have done better. I mentioned greening government earlier and I would like Mr O'Neill to lead us through the procurement side which probably appears as our biggest area of missed opportunity, if I can put it that way. Mr O'Neill: I am Brendan O'Neill. I am Head of the Policy Unit with the Central Procurement Directorate which is within the Department of Finance and Personnel. The overarching policy for public procurement is that of achieving best value for money. The definition includes that it is a combination of whole life cost and quality to meet the costing requirement. This definition allows for inclusion as appropriate of social, economic and environmental goals within the procurement process. These three goals together are classed as sustainable development. In effect, within the concept of best value for money public bodies have scope to compile procurement specifications which include environmental policy objectives. The directorate for which I work is concentrating on the development and implementation of the new policy and as part of its remit has prepared and disseminated guidance through our Procurement Board on environmental procurement and this has been issued throughout the public sector. The purpose of this guidance is to assist contracting authorities in identifying the most effective ways of integrating environmental issues within the public procurement process while adhering to the procurement regulations, the EC treaty and directives. The guidance in fact is based on the joint OGC and Defra note on environmental issues in procurement and adopted by ourselves to reflect the circumstances in Northern Ireland. The guidance encourages contracting authorities and purchasers to consider the environment from the outset when they are looking at procurement. There is more scope available in the early procurement process when defining needs and specifications and early action is therefore more likely to be successful in using procurement to advance the green issues. The guidance also asks authorities to carefully plan the process, to use performance or functional specifications, to assemble the relevant expertise and to initiate early dialogue with the supplier community. This can be useful in finding out what is available out there and informing the market of future requirements and in stimulating innovative response. The directorate is working with colleagues in the Department of the Environment on a number of fronts. We are working together on the Sustainable Development Strategy covering more than waste. This has two main themes: one looking at the framework for the government to state and, secondly, public procurement itself. The directorate, if you like, is in a pivotal role in government and sitting at the centre and supporting the Procurement Board and working closely with departments. We have brought together the construction client group, an interdepartmental group which is leading on the implementation of the Achieving Excellence initiative, which includes achieving sustainability in construction procurement. We have an Aggregates Task Group, another interdepartmental group, which has been established to consider what measures can be undertaken to ensure that the appropriate levy is paid on aggregates used in public works and to stimulate the use of demolition waste and recycled aggregates. In relation to procuring materials made from recycled products, the directorate again put together with colleagues from centres of procurement expertise - these are centres which have a specific portfolio in relation to procurement and come from the housing, health and education sectors, road and the water service - call-off contracts using the specifications, which are set out as "quick wins" in the integration guidance notes, contracts covering such things as office supplies, including PCs, photocopying paper, equipment, gas boilers, white goods, televisions etc, vehicles and consumables - light bulbs, tissue paper, paint. We are looking at all these areas. The most significant opportunity to date in this area has been the contract for recycled photocopying paper. This is a contract to cover central government and the health and education sectors which are quite heavy in their use of paper. It has been laid by the Education and Library Board here and is due to be awarded at the end of this month. It is anticipated that the outcome will be a price for recycled paper that will be at least approaching that of virgin paper but naturally with the advantages associated with environmental benefits. The directorate also manages a new electronic ordering system throughout central government. Ordering from call-off contracts or frameworks through this system gives staff a choice on-screen, so straightaway goods with a recycled content will be presented as available and gradually the availability of materials without recycled content will be withdrawn from the system. On the construction front, the directorate has concentrated on promoting the reuse of aggregates and the use of products made from materials that have a recycled content or are capable of being recycled at the end of their life. The directorate takes the opportunity to specify the use of such materials in building design for new build and refurbishment. In relation to procurement of major infrastructure contracts emphasis is placed on minimising the amount of virgin materials used. The directorate promotes the integration guidance as a base document which can be enhanced to meet particular circumstances. The guidance is in itself generic in nature and can be applied either to PPP/PFIs or major infrastructure projects just as well as to the purchase of pens and pencils. More specifically the directorate has set up another interdepartmental group on sustainable construction. The remit of this group is to produce and issue guidance on the implementation of the recommendations relating to aggregates, in order words to develop a demolition protocol, and this will be a planning and management tool for planners, developers and consultants working on demolition and redevelopment projects, setting targets for recycling and reuse of aggregates and, in conjunction with WRAP, to undertake a study into the viability and promotion of recycling centres within Northern Ireland. The group has recommended contracting authorities to adopt the use of certificates in all procedures and ensure that the appropriate levy is paid on virgin aggregates. It would also encourage contracting authorities to give bidders credit for the use of environmental management systems during the evaluation of tenders and ensure that they complete and submit the waste management declaration. This declaration ensures that all waste produced as part of a construction project is properly disposed of and that the records are retained. I hope this has given you some indication of what government is doing. Q296 Mr Hepburn: It has certainly answered the next few questions I was going to raise. Has the department any plans for any more targets, either for itself or for government as a whole? Mr O'Neill: Yes. In the Sustainability Strategy it is hoped that in relation to the government estate and public procurement it will contain targets. We have targets in relation to the application of the "quick wins" and to moving towards greater use of recycled products and away from virgin products. Q297 Chairman: Time is catching up on us a little bit. We have not yet discussed the issue of illegal dumping and I would like us to cover that. It is a major concern for this inquiry. We note the involvement of paramilitaries and organised criminals in the trade. We also note what is happening in the Republic where it looks as if there has been a considerable injection of funding to start to tackle illegal dumping in that part of the island. Could you talk through with us your views as to what additional resources would be needed within a Northern Ireland context to start to tackle illegal dumping? When I am talking about resources I think you mentioned earlier on £2.5 million, so financial resources are part of the answer, but also I would like you to look at human resources in terms of who is going to carry out this work. Could you give us an answer that covers all of those areas in terms of whether or not you share our concerns, what we need to do about them and where the money is going to come from? Mr Aston: We share your concerns. The department takes the matter very seriously indeed. What we have are clearly about 250,000 tonnes being illegally deposited and we think beyond 400,000 tonnes being illegally transported because some of it, bizarrely, is being legally deposited almost when it crosses the water, but illegal clearly because the movement should not take place. We have a range of direct cross-border incursions for deposit without any form of protection, very clandestine, and we have sham recovery, re-badging waste. That is clearly environmentally damaging and economically corrosive. The costs of cleaning that up are enormous. If we look at parallel contaminated land provisions we know that it will cost us a great deal to repair the damage that has been done. The only up side is that the effects and locations can be traced and we are looking at aerial surveillance and all sorts of mechanisms. Any landowner should be extremely wary of the liability that they are taking on. The other side of that is the very negative impact on the whole positive campaign of Wake Up to Waste or The Race Against Waste, both north and south. Both jurisdictions are affected. There is one other dimension which I want to touch on and that is fly-tipping. Just to give you an idea of the scale, and I have given you some of the tonnages involved, since taking responsibility in December 2003 we have had 590 complaints, 14 cases going to the Director of Public Prosecutions, 126 cases pending and 25 significant operations closed down. A specially formed team, the Environmental Task Force, has been working day and night in conjunction with Customs, DVLNI, Garda Síochána, councils both north and south and PSNI. I think they have been extremely effective. In human resources we think we need probably another 70 people to deal with this. That is the basis of the £2.5 million together with additional surveillance techniques. It is being addressed. We do share data. We have had meetings at the highest level and at the operational level north and south, but our difficulty is that we are rushing to plug the gap and the tap seems to be still at full bore. Our difficulty there is getting back to the producer of the waste and this responsibility and liability issue, which brings us to the second question. Before I come to the second question you asked about money. We have to have this money as what we call a straight departmental running cost. We cannot predicate it on environmental receipts. If we do not match the northern resources with the southern resources tighter controls down south will move it up north. It is that simple. The underlying principle of this and the question underneath it is, is the law itself adequate? The answer is no. These are unique conditions that we face. We know with the introduction of landfill tax in 1996 that the collateral damage was in fly-tipping, particularly in London, and organised crime was involved there. Here we have a huge differential in pricing which is driving materials to the lowest common denominator. You have to take the financial advantage away. One of our first steps has been to move from the magistrates' court to the crown court because we move from a £20,000 penalty to an unlimited fine and a longer term of imprisonment for criminal activity. However, that doubles our manpower requirements because you go from 23 days to prepare a case to nearly 50, so there are down sides to that. We also need to look at how we might make people feel more uncomfortable about the trade. One I have alluded to is how we make the producer responsible back at the point of origin so that if we do catch waste travelling illegally then the producer of that waste and all those along the chain suffer directly in financial terms. One of the ways is by changing our powers to arrest the drivers of lorries and detain lorries, to fast-track cases, so that if we have an illegal shipment we have a £70,000 lorry sitting waiting to be sold off if someone does not pay the appropriate cost of repatriation or safe burial. What appear to be extreme measures are highly necessary because, unlike any other form of smuggling, t is causing significant harm, not just to the economy but to people's lives. We are taking this extremely seriously, so we are looking at a review at the law at the moment, even down to the point of looking at vehicle trackers on trans-frontier shipments. The other very important side of this is that we like the idea of trade for the recovery of materials. Legitimate trade treating waste as a resource is appropriate, not as a pariah. In this kind of activity we need to take away the financial gain and once we do that it will evaporate. Until we do that we think we have a serious problem. Q298 Chairman: There is some comfort in your comments about the seizure of vehicles. I think that would probably more than anything else do a lot to discourage those operating from doing so, if they knew that the vehicles they acquired were going to be confiscated and the costs set against recovery or land recovery. Would it make sense in a Northern Ireland context to limit the scope of exemptions from waste management licensing so that abuses at sites could be minimised? Mr Aston: Yes, I think it would make eminent sense to limit exemptions across the UK. One of our new challenges will be that under definitions of agricultural waste, which will increase some of the areas of significant challenge, out of 29,000 farmers it is likely that 20,000 will seek exemptions, many entirely legitimate but it will also open up opportunities which will be very difficult to police effectively. The other side in terms of changing things is that fly-tipping - which is too joyful a term, I am afraid; it does not describe the harm and damage that it does all round - was dealt with and the powers have been retained by district councils to deal with fly-tipping and to clean up land, but they, naturally, in many cases have been a little reluctant to do so because recovering costs is difficult. Equally, 50 per cent of the calls to the department on this issue are to do with localised fly-tipping. We need to clarify the law and give the local authorities the right powers and the responsibility of dealing with those important local cases. That again will make us more efficient and effective in the work that we do. That is a key area for us. Q299 Chairman: You have just mentioned the local authorities. Does it also make sense at the moment to have 26 districts being the competent authorities for controlling trans-frontier shipments of waste? Mr Aston: It does not and they will not be for much longer. One of our moves is to transfer those responsibilities to the department and we have transferred responsibilities for special waste for movements within the UK. Because of the growth of definition and because of the high level of activity of that particular hazardous waste team - we deal with nearly 24,000 legitimate consignments of hazardous waste on an annual basis - there is a high degree of control exercised by that team. Q300 Chairman: Mr Aston, you and your colleagues have been very helpful to us and very generous in your answers. I believe we have covered most if not all of the questions we had for you. I am sure if there are any others we can write to you and clarify one or two points. Is there anything that we have not mentioned that you expected us to mention? Mr Aston: The answer to that is yes, but I will be brief. We are more than happy to continue to engage with you. We particularly value the degree and quality of scrutiny that the committee provides. The dilemma for the subject, and if the committee was not already alert to that it is now, is that there is a tremendous capacity for people to confine this to something simple and straightforward through a misplaced familiarity. It is inordinately complicated politically, physically and financially. The area that we think is a key driver is market development. We can segregate; how can we reprocess, and when we have reprocessed, which we think we can manage, where are our markets? Northern Ireland has a particular challenge because we have a strip of water and problems of access. That is one area which is very important. In relation to the one plan which we have touched on, linked to one authority and to the review of public administration and the current debate over where the locus of the agency shall or shall not be, we have two cris de coeur from advisory boards about this. That matter is being very carefully examined but bear in mind that 50 per cent of local authorities' budgets is on waste management. That is going to grow so therefore it is all wrapped in. Finally, behavioural change is a huge and long term investment. We would very much welcome the observations of the committee on steps that we might take because they are key investments which do not tie into shorter immediacies of political priorities but they are an imperative because across the UK we continually focus on waste management. Our focus should be on its production in the first place and prevention by us talking to the sectors. We have had a link with stakeholders through the Waste Management Advisory Board but one of the disappointments has been that the stakeholders who came forward were not from the manufacturing industry. We need that link and we think that if the government is going to have an action plan, which we think it must have to demonstrate leadership, it must have also an achievements report but we would like to see the same from sectors. We would welcome comments about how we might engage to the point of commitment rather than to the point of a thousand new ideas about what to do with those sectors because that is where we get delivery. Thank you very much. Chairman: Thank you very much, and your colleagues. Memorandum submitted by The Quarry Products Association, Northern Ireland Region
Examination of Witnesses
Witnesses: Mr Paul Walsh, The Queen's University Belfast, Mr Gordon West, Regional Director, and Mr Bill Weir, Chair Planning & Environment Committee, Quarry Products Association Northern Ireland, examined. Q301 Chairman: Gentlemen, welcome. Thank you for attending and thank you for being here earlier. It is always appreciated by the committee when people take an interest in our work. We have a number of questions. I am sure many of them will not be surprising to you. I wonder if I could start by referring to the QPA's somewhat scathing response to the government's review of the Waste Strategy. You will have heard us earlier on talking of the review. You urge urgent action on waste minimisation. What action specifically would you like to see? Mr Best: First of all, thanks very much for inviting us here today. Some people may ask what the Quarry Products Association's interest is in waste management. Obviously, as the committee are very much aware, one of the big aspects of the Aggregates Levy relief scheme is the use of recycled aggregates. Very early in our discussions with Customs & Excise we realised that if we as an organisation were to set targets we needed some sort of infrastructure in place in Northern Ireland. It was quite evident a year and a half to two years ago that no such infrastructure existed. We will hopefully be able to inform you as the meeting goes on about what we have done to progress that. From a waste minimisation aspect from our side in looking at C&D waste, etc, one of the first issues is planning and having waste issues designed into contract, ie, what waste will a project create at construction stage and how will it be dealt with, what waste will that project generate through its lifespan and how that waste is going to be generated? One of the groups that Bill and myself sit on is the Construction and Demolition Waste Industry Group which has been set up along with Investment Belfast. On that group we have all interested parties. The QPA set that up through our participation in the Construction Industry Group but we also have CPD, we have DoE, we have the demolition industry and we have professional people like consulting engineers. We feel that this group has the potential to make a significant contribution to the whole aspect of waste, particularly around construction. What we are currently doing is drafting a paper which will be given to a cross-party team of MLAs before the end of the month. What we are saying in this is that this is what the industry can do and this is what you can do as MLAs to help drive this whole issue forward and help Northern Ireland plc utilise more of its construction and demolition waste. Perhaps I can read this out to you. In the whole role of implementing sustainable waste practices and particularly waste minimisation clients need to set waste minimisation and management targets and encourage environmental performance through appropriate contractual arrangements and tender assessment criteria. We have designers, as I have alluded to earlier, that minimise waste generation within appropriate design and maximising reuse on site - that is the key issue - and we also have specifiers specifying reclaimed materials and construction. Obviously, there is also the education of suppliers, ie, educating contract managers on building sites into good practice. We look south of the border with some envy because they have developed guidance on construction and demolition waste management, a handbook for contractors and site managers, and that been done through the Construction Industry Federation in the south. Something similar here in the north would be very beneficial. There is of course the whole issue of our own industry which we are educating our members on in appropriate waste management facilities, how to go about getting the permissions, etc. That is an aspect that we are currently very hot on. Q302 Chairman: Thank you for that. It is always refreshing when you have received criticism about a department when those that put forward the criticism come with positive answers as to how we could improve matters. I am grateful for your response. You said you were going to publish the paper to MLAs at the end of the month. I am sure you would not mind passing a copy to the committee. Mr Best: That is not a problem. Q303 Mr McGrady: On exempt sites could you give us some idea as to how the sites exempt from waste management licensing provision are supervised? Have you any constructive or deconstructive criticism on how that could be either improved or amended? Mr Weir: I am Bill Weir of the Environment Planning Committee for the QPA Northern Ireland. On exemption in the construction sector, there are going to be two sides to the exemption. Traditionally in construction where you had what was known as "cut to dump" the material that was being removed from site was being removed to infill agricultural ground probably, to raise the level of ground close to the site of construction, which provided an economic disposal of the material. The problem with that is that it is seen as being uncontrolled development so, getting back to Gordon's point at the start, it is the designers of the infrastructure schemes who have a duty to plan for the disposal of the material off-site and to plan for where that material is going to go. That becomes part of the due planning process. Then, whenever the project enters the construction phase there is a clearly developed plan as to how all those materials are going to be dealt with, which means that an exemption which would be required for that material would be dealt with within the planning and design process. A comparison as to how this is operated in relation to health and safety would be the construction design and maintenance (CDM) regulations that are used to manage health and safety in relation to construction projects where there is a duty on the designer to plan for the future maintenance of the structure that has been erected on health and safety grounds. The second aspect of it I would answer specifically for quarry locations where there is the opportunity to obtain an exemption to permit the quarry locations to receive inert construction and demolition waste for the purpose of storing and reprocessing the material. In that case the exemption provides an excellent opportunity to encourage the development of the recycling business within the quarries and to provide a good quality disposal route for inert construction and demolition materials, such as waste road-making materials, bricks, concrete and all that type of material. The industry has committed through the Aggregate Levy Relief Scheme to generating a recycling industry for construction and demolition waste and to trying to provide five per cent recycling by 2011 within quarries. That is certainly the way the industry sees of promoting that. The logistics of that method of disposal are good in that materials can be delivered to a site and waste materials can be taken from a site and reprocessed in a controlled environment within the quarry. Quarries that have signed up for the relief scheme are undertaking significant environmental improvements to their locations which means that they are dealing with the issues pertaining to the processing of that material, so they therefore provide a good environmental solution to processing those materials. The additional benefit for the industry is that the development of a stream of recycled material is directly replacing virgin extraction, so it extends the life of the sites and that makes the industry more sustainable in the way in which it is conducting its business, so the industry sector is keen to engage positively to encourage the development of this type of approach. We see it as part of our social responsibility as well as a commitment that we have made through the Aggregate Levy Relief Scheme. Q304 Chairman: I am conscious, Mr Walsh, that you come at this from a slightly different angle from the QPA. Please feel free during our questioning to intervene at any point and give a view. Mr Walsh: The submission that we made goes back to a bit of research that was done in 2002 before waste management licensing was introduced, and indeed I think before the IPPC changes were introduced. At that time we identified that there was potentially a situation where a quarry could have IPPC regulatory involvement for its processes and then a waste management regulation for the recycling activities that it might get involved with. Obviously, when the final draft of the legislation was introduced that was clarified somewhat and the exemptions that Bill has spoken of were introduced. In relation to exempt sites, there are probably quite a lot of sites that are exempt. Some of them I would call official in that they have gone through the process of the documentation and applying for the exemption. There are other sites that have not gone through that process even though they probably could get the exemption (if indeed that was available). Again, it comes back to the need to change the perception in the industry, that you do have to get permissions and approvals for things. That is why it would be quite useful to be able to link that through with the task force group that the QPA have been involved with because that puts the onus on the designers to educate themselves about where materials go. Again, through the planning procedures and process, if that loop could be closed whereby in the initial planning application there had been some identification as to where materials were going to end up, that would force the designers and contractors to identify where things were going. The only other point is that the quarries - and undoubtedly the quarry industry will be able to play a leading part in developing recycled aggregate streams - are not necessarily always in locations that are immediately adjacent to where construction and demolition waste has been produced. It should be noted that the Larne quarry recycling centre for construction and demolition waste has the full rigours of the waste management licensing regulations to comply with, including the technically competent person requirements, and it should be noted that there are slightly different regulatory regimes there. Q305 Mr McGrady: Maybe you could give us some idea of the quality of things that you are talking about. How much construction and demolition material would be sent to these exempt sites and what proportion of the total would that be? How much of that is active rather than inert materials? You may not have those figures off the top of your head but perhaps you could give us a broad idea. Mr Weir: The answer is currently very little material returns to quarry sites. The method of disposal continues to be probably one where the material disappears, for the want of a better word. There is obviously an economic reason for that. Even with the increased level of enforcement, enforcement has probably correctly concentrated on the more harmful waste, such as the transnational shipments of waste management across the border, and relatively benign material, such as concrete blocks and stuff like that, has not been a hot target for disposal, so there is still a lot of fly-tipping going on in the industry. There are two reasons for that. First of all there is elsewhere a cost for disposing of it in that way. It can be disposed of probably relatively conveniently to the site of construction and that is normally what happens. The second reason for that continuing is that there is no encouragement through the contracting process currently to make contractors want to have the proper documentation and while we have a duty of care system in place through the procurement process as it currently exists no duty has been passed down to the purchasing departments to require contractors to provide them with proof that the disposed materials from those construction sites have been dealt with correctly through the duty of care documentation system. That is an essential component of improving that situation. The reason I say it is an essential component is that the cost of virgin materials in Northern Ireland is so cheap. Virgin materials cost in the region of three pounds per tonne on average, and that is the average of the high quality to the low quality, so there are low quality materials available in the market place for maybe £1.25 or £1.50 a tonne. The cost of transporting material 20 miles is about £1.50, so you can immediately see that unless there is a push through the system of regulation to encourage the material to return to the quarry where it is possible for a gate fee to be charged on entry to the quarry to cover the costs associated with dealing with the material, the recycled market does not really get started. If you have regulation coming into the sector through the people who are undertaking developments being responsible to see to it that the materials are disposed of correctly, that will stimulate the development of a proper recycling system where the materials are being returned and are being dealt with in a responsible way. There is in that regard the quality protocol which has been promoted by WRAP, which clearly sets out the correct methodology for dealing with those materials which are arriving at legitimate sites such as quarries. The second part of the question relates to the disposal of hazardous waste, and the answer to that is that no hazardous waste should be transferred to any of those sites. It should be dealt with through the special waste regulations. In terms of the types of material that might currently end up at a quarry site, you would be talking about things like wood or paper or bits of plastic with maybe bits of metal coming in in the reinforcing materials. The protocol would mean that those things would have to be segregated out and disposed of correctly at the quarry site but you would not be talking about anything more hazardous than that type of material. Mr Best: If I could quote from the Symonds report, which was carried out last year at the behest of Customs & Excise, it says that slightly less than 20,000 tonnes of hard construction and demolition waste is currently going to landfill as waste. Given that that is against an overall estimate of 2.5-3.75 million tonnes of all construction and demolition waste that exists, that may paint a false picture in that anything outside that 20,000 tonnes is being fly-tipped. One of the things that we recognised in the Construction Industry Group, which is recognised within the Aggregates Task Group report, is that in Northern Ireland we are very bad at documenting evidence of recycle and re-use. There is a heck of a lot of recycling and reuse going on but it is not documented. Reading the task group report, I think the departments have committed themselves now to changing that and documenting what reuse and recycling is going on within government contracts. Q306 Mr McGrady: Has your industry made any assessment of the degree to which the exempt sites act as a magnet or an outlet for illegal dumping both within Northern Ireland and from the Republic of Ireland to Northern Ireland? Have you any assessment of what is happening there? Mr Best: We certainly will not have any assessment within any of our members' sites but I think there is the danger - and this is where the quality protocol would come in because of the inspection regime that is tied into it - of unscrupulous operators hiding hazardous waste within inert waste. If the quality protocol was adopted here that should be addressed. Mr Weir: The quality protocol deals with that in that in the acceptance of the material it has to be photographed on entry and it has to be inspected when it is tipped. That indeed is why there is a specific cost in doing this because you do have to develop a very clear infrastructure to ensure that these materials are being dealt with correctly. By doing so you provide a suitable method of being able to reprocess those materials. You also provide the opportunity for the materials to be incorporated back into products at the highest value added point at which they can be reincorporated into the products. The classic example there would be road planings, which currently might end up in farm lanes or at the entrances to fields or places like that, whereas a better way to recycle them is to put them back into road-making, into asphalts, which again can be done at the quarry sites as long as the regulation is pushing the material to the quarry sites and that enables the quarry sites to make the investment in the infrastructure to allow for the reprocessing of those materials. Mr Walsh: Could I add a couple of comments to that? It appears to me, certainly through the research that I have been involved with, that we have moved from a situation where on sites material was knocked down or dug up or whatever and put in trucks and brought to landfill. Certainly where there is a lot of concrete involved now most of that has been crushed and is being used to fill parts of the site in a low value application. That is progress. It has certainly cut down the amount going to landfill. However, the opportunity is still being missed there for that material to be taken and the useful fractions of it to be used, for example, in the manufacture of concrete or other materials. There are plenty of examples, and plenty of research has been done across the world, on the suitability of using materials like that, with again very little quality impact in most cases, but there is a real need to get that knowledge from the web sites and the papers and the journals and get it into practice. From the university perspective it feels that there is a training need there but the clients probably have not quite identified yet that they have that training need. Q307 Mr Hepburn: What progress has been made in respect of government altering specifications in its own procurement to encourage the development of markets for recycled aggregates? Mr Best: Up until the Aggregates Recycling Task Group report, very little in our view. There has been a lot of talk about leadership and the lack of it and I would like to pay tribute to John Macmillan, Director of CPD, who instigated the setting up of the Aggregates Recycling Task Group, and in my view if the proposals and action points, six of them, that are identified within the report are implemented they will make a significant change within government procurement, certainly in construction, within Northern Ireland. We are focusing on this through the Construction Industry Forum for Northern Ireland. I believe that we have good news to tell, that this issue is being progressed very rapidly. Various government departments have now signed up to sustainable construction, etc., and although there has been very slow progress to date I think that is going to speed up. Mr Weir: In terms of central procurement there have certainly been very positive moves. Central procurement is not the holder of the budget to spend. The people who are spending the money tend to be focused on short term annual expenditure and are maybe not so focused on taking a longer term view as to what is going to represent long term value. A number of the departments that we work with, such as the Water Service and the Housing Executive, have shown a desire to innovate and look at these issues in a more proactive way than others have. Other departments tend to take a more traditional view and perhaps show a reluctance to take the risk of innovation within the products that they are using, so whenever you come up with offers of new or alternative products you really have quite a hard job selling the message to the client. I think there is an education problem in some of the departments in that I think the industry is more aware of the environmental problems and how to deal with them than a number of the client bodies are in terms of their approach to the management of their capital expenditure budgets. I think there is quite a bit of work that needs to be done on educating those people who are the stakeholders of the budget as to how they should go about spending their budgets. The other problem is with the traditional method of controlling new issues through people who hold budgets to spend money in government. We are not very good at devolved government here but in Civil Service terms they are very good at devolving responsibility, so you normally find that there is a clause inserted in the contract that devolves the responsibility to the contractor without the client necessarily taking ownership of the duties that they could positively involve themselves in which would create a better and more sustainable type of process. I think a change in thinking is required in how these things are tackled through the procurement process. Mr Walsh: I concur with most of that. In particular I think that there are plenty of specifications available which allow for the reuse of materials that would otherwise be waste. The issue is that very often the people with the responsibility to do the design and lead the process through are too busy or too pushed for time or money to take the time out and innovate and think latterly around the problem. I would also like to put on record that very often in a lot of construction-type projects the decision is made to knock down or do away with something prior to the design for maybe the replacement of the facility. I have seen examples of college buildings, "We are going to knock that down", instead of looking at it and saying, "We want a new college facility to do X, Y and Z", and starting the design process with the existing structure rather than from a blank site. Very often those decisions are made at a higher level than the design teams that are going to be involved with the project. Mr Best: One of the recommendations that we were making in the Construction Industry Waste Group will be that CPD immediately initiate an education and awareness programme for government officials with the help of WRAP. The WRAP web site that deals with aggregate is an absolutely first-class source of information. One of the things that we are continuously preaching is that we do not have to redesign the wheel. They are doing this daily in GB and other parts of the world. We just need informed decision-making to get the thing moving. Mr Walsh: The WRAP web site is a good example. There is lots of information, lots of good practice. I have heard designers say, "We need three weeks to sit down and read half of what is there", so I suspect that there is a need for good local practice to be captured in some way and probably delivered orally to people, possibly with site visits and things like that to push back the boundaries. Q308 Mr Hepburn: The Aggregates Recycling Task Group have just produced a report which is putting forward proposals to try and increase the amount of recycled aggregates in government construction projects. What impact do you think those proposals will have? Mr Best: This is all great stuff in black and white when I read it. This was unprecedented, coming out from CPD. What we have now asked is for implementation plans to be drawn up by each of the departments from these action points. If that takes place, as I said earlier, we will see significant progress towards green procurement. One of the other aspects of it which we have noticed and have raised, starting with Roads Service, is that it is all very well putting things in black and white that says that contractors must produce documentation as to where the materials are coming from and where they are going, but if you do not have people on the ground who are going out and checking it is not worth the paper it is written on. We have not seen any evidence of officials asking for confirmation of where the aggregates are coming from in relation to the Aggregates Levy, so we will be scrutinising it intently. Q309 Mr Hepburn: Do you think a higher aggregates tax would increase recycling of construction and demolition materials? Mr Best: In a word, no. Mr Weir: The only thing that the aggregate tax helped to encourage was the development of illegal operations, which it was quite successful at. It proved to be a significant burden for the legitimate sector of the industry and I think the agreement that have we reached through the Aggregate Levy Relief Scheme is a landmark agreement for Northern Ireland. It shows partnership between industry and government at policy level which I think is possibly unprecedented and it provides a model that can be utilised. We have heard this morning for example of the severe resource problems that the Planning Service has. They also severely neglect the minerals industry but are aspirational about introducing such things as a review of the mineral planning process. We as an industry are suggesting to them that they should adopt the Aggregate Levy Relief Scheme and the environmental code attaching thereto so that that can be used in a joined-up way through government to regulate the industry. If that means making the environmental code in some way more of a legal document, that provides a further opportunity to streamline the management of our industry through a partnership approach towards policy, and a similar approach towards the development of the management of waste will produce quicker gains for society than a simple continuous investment and enforcement. I think it is a much more positive model that will produce a much quicker win for Northern Ireland society. Mr Walsh: The aggregate tax levy penalises the contractors, the people who are at the sharp end, and absolves responsibility from the decision makers, the designers, the planners. It is a very blunt instrument that allows those in the position of decision-making effectively to reduce or avoid their responsibility. Q310 Mr Hepburn: The Queen's University Belfast's submission mentions the role of the Integrated Pollution Prevention and Control regulations as being particularly important. Can you explain what you mean by this? Mr Walsh: As I said earlier on, that original paper was prepared back in 2002 before the IPPC regulations were introduced. The IPPC regulations apply to processes in industry, particularly from a construction perspective and things like concrete production and cement works. Our feeling in preparing that study at that time was that this set of regulations would apply to processes within a quarry; yet at the same time the recycling activities would have to conform with management licensing regulations. In other words you were going to end up with two separate regimes to manage the one operation which was going to be a negative for the quarry producers to take part in recycling. Subsequently, the way in which the regulations were introduced in late 2003 means they have allowed the exemptions at the quarry end so that they do not have that waste management aspect to do. I guess the feeling that we had in preparing that study was that if you wanted one piece of legislation to bring the control of industries under a common theme the IPPC may well have been the piece of legislation to do it. As it is, it has not. An exemption has been introduced at this stage to deal with the problem that we identified. I still would suggest that probably it would be a desirable thing to have one set of regulations dealing with the quarrying and the construction end of the industry so that one set of companies can work with the regulator to develop better systems and procedures rather than having to meet different requirements and different dates for different people. Mr Weir: The exemption exists for the receipt of the material. The processing of the material within the quarry will still follow under the IPC or the IPPC regulation system so that the processing of the product is controlled and regulated but at least you have only one set of regulations to deal with. That maybe leads on to the wider issue which is a concern to our industry as to the number of environmental enforcement agencies that are developing. Certainly we would agree with the Queen's University position that we would like to see a single environment agency for Northern Ireland. We would like to deal with one environmental regulator who is responsible for all environmental aspects of our business so that we could agree short, medium and long term plans as to how we manage and control all the environmental impacts from our activities. It is probably the case that IPPC regulation provides the best opportunity for doing that. We also as an industry are concerned in that we are being levied through the "polluter pays" principle so that we are in fact having to pay for a plethora of regulators which are visiting us. It would seem that their operating costs rise at a much higher rate than general inflation so that the regulation fees increase in some cases by double digit percentages on an annual basis. That obviously is imposing a significant burden on the industry. We certainly feel that that could be simplified for us and be made more cost effective for government through the formation of a single environment agency with responsibility for all aspects of our industry. Q311 Mr Luke: Could you comment on the role you think the Landfill Directive may have to play in encouraging aggregate recycling? Mr Weir: The role of the Landfill Directive is a cost plus role in that if materials have to end up in the landfill site then there is a significant cost of disposal and that encourages the reprocessing of those materials. That only works in a very closely regulated framework where we currently have the situation where illegal disposal or fly-tipping is quite prevalent. It is in effect having no beneficial effect at this point in time but it has the potential to provide some assistance. I think the majority of the assistance will come through procurement and through a procurement-driven push to encourage people to dispose of materials through proper recycling routes and the encouragement of the use of more recycled material. Mr Best: Just to add to that, and it goes back to our point of design, if the designer is designing in the legal cost of disposal at that stage then the client is fully aware of the cost to the project of legal disposal. He will then look at ways of disposing or reprocessing, the cheaper options, and obviously the cheaper option is reprocessing. We will be able to pass on to the committee details of approximate costs for reprocessing C&D waste in Northern Ireland. I can do that for you. Mr Weir: For a government procurement that provides a very good model for evaluating projects if you have to benchmark it against legal disposal and then look at alternatives. It provides a good methodology for deciding what is the best way to get best value for the contract that is contemplated. Q312 Mr Luke: Why does Queen's University think an evaluation of the use of primary aggregates for landfill capping should occur? Is this a common use for primary aggregate? Mr Walsh: Traditionally in this country there has been quite a lot of quarry product used to cap landfill sites, to produce haul roads and so on through landfill sites. That effectively has represented quite a waste of material that could be used for other purposes. However, there are situations in quarries where there is waste product produced or product that has a very limited market. We feel there is opportunity for those sorts of materials to be used and exploited usefully for the landfill-type situation or indeed usefully exploited in conjunction with reclaimed construction. To give you one example, modern landfill design requires bentonate slurry liners to prevent leachate. In this country we have quite a lot of weathered basalt which my colleague tell me is of no particular use in construction or from a quarry operator's point of view. Our contention is that it has quite a lot of similar properties to bentonate that is brought into the country from abroad. Our point is that there are potentially great opportunities to look in detail at particular products from particular locations, particular waste streams, to try and capitalise on the benefits of those for use in landfills. Q313 Mr Luke: Again, would not a higher aggregates tax play a role in reducing demand for this outlet? Mr Weir: The aggregates tax to my understanding is the tax that is applied to all materials coming from a quarry when it has been sold, so a higher tax could reduce the will of landfill operators and so on to explore the potential of using other products and they may end up using geo-textile or fabric-type liners or capping materials instead of using materials that are effectively waste. Mr Weir: The point there is that for the class of product that you are talking about there are two classes of product going up to the quarry and the landfill sites. There are capping materials and there are roads within the site. The predominant volume of material will be for capping materials. These capping materials have normally been provided either through construction projects where virgin clays have been excavated or from quarries selling the lowest value material that exists within the quarry, the material that is unsuitable for processing into aggregates and construction type materials. The quarry tax does apply to those materials so in fact a higher tax would actually be a disincentive to using those products that occur for the legitimate purpose of capping landfill sites and that would be a negative aspect for the industry because the material occurs naturally. It is therefore there to be disposed of, so if quarry tax created a barrier to its sale the same material would simply be accumulating at the quarry locations. Q314 Chairman: You mentioned earlier on the Quality Protocol for Aggregates, a very interesting document produced both by the Association and WRAP. We have heard that the department has been reluctant to recognise the protocol within Northern Ireland. Why do you think that is? Mr Best: "Reluctant" may be too strong a word. I think "apprehensive" may be a better term. There is obviously a lot of technical detail in the protocol and you need a bit of technical expertise to understand it. The document was put together by WRAP, or the QPA initially, and the Highways Agency because of the whole definition of waste, that a product will no longer be termed a waste until it is part of a structure, ie, a road or a building. Our association saw that definition as a major barrier to encouraging recycling. We handed this document to DOE in July of this year. To date it has been discussed internally. They have had meetings with WRAP and yet we still have not had any decision as to whether they are going to support it or adopt it. In that time SEPA have now supported it. What that document says is that the onus is still with the operator to prove that the material has been recovered and that is where the quality protocol comes in. The department then will instruct its officials to go out on to site and assess any material. They will look for evidence that the material has been processed to this quality standard which ties in to the new European aggregates standards. I think the apprehension within DoE is just down to a lack of technical knowledge. I have spoken to John Bart of WRAP and WRAP are quite willing to come over and give DoE any advice and so on about how to implement this or to allay any of their fears. We in QPA see this as a key instrument to encourage recycling within Northern Ireland because what this will do is take all that reprocessed material out of the duty of care, the waste management licensing that currently exists. Q315 Chairman: Gentlemen, time has beaten us once more. However, you have answered the questions that we had for you. As I asked the last group of witnesses, is there anything we have not asked you which you expected us to ask you? Mr Weir: I do not think so. Mr Walsh: No. Mr Best: No. Q316 Chairman: That being the case, it is very good to re-make your acquaintance. Thank you for your input. It is valuable to us. We would be grateful for the information you said you would provide to us. That will assist the committee. Thank you also for taking the time. It is very important that we hear as much as we can from both industry and those within the university that are studying this particular problem. It helps and assists the committee. Thank you. Mr Best: Certainly, Chairman, we will keep you informed as progress on the industry group and implementation of the task group's recommendations. |