Supplementary memorandum submitted by
David Levy
It is apparent that the Environment Agency
have been presenting to the Efra Committee via Baroness Young's
evidence a slanted perspective. The Committee will not have the
evidence in full on which to make their conclusions.
The failure to answer the question about the
missing million tonnes of hazardous waste should have raised the
Committee's concerns and the failure by the Agency to instruct
the Committee on the reclassification of hazardous wastes as recovered
fuels, is an oversight that makes the rest of the conclusions
pointless. This the Agency would know and should be made to account
for. The Substitute Fuels Protocol Revision has led to an inadequate
consultation including a failure to consult the Committee whose
auspices first delivered the SFP, after public disquiet about
health and safety matters. (1996 Select Committee on The Impact
of Cement Manufacture on the Environment.)
As representatives of the Cement Community Network
we have requested the opportunity to present our case to the Committee
for balance, openness and accountability. We are distressed about
the Agency's keenness to proceed in this matter without addressing
the issues of filtration, BPEO, BAT, hazard analysis and risk
assessment of the substances being burnt and being imported to
our shores to be incinerated.
By addressing the latter point the Committee
could provide the solution to the most hazardous wastes going
to purpose built hazardous waste incinerators maybe grades 1 and
2 , whilst the less hazardous wastes could be disposed of in cement
kilns grades 3/4 and 5. That way the revised SFP will not end
up being the death knell of the HW Industry.
David Levy,
Wiltshire Waste Forum/NGO, The Air That We Breathe
Group/Chair, Viridor Liaison Group/NGO, Centre for Environmental
Protection/Adviser
25 November 2004
| 
