Memorandum submitted by the Chartered
Institution of Wastes Management
The Chartered Institution of Wastes Management
is pleased to provide the following evidence to the Committee
on the work of the Environment Agency.
1. THE AGENCY'S
ROLE
There have been questions in recent years regarding
the appropriateness of the Agency developing and implementing
policy particularly in the waste sector. The Institution believes
that it is essential that the Agency uses its practical experience
to develop regulatory and strategic policy. This, however, should
not be undertaken in isolation, but in close cooperation with
Defra. The Agency should be an integral part of the review of
strategic policy and its detailed role should be considered in
the development and workings of any Strategic Waste Authority/Network
under the waste strategy review.
The Agency's most important role for the waste
industry is as a regulator. Often the interface between the Agency
and partner regulators is complex—eg in fly-tipping response
and enforcement. This needs to be guided by clear protocols and
with appropriate resources available to both organisations. The
Agency's credibility rests on performing its regulatory role efficiently
and effectively, and only where this is being delivered should
the Agency use resources in an advisory role. It is clear, however,
that the Agency has valuable experience and information to offer
in this respect—although businesses will often prefer to
get advice other than through a regulatory body.
2. RESOURCES
The Agency needs to be fully resourced for all
its activities. Fees and charges paid by operators for permits
and for compliance monitoring are partly risk/performance-based.
The Institution would like to see further development of this
approach to incentivise reduced risks and good performance. However,
the Agency must also avoid being seen as only "regulating
the regulated". As Grant-in Aid reduces, pressure grows on
non-directly funded activities such as enforcement and prosecution.
The waste management sector is highly regulated and compliant
businesses need to know they are not having to compete with non-compliant
or illegal activities. The Institution is happy to support short
term proposals to resource activities such as flytipping response
through a variety of "additional" sources (eg the landfill
tax funded BREW fund), but sees this as no substitute for proper
steady-state funding of these essential activities.
3. EFFECTIVENESS
The Agency faces a natural tension between centralised
and local service delivery, and between copious guidance / standardisation
and local pragmatism/flexibility. This industry depends on Agency
openness and consistency to allow fair competition. Where services
need a high degree of skill and specialism they should be centralised
as far as possible. The creation of Strategic Permitting Groups
has concentrated most PPC permitting into three teams and this
has undoubtedly helped the highly complex process of re-permitting
all landfill sites. Delays in preparation and issue of permits
is one of the most consistent criticisms of Agency performance
from our members—especially where this is done through localised
teams. Other complex tasks such as hazardous waste site audits
need similar expert teams, and this approach should be followed
wherever possible to support consistency. Localised service priorities
are inevitable given different circumstances in different areas
but a high degree of national standardisation and guidance is
clearly essential—one man's flexibility being another's
unfair competition. Training and preparation of Agency staff to
assimilate and use this guidance is essential, and CIWM would
like to see greater encouragement of staff to take up appropriate
professional institution membership with continuing professional
development.
The Agency also suffers from too many "generalist"
staff and not enough specialists. Some waste-related skills areas
such as landfill gas control have been left to dwindle.
4. RELATIONSHIPS
WITH STAKEHOLDERS
Generally the relationships between the Agency
and its stakeholders are good. There are examples of good practice
from the Landfill Directive Implementation Group, the Hazardous
Waste Forum and the Agricultural Waste Stakeholders Forum of which
the Agency are keen supporters. The dialogue at these groups with
the Agency has been open and constructive, some positive initiatives
including the development of guidance has resulted. Such a positive
dialogue and partnership development can only be improved by providing
the Agency with greater funding certainty.
5. EXECUTIVE
SUMMARY
The Institution has some positive experiences
from its dialogue with the Agency over recent years but wants
to see further improvement in:
— greater clarity in the strategic
policy role of the Agency including delivery of timely and comprehensive
guidance—and how this role will fit in with other organisations
in providing an integrated service to monitor and support sustainable
waste management strategy
— Long term and dependable funding
for non-chargeable activities—especially enforcement and
development work with partner organisations
— Development and retention of staff
with key specialist technical skills, and continuous development
for its staff.
Finally and most positively the Agency has done
a lot to communicate better with its stakeholders in waste management.
CIWM would like to see more of this supported by a greater certainty
of long term funding.
CIWM
December 2005
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