Memorandum submitted by Land Network International
Ltd
Note: Land Network was started under a series
of DTI (Enterprise Initiative) programmes in the mid '90s. A national
Network of farmers within a "reverse franchise" currently
operate 17 on-farm composting sites recycling a range of municipal
and industrial "wastes".
1. We take the view that the Agency has
two jobs to do:
(i) Enforce the law, ie catch the bad guys.
In any society, this is fundamentally necessary and they do, at
least partly, a good job.
(ii) Enable good practice, ie help the good
guys. On the whole, they are a dismal, even criminal, waste of
national resources in this respect.
2. The Agency is restricted by two things:
(i) Its own structure, organisation and staffing
policies.
(ii) Bad regulation which it is charged with
enforcing.
3. Agency structure, organisation and staffing:
(i) A statistic will help understand why
the structure is flawed. There are 56 words in the Lord's Prayer,
229 in the 10 Commandments, and 35,709 in the eighth set of Notes
for Guidance from Agency Head Office to officers on the ground
(who, presumably, will have read the previous seven sets). The
officer is a general practitioner who may have over a hundred
different technologies on their patch. It is not possible for
them to read all the paperwork coming out of Head Office. It is
not possible, however well qualified and experienced they are
(some are well on both, most are not), they can never have a "feel"
for a situation on the ground.
Result: Bad judgements that cost too much
and take too long.
(ii) Putting a situation into "Process"
of a series of internal consultations with officers who may be
specialist (and may not) suffers from the inevitable bad decisions
(because the staff concerned do not visit the site or meet the
people, they exercise remote judgements).
Result: Bad judgements that cost too much
and take too long.
(iii) I have spent 10 years and, in real
terms, probably several hundred thousand pounds Sterling, in training
officers to understand just a little about what I do. They are
all inexperienced in recycling, not trained adequately and do
not have a culture of enablement. Result: The original plan
for the DTI was that we would, by now, have around 3,000 farms,
each handling 2,000 to 4,000 tonnes pa on a proximity basis. We
have been delayed and failed because of over-regulation. We have
17 operational sites, some fully Licensed, and will handle 300,000
tonnes plus by the end of the current year to March 2006. That
is not enormous but it isn't trivial. We have never polluted.
(iv) The Agency's idea of efficiency is to
introduce a call centre (very fashionable—it would be lower
cost and probably no worse in time wasting if it were in India),
or (much worse) to have Planning Liaison Officers who just create
problems. Both are just another layer of bureaucracy that costs
money and makes everyone frustrated and uncompetitive.
4. Bad Regulations:
To be fair to the Agency, its statutory duty
is to enforce the Law. Some of the regulations are just wrong
and counter productive. I will quote here a statement from a senior
officer who has my respect. "As we have discussed before,
we both know that there are many more wastes which are capable
of conferring agricultural benefit is spread than are currently
listed in the exemption. However, we have to work within the constraints
of the legislation as it stands."
Result: I could give you literally hundreds
of instances where the legislation and the Agency's interpretation
of it inhibits safe and sensible recycling.
5. Conclusions:
(i) The Agency has a passable performance
in policing, but not good.
(ii) The Agency fails miserably, even criminally,
in enabling those who are capable.
(iii) The consequences for targets, the environment,
the economy and individuals are moving towards the catastrophic.
6. Remedy:
(i) Cut the staff by at least a third. Specialise
the field staff.
(ii) Train the staff to be comparable or
better than the industries they serve in, pay them at least a
third more and empower them to make decisions on their own, quickly.
(iii) Use the skills already present in industry
in self-regulation coupled to loss of licence to operate for those
who break the rules and pollute. (We have a scheme which operates
like a road driver's licence.)
Then, with the right leadership, we can do this
job safely, to volume target and sustainably, environmentally
and economically.
Land Network International Ltd
January 2006
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