2 Problems in implementing the Waste
Management Strategy
6. The Government's Greening Government initiative
is a key theme in the Waste Management Strategy and is a means
by which Government can demonstrate leadership by improving its
own environmental performance. The Department has made little
progress in this area and has not even met its own in-house measures,
many of which have been put in place only recently.[7]
7. The results of the Department's waste audit have
provided it, for the first time, with a baseline assessment of
its own performance. This has resulted in an action plan, to be
used as a model by the other NI Departments, who are now committed
to producing their own waste management action plans by the end
of the current financial year. Although very belated, this is
an important first step towards aligning NI Departments' targets
and performance with those of their Whitehall counterparts.[8]
8. There are particular difficulties in dealing with
the serious problem of illegal dumping of waste from both sides
of the 370-kilometre border with the Republic of Ireland, not
least because of the involvement of organised crime and the huge
profits to be made by illegal operators. This situation has been
encouraged, in part, by the less stringent legal control framework
in NI, exacerbated by the past legislative delays, and a differential
in the tax regime.[9]
9. Compliance monitoring and enforcement of waste
legislation has suffered, until recently, from a shortage of suitably
qualified staff. Although the Department has now devoted an additional
£600,000 to enforcement, this compares poorly with the £2.5
million that it considers would be required to do the job properly.
Even this sum is outweighed by the estimated £5.6 million
lost to the exchequer through uncollected landfill tax as a result
of illegal dumping, up to March 2004.[10]
10. The case study highlighted in the C&AG's
Report is a shocking illustration of the illicit gains available
to those determined to trade in illegal waste. Because of the
clandestine nature of illegal dumping, and the wide variation
in types of illegal sites and in the waste they contain, its extent
is difficult to estimate. However, the Department confirmed that
it would not be unreasonable to estimate an average of £1
million per site in illegal profits, with around £24 million
going to the black economy annually from this source. This does
not take account of the environmental clean-up costs of illegal
sites which, because they are not properly engineered and managed,
are difficult to estimate.[11]
11. Tackling illegal dumpers is often a hazardous
operation for investigation staff. Consequently, the Department's
account of significant recent successes in shutting down illegal
sites and mounting stop-and-search operations with police is most
encouraging. Such operations must continue, and even increase,
if the Department is to achieve its new target of reducing illegal
waste to 1% of total waste arisings in the next ten years.[12]
12. Councils clearly have a key role to play in delivering
the Waste Management Strategy targets, especially by developing
and delivering their local waste management plans. The NI Landfill
Allowance Scheme provides for a £200 fine per tonne to be
paid by Councils who fail to comply with the landfill reduction
targets. In addition, non-compliance could risk an EU infraction
fine for the UK. The Department has made it crystal clear to Councils
that they would be liable for any fines levied. The bill for any
such fines would ultimately be payable by ratepayers.[13]
13. In 2001-2002, the waste management grant paid
by the Department to assist Councils in developing plans and acquiring
waste infrastructure included £1.3 million that constituted
payment in advance of need. The Department said that this resulted
partly from Councils' delay in implementing their plans and partly
from their invalid assurances that they would spend the money
within the financial year. This represents poor financial control
by the Department and occurred at a time when implementation of
the Waste Management Strategy was being hampered by under-resourcing
in other key areas, such as clearing the legislative backlog and
tackling illegal dumping.[14]
7 C&AG's Report, paras 3.2-3.5; Qq 8-9, 48 Back
8
C&AG's Report, paras 3.6-3.7; Qq 49-52 Back
9
C&AG's Report, paras 1.4, 1.6; Q5 Back
10
C&AG's Report, paras 1.4-1.6, 3.22-3.23; Qq 5, 54-57 Back
11
C&AG's Report, paras 3.26-3.27 and Figure 9; Qq 58-62 Back
12
C&AG's Report, paras 3.24-3.25; Qq 61, 64, 106 Back
13
C&AG's Report, paras 2.16, 2.19; Qq 31-37 Back
14
C&AG's Report, paras 2.29-2.30; Q 6 Back
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