Examination of Witnesses (Questions 1-58)
Q1 Chair: May I welcome
you very much indeed? Thank you very much for being with us.
This is our first evidence session on the Hazardous Waste National
Policy Statement inquiry. We are required to look into this as
the Select Committee responsible under the Planning Act. We are
delighted that you are with us to participate and we thank you
in advance. Perhaps, you could introduce yourselves, from left
to right, for the record.
Gill Weeks: My
name is Gill Weeks. I am Regulatory Affairs Director for Veolia
Environmental Services. I have been with Veolia and its predecessor,
Cleanaway, for 25 years; I was a member of the Hazardous
Waste Forum when they were drawing up their action plan in 2003;
I chaired the Treatment and Capacity subgroup for the Hazardous
Waste Forum. Currently I'm on the Defra Hazardous Waste Steering
Group and Chair of the ESA Hazardous Waste Committee.
Matthew Farrow:
Good afternoon. I cannot quite match that I am afraid. Matthew
Farrow, Director of Policy at the Environmental Services Association,
which is the trade association for the waste management sector,
so many of the firms which deal with and treat hazardous waste
are members of ESA.
Dr Wilson: My name
is Dr Gene Wilson. I'm Group Technical Director of Augean plc.
We are a specialist hazardous waste management company working
throughout the UK. My expertise is in planning and, obviously,
hazardous waste. I am responsible for environmental permitting
and planning issues in my business. I have a background, prior
to Augean, of being in consultancy, running a planning and permitting
team in that consultancy, over 18 years, on waste treatment.
Q2 Chair: From
where you sit, what difference do you think the National Policy
Statement will make?
Matthew Farrow:
Perhaps I can kick off, Madam Chairman. Broadly, we are supportive
of the National Policy Statement. We support the Government's
hazardous waste management strategy and we agree with the assessment
in the NPS, in broad terms, of the need for new facilities. Given
that these are significant economic commitments for companies
to make, it is important to them that they have some confidence
in the IPC process and its successor process. Overall, we feel
that the NPS sets out the need appropriately. We have some caveats
around the detail, which I will come to, but we think it will
give some confidence to companies considering investing in this
market.
The one additional point I would make at the
outset is that, while the strategy itself and the NPS say all
the right things in terms of saying that, as a country, we want
to see hazardous waste dealt with in the best possible way—and
we expect the industry to come forward with those proposals—from
the industry's point of view, the one concern they have is whether
the enforcement of the new regulations around hazardous waste
will be sufficiently strong to make sure that topend, highquality
facilities, which ESA members might want to build, are going to
earn a return on investment. We have some concerns that, if enforcement
is not strong enough, suboptimal treatment will stay in
the market for a long time. I am happy to return to that issue
if the Committee wishes.
Q3 Chair: Do you
envisage any difficulties with the fact that the policy is being
set by one Department, Defra, but the planning is being implemented
by another, Communities and Local Government?
Dr Wilson: I wouldn't
think so, because these are not new policies; they are drawn from
the existing policy framework, through the PPSs and the other
policies that have been in place for a long time. One of the
exercises that we did when we examined the NPS was to look at
how it fitted with current policy. Certainly, on all the environmental
assessment parts and from my knowledge of PPS10, which is the
main waste policy, it is consistent with that, so I do not see
a problem with the fact that it has been derived from Defra as
opposed to DCLG.
Q4 Chair: In your
written evidence, you largely welcome the introduction of an NPS,
and you refer to long delays in obtaining planning permission
as being a significant barrier to delivering new waste management
infrastructure. Are you able to give us any specific examples
of applications for such facilities, which have suffered from
what you would deem to be unreasonably long delays?
Matthew Farrow:
In terms of hazardous waste specifically, I do not know if my
colleagues, Gene or Gill, can give an example.
Dr Wilson: There
has always been an issue with planning and potential delay. Some
applications go through efficiently, but others can be subject
to extensive delays, in the appeal system in particular. Once
an application has to go through the appeal system, it can be
at least 12 months before a decision is made and that, given
the investment that is being made in the process and the fact
that you are not able to implement that facility in the timescale,
affects the ability to deliver high standards of hazardous waste
treatment and management.
Gill Weeks: One
of the reasons we did not jump in with a specific example is because
there has not actually been any major hazardous waste infrastructure
built for a number of years, because we have been waiting for
the strategy and everything to drive it forwards. While there
have been some smaller developments, there has not actually been
any major piece of kit built in the UK for some time.
Q5 Chair: If any did
spring to mind, you would be very welcome to write to us with
specific examples. Just looking at the fact that probably many
have waited until the new regime is in place, would you say it
is looking at appropriate locations, more in an industrial area
rather than a residential area, and also getting in at the ground
level with, say, parish councils at the earliest possible stage?
Do you believe that that helps facilitate planning and commissioning?
Matthew Farrow:
In terms of the developers making those approaches, yes. We obviously
believe that it is in the developer's interest to be as open as
they can be about the applications they are making. Again, if
colleagues have any examples, they might want to refer to the
sort of things we do.
Gill Weeks: My
company built a hazardous waste incinerator in the North West
quite a few years ago. There was extensive liaison with the local
community about the siting of the facility, and we set up a liaison
group at the very beginning, before the actual building works
were carried out. We found that very, very useful. What is set
out in the NPS, largely, we would all agree with in terms of consultation.
I know Gene has some particular concerns in some areas to do
with perception, which I am sure he will pick up on, but generally
where they would be sited would be appropriate to the type of
facility you would be building.
Dr Wilson: I think,
certainly within those companies that have been in the sector
for some time, there is a mature attitude towards selection of
location. There is an understanding that some locations are going
to be less suitable than others. We are very careful about where
we choose to put our sites. Notwithstanding that, it is also
extremely important and a standard part of the sector's approach
to new applications to undertake extensive consultation with the
communities, the parish councils and so on. That is an ongoing
process. Really, the majority of the major companies are already
doing what is set out in the NPS in terms of consultation.
Q6 Chair: Just
reverting to the answer you gave that not many major facilities
have been put forward for planning permission, is there a possibility
that developers will submit applications for larger facilities
than they might otherwise have done, under the thresholds for
nationally significant infrastructure projects, just to bring
their applications within the provisions of the Planning Act and
benefit from the more streamlined planning application process
under the NPS?
Gill Weeks: I think
Gene will probably supplement my answer to this, but really only
two groups are caught under the Hazardous Waste NPS. They are
the 100,000tonneayear for hazardous waste landfill
or deep storage, and 30,000tonne for other treatment facilities.
Now, that 30,000tonne threshold I know is in the Act, but
it is quite a low threshold that could catch a number of facilities,
in particular something like a soil treatment plant. Would people
go above or below? It would depend on the facility but, yes,
I could see some people saying, 'We will try to creep under, rather
than go for a bigger facility.' Although this is more streamlined,
there is an awful lot of work upfront with this type of application.
You have to do all your consultations. Again, I think Gene will
supplement this, but you have to do a lot of consultation, a lot
of work, a lot of environmental assessment before you actually
submit the application, so that might put people off if they think
they can get it through local planning, if it is not too contentious.
Dr Wilson: I would
agree with Gill, particularly when you get to the sub50,000ayear
facilities. Operators would be very tempted to seek to put those
facilities out of the IPC system. The IPC system is costly; it
is not cheaper than going straight through the Town and Country
Planning system, particularly if you do not have to go to appeal.
The IPC system guarantees, essentially, that you go through some
inquiry process, essentially a hearing process, which is always
expensive. There are costs put out in one of the annexes of the
NPS document. Those costs essentially relate to the fees. They
do not relate to the costs to the applicant in terms of preparing
for that process, and those costs are quite substantial.
Q7 Chair: It is
difficult without breaching confidentiality—are you able
to say what the average costs would be of even preparing that?
Dr Wilson: I can
say that the overall costs for, say, a relatively small facility
such as a soil washing plant are potentially between about 6 and
16 times more than getting a straight decision from a planning
authority. That assumes you do not have to go to appeal. Once
you go to appeal, the costs will probably be similar. Clearly,
if you have a good chance of getting an application through a
planning authority, you would prefer to do that, given that the
costs are very substantially different. If you took a soil treatment
plant, which is a lowcost lowvalue plant, it actually
could cost about 46% to 100% of the cost of the plant to get the
permissions in place, once you have gone through all the process
and got your permits as well. This is a really significant element
for perhaps small to medium enterprises that are investing in
this sector.
Q8 Chair: That
is helpful. Are you concerned that the NPS, we understand, will
apply only to England? Is that correct? It will not apply to
the devolved Administrations. Is there a danger that developers
will either gravitate towards sites in England or towards sites
in the devolved Administrations, resulting in a disproportionate
number either side of an arbitrary border? Have you formed a
view on that?
Matthew Farrow:
Again, I ask colleagues to come in on that. Clearly the legal
situation is that the NPS applies to England. I think we see
the market as a UK one, and again I might touch on selfsufficiency
as a country at a later point. Whether there would be any arbitrary
effect on borders—
Gill Weeks: I do
not think so. Generally speaking, most of the facilities where
hazardous waste arises tend to be in England and most of the current
hazardous waste facilities are in England, so I do not think that
is going to make any difference.
Matthew Farrow:
I would have thought that the economics of the site would probably
be the key factor, as opposed to which side of the divide it falls.
Q9 Dan Rogerson:
Good afternoon to you all. In the evidence from ESA, you raise
this issue about existing facilities that are looking for an extension
on their lifetime. Do you think it would be preferable for facilities
that are above the threshold, where permissions and impairments
were granted under the previous regime, now to be covered by this
NPS?
Matthew Farrow:
By the new system. I think we have a concern about that, don't
we, that it might be disproportionate in terms of extension of
the existing facility?
Dr Wilson: The
extension relating to a treatment facility would be based on capacity.
Again, the same comments apply as those made on initial capacity
for treatment facilities. On landfills, we feel it is odd that
the implication is that you would have to increase the capacity—how
much waste comes in through the gate—before it came under
the IPC, whereas a void extension, is probably far more contentious
and of far greater significance to provision of the national requirements
for hazardous disposal, and is potentially not caught. We think
that actually the Planning Act is ambiguous in the way that it
is set out and what the NPS could do is perhaps give some clarification
to exactly what is meant. It is ESA's view that it should apply
to void extensions. It obviously does not say that in the regulations,
so that cannot be changed at this time, but that is the position.
Q10 Dan Rogerson:
The second issue around definitions and the sort of thing that
you were discussing there is about whether the threshold is triggered
by the amount of waste that is handled at the site or the hazardous
part of that waste. The Chartered Institution of Water and Environmental
Management (CIWEM) raised the extreme example of a steel ship—a
very weighty item—and the fact that a small percentage of
its overall mass would be hazardous waste. What is your response
to those kinds of questions? What is your view on that?
Gill Weeks: That
was an extreme example but it does happen. The policy just needs
to be clear. We do not want to have debates and people in a position
where they do not know where they fit. We have always asked for
clarity in legislation and guidance. If it is the intention that
decommissioning oil rigs, ships or whatever should be in IPC,
then that should be clear. I do not have a particular view about
whether it should or should not be in; I just think it needs to
be absolutely clear, otherwise we are just going to be arguing
with local authorities about whether it comes to them or goes
to the IPC. It just wastes time.
Q11 Dan Rogerson:
Just picking up on something you were saying earlier on about
SMEs. In my constituency there is a family company that has taken
on a lot of construction waste, which would have gone to landfill
years ago, and they are now recycling it. From what you were
saying there, you think there may be big problems for them if
their business expands the tonnage that they cover. If they extend
the footprint of their organisation, that might bring them within
these sorts of provisions. Is that something that is of concern
to you, where larger bodies cooperate perhaps with SMEs to do
particular specialist work? Can you foresee that being a problem?
Dr Wilson: I am
not entirely clear about the question.
Gill Weeks: If
it is a construction company, then a large part of what they are
handling will be nonhazardous. What they might need to
do is just really look at how their site is permitted. They should
talk to the Environment Agency. It is probably simply a case
of better segregating their waste, so that they have a small amount
of hazardous waste and the rest of their material is nonhazardous,
and the permit reflects that. Something like a construction company
would be unlikely to go over the threshold, unless they were going
into soil treatment.
Q12 Dan Rogerson:
I was thinking more of the companies that handle and recycle stuff
from construction sites, rather than construction companies themselves,
and whether this would make life harder, as we often hear it does
for smaller companies, than it would for bigger organisations
that have teams of people who are able to propose multiple facilities
around the country, and therefore have specialist teams to do
it. Is that an issue for them?
Dr Wilson: For
those companies, this will not make it worse than it already is.
They would get the expertise from consultancies and so on. Where
we would be concerned is whether the costs are proportionate to
the facility.
Q13 Neil Parish:
Good afternoon. Do you agree with Defra's assessment of the need
for specific types of national significant hazardous waste infrastructure?
At the moment, they have waste electrical, oil regeneration,
treatment plant for air pollution, thermal desorption, bioremediation,
which is soil washing, and ship recycling. Do you agree with
those and do you think there are some types of waste that have
not been included in the NPS?
Matthew Farrow:
Broadly, yes, we think the assessment of need is broadly appropriate.
Some of the data—I think we mention this in our submission—are
a couple of years out of date. It would be prudent, I would have
thought, that they continue to review the latest data. There
is always the potential for new technologies to come along. Obviously,
part of our role as the industry is to be innovative. We do not
want anything that would stifle that innovation. In broad terms,
we do think it is about right, but I do not know, Gill, if you
want to add anything?
Gill Weeks: I think
you have pretty much covered it there, but things will always
come along that we have not thought about, or that were not thought
about at the time when the NPS was coming along. One of the issues
raised in the Chartered Institution of Wastes Management (CIWM)
evidence talked about the need to look at lithium batteries.
When these hybrid cars that have just gone on the road, and hybrid
vehicles, start to come to the end of their lives and are being
dismantled, we need facilities to deal with those very large,
heavy lithium batteries. Whether it will go over the threshold
of 30,000 tonnes, I perhaps doubt, but those are the kinds of
facilities that might come.
Also, the statement of need, as Matthew said, is
based on the data that we produced earlier. We need to look at
that again and we also perhaps need to revisit the work that was
done for the Hazardous Waste Forum on the Treatment and Capacity
sub-group, so that we have very uptodate information
on both what has actually been built in the interim years and
what is in the planning stage, so that we know what is coming
on line. One of the problems is that the hazardous waste market
is quite diverse. Several companies are involved and obviously
there are commercial considerations, so what is coming on line
is not always broadcast. We need to get a feel for that across
the country.
Matthew Farrow:
If I might add to that, one of the reasons why it is important
to keep reviewing the data is that the overall balance of the
economy and economic health has an impact here. We have a Government
that is talking about rebalancing the economy and trying to promote
manufacturing process industries. We feel, and certainly hear
from our clients in those industries, that it is important to
them in thinking about the UK as an investment location that there
is a strong, modern, appropriate hazardous waste network able
to deal with the waste that they produce. There is an issue here:
as the economy goes forward, hopefully we will see a renaissance
of the process industries and manufacturing. It is important
that our industry is enabled and has the right framework to meet
the needs of those companies.
Q14 Neil Parish:
Linked to that, but slightly going back to Dan Rogerson's
questioning, is that the NPS talks an awful lot about tonnage
of waste. Surely it depends on the concentration of the amount
of hazardous waste within that tonnage. Surely you could still
have a nationally significant amount that was much smaller, but
of very concentrated waste. Does it cover that enough, do you
think?
Gill Weeks: One
of the things that perhaps we should have said from the outset,
which I am sure you have picked up from the papers, is that this
is quite a different NPS from most of the others that you are
looking at. If you are going to build an airport, put a new rail
line in, underground gas storage or whatever, hazardous waste
is not a single thing; it is a lot of different things, as you
have just signalled. It could be a small amount of something
very, very hazardous or a large amount of something not very hazardous,
and all things in between. It can be solid; it can be liquid;
it can be gas; it can be a mixture. That is why I think this
NPS has to be a little bit more generic than perhaps some of the
others.
Hazardous waste in itself has a legal definition,
and it is not defined by how hazardous it is. It either is hazardous
or it is not. You could have a tonne of soil, which has very
low levels of, say, lead or zinc or something in it, which would
mean that it was hazardous because that level of contamination
was above a threshold. Then you might have a jar of arsenic or
something, which would also be hazardous. It does not take account
of the difference because the hazardous waste legislation does
not take account of that. It either is or is not hazardous, and
that really is a matter of fact between the producer and the Environment
Agency if there is a dispute.
Q15 Chair: Can
I just ask, when the list of hazardous waste is amended, what
is the lead time for the industry to adapt to the change?
Gill Weeks: When
the hazardous waste list is changed, there are usually two years,
something like that, I think it is. It would be a couple of years.
Chair: That allows you,
as an industry, enough time.
Gill Weeks: You
have a little bit more notice, because you see it being debated
in Europe, so you see the proposals for change going to the Technical
Adaptation Committee in Brussels, so you see, "Oh, they're
looking to drop the level on zinc," and then you run round
and say, "Is that going to affect the types of waste we handle
or not?" Then it goes through quite a lengthy debate in
Brussels, before it actually comes through, and then it has to
be brought into the UK legislation. Although I might say it is
a couple of years from when the legislation is formed in the UK,
you have actually seen it coming some time previous to that.
So, yes, you have time.
Dr Wilson: The
sector is very closely aligned and obviously very much driven
by regulation, so it keeps a very strong eye on what is actually
happening and how things are changing. It also works very closely
with the Environment Agency, so the Environment Agency would consult
us about how easy it would be to implement changes. That may
have an effect when it is implemented, but it also affects how
they approach the issue in the, say, first 12 months. They
would take a lighter approach initially while we are adapting
to a change. It is a wellworked system in terms of changing
and adapting to regulatory change.
Q16 Neil Parish:
Do you agree that there is a need for hazardous waste landfill
to be included in the NPS, despite the fact that Defra's hazardous
waste strategy stated existing landfill facilities appear to be
adequate?
Matthew Farrow:
In terms of new facilities?
Neil Parish: Yes. Are
they particularly desirable?
Matthew Farrow:
I think the options need to be kept open because things are hard
to predict. Two points, I suppose: the first is the NPS rightly
says this should be a marketled system. As Gill was saying,
it is a very varied, complex market, and it is difficult to predict
future needs precisely. The other point worth making is that,
while we are all very familiar these days with the waste hierarchy—and
I think quite rightly, for the more general waste stream, household
waste streams—all of us in the industry, yourselves as politicians,
householders, want to see everything as high up the hierarchy
as possible. While that remains true for hazardous waste, the
public also expects us as an industry to deal with it completely
safely. There are some hazardous wastes, again colleagues can
give you examples, no doubt, where safe disposal and destruction
of the hazardous material is the best environmental option. While,
where we can as an industry, we will look for ways to recover
some value or some material and push it up the hierarchy, hazardous
waste has to be thought about slightly differently. The absolute
priority must be safe disposal, where that is the right course.
I do not know if colleagues want to add anything.
Dr Wilson: I want
to add something. There is no doubt that there will be an ongoing
need for hazardous landfill. Yes, as we stand, there is probably
sufficient capacity, but what the NPS also mentions is, of course,
that some of those planning permissions will run out with time.
Unlike a treatment facility where, once you have a permission,
it is there forever, landfill is always a temporary use. All
landfill permissions will have a maximum life of probably 15 years.
We have only eight hazardous landfill sites that accept a wide
range of wastes. There are a number of others, but those are
the key sites, and I would say at least five of those will probably
run out of time, in terms of their planning permission, in the
next five years. We would expect them all to seek an extension
of time or a need for a replacement site. While the rate at which
waste going into hazardous landfill might slow down, for the foreseeable
future there will be a need to continue to put waste in.
Q17 Neil Parish:
The Government's strategy on general waste is to put a higher
and higher tax on landfill. We are talking about £80, I
think, by 2015, per tonne, on landfill. Wouldn't the argument
go that the more difficult you make it to get landfill hazardous
waste sites, the more you drive the industry to recycle more of
that hazardous waste? That is what worries me if we make it too
easy to go for a landfill hazardous waste site.
Gill Weeks: I understand
the logic there but, as we have just said, there are certain waste
streams for which hazardous landfill is the best environmental
option.
Q18 Neil Parish:
Can I just press you on that point? Is it the best option or
is it the cheapest option?
Gill Weeks: No,
it is the best environmental option. The classic example is asbestos.
There is very little you can do with waste asbestos. It is particularly
hazardous, as everybody knows; it needs to be dealt with properly.
You can solidify it. You can vitrify it and put it in glass,
which is very expensive, but the best solution is to put it in
landfill. Again, hightemperature incineration is regarded
as disposal, but there are certain chemical wastes that are produced
by the pharmaceutical sector that have to be destroyed. It is
no good looking at recovery. One of the waste streams that my
company handles is a byproduct of Teflon, the nonstick
element of your frying pans, but the material itself is very hazardous
and has to be destroyed for the environmental benefits. That
is a very important point; we are looking at environmental benefit.
Yes, landfill is the last resort, but it is the only resort for
a limited range of materials. Then all treatment plants produce
some residue at the end, which has to be disposed of. So, even
for nonhazardous waste, we will always need landfill for
a fraction of it, and the same with hazardous waste.
Q19 Neil Parish:
You pay the tax, do you, as well?
Gill Weeks: On
the landfill, yes absolutely. It's the same.
Neil Parish: The same
rate?
Gill Weeks: Yes.
Q20 Chair: In
terms of the landfill facility being renewed, will the renewal
be under the old rule, because it will not breach if there is
no change?
Dr Wilson: As the
legislation is drafted, it suggests that the renewal would fall
outside of the IPC regime.
Q21 Mrs Glindon:
Just moving on from that and talking about the landfill sites,
Defra actually states in the NPS that operators may not decide
to seek renewal of planning permission for existing hazardous
waste landfill sites. Do you think this is likely?
Dr Wilson: It is
very possible, because it would be dependent on the constraints
of the site. Some may be entirely limited by land ownership or
geological circumstances. Ultimately, there will be a limit on
how much you can extend a site. At some point, the operator will
have to say, "I can't renew here. We need a new site."
Q22 Mrs Glindon:
If there was a possibility, do you think there would be renewals
of existing sites?
Dr Wilson: It is
generally easier to get an extension of permission than it is
to get a new site. Operators will generally go for a renewal
rather than a brand new site.
Q23 Mrs Glindon:
Thank you. I want to ask about lithium batteries, because the
Chartered Institution of Waste Management has suggested that there
will be a need for an Nationally Significant Infrastructure Projects
(NSIP) facility for recycling lithium batteries, which could come
about in seven to eight years, because of the increase in hybrid
cars—the increasing popularity of these cars. Do you agree
with this assessment that that will happen in the next seven to
eight years?
Matthew Farrow:
I think Gill touched on this before. We think it is a reasonable
point to make. It is very hard to predict absolute numbers and
so on, but clearly there is this big movement towards electric
vehicles, if you look at the Committee on Climate Change work
around climate change mitigation and the focus on that sort of
technology. We think it is a reasonable point to make.
Gill Weeks: Whether
it will come under IPC or not will depend—if hybrid cars
reach a level such that more than 30,000 tonnes are being scrapped
every year, then yes, it would be realistic.
Q24 Mrs Glindon:
Specific sites would be developed as such to deal with them?
Gill Weeks: The
UK would need to have facilities, ideally, for dealing with those.
Otherwise we would have to export them to another European country
for them to deal with them. These endoflife vehicles
will have to be dealt with somehow.
Q25 Chair: You
mentioned earlier the size of the lithium battery. How big are
they?
Gill Weeks: I'm
not an expert on that, but my understanding is that they are about
the size of your boot, are they not?
Matthew Farrow:
They are pretty big, yes.
Chair: Are they substantially
bigger, just to give us an idea?
Matthew Farrow:
Yes, they are bigger than traditional car batteries, much bigger.
Q26 Chair: In
terms of transporting them abroad, it would be some substantial
cost, if we did not have the solutions here as well?
Gill Weeks: The
NPS mentions selfsufficiency. There is, not necessarily
a regulation as such, but a desire for the UK to be selfsufficient
in waste management.
Matthew Farrow:
That is an important point, because the details of the NPS, where
it touches on selfsufficiency in two or three different
sections, is slightly unclear in one or two cases. As Gill says,
the general flavour from the wording is that the Government sees
it as a desirable, if we can move as close to selfsufficiency
as we reasonably can, but the wording slightly varies about disposal
facilities. We would feel as an industry, not surprisingly perhaps,
but I think the public probably would share the view, that unlike
general waste, for hazardous waste it is right and proper for
the UK to deal with that within its own borders—both, without
overdoing it, from a moral point of view and from that of transport
and the risk of accidents through longdistance transport
of hazardous waste and so forth. The NPS could possibly be slightly
tighter and clearer on making that point.
Q27 Chair: Would
that go for—well, I call them ghost ships? I have forgotten
what the correct term is, but I mean ship recycling. Would you
say that goes for ship recycling as much as for batteries?
Gill Weeks: Nobody
here on this panel is an expert on ship recycling, but I guess
that is very, very specialised and that you have to weigh up the
employment side against the fact that you might be dismantling
somebody else's ships.
Chair: I think that we
have the technology.
Gill Weeks: We
have the technology and it is employment for the UK. Whereas
we had ship building, now we can have ship dismantling.
Chair: We will not go
there.
Matthew Farrow:
We can't quite say "progress".
Q28 Richard Drax:
Good afternoon. The ESA's written evidence did not specifically
address new technologies. Does the NPS provide sufficient flexibility
to accommodate new technologies that may emerge in the future?
If not, how could the NPS be improved to provide this flexibility?
Matthew Farrow:
Overall, we think it is reasonably clear in the NPS that the technologies
they talk about are not an absolute list that is fixed. Whether
we would actually want some stronger wording on that—I am
not sure we would, to be honest. As it stands, it is flexible
enough.
Q29 Richard Drax:
It is, okay. Do you consider Part 4 of the draft NPS clearly
sets out the assessment principles that the IPC will use to assess
applications?
Matthew Farrow:
We have one or two specific caveats about those, which I think
were referred to in the evidence, about things like wholelife
costing. The bulk of the criteria set out are appropriate, but
we wonder whether one or two—if you like, we could perhaps
touch on the wholelife costing issue—would lead to
more complication, cost and trouble all round than it is worth.
Dr Wilson: We would
question the merits of that to the overall planning decision.
We are not really quite sure what the purpose of it is and we
are certainly not sure about what is intended to be produced.
There are one or two points in the NPS where it is suggested
we should do a certain assessment, but no guidance as to how that
assessment should then be undertaken. We are concerned about
this creating new industry, as has happened in the past, unfortunately,
with planning guidance. Yes, on wholelife costing, we would
like to understand a lot more about what that actually entails
and we would question whether it was necessary. As Matthew has
just stated, we are happy with the broad assessment criteria.
I have had people consider the appropriateness in their particular
areas of expertise, and they are generally consistent with what
you would expect from current Government planning policy. There
is nothing there that either concerns us or is unexpected.
Q30 Neil Parish:
The CIWEM comments that the NPS has "done little to improve
the really difficult grey area between planning and environmental
permitting". Does the NPS clearly set out the distinction
between the operation of planning and pollution control regimes?
Matthew Farrow:
We were discussing this earlier.
Dr Wilson: If I
may explain the grey area. The grey area is really about planning
authorities and Environment Agency officers understanding what
their role is, in my view and my personal experience. I believe
that the planning system has clearly set out the requirements
for dealing with land use consequences and that the permitting
system is clear about pollution control. There is planning guidance
on pollution control and there is planning guidance about how
the two regimes interface. There is clearly an overlap between
the two. The NPS says exactly what I would expect it to say in
terms of planning policy and also makes clear that there should
not be duplication, which is one of the major concerns of industry:
that it does not have to be regulated by two people for the same
issue twice. Our view is that it is really a training issue for
the Environment Agency and the planning authorities, rather than
a concern that the NPS or any other planning policy has not made
it clear on many occasions exactly how the interface works.
Q31 Neil Parish:
If you were going to build a house in a floodplain with a one
in 100 years chance of flooding, the planning authority could
decide to overrule the Environment Agency if they object. Surely
in a case of hazardous waste, I would have thought it would be
very difficult, would it not, for a planning authority to take
that same line, because they are not the professionals who are
dealing with the pollution side of it? How does it work? Can
the Environment Agency actually block an application? Have they
got those powers or are they a statutory consultee?
Dr Wilson: The
Environment Agency is a statutory consultee to the planning system.
They cannot overrule the planning authority. I do not know whether
they could challenge them in the courts; I am sure they could
but I have not seen that happen. It is quite clear: the planning
authority makes a decision about land use. It takes advice from
the Environment Agency, and planning policy and the NPS require
that the decisionmaker, rather than planning authority,
should take account of that advice. I think that is right and
proper. There could be circumstances where they may go against
that advice, but we must not also forget that, a hazardous waste
infrastructure, as it is being dealt with in this Select Committee,
would be subject to a permit. If the Environment Agency will
not issue a permit, there is really no point having planning permission.
Q32 Chair: Are
you happy with the provisions as set out in the National Policy
Statement, as regards building—they call it 'flood zone'?
Do you believe that is a robust enough test, the sequential test?
Dr Wilson: The
sequential test is set out in floodplain policy PPS25, so the
NPS could not go any further than that which is already set in
policy. It is appropriate and there are circumstances where that
policy may be overridden.
Q33 Chair: Is
that because they have to be sited near water?
Dr Wilson: Yes,
some facilities would be sited near water. That does not mean
they necessarily have to be sited in a floodplain. There are
locations that you would choose. Frankly, I would be surprised
if this sector made applications in a floodplain, unless there
was a very good reason. It does not have a good experience of
floodplains.
Q34 Neil Parish:
I was really just giving that as an example. You were basically
saying that a site could be granted planning permission but, if
the Environment Agency did not think the environmental controls
were right in that particular instance, they would not issue a
permit so that could not be used, irrespective of whether it had
planning permission.
Dr Wilson: Absolutely.
Q35 Dan Rogerson:
The IPC has suggested that applications for environmental permits
and other necessary consents should be made before the application
for development. Do you agree that this would be a more sensible
approach than making separate applications concurrently? Going
back to the Planning Bill—I served on the Committee when
this went through back in 2008—there was a view from some
companies that you do not really want them going alongside, because
you are spending both lots of money at the same time. If one
of them goes, you have wasted it. What is the best approach?
Matthew Farrow:
You have to have both, of course.
Dr Wilson: The
ESA position—this issue has come up many, many times, and
you have identified at least one—is that it is horses for
courses. It depends on the circumstances as to whether you should:
a) resolve your permitting issues before; b) resolve them during
or; c) even wait until after you have planning permission. To
a degree, it depends on what the key issues are relating to development.
If pollution control is the absolute key issue, you may want
to get that resolved early on. In any circumstances, you would
get it resolved in terms of principles and that the Environment
Agency is satisfied that they would be able to issue a permit.
It is foolish to make a planning application without having that
confirmation.
Dan Rogerson: So a preapplication
option.
Dr Wilson: Absolutely.
The other thing to be aware of is that, for many waste facilities,
the Agency is unable to issue a permit until planning permission
is in place.
Q36 Dan Rogerson:
An alternative suggestion, a very different one put forward by
the Chartered Institution of Water and Environmental Management,
is that you would merge the two processes and have one common
process. What do you think about that, if that happens, and that
the NSIP should cover that?
Matthew Farrow:
Just for the larger installations?
Dan Rogerson: Absolutely,
yes, for the ones that would be covered by the IPC.
Matthew Farrow:
My instinct is that it would be difficult to do it. It is a nice
idea, hard to do in practice.
Dr Wilson: I would
think the fundamental difficulty is that you have two regulatory
systems that you are trying to tie together. That would make
it very difficult. I am sure it is possible, but I cannot particularly
see great benefits from it. We have a system that works in a
way and is satisfactory in that respect.
Matthew Farrow:
They are trying to do two different things—planning and
pollution control.
Dr Wilson: That
is because of the way that we define planning and pollution control.
Dan Rogerson: Again going
back to the passage of the Bill, in certain other areas, they
thought it would be more possible to combine other aspects of
infrastructure, with separate permitting agreements, because planning
was covered by different Acts for, say, transport, electrical
issues, some of the road supply issues and all those kinds of
things. It is a different situation.
Q37 Chair: The
IPC itself has raised some questions about the terminology used.
Do you think that the NPS, in its draft form, should be more
consistent and use more defined, carefully crafted terminology
in describing the relationship between the IPC and other relevant
bodies for this purpose, such as the Environment Agency? It says
"liaise", "consult", " to seek advice"
and "cooperate". Are you exercised by this at all?
Matthew Farrow:
I do not think it came out in our initial work on the NPS with
the companies. Looking at the IPC submission, they seem to make
a reasonable case. Obviously they are the body; in a sense, this
is partly aimed at them, partly at the industry and the public.
In principle, the Government ought to take their points into
account.
Dr Wilson: I have
not gone back to look at the context of each of those individual
points, but I certainly think it does need to be consistent, unless
there is a context in which it is worthwhile to use a different
terminology. Otherwise, it will become confusing, because people
will assume that it has been phrased differently for a reason.
When you have been to a planning inquiry and you are mulling
over policy, those are the sorts of things you can spend many
hours on, so consistency is very helpful.
Q38 Mrs Glindon:
You have expressed concern about the requirement for applicants
to carry out an assessment of community anxiety and stress in
relation to the impact on health. Do you think that this requirement
should simply be removed from the National Policy Statement or
do you accept that it is necessary, but there is a need for clear
Government guidance on undertaking such an assessment?
Matthew Farrow:
I think both would be options, to be honest. We recognise as
an industry that, as the NPS says, these sorts of facilities often
cause concern among communities, and so our member companies look
to explain how the site will operate and the technology. Again,
we can go into examples and details of all the classic ways that
tends to be done, through open days and so forth. The principal
concern we had about that section of the NPS, which is only a
couple of lines but is almost a throwaway section, is that it
is very unclear exactly what the company is expected to do—what
sort of assessment, what sort of ways it could seek to allay anxiety
and stress that was seen to be there. Either removing it or,
if it stays, giving much clearer guidance as to what exactly companies
would be expected to do—that was our position. Again, Gene,
I know you have thought about this a bit.
Dr Wilson: It is
part of the perception issue. Hazardous waste, among a number
of other types of development, nuclear power and so on, all have
a major problem with perception of what the impacts are, rather
than with the actual impacts. As you probably know, perception
is a material planning consideration if it is objective and if
it has landuse consequences—all quite difficult things
to assess. That is what is in current planning policy. The introduction
of an assessment of stress and anxiety is not in any other current
guidance that I am aware of. There is no guidance on how you
would deal with that. I think that, given that if you are serious
about putting in hazardous waste facilities, you will make sure
that they are technically appropriate, that they are in the right
location and that they meet policy, perception is essentially
your biggest issue. I believe that it should be given considerably
more consideration in the NPS, also given the fact that it is
a factor that has been discussed and addressed at many planning
inquiries now, so there is a wealth of experience of dealing with
it. It is appropriate that the NPS should actually give some
guidance to the IPC about how it should assess these issues, and
therefore to the applicant, about how it should present information
on them.
Q39 Mrs Glindon:
As a former member of a local authority planning committee, I
understand this is a very important issue. Do you think that
the Government should take a more proactive role in seeking to
alleviate the stress and anxiety that may be caused by unfounded
perceptions of the health risks caused by such facilities?
Dr Wilson: On a
much broader issue, it is largely about education, as I am sure
you appreciate—about people understanding what the developments
are about. We have a national issue with that on a number of
subjects, including hazardous waste, including nuclear power and
so on. On a more specific basis, certainly the public consultation
engagement exercises that our companies undertake and many of
the companies in ESA would undertake are part of the process of
trying to alleviate that issue. Where the difficulty comes for
decisionmakers—the people who are standing there saying
what is happening here—is that it is very difficult. How
do you measure the level of anxiety or stress? How do you tell
the scale of the perception of harm, when there are a small number
of people who make a lot of comments and are very vociferous and
give an impression of a very great number of people upset and
concerned? It is very difficult, because you do not know. As
an applicant, I find it very difficult to assess and the decisionmakers
are in the same boat. I am sure you have had the same experience.
Is it just the person who is actually speaking to me or does
the whole community have a concern about this issue?
Matthew Farrow:
Part of the challenge for the NPS on this is that, compared with
technologies like nuclear power stations or even traditional energy
from waste plants for the household sectors, as colleagues have
been saying, this is such a varied sector. People have a perception
of the idea of a hazardous waste facility being constructed near
them, but actually they could be talking about a wide range of
different types of site and facility. That perhaps makes it harder
for the Government, the industry collectively or the NPS to address
the perception issue for hazardous waste than that for other technologies
that are more uniform.
Q40 Mrs Glindon:
Do you think it will probably be down to each individual application
and maybe it is not something that the Government could make an
intervention on generally? As you say, it is an education issue
about the whole issue of what hazardous waste means.
Matthew Farrow:
I think it is a little bit of both. Inevitably, it always comes
down to the site. It is quite right that companies are expected
to do what they can to explain and allay unfounded concerns.
In broad terms, of course, we welcome the Government emphasising
the fact that, as a society, we expect hazardous waste to be dealt
with somewhere to the highest technical standards and those sites
have to be built. If you look at the Waste Review, which was
about nonhazardous waste, the Government committed sensibly
to producing a guide to energy from waste and a range of technologies,
partly as its contribution to trying to broaden the understanding
among local authorities, communities or stakeholders. That is
harder to do for hazardous waste, because the range of technologies
and the scale of the sites is so different, but obviously we welcome
any support that the Government could give on that.
Gill Weeks: On
the perception issue, it is very difficult to just get across
to the public what hazardous waste is. I always use the analogy
that most people are quite happy on a Saturday to walk up and
down the aisles of B&Q. They are in a DIY warehouse and they
are happy, but something like 80% of the paint, glues, garden
sprays etc on those shelves in B&Q, if it were to be discarded,
would be hazardous waste. It is that kind of thing. People see
somebody bringing a hazardous waste plant to a field near them,
and they are up in arms about it. Of course now, with social
networking and everything else, it is easier for the level of
anxiety to be raised by others. I think that is something that
we will have to address: how we can satisfy the IPC that we have
addressed the stress issue. As Gene said, I do not know how that
is ever going to be, "Yes, you have done enough."
Q41 Chair: You
mention that guidance should be given to the IPC. Of course,
when the IPC goes, we are going to have the Major Infrastructure
Planning Unit (MIPU) taking over its role. I have not sat on
a local authority, to be honest, but when there was an application
for a waste disposal site, the scientific studies that were thrown
at us showed there were carcinogens or claimed that there were
potential carcinogens. It was obviously used to whip up a certain
amount of hysteria to ensure that the planning authority turned
the proposals down. Do you think there is less possibility of
that happening under these NPS procedures?
Gill Weeks: No.
Chair: More possibility?
Gill Weeks: My
immediate reaction was no, I do not think there would be less
possibility. If anything, there would be more, because you now
have specifically to address the public concern. You almost have
to go out, knock on doors and say, "Are you concerned?"
The answer is likely to be yes.
Chair: That is why I think
it best to get in on the ground, at parish council level, at the
earliest possible stage. Assistance to a village hall goes down
very well. It would be something like that.
Q42 Richard Drax:
Part 5 of the NPS deals with generic impacts, as I am sure
you are aware—flood risk, historic environment, noise vibration,
etc. The next two questions are based on the ESA's written evidence
and I think they have been drafted from concerns that the ESA
has raised. The first question is, does Part 5 of the draft
NPS correctly identify the generic impacts relevant to all hazardous
waste infrastructure projects? As part of the same question,
are there any impacts that you believe have either been excluded
erroneously or omitted?
Dr Wilson: We made
a minor comment on insect infestation, because we are not really
aware of insect infestation being a problem with hazardous waste.
Because it is hazardous, they do not seem to infest it.
Q43 Richard Drax:
That is actually my third question, so you have jumped the gun
there. Actually, do you agree with the inclusion of insect infestation
in the list of generic impacts? That was the third question.
Dr Wilson: We are
asking, why it is included? We are not sure why it is included.
Richard Drax: You are
not sure.
Dr Wilson: It seems
to be given a profile that it does not have.
Matthew Farrow:
We do not see a need to include that as relevant.
Dr Wilson: Generally,
as I indicated earlier, we have looked at, and had experts in
their field look at, the various sections of the generic assessment—so
an archaeologist looking at the archaeology, geologists and so
on—and they have all come back and basically said the same
thing, that it is appropriate, it is what we expect to see. There
is very little that would leap out at us as being of concern.
Q44 Richard Drax:
Secondly, do the—there are quotes here; one assumes ESA's
quote, I am assuming. Do the "applicant's assessment"
sections in Part 5 provide sufficiently clear guidance on
how the applicant should address each generic impact?
Dr Wilson: The
answer is much the same. In general, we are comfortable with
what is being suggested.
Q45 Richard Drax:
Finally on infestation—I do not want to dwell on it too
long—are you aware of this problem having arisen in the
construction, operation or decommissioning of hazardous waste
facilities in the past?
Dr Wilson: No,
we are not. That is why we are querying it as a possibility.
Richard Drax: It is a
bit of a nono really. Thank you very much.
Q46 Chair: You
have already answered on wholelife costing, for which we
thank you. You all seem remarkably relaxed about this, which
is clearly something that is always very welcome when witnesses
appear before us. Obviously, you are taking an industrial view;
do you think this will be shared by others in the industry?
Matthew Farrow:
Is that across the waste management industry?
Chair: Yes, and welcoming
the NPS, as you appear to.
Matthew Farrow:
Certainly ESA represents all the major companies active in this
field and what you have heard today is our collective view. I
guess I would return briefly to the point I made at the start,
which is that the NPS, we feel, with the caveats we have made,
is broadly appropriate in terms of trying to take the hazardous
waste management strategy that the Government has published and
say, "Right, these are the sorts of facilities we would expect.
This is how they should be assessed."
As an industry, we are keen to make these investments
and are gearing up, but the concern ESA members have is that a
lot of new regulation is coming into play, the waste hierarchy
is being applied to hazardous waste and so forth. The concern
is, if enforcement of that by the Environment Agency is not sufficiently
rigorous, we are going to find a lot of suboptimal treatment
processes, which perhaps were acceptable and appropriate in the
past but, judging by the Government's wording on this, are not
what we as a country we should be looking for in the future.
ESA members feel that they will persist in the market for a long
time to come. Often that might occur because permits are written
very widely and they are not reviewed that often. The concern
is then that, if I build a stateoftheart plant,
am I going to get the waste streams in the market, because there
might be cheaper options, either in other member states in the
EU or in the UK through nonESA members, who are going to
undercut me? The NPS is written as if it is an assumption that
this is what we need; the market will deliver. In principle,
yes, but the concern will be enforcement, particularly given the
budgetary constraints on the Agency.
Q47 Chair: Are
they able to undercut you in other countries because they have
a bigger landmass, so it is not such an issue, or a swifter planning
procedure? Why should they be in a position to undercut what
your members are able to do?
Matthew Farrow:
Often they are quite technical issues. You can export hazardous
waste for recovery. My understanding is that, in some cases,
that might go to other member states where municipal incinerators
are classed as recovery but allowed to take some hazardous waste
as their waste feedstock. We would argue those incinerators in
other countries are not operating to the sort of standards that
the specialised hazardous waste incinerators in the UK do. Yes,
it is technically allowed, because it is an export for recovery.
In those quite technical areas, we feel there might be a disincentive
for ESA members to invest in what I think the Government and the
NPS are looking for.
Gill Weeks: The
export of hazardous waste is a big concern for us. The reason
why other member states can do it cheaper is that generally there
is an overcapacity in northern Europe at the moment in energy
from waste plants and incinerators, whatever we want to call them,
and so they are selling off their free capacity, in a way, so
you can ship waste over to the northern member states relatively
cheaply. The other thing you tend to find is that some member
states' governments take a more relaxed view of how they classify
things as recovery. To give you one example, if you backfill
the German salt mines with hazardous waste, it is regarded as
a recovery operation because they say they need to backfill to
prop up the mine.
Q48 Chair: I am
slightly concerned. If there is an EU definition in the Directive
of what constitutes hazardous waste, it all seems to come down
to what Mr Farrow was saying about the definition of recovery.
I am slightly concerned about why it would be allowed to enter
a general energy-from-waste plant.
Gill Weeks: In
the UK, the Environment Agency, not without exception but generally
has tended to permit and the applicant applies for municipal waste
only. In other member states, they have applied for municipal
waste with, say, up to 5% or 10% hazardous, which can go in as
well. Their facilities are permitted in a slightly different
way. It is just the way that their permits are done.
Q49 Chair: Obviously
we will be taking evidence from the Environment Agency on this,
but when there was an energy-from-waste application in what was
my constituency—sadly it is not my constituency now—they
tend to say, "We will build a bigger chimney," which
is not necessarily what those living closest to it want to hear.
What I do not understand is that, in Scandinavian countries especially,
they seem to accept these facilities as being a fact of life,
because they want to use the products; they live in an industrial
society, but the waste will be disposed of in an ecologically
and environmentally friendly way. Why is that debate not happening
in this country?
Gill Weeks: That
is a very good question. As you say, you can go to places, and
I have been to a place like Finland, where Friends of the Earth
and Greenpeace will actually support an application for an energyfromwaste
plant, because it is giving energy back to the local community
and they are able to use the heat, etc. In this country, they
actively object from day one. It is really a cultural thing.
Matthew Farrow:
It is partly, I suppose, because in the UK, going back some years,
we have had a history of landfill as a main disposal method, of
course, which you have not had in many European countries for
geological reasons. Also, as Gill says, culturally, district
heating systems are much more common on the continent, but they
are seen as not quite the way we do things in the UK.
Q50 Chair: Forgive
me, because my uncle gets his heating and electricity from that
in Denmark. We have the acceptance there that underground heating
is a good thing. There are EU standards to show that there should
be no residue going into the environment. Why are we more sceptical,
as the British public, in accepting the fact that this is safe,
when the other countries accept it?
Gill Weeks: My
understanding, and I might not be 100% right in this, is that,
in a number of member states, the local authorities—Länder,
or whatever they are—have an interest in those plants, so
they build them with a partner or a number of partners, so the
facilities are actually part-owned by a number of local authorities
and, say, a commercial company that runs it. There seems to be
more of a benefit. The community seems to feel they own it more,
and they seem to get some sort of planning gain or benefit in
terms of cheaper electricity if they live near one of these facilities.
Q51 Chair: I think
you produced a manifesto before the last election. Is that something
that you try to sell to the different parties?
Gill Weeks: Yes,
we would love to see it being more accepted. There is one Energy
from Waste (EfW)
plant in Austria where they actually light it at night. It is
a beautiful facility in the middle of a town, covered in tiles
and lit up. We have seen from some of the newer EfW plants that
have been built in the UK that, architecturally, people are starting
to try to make them look more attractive, so that they are more
acceptable. The big issue is trying to get the heat used in the
UK, finding enough facilities and operations that will take the
heat. My company has one in Sheffield, where we have an EfW that
is connected to the district heating.
Q52 Chair: Is it the
case that you have to build? There is SELCHP, as a combined heat
and power station in southeast London, but it never connected
in. I could not quite understand. I think they got the permission.
Gill Weeks: It
is getting the permissions and actually getting the pipe work,
connections and everything in. It is quite difficult to retrofit.
Q53 Neil Parish: I think
quite probably we do not incentivise enough for people, do we?
They do not get enough benefits and then they are not quite so
keen, whereas if they got greater benefits they might be keener.
The question I wanted to ask is: what about the export of waste
beyond Europe, to the Middle East and the Far East? Does that
happen quite a bit?
Gill Weeks: With
hazardous waste, no.
Neil Parish: Is it not
allowed to be exported or what?
Gill Weeks: By
the UK Government, Defra, it is forbidden to export waste for
disposal from this country unless it was a very small quantity
of a particular metal that had a very high value or something.
To my knowledge, all waste for disposal is banned, so you can
export only for recovery. Export to nonOECD countries of
what is classed as Red List waste is very strictly controlled
so, no, hazardous waste does not leave the UK to go outside the
EU.
Chair: Legally?
Gill Weeks: Yes.
Q54 Chair: One
of the things we are obliged to do as part of our parliamentary
scrutiny is to confirm that the consultation that has been followed
by the Department, in regard to the NPS, has been followed. A
number of criteria have been set out for that purpose. Are you
satisfied as an industry that there has been a proper consultation
process on the NPS?
Matthew Farrow:
In terms of the formal procedure, yes we are, and we are preparing
our response to the formal consultation. In terms of consultation
with the Department while it was being worked on, I will to look
to Gill on whether we felt comfortable with Defra's engagement
before they actually published the consultation, which I guess
is partly what your question is getting at.
Gill Weeks: I
think it is fair to say that, through the hazardous waste groups
that Gene and I sit on, we have had quite a lot of dialogue with
Defra about this, so I think I am quite happy.
Q55 Chair: Are
you confident that the publication of the draft NPS has received
a sufficiently high profile, in the industry as a whole, to allow
all interested parties to be aware of and respond to the consultation
in the timeframe allowed?
Gill Weeks: Whether
nonESA members have picked it up, I am not quite sure, but
there has been a reasonable amount of publication in the trade
press and in general.
Q56 Chair: Can
I just take you back to what you said, Gill Weeks, about
the technical amendments before the committee of experts in Brussels?
I know you might track it and you might be aware of it; do you
feel that you are sufficiently formally consulted on those, because
they will have a major impact on your industry to the extent that
there is a mechanism to amend them, in any way, before it is agreed
there? Obviously once it is agreed, it is very difficult to change.
Gill Weeks: It
is difficult to answer that, because it is really how much time
we as a company and the representatives want to put into these
things. There are lots of debates going on in Europe. We have
some dialogue with Defra through these various groups that we
have, so they will have a representative who goes out to Brussels
and sits out there. The Environment Agency generally puts a technical
person on that group as well. Whether you get enough feedback—it
is not always clear what the UK position is before it goes to
some of those meetings, so it might be nicer to have a little
bit more from Defra before they go to meetings and put the UK
position. Could I just come back though, Madam Chairman?
I realised after answering Mr Parish's question about exports,
I am not an expert on WEEE[1]
and electrical equipment.
Chair: WEEE is not our
responsibility.
Gill Weeks: Okay.
When I said no hazardous waste goes outside the EU, I am not sure
that is a true statement when it comes to WEEE. I just wanted
to clarify that.
Matthew Farrow:
If I could briefly add to Gill's original point about the technical
committees, I think, as she implies, the feedback from Defra is
a little bit variable sometimes. The broader point I would make
behind that is that Defra and the Environment Agency of course
have pretty tough budget conditions and fewer people doing lots
of jobs. A lot of this stuff is very technical, so we are looking
ideally to real experts in Defra. That feedback is a little bit
variable and, going forward, it is important that Defra is able
to reassure us that they have the right people who know their
stuff, who can liaise with the industry so we can help.
Q57 Chair: Dr
Wilson, you provided details of the costs of planning applications.
I think you gave a percentage of the cost of the plant itself.
Is there any way you could give us more detail in writing? That
would be very helpful to the Committee.
Dr Wilson: Yes,
I would be happy to do that.
Q58 Chair: As
a percentage, how much of the industry do you represent?
Matthew Farrow:
Of the broader industry, so nonhazardous as well as hazardous,
around 80% by value, so all the major companies that operate in
the UK, plus a good slice of the SME market. For hazardous waste,
it is similar or higher possibly, because there are a much smaller
number of companies. Certainly, all the significant UK companies
that operate in this market are within our membership. There
may be one or two smaller ones that would fall outside.
Chair: Thank you very
much indeed for being with us, participating and for being so
generous with your time. We found it enormously helpful.
1 Waste Electrical and Electronic Equipment. Back
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