WASTE WATCH

  Waste Watch is the leading cross-sectoral organisation promoting waste reduction, re-use and recycling. Supported by the Department of the Environment, Transport and the Regions, the National Lottery Charities Board and a range of business sponsors, Waste Watch has over 400 member organisations from the local authority, community and business sectors in waste management and recycling.

INTRODUCTION

  Waste Watch welcomes this inquiry, and thanks the Environment Sub-committee for the opportunity to contribute. Our response will be mainly limited to specific points we wish to draw to the Sub-committee's attention, broadly themed into four key areas:

—  the Agency's educational and advisory role

—  waste regulation issues

—  relationships with the waste management industry

—  strategic vision and sustainable development

COMMENTARY

  We welcomed the formation of the Environment Agency. The step change that was made by integrating environmental regulation of air, land and water was an important process, widely admired by many other countries as a visionary and positive move. We still share this view.

The Agency's educational and advisory role

  In many regions the Environment Agency has taken a positive and proactive role in educating and advising on environmental matters. In particular, they have been supportive of many business waste minimisation programmes around the country. We see this as an important area of work for the Agency, and would encourage its further development, especially in partnership with ngo's and other advisory agencies.

  In some regions, the Agency has also sought an active role in working with schools, although we have found wide regional variation in the priority given to work of this kind. Again, we would welcome greater activity in this area.

  The Agency has increasingly sought to involve itself in the Landfill Tax Credits Scheme. In some regions, external funding managers are being employed by the Agency. In the Anglian region, this officer has played a positive role in helping to develop educational initiatives, and has also, subject to DETR approval, been able to assist in the provision of the 10 per cent leverage funds that are often needed to access resources from landfill operators. Waste Watch can report a particularly positive experience of working with the Agency in this region, where they have supported development of our Schools Waste Action Club programme with local authorities in the region. We are hopeful of development funds for a major programme of waste education in schools in Norfolk, Suffolk, Milton Keynes and Essex, in which the Agency has played a significant supporting role.

  The Agency has also in their Southern region sought to encourage co-ordination of landfill operators' donations to Landfill Tax funded projects, to try and avoid some of the unnecessary duplication that has been taking place and encourage a more strategic approach within a region to the use of Landfill Tax credits. This is taking place in the South East Economic Development Agency (SEEDA) region and is commended to the Sub-committee as an example of positive activity on the part of the Agency and others. Our only concern is any question that there might be about potential conflict between the Agency's role as a regulator of landfill and their advisory or co-ordinating role that they also seek.

  The Agency has been supportive of the development of the National Waste Awareness Initiative (NWAI) for which Waste Watch is acting as the managing agent, supported by Save Waste and Prosper Ltd and Biss Lancaster. The NWAI is governed by a wide steering group from across the waste management spectrum, and has as its primary task the challenge of raising public awareness of waste issues, and seeking changes in attitude and action as a result. NWAI is operating in a complementary fashion to the DETR's are you doing your bit? campaign, and is also supported by the Department directly with some national funding through their Environmental Action Fund. Waste Watch has welcomed the Agency's support for this initiative, which will be launched nationally in Spring 2000.

Waste regulation issues

  Waste Watch supports the introduction of the OPRA (Operator Pollution and Risk Assessment) approach by the Agency to waste regulation. The focus on paying greater attention to higher risk pollution sources and material waste streams is long overdue, but no less welcome.

  From our own knowledge of the community based waste management sector, and personal experiences, we are convinced that this approach should have a greater environmental impact than previous approaches, which relied more on a "tick box" mentality and the achievement of inspection visit targets that did not necessarily pay sufficient attention to pollution "hot-spots". From my own experience several years ago of managing a community recycling operation which included a depot storing waste paper, cans and furniture, I recognise that my regular, Friday afternoon visit from the waste regulation inspector was as much to do with the need to complete a certain number of visits each week as it was to do with whether we were complying with our waste management site license requirements to keep the back yard clean. His time may have been better spent investigating the razor-wire clad, rottweiler guarded "waste transfer stations" further down the same road. The introduction of OPRA will hopefully focus the Agency's waste regulation resources where they will have most impact.

  In a similar vein, Waste Watch remains disappointed at the slow rate of progress within the Agency in addressing the question of site licensing requirements for small scale community composting schemes. Currently, small community composting schemes are being hampered in their development because of the excessive cost of site licenses and the detailed licensing requirements that the Agency is seeking to impose on projects that are actively seeking to foster environmental improvement in their community. These projects wish to do this through the small scale collection and composting of garden and kitchen waste, and returning the composted material to gardeners and householders for use in the community. Better examples of using waste generated locally and adhering to the proximity principle could not be found, yet current attitudes in the Agency are blocking this development. Waste Watch supports the efforts of the Community Composting Network (CCN) to change this situation, and encourages greater dialogue between the CCN and the Agency to reach a workable solution.

Relationships with the waste management industry

  Waste Watch welcomes recent developments which have seen the Agency and the waste industry engage in "job swapping" and work sharing initiatives to develop greater understanding between the regulator and the regulated. This can only help to improve relationships at an operational level, but needs to recognise and account for any conflicts of interest and the need for openness in the regulatory environment.

  Waste Watch is concerned that relations between the industry and the Agency may not have been helped by the Agency's recent "Hall of Shame" exercise, which seemed to be designed primarily to raise the public profile of the Agency, and not necessarily designed to encourage better practices on the part of the industry. In principle, the concept of "naming and shaming" environmental miscreants is one we approve of, but only if the basis for the league tables of shame is a fair one. Using a crude measure such as the level of fines imposed by the courts, when this is notoriously variable seems to be too simplistic a method, and potentially places the whole idea into disrepute. The waste industry and the Agency would be well advised to have better dialogue on this matter, to seek a more sophisticated way of drawing attention to those whose activities create pollution. In doing this some recognition of the role of the waste management industry as both a provider of treatment solutions for industry and as a sector perhaps more exposed to scrutiny (as they carry others' waste for them) might lead to a more rational dialogue on this subject. Because of its exposure and its role as an environmental service provider, the waste management industry has a higher duty to make its activities as open to public scrutiny as possible, and co-operate with the Agency in exposing the activities of poor performers in the sector. This sort of approach will improve public confidence in the industry, and the genuine role of the Agency as a tough but fair regulator.

Strategic vision and sustainable development

  The Agency has an important role in supporting the Government's vision for sustainable development by being an effective environmental regulator and by actively engaging with the public and industry through education and advice. It has the potential to act as a significant bridge between the public and the Government on matters of environmental sustainability, and we would encourage the Agency to play a stronger role in this. In the Thames region, the Agency is currently engaged in a process of public dialogue with many stakeholders on the theme of creating a "Greenprint for London". Initiatives of this kind are to be welcomed, and are commended to the Sub-committee as examples of how the Agency can be proactive in seeking to achieve greater sustainability.

  Impetus for this work may come with the appointment of a new Chairman. In our view, the Agency would be best served by a Chairman with a genuine and credible commitment to environmental protection, who can command support from across the spectrum of industry, ngo's, the public and local and national Government. We look forward to such an appointment being made.

CONCLUSION

  The Environment Agency has come in for much criticism in its relatively short life, much of which is justified, but some of which is perhaps a little unfair for an organisation that was ambitious and progressive in its creation, and has had to create a new organisational ethos from three very different regulatory and organisational backgrounds. However, it has now had plenty of time to overcome those early organisational issues, and is increasingly looked to for leadership in protecting the environment, and openness in making environmental information available to the public. As with many other organisations, we hope that our high expectations of the Environment Agency will be met in the future.

Ray Georgeson

Executive Director, Waste Watch

October 1999