IWM sees landfill permits as short-term solution

The view comes in response to the Department of the Environment, Transport and the Region's consultation paper on tradable landfill permits which looks at how they could be allocated, how the trading mechanism will work and what sanctions will prevent non-compliance. The system could mean that an authority which has invested in recycling would be able to trade permits it no longer needed with an authority which continued to landfill large amounts of waste.

Chris Murphy, deputy chief executive of the IWM, said: “The IWM considers that the permit system is not likely to feature significantly in a strategic planning sense, but may be applied as a short-term solution for local authorities falling short of their diversion target and prove of benefit for those proactive or strategically well placed authorities who exceed their target diversion.”

The Institute supports the annual allocation of permits and said that the most up-to-date information on landfill rates should be used for the initial allocation. The DETR proposed that the allocation could be based on current rates or on 1995 biodegradable municipal waste arisings.

The IWM added that the banking and borrowing of permits could be adopted to ease the impact of reaching the targets as long as the system is rigorously monitored and is simple and cost effective to use.

Unfair

But the Institute warned that the trading system may result in unfair competition where a direct services organisation collects commercial waste alongside its municipal waste contract, and a private sector operation collects commercial waste only. This is because the direct services organisation would be subject to the permitting system, whereas the private sector contractor would not.

Mr Murphy added: “This is clearly not acceptable and would require redress, either through exemption of the commercial fraction from the permitting system or some other measure such as a redefinition of municipal waste.”

The Institute said that it would prefer an electronic system for permits to a paper-based equivalent. But there is debate as to whether the Environment Agency should run an electronic database to handle the permits. On the role of the Agency, the IWM said that the EA could host a forum for trade of permits thereby facilitating the trading process without active assistance and maintaining the objectivity of the Agency’s monitoring role. The IWM added that there should be a body representative to lend practical advice to the implementation and the monitoring of the system.

The IWM also said that interim targets should not be mandatory and that there should be a review process built into the scheme to consider revising the method of allocation after the first of the mandatory target dates in 2010. This which would take into account any changing circumstances which come to light over the initial part of the scheme and allow appropriate changes to be made prior to the second and third target years.