This was the warning message today from the Environmental Services Association to DEFRA in a response to the department's second Landfill Directive consultation paper. The ESA, which represents large to small waste management firms, also says that the Department has failed to take-on-board comments the association made in response to the first consultation.
Dr Stuart McLanaghan, in a letter to the department, says that the ESA continues to be gravely concerned by “ongoing delay in providing industry with the necessary framework of a regulatory package and a clear suite of guidance to implement the Landfill Directive (LFD). The delay in the production of agreed waste acceptance criteria (WAC) is a formidable obstacle to creating this framework.”
The ESA considers that without this framework, there is a very real prospect of both a regulatory hiatus and of insufficient market confidence to invest in the next generation of waste treatment and processing infrastructure. “There is therefore a very real risk that the UK will fail to achieve compliance with its statutory obligations under LFD, with wider repercussions in other related policy areas across waste and the environment.”
The detailed response, which has been carried out in consultation members covers a number of specific areas. The ESA has long argued that hazardous waste should be treated to a high level so it can reach final storage quality. Of some surprise to some in the waste sector, DEFRA does not want such a high standard and ESA says that “the arguments presented by the Government against requiring hazardous waste to be treated to final storage quality are weak and unsubstantiated. The Government must seize this challenge and fully engage, as a matter of priority, with key stakeholders in order that the most sustainable solution for hazardous wastes can be developed.”
The following are edited sections from the ESA response to DEFRA. More information about the ESA is available from: www.esauk.org
New sites
The problems associated with failing to provide an effective framework are particularly evident for “new” sites. Without the necessary framework in place, ESA strongly questions the ability of the Environment Agency to define “Landfill Directive compliant” when issuing permits. Problems could be further exacerbated, leading to long delays, if permit applications are subject to moving 'goal posts' resulting from phased Agency production of the necessary LFD guidance package.
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