Illegal dumping of refuse derived fuel
31st May 2013
The rising incidence of illegal dumping and inappropriate storage of refuse derived fuel (RDF) in England has caught our regulatory and control systems on the hop. When landfilling dominated our waste management system, Government toughened-up its regulatory and inspection regime. This involved a duty being improsed on landfill operators to put forward financial provisions (renewable bonds, cash deposits and the like) prior to the granting of an operating permit, to bear the cost of cleaning up environmental damage or of closing the site.
Today, landfilling, now tightly controlled, has been overtaken by treatment-based processes such as recycling, and increasingly by refuse derived fuel production. While cases of landfill-related pollution have decreased, incidents involving refuse derived fuel are on the rise, in line with the financial rewards that illegal and poorly regulated behaviour can bring. Clearing an illegal dump becomes the financial responsibility of the landowner, while sites operating under a permit can walk away from their obligations with relative ease, leaving the clean-up cost to the public purse.
Our regulatory system has not kept pace with this new threat. Because our risk-based regulatory regime regards refuse derived fuel processing as low-risk, these sites are either exempt or are accorded minimal permitting obligations and regulatory oversight.
Just as Defra and the Environment Agency (EA) acted with alacrity to address the issue of recyclate quality, the time has come for Government to strengthen its oversight of refuse derived fuel operations. Firstly, operators should be required to make appropriate up-front financial security arrangements with the Environment Agency prior to award of an operating permit. Secondly, the Environment Agency should extend its new and more stringent Regulatory Position Statement for storage of refuse derived fuel in dock areas, to all inland sites, which should also be subject to more frequent Environment Agency inspections. Finally, more resources should be made available to tackle environmental crime – what was politely called fly-tipping has assumed industrial-scale proportions. The latest incident in Birmingham involving some 3,000 tonnes of baled waste is just one of many recent examples.
Unless the Government acts fast, the businesses of legitimate and responsible operators trading in refuse derived fuel will be seriously compromised, and the public purse will continue to pick up the cost of repairing environmental damage.
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