To be published as HC 1465-i

House of COMMONS



Environment, Food and Rural Affairs Committee

The Draft National Policy Statement for Hazardous Waste

Wednesday 7 September 2011

Matthew Farrow, Gill Weeks and DR Gene Wilson

Evidence heard in Public Questions 1–58



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Oral Evidence

Taken before the Environment, Food and Rural Affairs Committee

on Wednesday 7 September 2011

Members present:

Miss Anne McIntosh (Chair)

Richard Drax

Mrs Mary Glindon

Neil Parish

Dan Rogerson


Examination of Witnesses

Witnesses: Matthew Farrow, Director of Policy, ESA, Gill Weeks, Regulatory Affairs Director, Veolia Environmental Services (UK) plc, and Dr Gene Wilson, Group Technical Director, Augean plc, gave evidence.

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 pulling 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 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 avoiding extension, and therefore the extension in time of the life of a site, 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 cap to avoid 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. 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 colleagues who was brought in for the CIWEM evidence talked about the need to look at lithium batteries. Now, 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 of capacity, 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 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 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 that 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 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 disposable 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", "2seek 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 undertakes 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 stuff 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 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 owned by one, two or 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 in Austria where they actually put lights on it. 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 export on WEEE 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.

Prepared 15th September 2011