ATF professional spoke to Malcolm Lythgo, the Environment Agency’s Head of Waste Regulation to find out about the current challenges the organisation faces and how it is managing them now and into the long term.
Malcolm became Deputy Director for Waste Regulation in early 2018 having spent 25 years with the Agency working across a range of regimes in local and national teams. Knowing how broad and complex the waste sector is we wanted to find out specifically what challenges face the complex industry of vehicle dismantling.
The first item we discussed was the fight against illegal operators, a topic which is always high on the agenda. Although the EA has been successful in closing down larger illegal operators – current figures report closing 2 illegal waste sites a day, when it comes to smaller illegal operations the EA knows that traditional methods of enforcement can have limited effect. It also has to prioritise its finite resources to those sites creating the biggest environmental risk. Malcolm was very supportive of the recent findings of the Serious and Organised Waste Crime Review, an independent report into the Agency’s approaches and effectiveness in tackling waste crime. The report produced a list of recommendations that are now being worked through and include adopting new technologies, working more closely with other government agencies like the police, HMRC and DVSA (including the formation of a joint waste crime unit) and taking a stronger prevention and disruption approach such as using new powers to seize vehicles involved in the conduct of environmental crime. All of these steps will help modernise Agency tactics in dealing with the various levels of criminality operating in parts of the waste sector.
Last year in an article for ATF Professional Malcolm commented on the work being done by ATF Professional to help support legitimate operators.
He agrees that it remains important for the EA to work alongside the vehicle dismantling industry, and its trade associations, in support of the sector’s own efforts to cut supplies and access to illegal operators.
Malcolm was keen to share some of the EA’s recent approaches in putting a stop to illegal operators. One of these is through a partnership with eBay, something which is currently being assessed with the support of their new national Prevention & Disruption team. Another approach is using the national intelligence team to research information received by the Agency about possible illegal operators to “hot spot” activity. This will help better target resources to “disrupt and deter” operators that are found to be illegal. Malcolm also told us about a small pilot campaign the EA is running in the Portsmouth area to persuade illegal breakers to “get a permit or quit”. It’s the first time they’ve carried out a local behavioural change campaign as a controlled trial and they are due to evaluate and share the results in the Spring for 2019. Campaign tactics have included unannounced site visits by local EA officers, posters and vinyl banners at ELV ATFs, targeted mailshots, and private messaging through the online marketplace ‘Facebay’.
When asked what the EA’s approach to putting a stop to illegal operations is, Malcolm explained that there was not a “one size fits all” solution and much depended on the scale and risk the illegal activity posed. In many cases first steps are to make contact with a suspected illegal operator and encourage them to become a legitimate business, as in many cases it is lack of knowledge or experience by the owner. If however the environmental risk is significant and immediate the Agency can use its powers, where appropriate, to halt site activity and start a criminal investigation. This issue is not something which will be put to bed overnight and the EA is very aware of how frustrated legitimate companies can find things.
We also talked with Malcolm about other opportunities and risks. One opportunity that fits with the aims of the EA’s 25 year plan for the environment is looking at producer responsibility, which sits at the start of the life-cycle of vehicle parts. For example helping to influence manufacturing materials, as part of their environmental responsibility, can also help with the dismantling and recycling process at the other end of the vehicle life-cycle. Again this will not occur overnight especially as it seems that right now brand is more important that the environment, but vehicle sales are beginning to be impacted by consumer concerns over diesel and petrol emissions, making manufacturers more likely to sit up and take notice .
One of the greatest areas of uncertainty for the EA at the moment is around EU Exit and what this may mean for a range of sectors. Malcolm used the example of a “worst case scenario” on the export/import of waste. This could potentially result in stockpiling at legitimate sites as waste takes longer to be shipped abroad, operators going out of business as supply chains run more slowly and a potential growth in illegal sites as people try to deal with a backlog of waste. These sorts of scenarios (worst and best case) have been worked on by EA and DEFRA EU Exit teams over the last year. These teams are made up of staff from all the various technical, legal and operational functions across the organisation. The teams are also working hard on an agreement for existing notifications, to date 17 countries have agreed to honour the agreement and a further 10 are still in talks.
Related articles: Illegal dismantlers – Stop the Rot