ATF Professional spoke to Elena Wrelton, Environmental Compliance Manager at ELVES, the producer compliance scheme for end-of-life vehicles operating in Ireland about her role, the scheme and the future of ELVs in Ireland.
Originally from Kent, Elena relocated to New Zealand in the early 2000s. There she worked for the Government Environment Ministry in the waste and resources sector focusing on the operation of the Waste Minimisation Act, including producer responsibility initiatives, a nationwide television take back project and funding for waste projects – everything from food waste to construction and demolition projects.
We were keen to know if there were any differences between how things are run in NZ compared to Ireland/UK. Elena told us that there are some similarities, for example with a landfill levy in place and a strong role for local authorities in overseeing waste management. The country also faced similar challenges stemming from being an island with a similar size population to Ireland. Achieving economies of scale had an impact on the development of local solutions and transport was a significant cost for waste management activities. A big difference was not having the additional influence of European level regulation. In NZ there isn’t anything like a European Directive for example, and so for something like mandatory producer responsibility any change had to be internally driven, a challenge given short election cycles. At that time, all their producer responsibility was voluntary.
We asked Elena if she thought theirs was a more generous system to have or whether having a mandatory approach like over here is better?
“I think mandatory has a lot of strengths because it does provide a level playing field. With mandatory, you’re not just relying on some companies to do the right thing – everyone has to do something. Having everyone on board also helps with planning for the future.”
In 2015, Elena took on her current role in Ireland. Elena started quite early on at ELVES after it had been set up but before their approval was given. The concept and the policy of the business was already set up and Elena came in on the operational side.
We wanted to know about the background to ELVES and why it was created in Ireland to begin with.
Before ELVES was established, Ireland had a system of self-compliance for producers. Each producer had to register with each local authority and had to have their own network of ATFs. What resulted was basically duplication – it was a very administratively heavy way to provide a take back system.
Ireland was struggling with meeting the targets and aware that the higher targets were going to kick-in in 2015. That was an additional incentive to create a new system.
The idea was rather than having each manufacturer doing their own thing, by pulling together all their resources so much more could be achieved. As an example, in terms of advertising and awareness, Elena told us that it’s better to have one larger budget which can be directed as opposed to having manufacturers working by themselves. ELVES provides an easier system for the manufacturers in terms of what they have to do. ELVES delivers on their compliance obligations for them, making it simpler and easier for them.
We asked if after streamlining and getting manufacturers on board, if there were any hurdles to overcome when it came to policy changes such as how there had to be an ATF within 45km of a population centre. Elena told us that it wasn’t a problem as such and the new system was better than previously when the regulations said there had to be one ATF per local authority. In terms of them getting started, there were a few challenges, such as timing. They had to wait for regulation change as the regulations before 2016 only allowed for self-compliance, not a collective compliance option. One factor that slowed down the amendment of the Regulations was the general election but at the end of 2016, the Regulations finally went through.
There was a bit of hesitancy with the changes and some apprehension from ATFs about the new scheme, but since it was established and trust has been built up most are keen to be a part of the ELVES compliance scheme. The benefits of having a scheme are now being shown.
“People are generally happy. Not all ATFs are required to be in our Network, but the Network currently more than exceeds what is required in the regulations and we have more people wanting to join. Our requirements are to have a minimum of 47 ATFs and one within 45km of a population centre of 15,000 people or more. We have exceeded what we needed to do.”
We asked Elena about Illegal operators and how problematic this is in Ireland. She told us that obviously it is an issue and a very genuine concern of ATFs. For ELVES, although it is not an enforcement body, it does what it can to help by encouraging the public to take their cars to legal operators.
As for public awareness about illegal operators, ELVES’ key messages: ‘to use an Authorised Treatment Facility’ (which can be found through their website) and to get the Certificate of Destruction (CoD), two messages that reinforce each other and drive the public to authorised sites. “Making people aware of this process, that it is there and what it means for them – until you get that CoD you are still responsible for that vehicle – is a big part of what we do”. For example, in Ireland, fines can be given to the owner of the vehicle if it is found at an illegal operator.
In terms of impact, it builds year on year, they do a range of advertising and PR, including print and radio – which always gets a great response. They also use events as a way to raise awareness – this year they were at the Cork Summer Show which took place in June and the 1980s inspired Forever Young Festival in Naas. Where possible they take along their Heinkel car which always draws a crowd to the stand.
ELVES are currently working with the Department of Transport to increase awareness via the motor tax reminders – a flyer has been going out with the reminders informing the public how to scrap their car correctly. One of the benefits of having a collective compliance scheme is that ELVES have a centralised education and awareness budget that allows them to make the public aware of how and where to scrap their vehicles. Last year they were at the Ploughing Championships, the biggest open-air event in Europe. Throughout the event they had a lot of farmers asking what to do with scrap vehicles they have on their land. Elena said: “It was good meeting people face to face to tell them exactly what to do with their old cars and to explain the process.”
EVs and the future
With regard to EVs, they are starting to come through in small numbers so ELVES has developed the Electric ELVES programme to support all ATFs in the handling of them. But there are mixed reports on the volume of EVs entering yards. Some ATFs have had a few and are getting prepared for this new area, others haven’t seen one arrive and they don’t anticipate one for a while. A lot depends on geography – it is more likely EVs will be seen in a city as opposed to the countryside due to the distances that EVs can travel before needing to be charged. It varies, it’s more at the forefront for some than others. But over time, as more knowledge is gained and an understanding of where the value lies within these kinds of vehicles, ELVES expects ATFs to dedicate more to this side of the recycling business.
Elena told us what they are trying to get across to ATFs through the programme. Firstly, ELVES want to ensure ATFs are able to identify these vehicles, are aware of the potential high voltage nature of the batteries and understand how to manage the associated risks. This includes the li-ion batteries found in mild hybrids, which although may be a lot lower voltage, may not be as easy for ATFs to identify as an electric or hybrid vehicle.
Secondly ELVES wants to ensure that all ATFs are aware of the support that can be provided through the Electric ELVES programme – for example free collection and recycling of the battery and additional support in the event one may be damaged or critical.
With various Government backed initiatives in place to increase EV take-up, the Electric ELVES programme is supporting ATFs at the ELV stage helping ensure ATFs are aware of what they need to do.
“Things are changing rapidly in the vehicle sector and, in time, this will filter through to how we manage ELVs. Electrification, automation and potential changes to how we use vehicles will all bring challenges. In the immediate future, with the evaluations of both the ELV Directive and Batteries and Accumulators Directive underway, we do expect some changes and clarifications to better support the reuse and recycling of electric vehicles in line with the circular economy.”
“With EV batteries currently falling under both Directives, we have designed our Electric ELVES programme to make sure it delivers on both, feeding information back to the battery compliance schemes as required. We have worked with the National Waste Collection Permit Office (that manages the waste data collection system) to ensure ATFs are able to report batteries reused as part of their annual environmental returns.”
As for the future, ELVES sees that their Electric ELVES programme will continue to be a key focus. In September they ran the first set of electric and hybrid vehicle awareness courses for ATFs in Ireland. Running the courses, showed the demand from ATFs for support in this area. “It is a growth area, as more EVs start arising at ATFs. It is vitally important ATFs have access to the right information and support in the handling of this new technology” Elena said, “Our work on the Electric ELVES programme will aim to do that”.