Correspondence from Biffa Waste Services
in Response to notes by M B Recycling Ltd 27 September 2001
As a follow up Michael Baker's informative note
on the technical reprocessing aspects I write to affirm Biffa's
full support that any new UK standard must be to the highest possible
level available in the market place. It is our understanding that
there is sufficient technological choice for total mass loss emissions
of 3per cent or less to be achieved and we would certainly be
very much against introducing standards which do not reflect these
types of overall net losses.
Technology specifics apart we would assume that
any plants processing refrigerated equipment would be subject
to total mass balance evaluationwith all processed units
being subject to a rigorous audit procedure with inputs weighed
on entry into the site and all net exports of processed materials
also subject to mass balance reporting as part of an IPPC type
framework. This may not be possible in 2002 but should form part
of the objectives of any standards code being developed for operators.
Clearly such systems can be bypassed but such
risks are overcome on landfill sites by full video observation
seven days a week, 24 hours a day of entry routes into sites.
These video records can then be subject to random viewing the
by the regulator during site auditsboth inbound and outbound.
Such levels of control would be necessary to satisfy any contractual
arrangements whether the contracting party is the Treasury, local
government, manufacturers or a shared responsibility type supply
If technologies which do not satisfy the standards
which Michael Baker sets out as contained within the E DIN framework
then they should at least be subject to full mass balance assessment.
In reality market distortions between this inferior type of equipment
and those with lower CFC losses can be adjusted by introducing
a CFC trading framework. This is outlined in the attachment which
is my letter to Michael Meacher of 30 July. The effect of such
measures is to level the economic playing field and make investment
in sub standard equipment uneconomic because users would have
to procure tradeable permits from the more efficient processorsin
effect rebalancing the market place. This latter measure should
not be necessary howeverwhy don't we just go to the simplicity
of adopting the Best Practicable Environmental Option (BPEO) when
we have the opportunity? To do anything less would simply be a
fudge and lay us open to accusations of ineptitude from the great