The inquiry was instigated after the Cabinet Office's Better Regulation Task Force warned in July that several key policy decisions would have to be made quickly and transparently if another "fridge fiasco" with scrapped cars and electrical appliances was to be avoided (ENDS Report 343, pp 42-43 ).
The inquiry is focusing on preparations made for implementing the Directives, the Government's role in negotiating them and the Environment Department's capacity to deal with them.
Geoffrey Bridges, director of dismantler GW Bridges, said that the number of abandoned vehicles "will probably double, if not more" from a current estimate suggested by the Committee of 340,000. Alan Greenouff, chairman of the British Vehicle Salvage Federation, suggested it would reach 500,000. Either way, the figure is far higher than the 147,000 predicted by the Government's regulatory impact assessment of the Directive.
The Society of Motor Manufacturers and Traders, which last year persuaded the Government to make last owners pay the disposal costs until 2007, disagreed. "Abandoned vehicles have been a significant problem for a long time," said Paul Everitt. "The entry into force of this Directive isn't a key off to make the problem worse."
SMMT continues to claim that "around 80%" of ELVs by weight are recycled, and thus the UK has already achieved the 80% reuse and recycling target which Member States must meet by January 2006. Shredder operators claim the true figure is 72.5% (ENDS Report 339, p 17 ). SMMT's Steve Franklin said that the Automotive Consortium on Recycling and Disposal intends to help resolve the dispute by setting set up a shredder trial to establish the average metal content of ELVs.
Dismantlers also argue that the abandoned vehicle problem will be exacerbated by a shortage of ATFs. "The delays and lack of clear advice and instructions has [sic] prevented companies from moving forward on investment in appropriate premises, equipment and other facilities...," said the BVSF. "This is likely to mean insufficient capacity to deal with ELVs...and a worse situation than the fridge problem."
Another reason is that some dismantlers may feel they have no way of knowing how they will recoup the cost of upgrading their facilities. "I'm having fingers stuck into me by the DTI, DEFRA and the Environment Agency telling me I've got to do this but I don't," said Dick Smith, managing director of HBC Vehicle Services.
Mr Bridges disagreed that there will be a lack of capacity. "We see the Directive as an opportunity. By becoming more professional and hiking capacity we hope to be ready." However, increasing the capacity of certain sites will not provide the national network of ATFs which the Directive requires so that motorists do not have far to take their cars to be scrapped.
The density of such a network is a key issue for car manufacturers, who will have to submit annual plans for providing what the Directive describes as "adequate" collection networks (ENDS Report 342, pp 50-51 ). Mr Everitt told the Committee that the industry wants "more flexible approaches", such as the pooling of manufacturers' networks or simply a free-phone number, in areas of low population density.
The BVSF also warned that its discussions with the Environment Agency have left it "seriously concerned as to whether it will have sufficient resources to operate the new permitting requirements for ATFs and be able to police the system."
According to Biffa, informed industry sources suggest that at least one-third of scrap yards are operating illegally. But "no one in the DTI or DEFRA seems prepared to shut down the thousands of scrap yards operating in the UK to grossly polluting standards."
"DEFRA tells us there is no longer a problem with fridges - there is. We are still emitting 50% of the ozone-depleting substances those regulations were supposed to cure," he told the inquiry.
For companies contemplating investment in logistics or reprocessing, he said, "there is no assurance that there will be a level playing field on enforcement."
The lack of vision in Government, said Biffa, has made the working of Departments "ad hoc, non-strategic and reactive". It is "somewhat harsh to lay all these inadequacies purely at the door of DEFRA" - the "unwilling handmaiden of a process in which they do not have a hope of coping without the support of the Treasury, Office of the Deputy Prime Minister and DTI."
Biffa was scathing about the DTI, alleging that it "sees its task as primarily about delaying the introduction of incremental costs to their private sector industry customers. As a result, strategy...is characterised by deferral of deadline dates, watering down and the transfer of liabilities onto local authorities..."
How the DTI, which has the lead on the Directive, intends to ensure that a "high level" of separate collection of electrical appliances is achieved remains unknown.
A few months back, several business organisations said the DTI had told them it planned to place some form of duty on local authorities to provide collection systems (ENDS Report 344, p 16 ). But Dirk Hazell of the Environmental Services Association told the inquiry that the DTI "has indicated that it is not minded" to introduce such an obligation.
"As it is generally accepted that the UK already achieves the 4kg per capita collection target...there is little incentive for the Government to promote the separate collection of WEEE," explained the ESA's written evidence.
The retail sector appears to have fought off the threat of mandatory in-store take-back, which is a requirement in some European countries. Instead, said James McKechnie of Sainsbury's, "we are lobbying to say can we part-fund local authority schemes." Mr McKechnie said that some councils are interested in providing collection facilities - if funding is provided - especially if WEEE can count towards their statutory household waste recycling targets.
The British Retail Consortium was unimpressed by the DTI and DEFRA's preparations for implementing the Directive, which should be transposed into UK law by August 2004.
The two Departments, it said, have only very recently completed a survey of civic amenity sites to understand what provision is already being made for WEEE collection and the gaps that need to be filled to meet future collection targets. Although the UK already meets the 4kg per capita target, the Directive requires the targets to be revised by 2008.
According to the BRC, the ad hoc working groups set up by the DTI and DEFRA with retailers, reprocessors and retailers "lacked a clear set of objectives" and "only satisfied the need to adhere to procedural steps in consulting with stakeholders and allowed the Government to show a degree of willingness in gathering external views."
Although DEFRA has allocated funding to several local authority WEEE collection and recycling projects, "there has been no evidence to suggest collaboration of data or Government developing policy against any of the outputs..."
The "secondary role" and "limited involvement" of DEFRA has left the BRC concerned about "its capacity to implement the Directive". Its high turnover of staff has "stifled decision making" and left it bereft of understanding of industry.
The ESA would like to see a system of tradable permits introduced for WEEE, similar to those used by the "broadly successful" packaging regime. But the DTI's discussion paper on how to implement the Directive, issued in March, suggested that a statutory system of compliance notes should be kept separate from the financing system (ENDS Report 339, pp 45-47 ).
The Government has given no indication of how it proposes to monitor and verify the recycling and recovery of WEEE in countries such as China and India, the ESA pointed out. In the US, environmental groups have accused PC manufacturers of sending most of their waste equipment to such countries, where labour costs are low and workers can be exposed to hazardous substances (ENDS Report 341, p 33 ).
Whitehall also appears to be doing nothing, said Mr Hazell, to implement the Directive's requirement to encourage waste minimisation.