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Committee for the Environment

Inquiry into Used Tyre Disposal

The Chairperson:

You are very welcome, Ricky. Thank you very much for coming all the way to Hillsborough. Did you enjoy your drive down here?

Mr Ricky Burnett (Arc21):

Fortunately, it is a lovely day.

The Chairperson:

We have your briefing. If you give us a 10-minute presentation, I will let members come in for questions.

Mr Burnett:

Thank you, Madam Chair and members. I am policy and operations director with Arc21. As members will be aware, Arc21 is one of three waste management groups that were set up by councils in Northern Ireland. My group covers 11 council areas located along the eastern seaboard, with Ballymena Borough Council being the most northerly and Down District Council the most southerly.

In responding to the invitation to give evidence to this inquiry, we were fairly conscious that individual councils had also been approached and that they would have their own views and offer their own statistical information to the Committee, and we felt that it was appropriate to let those councils have their say. We, therefore, decided collectively to focus in a wee bit more detail on the strategic perspective, and that is what we have tried to do in our concise response to the Committee. We tried to look at it from two basic angles: the current framework, particularly the enforcement aspects; and, secondly, whether that framework is the best framework available to ensure that tyres are properly managed or whether there is another framework that could improve on that situation.

I will deal with the enforcement side of things first. I think that the evidence that has come forward to the Committee so far suggests that enforcement could be improved. As members will be aware, the enforcement function primarily lies with the Northern Ireland Environment Agency (NIEA). We feel that the agency could make enforcement a greater priority within the current framework. What this highlights is the fact that improvements could be made not just in the management of waste tyres but in the management of waste in general and illegal operations. For me, it highlights the fact that there is an opportunity here to ensure that there is greater liaison between councils. We believe that NIEA and councils have a role to play.

Members will be aware that a protocol was developed, certainly in respect of fly-tipping, whereby we tried to bring that liaison to a head. Talks are still going on. In fact, I was at a meeting in the past month with senior officials from NIEA and officials from the Northern Ireland Local Government Association (NILGA). I think that we are beginning to see a bit of light at the end of the tunnel after the difficulty in coming to an agreement about the lines of demarcation. Senior officials from NIEA are certainly talking in more constructive terms about trying to arrive at a position where both organisations, which have separate strengths, merge those strengths and take advantage of them. At the moment, that is not happening, because they are working separately. There are no real mechanics for liaison between those groups, and I think that that is a fundamental flaw.

For my sins, I have previously worked with Glasgow City Council and the Scottish Environment Protection Agency, where I dealt with incidents of fly-tipping. In fact, I was personally involved in an investigation into a fire at a used tyre outlet, so I have a wee bit of experience with this. One of the things that is different in Scotland compared to Northern Ireland is that there is greater liaison between councils and the environment agency. I saw that from both sides there, and that is what is lacking in Northern Ireland. There is certainly a lot of scope there for that at a regional and local level. I think that we have to acknowledge that that there are local circumstances that must be taken into account. It is about putting the framework in place that allows that to happen.

There was an organisation known as the pollution co-ordinating committee where the environmental regulators and councils talked, at a regional level, about the big strategic picture. That then flowed down to similar meetings at a local level between council representatives and local representatives from the environment agency. That is a model that could be worth looking at, and tyres certainly come into that phrase.

The current legal framework in respect of the duty of care is really the main plank of enforcement. As members will be aware, it is a self-regulating regime. The stark reality is that it is not too difficult to circumvent that if you have parties that want to do so. It is about recognising where that is, or could be, the case and then structuring your activities to address that. It is not really too difficult. However, it will require local knowledge, which councils have, and the bigger picture, which the NIEA has, as well. It is a matter of those organisations getting together and sorting that out. There is a lot of scope for improvements to be made in the current framework.

Are there other ways of improving the framework? In our response, we very much favour work on a more producer-responsibility type of approach to dealing with waste tyres. Waste tyres are one of those materials that lend themselves to that type of model. Producer responsibility could cover a wide range of things. The devil is in the detail, and it would be important to look at the detail. It would bring the strength of linking the manufacturing and production element of the product with the retail element. What happens at the end use of that product — the treatment and disposal? It would bring a much clearer linkage between those. That strength in the framework could improve the management of waste tyres.

The private sector has the capacity to deal with that. I do not think that there is anything to suggest that it has not. However, it is a matter of applying a framework that will encourage and improve that management in a cost-effective way, which is quite important, particularly for tyres. It is a niche material, as members will appreciate. The danger with niche materials is that organisations may be able to set up a monopoly, which, at the start, is fairly cost-productive but, as time goes on, unless that monopoly is challenged, prices will escalate to an unacceptable level.

In some respects, the evidence suggests that the disposal of tyres has improved over the decade. I do not think that anyone has come before the Committee to suggest that that is not the case. From a strategic perspective, the current waste management strategies call towards resource management. Bizarrely, it is clear that that is happening. Increasingly, waste is being viewed as a resource, and rightly so. It is a material that has a value and a worth. However, the downside is that when you have a material that has a value and a worth, criminal elements will go in there and take advantage of the financial rewards that can result from circumventing the correct procedures and processes. It is about targeting those kinds of people as well. From a strategic perspective, that is possible.

In summary, first of all, we think that there is scope within the existing framework for the enforcement activities to be smarter and for there to be closer liaison between councils and the NIEA. Secondly, changing the existing framework to producer responsibility is something that should be looked at in great detail. Strengthening the links between the three aspects would bring a strength that would enable the management of waste tyres to improve. I know that is very short, but I hope that it is concise enough. I am open to any questions that members may have.

The Chairperson:

Thank you very much, Ricky. People working together — the councils and the NIEA — does make sense. Councils have more local staff on the ground to keep a watchful eye on the illegal dumping of tyres.

Mr Burnett:

I absolutely agree. Each organisation has its strengths, and it is important that they are brought together to take advantage of those strengths. That is what is missing. It is just not there at the moment. I know that NIEA is castigated and, in some cases, rightly so. However, I detect a change; it does want to work more with councils. I hope that that is not rhetoric, and I hope that it actually sees that through on the ground. I was encouraged by the meeting that was held with senior officials of NIEA. The protocol that was developed for fly-tipping is as applicable to tyres as it is to anything, and NIEA said that it was willing to look at some aspects of improving it. I do not like the word “concessions”, but NIEA might take on more responsibility, even within the lines of demarcation. I take heart from that, because I believe that there is a true willingness to try to work together. Unless that is brought about, it will be difficult to improve the situation.

The Chairperson:

NIEA just never seems to have enough enforcement officers on the ground.

Mr Burnett:

I accept that there is a resource element, but every organisation that sits in front of the Committee, including councils, can make that argument. Sometimes it is too easy an argument to hide behind. This is about working smarter within your constraints and about the strengths of both organisations. That makes rational sense, to my mind. Both organisations can then benefit. By working together and sharing intelligence you can only improve.

The Chairperson:

You mentioned producer responsibility. We have heard people talk about branding, registering and having serial numbers on tyres. What is your view on that?

Mr Burnett:

There are different ways of doing it. You can mark them, microchip them or whatever. I will be honest and say that I do not have sufficient depth of knowledge to be able to say that this would be better than that. You have to look at the particular material and design the producer responsibility around that. We have seen producer responsibility applied to batteries, end-of-life vehicles and waste electronics. Each is slightly different and has different characteristics. What we have to do is look at those characteristics. You will not be able to design a system that is flawless. I remember reading about systems on a beach one day, while on holiday. The final line stuck in my mind: “Show me a system, and I will show you an Irishman who will beat it.”

You can apply “Scotsman”, “Englishman” or whatever to that, but it is absolutely true: you will never get a system that is flawless. However, the important thing is to get a better system and improve it for the general good. Producer responsibility will do that. I believe that there are 13 countries in Europe that have producer responsibility, in its various guises, applied to tyres. I believe that Italy was going to introduce it this year, but now it has other problems to focus on.

The Chairperson:

Called money?

Mr Burnett:

Yes. France, Spain, Portugal, northern European countries and Scandinavia have all introduced producer responsibility. Denmark may be an exception: I think it has a tax levy system and a greater role for intervention, so it is slightly out of step with that trend in northern Europe. There are different models in different countries, and we need to look at those models and take the best elements which would apply to our own local situation. Our local situation might differ slightly.

I know that that is not a concise or black-and-white answer to the question; a bit of research needs to be done. However, I firmly believe that a system could be designed that would be appropriate to us. We would need to consider the application of that system within this devolved Administration and the impact that it might have, not just on the other devolved Administrations, but on the Republic of Ireland. We are the only part of the UK which has a land border, as you know, and sometimes the other devolved Administrations do not appreciate the impact that that can have. All those things must be taken into consideration. However, I absolutely and firmly believe that a system could be designed that would be appropriate for us.

Mr Boylan:

Thank you very much for your presentation. Just to follow on from it, obviously, we have talked about microchipping and everything else but, realistically, what is the practical way forward? You mentioned the need for better linkage. Maybe I caught you wrong, but did you say that in Scotland there is better linkage?

Mr Burnett:

In terms of enforcement and the organisations involved, in particular councils and the environmental regulator, the linkage I was referring to was the life cycle of the material in tyres. There are the people who manufacture and produce it, those who retail and sell it and, once it has been used, there are those who dispose of it. It is about linking that.

By implication, producer responsibility puts the onus on producers. At the moment, in our free-market system, manufacturers do not really worry too much about what happens to it afterwards. Retailers do not worry too much. It is almost as though they are in separate silos. We are pushing that responsibility onto them more. They, through their own pressures and obligations that they have to make, will bring strengths to the table that will make the system better. They will actually help the enforcers and regulators to address those who are hell-bent on making money through what is nothing more than criminal and illegal activity. There is no real, great motivation for retailers and manufacturers to actually deal with that. They will say that there is, but the reality is that when it comes down to it, there is not really.

Mr Boylan:

I agree with what you say. I have some reservations. Obviously, there needs to be some form of enforcement. However, that comes at the end of the process, when you have gathered evidence and intelligence and are able to follow up on it. Basically, the practical thing for us, which we need to address at the end of the inquiry and come up with recommendations, is how to record. A recording system is needed, from producer to end of life, disposal or whatever it is. Have you any examples of that? Is there anything out there? Is it the likes of invoices, audits, or what?

Mr Burnett:

Yes. If you look at waste in electronics, an area where producer responsibility has been dealt with, it is done exactly like that. It is linked into sales and what is produced. What is done is almost like a mass balance. You could do that to some extent now within the existing enforcement framework. If you go into a retail outlet, they will have sold X amount of tyres. Normally, when you buy a tyre, you give them your waste tyre. Therefore, with a certain tolerance, if the retailer sells 100 tyres, you would expect them to dispose of, say, 95 or 96 tyres. If, suddenly, their books showed that they had disposed of only 50 tyres, alarm bells would ring. Even within the current framework, that is possible.

However, by introducing more of a producer responsibility framework, there would be a better chance of a more auditable trail being introduced. To some extent, you can mark tyres and what have you. That would help. By doing that, you would improve the situation. Although it would not give you 100% guarantees in everything, it would certainly lead to innovation. It would encourage retailers to keep prices down. It would also help enforcement. Totally changing towards more producer responsibility would be a win-win situation on a number of fronts.

As regards the detail behind it, I would love to be able sit here — in fact, I would not sit here and tell you the answers. I would keep the answers for my own commercial ventures. I would love to be able to say that I had the answers, but I do not. I believe that the answer lies somewhere within that approach. It is a matter of taking the different guises of producer responsibility and applying the right ones for this Administration.

Mr Boylan:

I have one final question. It is important that we look at it from the point of view of producers. There are a lot of car dismantlers. I know that, in some areas, people can go to car breakers or car dismantlers — whatever you like to call them — and pick up a reasonable tyre for a certain amount of money. Unless you can trace that tyre back to the production line, you will lose out. That is an element of it as well. I think that that is the way to go, it is just whether we invoice it or come up with some marking for tyres.

Mr Burnett:

We already mark sheep and cows, so why not tyres? Products have serial numbers. It is not beyond the bounds of possibility. Do you mark it or put a microchip in it? There are ways round every system of doing it, but there will be a best way. Microchipping has some advantages. It is a way to do it. You tie that into the auditable trail of where those tyres will go, and it makes it a wee bit easier. We also have to recognise that there is a slight cost associated with that. However, when ordinary people are paying close to £2 for a tyre, I do not believe that introducing a more producer-responsibility approach will actually make it more expensive. I cannot see how that could be the case. I am sure that manufacturers will say that it would be, but I would like to see their evidence for that, because I am not so sure that it would. The producer responsibility will motivate them to find a way to do it that keeps the cost down, because it will be in their commercial interests to do so.

Mr Boylan:

Do you still think that the Irishman will find a way round it? [Laughter.] Sorry, you do not have to respond to that.

Mr Burnett:

Or a Scotsman, I might add. I would not be nationalistic about it in any fashion or form.

The Chairperson:

Let us just say “people”; that does not point to anyone.

Mr Burnett:

I am quoting the article that I read.

Mr W Clarke:

Thanks, Ricky, for your presentation. You have probably answered most of the questions that I was going to ask about the audit trail. That is the biggest weakness, and you outlined that. You need a document, an audit that follows the tyre’s cycle. For example, it could go for retreading, but the document needs to follow it on that journey. I agree that the microchip is the best solution. You could cut out a serial number and dispose of the tyre whatever way you want. It is slightly more difficult to do that with a microchip.

I liked the idea of an exchange scheme where you would be exchanging your tyres for new ones, and there is an audit of that as well. A number of European countries have not-for-profit organisations that collect the tyres on behalf of the producers, and they actually finance those organisations. First, what are your thoughts on that? Would that work, given the current economic climate, with high unemployment? Is there an opportunity for that to work in the North? Secondly, have you any data on the number of tyres that are recovered in Arc21’s jurisdiction, and how many are actually used in Arc21’s jurisdiction?

Mr Burnett:

I will deal with the second question first: no, I do not have any data. We took the view that we would leave it to individual councils to bring individual data to the Committee, rather than collate it, because the councils are better placed and, in fact, wanted to respond to you individually more than collectively. We felt that our response should look more at the strategic picture, which you touched on in your first question about the exchange scheme and the not-for-profit, social-enterprise-type approach. I think that it lends itself very much to that type of approach. There are advantages that certainly could be got from that. I am sure that it would appeal to manufacturers and retailers as well, because they would be able to demonstrate an element of corporate social responsibility. They would be able to show that it is not about making money but about the proper, responsible management of a resource rather than a waste product. That type of approach would certainly tick an awful lot of boxes.

Mr W Clarke:

My thoughts on that would be that the collection point would be moved on to another part of the business, the not-for-profit business, which would actually recycle the tyres.

Mr Burnett:

Traditionally, as you know, the collection point is the retail tyre outlet, and that is probably the core. You go to the tyre depot, change your tyres and leave the old ones there. I suppose that, to some extent, it is unlike any other waste stream in that regard. That would still be the core — the actual collection point. The social enterprises and the third sector could come in and take it from there. I think that, on the whole, it would be difficult to move away from having the collection point away from the point of sale. You could still have other points of collection to offer as an alternative. However, the retail point would still be the heart of it.

The Chairperson:

Thank you very much, Ricky, for coming to speak to us.

The next presentation is from Kerr’s Tyres. There is no briefing paper; it is just an oral briefing from Norman Kerr, who is the proprietor of Kerr’s Tyres.

Mr Norman Kerr (Kerr’s Tyres):

Hello.

The Chairperson:

Hello, Norman. You are very welcome. Thank you very much for coming to Hillsborough to talk with us. Please give us a presentation of about 10 minutes, and then members will have questions to ask you. Is that OK?

Mr Kerr:

Yes. Basically, we in the tyre industry see the problem as coming from us. We are not regulated or licensed; there are no laws or legislation to say what we should do with our tyres. We all have our own ethics as tyre dealers and we dispose of our tyres responsibly, but the majority of the trade is where it originates from. There is no licensing or legislation; there is absolutely nothing. That is where the problem starts from. The tyres are fly-tipped, put on bonfires or given to farmers for their silage heaps. Until you go to the root of the problem, it will always be a problem for Northern Ireland.

As a body, we are quite willing to pay to be licensed. We understand that the Assembly does not have money to regulate it, police it and enforce it. The majority of tyre dealers in Northern Ireland are more than happy to pay to be licensed and for you to police us. That is where we are at the moment.

The Chairperson:

Sammy Wilson will be very pleased to hear that.

Mr Kerr:

We understand that, in these economic times, you cannot find £100,000 a year to police the tyre industry. However, it is a problem that you need to address. We are reasonable tyre dealers; we are willing to pay to be licensed so as to regulate what happens with our waste tyres.

The Chairperson:

Who should be dealing with the waste tyres and who should be disposing of them? The manufacturers?

Mr Kerr:

No, it is our responsibility. We are the people making profit from the sale of the new goods, so it is our responsibility to deal with the removed product at the end of the day. We are quite happy to send them to licensed tyre dealers to get them shredded and used in an environmentally friendly manner, but nobody will police us. It might sound strange, but we are asking to be policed. We want somebody to say to us, “You fitted 40,000 tyres; can you show me what happened to the used 40,000 that you took off?” Absolutely nobody does that. Until you do that, it will keep going.

The Chairperson:

That is where the problem is. Nobody manages or monitors it.

Mr Kerr:

There are four licensed dealers in Northern Ireland that can dispose of your product. None of them has ever picked up a tyre from a used tyre dealer. Where are those tyres going? They fit between 15% and 25% of the tyres in Northern Ireland, which is about 250,000 units. Where have they gone to, and where are they going to?

The Chairperson:

They have gone missing.

Mr Boylan:

Thank you very much for coming to the Committee. It is my understanding that most people who change tyres pay perhaps £1·50 or £2.

Mr Kerr:

Yes; to dispose of the product.

Mr Boylan:

Yes. As a customer, that is fine. I do not mind paying it, but I want them to be disposed of properly. There are a couple of different sets of people. There are the likes of you and the retailers, who are selling the tyres. You also have the car dismantlers. I do not know how you would get a record of that, because I can go to any car dismantler and buy a tyre for £20 with a reasonable tread on it. A lot of people do that, especially in these economic times. Are we saying that none of that can be traced?

Mr Kerr:

Correct.

Mr Boylan:

You are coming from within the company. Are you saying that there should be a paper trail? Do you get invoices for tyres?

Mr Kerr:

I have a paper trail. Reasonable tyre dealers have a paper trail. It is simple. You cannot get in a taxi unless it is licensed — well, you should not — and hand over money. However, you can buy a tyre anywhere from anybody.

Mr Boylan:

We are trying to get the operator licensing passed at the minute. Do not record that. [Laughter.]

I agree with you. There is a beauty spot outside a town in my constituency where people go walking and use the lakes for fishing. I guarantee that, if I were to go there today, I could find tyres dumped in the forest. I phone the council regularly about that. Someone from the council comes down, and this person and that person do not want responsibility. Eventually, thankfully, someone from the local council will lift those tyres, but that is down to the ratepayer. What bugs people is that they pay £1·50 or £2 for disposal yet tyres are found lying or, when you are driving down the road, you see someone stop and fire them over the hedge. That still happens. We will not get all of it, but, if we can get 95% of it disposed of properly —

Mr Kerr:

I cannot understand why you cannot get all of it. It is not rocket science. It is quite simple.

Mr Boylan:

The only way to get all of it is to have a proper paper trail and a proper audit of every tyre that is produced. There will come a time when car dismantlers will go over to England and bring cars back here and break them up. You need to have a clean slate and start all over. If you are going to code, mark or chip every single tyre that is produced from 1 January 2012, there will still be a transitional period until we get rid of the existing tyres and get on the straight and narrow. Have you any suggestions to the Committee on how to introduce that? I do not think that there is a foolproof way, but we should try to get the biggest possible majority of these tyres.

Mr Kerr:

There is no foolproof way in anything, and people will always find a way around it if they want to. That goes without saying. Anyone who supplies or fits a tyre in Northern Ireland should have a licence, and, if they do not have one, they should not be allowed to do it. It is that simple. We will fund the money for you to employ the people to go around and police it. As a body, we are quite happy to pay £1,000 a year per centre just to have a licence. That would allow me to be inspected, and I could show that I fit 20,000 tyres a year and my paper trail for the 20,000 tyres that I had taken off.

We are quite happy to do that as a body. I have spoken to probably 80% of the tyre dealers in Northern Ireland, not one of whom has an issue or a problem with it. In fact, they are all saying that they hope something comes of it. The other 20% are scrap men and second-hand dealers, and they will not buy licences but try to work underhandedly. Dealers from our body would be paying between £150,000 and £200,000 a year to pay for one or two people to work on the ground. We could phone them to say that Joe Bloggs has opened a tyre shop next door. If he does not have a licence number, he should not be trading. If he trades legitimately, has insurance and disposes of his product correctly, he has every right to trade, like everyone else.

Mr Boylan:

Taking all of what you said into consideration, tyres need to be marked in some form, because there is no way that you would be able to trace them.

Mr Kerr:

Why could you not trace them?

Mr Boylan:

Obviously, there needs to be some number identification, and that cannot just be an invoice, because you are given a certain number of tyres on an invoice. There might be a miscalculation. If we are serious, the only way that we could possibly do this is to identify clearly each tyre.

Mr Kerr:

You cannot do that. It is too impractical.

Mr Boylan:

At the production stage, it would not be very hard to put a number on it.

Mr Kerr:

It has been tried all around the world, and it will not happen. The manufacturers will not do it. You need not think that the manufacturers will listen to us in Northern Ireland, which represents 0·01% of the tyre industry, and decide to chip tyres. If they were to do that, they would have to do it for everyone.

Mr Boylan:

We are not saying that the tyres should be chipped. If we are serious about trying to deal with the problem, the tyres need to be identified. Some marking is needed. It could be a simple mark or a simple number.

Mr Kerr:

Every single tyre produced in the world has a unique code. There are serial numbers on them, so that is not an issue. The issue is who will write them all down. I fit 40,000 tyres a year; I would have to employ two men to register 40,000 serial numbers every year. That becomes impractical.

Mr Boylan:

We will take it on to the next step. If the manufacturer is marking a tyre and taking down the serial number, the information has to be stored somewhere. It has to be on a database. The manufacturer does not just manufacture a tyre and go through all the business of putting a number on it without having some kind of database. I would safely say that most of the main manufacturers have that. Are you saying to me that they do not?

Mr Kerr:

No, they do not. They can only identify them as batches. That is purely and simply for quality control. The American transport industry also insists on a Department of Transport number.

Mr Boylan:

So it is only in batches.

Mr Kerr:

It is only done in batches, and that batch could end up in China, here or absolutely anywhere. As reasonable tyre dealers, if I fit 40,000 tyres I have to provide a paper trail of where my 40,000 tyres went to. Those 40,000 tyres had to go to a licensed recycler of that product. You then go to him and say: “Joe, David and Norman each gave you 40,000 tyres. What did you do with those 120,000 tyres?” That is the next step in the line. He has to say to you: “I shredded 200 tons and sent them to Readymix for use on roads. I took the steel to T-Met to be recycled there. There is where my by-product has gone.”

We do not have 1,000 outlets to get rid of tyres. We have only four. We can send them to only four places; that is it. So you do not have to run to 1,000 people to see what happened. You just have to go to four people to say: “Right, they told us they gave you the paperwork for those tyres. What did you do with them?” I am not trying to be funny but it is that simple.

Mr Boylan:

We are trying to find a way around, but, listening to what Norman said, it seems a very simple process: just get a document for whatever number of tyres, go to wherever you dispose of them, and that is it. The whole enforcement idea behind all that is that as long as somebody is checking on that every year or checking the documents —

Mr Kerr:

That is part of your licence remit every year. To get a licence renewed, they must come out and inspect whether you have insurance and whether you sent your tyres off reasonably. If you did, well and good: you will get your licence renewed. If you did not, it will be revoked and you cannot trade. Personally, I think it is quite simple — maybe it is too simply.

Mr Boylan:

We are only asking. That is why we are doing the inquiry. However, it seems to me that if it was that simple, I would not still be phoning up the council to get tyres removed from forest parks where somebody fired them over a hedge. That is the problem.

Mr Kerr:

It has always been that simple, but nobody has been willing to pay for it to make it simple. As the National Tyre Distributors Association, and as independent tyre dealers within Northern Ireland, we are willing to pay for it because we can clearly see that nobody else is. The Government are not willing to do that and you do not have the money. We understand that. We are not having a go at you to say why are you not paying for that? We understand that nobody has the money. Money has to go elsewhere where there is more of a priority. We are willing to say that we will pay for it.

Mr Boylan:

Norman, the consumer will pay for it.

Mr Kerr:

Ultimately, the consumer will pay for it.

Mr Boylan:

That is the main one: the consumer will pay.

Mr Kerr:

Ultimately the consumer will pay for it.

Mr McGlone:

They are at the minute.

Mr Kerr:

The problem we have is that they are paying for it already and their tyres are not being disposed of legally.

Mr Boylan:

We know all about it. Thank you anyway for your presentation.

The Chairperson:

Sometimes, a simple, straightforward method is the best method if it is workable.

Mr Boylan:

Throwing them over the hedge.

Mr McGlone:

Thanks very much, Norman, for bringing a bit of light to this issue. My father, God rest him, was in that particular trade, too. I understand that even if you had all the numbers of the day on each and every tyre, they would be buffed off. We know the way it works.

I want to get a wee bit more clarity around what you are saying. You have a licence. Your VAT returns will show how many tyres you take in, and your returns at the end of the year will show how many you sold. They will also show how many you charged £2 for on each invoice. You are saying that that should be tied in with the licence so that you have an input from the submissions made to the VAT authorities, you know precisely the total number of tyres remaining in stock, and everything should square. If that does not square, your licence is not renewed.

Mr Kerr:

The first question is why it does not square. If you cannot explain that, there is obviously a reason. A problem can be identified with that dealer. At that point, it is up to you to police that in some way, in whatever fashion you wish, whether through fines or treating it as a criminal matter and reported to the police.

Mr McGlone:

The second thing is the associated costs. We are probably already paying the cost of gathering up old tyres wherever they are and getting them dealt with, and for additional enforcement measures. It seems clear to me what you have outlined as someone in the trade who knows what it is about, how it works and how it can potentially go wrong. There is only one thing, and I suppose we can do nothing about the breakers because they are unregulated: the guys who are sending the tyres they are maybe taking off old cars somewhere along the line and selling them off for whatever it may be. Those people could still prove to be a problem. Have you any ideas on that?

Mr Kerr:

Yes, they have to be licensed. If you want to sell a tyre in Northern Ireland — new, used, second-hand or whatever — you have to be licensed.

Mr McGlone:

So you are saying license the whole works.

Mr Kerr:

Yes: if anybody sells a tyre in Northern Ireland, they have to have a license.

Mr McGlone:

I am trying to drill down on that bit, because that will probably be the problematic one.

Mr Kerr:

The guy who is breaking a car is not where the issue stems from. He is removing a second-hand product as such. He is not actually taking an old product back in for that. He is just giving them to you and you are disposing of your own tyres yourself, usually in a car breaker’s yard. They buy the complete unit. They just screw a set of wheels on and leave the other set of wheels lying in their garage.

Mr McGlone:

To drill down a bit on that, how do you regulate that bit? You have just said that he comes in and somebody says, “There is a set of wheels, take them with you.” What about the old tyres?

Mr Kerr:

Each person will be responsible for them themselves. There is nothing you can do about that. It will not be a business. It will be an individual, through his household waste or whatever he does with his household waste. He will have four complete wheels or four tyres sitting in his garage. How you overcome that one is beyond me, but I reckon that 0·01% of people in Northern Ireland buy their tyres through a salvage yard. It is not a big business by any stretch of the imagination.

Mr W Clarke:

Thank you, Norman, for your presentation. I agree entirely. It is simple enough if you get a licensing system with proper audit and proper enforcement. That is the key and that is why we are here. The Committee was frustrated that enforcement was not taking place and that there was an ad hoc approach. It has done a disservice to genuine traders like you. It is simple enough, and the recommendations coming back from this will clearly point out that there needs to be properly resourced enforcement and a proper licensing system, one where you can lose your licence. Who would you like to see carrying out the enforcement? Would it be the Environment Agency, or local authorities, or should some other not-for-profit organisation be set up?

Mr Kerr:

A not-for-profit organisation should be set up that answers to a Committee, within the Environment Agency or whatever organisation you recommend within the Assembly. It should not be done by the tyre industry itself and it should not be done by anybody associated with it. It needs to be someone who is independent and who answers to you under your payroll, although we will fund the pot to pay that person. As an industry, we do not have a problem with that. It needs to be independent, and it needs someone with a bit of savvy and a bit of knowledge as to what to look for.

The Chairperson:

A tyre commissioner? [Laughter.]

Mr Dallat:

A tired commissioner. [Laughter.]

Mr Boylan:

It is a burning issue at the minute.

Mr W Clarke:

I am happy enough with that. I agree. It is a simple enough issue if the will is there to deal with it and you put in place proper licensing, regulation and enforcement.

Mr Kerr:

The will is there from the industry and the money is there from the industry. It is just a matter of somebody policing it and taking it upon themselves to do it for us. We are quite willing to do it and pay for it.

The Chairperson:

You suggested a figure of £1,000 a year. Would that be acceptable to the industry?

Mr Kerr:

It would be on the first licence. However, when the licence is renewed every year it would have to be at a different fee. However, for the first initial inspection, the industry as a whole feels that £1,000 is a fair value. We reckon that there are about 500 tyre shops in Northern Ireland. Realistically, you will get 300 of them and that will generate £300,000 in the first year, which should be enough to pay a salary for a few years. The licence fee could then be reduced to £100 a centre each year thereafter, and we would be willing to accept that. It would be enough to fund it for quite a long time.

The Chairperson:

It is well worth thinking about and recommending.

Mr Dallat:

I am sorry that we did not have Norman here at the beginning of the inquiry. I have just a couple of questions, as all of them have been asked. What is your view on banning the sale of second-hand tyres? I am thinking purely from a road safety point of view.

Mr Kerr:

From a road safety point of view it is a real problem at the moment. We had a meeting on Thursday night which normally lasts 20 minutes on that side of things, but lasted two hours because of the research that has been done recently. We see it regularly; unfortunately, the second-hand people do not have wheel alignment systems and do not invest in insurance. We spoke to insurance companies in Northern Ireland and asked whether a person is insured if he or she fits two second-hand tyres to a vehicle, goes off the road and the wheel falls off and kills four people. The answer is no.

Mr Dallat:

Hopefully, Chairperson, there is space in our report for that. I feel very strongly about the issue. Day and daily I see the carcasses of cars being taken away, but a lot of the tyres are going back onto other cars. They have not been X-rayed and nobody knows what fractures are in them. That could lead to a blowout on the motorway. I support that.

There is another thing about your scheme. I believe that if people are licensed they are generally honourable and probably do not require any more than self-certification, in the same way as you make your VAT returns or income tax returns; you submit it, and there could be spot checks. It is not something that is going to be terribly bureaucratic. It seems to be a simple idea, although it would not solve the whole problem.

Mr Kerr:

It is certainly not going to solve the problem.

Mr Dallat:

I imagine that you can get tyres online; I do not know.

Mr Kerr:

Yes, you can buy tyres online, but you have to bring them to the likes of us to get them fitted. That is not an issue either.

Mr Dallat:

I am glad about that.

Mr Kerr:

As a body, the only thing that frustrates us is whether we should pay for this and go ahead and do it if Joe Bloggs is going to open up next door without a licence. That is when we would kick up about it to you and ask why he is not being inspected and closed down and why he has not paid for a licence.

Mr Dallat:

Presumably, if a tyre distributor such as you is to be licensed, there are probably other basic things to look for apart from an ability to record the number of tyres purchased and sold; in other words, safety aspects relating to the equipment that is used for fitting tyres. I know of people who have been killed in tyre depots where rims have blown off and things like that. Our little inquiry into the disposal of tyres could include some sound recommendations that would add nothing to it.

Mr Kerr:

It is the only thing in the tyre industry that is legislated for, which is the duty of care. It is the only way, as a body, that we can tighten up on what people are doing. It is a problem that gives us all a bad name. We all get tarred with the same brush, unfortunately.

Ms P Bradley:

I am a small-business owner. Yours is not a small business. I do not know what your turnover is, but it is not the same size as mine. I know that I could not go to the Government and give them a grand and ask them to regulate something for me. What do you get out of this? There are lots of small businesses out there. There is one in my area that fits tyres as well as providing car washing and valeting. He is responsible, but tyres are not his main work; he does very few tyres. He is very good and very responsible; I know that because we have spoken about this issue.

There are lots of responsible small-business owners who are totally out of the market and who will not pay £1,000 to be regulated because it is such a small part of their business. Owners of small businesses have to be more imaginative and innovative nowadays to try to keep their businesses afloat. There are not too many small business owners who will sit there and say that they will give us £1,000 a year.

Mr Kerr:

The small business will become a medium-sized business over the head of this. It will eliminate the 1,000 other tyre people that you can go to in Northern Ireland that do not dispose of their tyres legally and correctly.

Ms P Bradley:

Do you think that small businesses will grow because of this?

Mr Kerr:

Yes, because Joe Bloggs, who fits three or four tyres a week and throws tyres in the skip will dwindle away. Those people will be got rid of. That customer base will stay with —

Ms P Bradley:

I do not think that it will get rid of them, to be perfectly honest.

Mr Kerr:

But at least they will be policed. That is what we are doing it for. We do not care about the licence, but the only way to police it is through the licence.

Ms P Bradley:

I agree wholeheartedly in principle with what you are saying. I think that there is a simple solution to this. We will take this back, and if we say, “This is a great idea; this is what we will do”, I can just imagine —

Mr Kerr:

Paula, I really do not care if I pay only £1 a year for a licence. We are just trying to think of a value; we do not care what it is. I do not care if I only give you £1 as long as someone is policing it.

Ms P Bradley:

One thousand pounds is a lot of money —

Mr Kerr:

That is fine. Make the value £1. The value is irrelevant to us. What is relevant to us is that someone is policing it. If that means that we have to give you £1,000 to get it policed, we will give you £1,000. If it means that we give you £1 to get it policed, and you pay for it yourselves, that is brilliant. I am a reasonable tyre dealer; I do not care. I would gladly pay £1. The fee is totally irrelevant to us. It was mentioned so that you could pay for the licensing scheme to be policed.

Ms P Bradley:

That is very generous of you.

Mr Kerr:

As an organisation, we will make a one-off donation to pay somebody’s fee for whatever, and you can give out the licences free of charge, as long as the licences are done properly.

Mr Dallat:

Paula makes a very valid point, and it needs to be discussed. However, certainly where I come from, if I leave my car in to be serviced and it needs new tyres, the man from the garage drives it down to the local depot and, presumably, he gets his 15% or whatever it is. I mean, you do not charge him the full price, do you?

Mr Kerr:

No. If we had a garage dealer who was coming to us with all his cars, he would buy his tyres at a different rate from the rate that you, just coming in off the street, would pay. That is correct.

Mr Dallat:

It is important, Paula. That is what happens in most cases that I know of. Garages do not undertake to put in all the balancing equipment and stuff that is needed, if tyres are not their main business. They go down the road and get them done at the tyre depot, they lift their profit margin and that is it.

Mr Boylan:

Just on that point, the whole notion of paying £1·50 or £2 a tyre is that an element of that should go into enforcement. Do you understand? That should be the practice. The principle behind paying is the proper disposal of the tyre, and that money should go towards enforcement.

The Chairperson:

People are quite willing to pay.

Mr Boylan:

I agree with Paula. Given the hard times, if you run your business and it is viable and the consumer is paying for it, which they do, that should cover it. Maybe we could discuss a price for a licence; it is open for discussion, but, generally, it is recovered through what we already pay.

It has been enlightening, to be fair. It seems nearly too simple to be true, to be honest. However, we will discuss that. It has been a good enough presentation. In the current economic times, small to medium-sized businesses need to be given an opportunity too.

The Chairperson:

The fee would probably not just be plucked out of thin air; it would be consulted upon with the industry.

Mr Boylan:

If that is the way we propose to go. It actually could be self-regulatory, by the very fact of having a licence and having to send in tax returns and everything else. That could be checked; do you know what I mean?

Ms P Bradley:

There is a simple answer.

Mr W Clarke:

There has to be proper enforcement. I do not think that this self-certification stuff will work. What you need is proper, robust enforcement. The reason why we are in this position now is that that is not being carried out. It is probably down to finance, as Paula said. I understand where she is coming from. Small businesses are trying their best. I think that there should be a sliding scale of fees, depending on how many tyres you are selling or replacing. There is room to manoeuvre. I agree with the point that Norman made about needing to target the illegal operators — the cowboys who are putting tyres on bonfires and dumping them all over the place — to grow the small businesses.

Norman: back to enforcement. That is the key to this. How many times a year are you inspected?

Mr Kerr:

The three centres? Once in the last five years.

Mr W Clarke:

Well, there you are. I rest my case.

Mr Kerr:

In that period, we have fitted 200,000 tyres or more.

Mr W Clarke:

And you wonder why there is a problem.

Mr Boylan:

We are not saying that Norman is doing anything wrong. He is operating his business.

Mr Kerr:

Willie is asking how often I have been inspected. I have not been, but I want to be inspected. That is the issue.

Mr Boylan:

We agree with that.

Mr W Clarke:

I want to tease that out. I am not saying that Norman is doing anything wrong, but there is an opportunity for everybody else. Norman has a big company, and he is not being inspected, so how are they targeting the illegal ones? They are not, and that is the problem.

The Chairperson:

The people know that there is nobody to watch over and inspect them, so they carry on the illegal practice.

Mr W Clarke:

The industry wants regulation, licences and enforcement.

Mr Kerr:

We want regulations and enforcement, and we want to be policed. We are willing to pay to have it done. That is basically where we are coming from as an industry.

The Chairperson:

Thank you very much. You have given us a lot of food for thought, and we will incorporate your remarks into our recommendations.

Our third briefing is from Southern Waste Management Partnership (SWaMP2008). We are joined by Graham Byrne, chief officer, Jason Patterson, technical officer, and Pearse McAleer, chair. Gentlemen, you are very welcome. Thank you very much for coming all the way to Hillsborough to give us a presentation. You can start with a 10-minute presentation and then members will ask questions.

Mr Pearse McAleer (Southern Waste Management Partnership):

I am Councillor Pearse McAleer from Cookstown District Council, the current chairperson of SWaMP2008. I thank the Committee for giving us the opportunity to contribute to your inquiry into used tyre disposal. I am joined by Graham Byrne, who is the chief officer of SWaMP.

Mr Graham Byrne (Southern Waste Management Partnership):

I will give a brief overview of SWaMP’s position on used tyres and will then transfer to Jason to get into the technical details. We have put together a table to show the numbers of tyres that we have had recycled in the area over the past five years. The total is in the region of 70,000 tyres of all shapes and sizes. That is roughly 14,000 a year that the councils have had responsibility for, and the average cost of recycling those has been between £15,000 and £17,000 a year. Our current rate is £1 to have a car tyre recycled by a firm in Craigavon, and that contract has been procured on behalf of our councils. The main quantity of those tyres comes from fly-tipping incidents. Some are removed from bonfires, and Jason will talk a little more about that. Some councils allow one or two tyres per person at civic amenity sites, and the main reason behind that is that, if we do not accept them, they will most likely be tipped in the country somewhere.

We have put together a few key facts. I know that you have had evidence on this before, but I will outline a few high-level facts that we got from the Environment Agency website. In the UK as a whole, it costs £2·3 million a year to investigate and clear illegal tyre activity. I thought that that was quite an interesting one. The second fact is that 450,000 tons of used tyres a year, if laid out in a straight line, would stretch from London to Sydney. There were a few other key facts. There are 18,000 tons of used tyres a year in Northern Ireland, the vast majority of which are obviously recycled properly. Our concern is the tyres that are not recycled but stored in large areas such as landfill sites. We are aware of one site in Wales that has been on fire for a number of years. They just cannot get the fire put out, so the pollution involved is extreme. Jason Patterson, our technical officer, will take you through the detail of this.

Mr Jason Patterson (Southern Waste Management Partnership):

I will go through some of the details surrounding the involvement of SWaMP2008 in the disposal of tyres in the region. In theory, councils should not have to deal with the disposal of any tyres if the policies in place with licensed tyre suppliers and garages were carried out correctly. We believe that the industry should be given overall responsibility for managing all tyre disposal, including fly-tipped or illegally dumped tyres in our region. That would reduce the need for our constituent member councils to have to deal with it and the associated burden on them and, ultimately, the ratepayers. In a number of consultations, including the revised waste framework directive, we have requested that there be overall producer responsibility.

On the issue of producer responsibility, historically, tyres have been banned from landfill since 2006. A voluntary producer responsibility system is in place, but there is no statutory responsibility on those producers to ensure that all tyres are sent for recycling or reuse. We believe that producer responsibility is the best way to ensure a cost-effective approach and to facilitate a fairer and tighter method of control.

Graham, in particular, has worked very closely with the Department to put together a number of other producer responsibility regimes, including work on the ultimate disposal of end-of-life vehicles and the waste electronic and electrical equipment (WEEE) responsibilities, whereby the burden of responsibility for ensuring that material, including fridges and batteries, is disposed of correctly is put back on the manufacturers and producers.

Historically, especially in the rural areas covered by SWaMP, there has been a build-up of tyres in the farming community following a change of farming practices over time. The move away from clamp silage to bale silage has left a lot of tyres in the countryside. We believe that the Ulster Farmers’ Union should work closely with NIEA to try to resolve the matter and to remove the large stockpile from the countryside.

I will move on to the legal framework. We are very concerned about NIEA’s ability to check the validity of current waste management licences and, more particularly, suspension orders on those licences. We need to know, on a weekly basis, whether the reprocessors that some of our councils are using are licensed to accept waste tyres. Graham has written to the Minister to request that a current live database be established for licensed reprocessing facilities, and, on the back of that, that the vehicles used by the reprocessers have some sort of identification, similar to the taxi disc plate system, to identify whether they are actually licensed reprocessors and hauliers of waste tyres.

Thankfully, the burning of tyres on bonfires is a diminishing problem in our region, mostly due to the very good work of council community relations officers. However, it still exists in some areas.

We have communicated our concerns about quantitative thresholds to the Department on several occasions. The threshold of waste that the Department wants councils to deal with is 20 cubic metres, which is an awful lot of tyres. It would mean that councils could end up paying thousands of pounds to deal with one individual incident of illegally dumped tyres in an area. We are asking for that threshold to be reduced substantially, down to the Scottish model of six cubic metres.

Mr G Byrne:

We would like to stress the importance of collaboration between central and local government if we want to get a successful resolution to this problem. We have done that before, as Jason mentioned, on a number of producer responsibility schemes. That is the way to go. We would like to see cost recovery for the councils’ involvement in that.

As Jason said, we have not had a response from the Minister yet — we hope to get one soon — with regard to our members’ suggestion that there be a live database for licensed facilities. Briefly, the reasoning behind that was that we were about to award a contract for tyre recycling, and we were unsure of the status of the company that we were about to award it to. Another member suggested that, if there was a system similar to taxi plates, you would be able to tell at a glance whether a vehicle was licensed or not.

The Chairperson:

Thank you very much. We heard earlier from two other groups, in a similar vein, really, on producer responsibility and better links between the NIEA and local government. That all makes sense. The last group mentioned licensing of tyre retailers: a clear paper trail of how many new tyres they sell in a year and how many old tyres they dispose of, with the licence fee to be determined. The industry is apparently quite willing to pay a fee to be licensed to be able to operate without the illegal ones. What is your view on that?

Mr G Byrne:

That could all be part of a producer responsibility scheme, really, as long as there is a duty of care. We know how many tyres go into the system. As long as there is a reasonable way of finding out that they are all covered and recycled, we are open to all considerations and keen to be involved in developing that.

The Chairperson:

Cathal, do you have a question?

Mr Boylan:

I had better get my question in quickly, before Willie comes back.

Mr Hamilton:

I nobbled him on the way in.

Mr Boylan:

Willie will have his own ideas when he comes back.

With regard to the presentation that we received previously, do you think that it would be a major burden on the industry if there was a suggestion of marking every single tyre in some form? Is that a route to go? The Chair has raised the issue of invoices. Maybe you could have three- or four-year annual checks, or monthly checks or whatever it is, going round the producers to check the documents and invoices. Do you think it would be a problem? Would it be a major burden to have every tyre identified in some way or form?

Mr G Byrne:

We have spoken about this, and we have read the Hansard reports of the other evidence and collected evidence ourselves. It seems to be the case that most people are paying about £2 per tyre for recycling. We are paying £1 per tyre, so we believe that there is financial capacity in the system to bring in an additional financial burden without adding a further burden —

Mr Boylan:

But there are practicalities of doing that. The last witness said that tyres are made up in batches. I am only throwing that out because at the end of this inquiry we will have to look at what way we want to resolve it or bring recommendations. If you go into any shop, there is a barcode on nearly everything. I am only using that as an example.

The Chairperson:

Even a packet of crisps has a barcode.

Mr Boylan:

There are millions upon millions of items out there being sold on the markets and in shops and whatever, and they are all barcoded and identified. What I am saying to you is, and I asked the question the last time, do you feel, in your experience — or if you have any knowledge of it happening anywhere else — is there any suggestion that it is a major burden to identify tyres, be it microchipping or even coding? That is the question; I am just asking if you have any views.

Mr Patterson:

Graham and I both discussed his previous work on producer responsibility in relation to fridges. He mentioned that, historically, there was a type of tag put on to every single fridge that came in to the yard.

Mr G Byrne:

It is just setting the system up, to be honest. Most people fear change and do not want to bring additional systems in, but once they are in, those systems seem to operate fairly smoothly.

The Chairperson:

Would having a serial number or a microchip incur a lot of costs?

Mr G Byrne:

I really do not have a figure for the costs, but as I have already said, I think there is probably a free board of £1 already in the market. I do not imagine that it would cost more than that per tyre.

Mr Boylan:

It is an interesting point, Chair. It seems to me that businesses now produce tyres and go to the whole bother of making them up in batches. To add a wee bit of a database or something else in, just for a security check and all — I am not saying that that is the way to go, I am just raising it.

You mentioned the work on end-of-life vehicles, WEEE and the batteries issue, and producer responsibility. Is there anything from the practical workings of that, bar the tags that you mentioned, that could be brought in to clearly identify tyres or help us in making sure that the majority of used tyres are disposed of properly?

Mr Patterson:

With all the producer responsibility schemes and regimes that are in place, the key, from our perspective, is full cost recovery for the councils. That will be the key to any regime that is proposed. WEEE works very well, in parallel with the battery scheme, where councils do not pay out any money as such. The materials come into the yard and are sent off for reuse or recycling, but on the back of it the recycling schemes contribute at the very beginning to the upgrading of the council facilities to accept these materials. That is the key to it: full cost recovery, and any additional infrastructure that has to be built or put in is covered by the manufacturers.

Mr G Byrne:

That is a key point, Chair. We already have the network of facilities, and if there is producer responsibility and it is free to the public to bring tyres into the sites, that is how the other systems have been so successful.

Mr Boylan:

Sometimes when we are going through this process, people forget that ultimately it is the consumer that pays for it, no matter what, at the end of the day. We want to come up with a system. I am using the Armagh District Council area, where I am from. I am sure that I could take you down straight away to places where I know for a fact that tyres are dumped. It is a burden on the council. We have paid our £2 or £1·50, whatever it is. The council is going to remove them at some point. All it needs is some public representative to give it a phone call. That is not acceptable. We are trying to come up with some recommendations that will deal with it.

One final point, and this is the opposite end of the thing. The last day we went for a visit to some of the disposal companies and saw how they are actually trying to deal with this. Is there clearly a market out there strong enough to take the disposal of tyres, in terms of mats or reuses? Is there clearly a market out there for it? Have you any experience of that? It seems to me that we are baling tyres down in Portadown and shipping them halfway across the world for certain other reasons. Are we getting to a point where we are going to extend licences so that people can stockpile all these tyres? That is the angle that I am coming from. Can you comment on that?

Mr G Byrne:

Stockpiling is certainly a concern in the SWaMP area. There is at least one site that has a massive stockpile, and certainly the local members and officers are very concerned about it. We believe that the market exists. Certainly, the company that we use has given us evidence that it has end markets. Obviously, with the price of metals at the moment, there is a ready market for that. Whether there is a market sufficient to cover all that is produced, or whether it will be used for energy recovery — it has the same calorific value as coal, and obviously the energy market is a fairly endless outlet.

The Chairperson:

We have been to a few projects. They are certainly sustainable. They are obviously making a profit, or they would not be there.

Mr Boylan:

The other side of it is Mr Carragher, who was in and gave us a wee presentation about how he wanted to go forward. We have to look at it in the round as part of this whole process.

Mr McGlone:

Gentlemen, you are very welcome, particularly Councillor McAleer. It is good to see you, Pearse. Can we deal with the quantitative thresholds? I just do not know enough about that. You have put it in your paper, and it has started to intrigue me a bit: the threshold for councils in Northern Ireland “should be set at 20 cubic metres” of tyres. Presumably, that is up to 20 cubic metres at one batch? A dump of up to 20 cubic metres? I was just trying to work it out in my head, from my limited experience at a place called Ballyronan that Councillor McAleer will know all about. In a cubic metre, you are probably talking about 20 tyres.

Mr G Byrne:

More than that.

Mr McGlone:

Aye, 20 or 25, depending on the size. That is an awful lot of tires, and an awful lot of liability and expense going back to the local authority. I can see an awful lot of merit in what you are saying. That is a big burden on the ratepayer in any given council area.

Mr G Byrne:

That came as guidance from DOE, in conjunction with the Waste and Contaminated Land (Northern Ireland) Order 1997. Our response to that consultation was that we felt they should adopt the Scottish model of six cubic metres as a maximum. That was not the guidance that came back.

Mr McAleer:

I should add that, particularly in the area that we both represent, it is a big burden. Cookstown is one of the places that would have waste tyres; something like 4,000 a year. It is a big burden.

Mr McGlone:

It would be.

Mr Boylan:

On that point, I know that we have agreed the protocols, but maybe that is something that we can look at. We have agreed that.

The Chairperson:

The Committee’s previous position is that we have accepted that 20 cubic metres is OK. We can stand over that; we think that it is acceptable. We have said there should be no hazardous waste for councils to deal with, but 20 cubic metres is acceptable.

Mr Boylan:

Generally speaking. We went through the protocols, and it was only afterwards that we found out about the hazardous waste. Now this issue has raised its head, and it will be very costly for councils if it is based on what the council actually has the capacity to deal with. Maybe this is one issue that we need to revisit.

Mr G Byrne:

It is an unusual example of a non-hazardous waste which is going to be much more expensive to get rid of.

The Chairperson:

Thank you very much for your input, gentlemen. We are hoping to produce a report early next year.