ELV DISPOSAL CO. Ltd

                                             50 saint johns park
                                                    Sruleen
                                                    Clondalkin
                                                     Dublin 22

                                       Telephone / fax 01-4571672
                                              Mobile 087-2360076

                                                   Briefing Paper
                       6th March 1999 - ELV Centre - Brendan Keegan

                                      End of Life Vehicle Proposal

                                 Document No. COM(97) 358 Final
                                Catalogue No. CB-CO-97-360-EN-C
                                            ISBN 92-78-22708-0

This paper was prepared at the request of SIMI and represents a summary of the key points of *c proposed new Directive on End of Life Vehicles, as detailed in the documents referred to above.  It is intended only as a briefing document and those with a vested interest in this project should refer to the full text of the document which can be obtained either from the EU Commission publications office or from the Department of the Environment.

In the following, text shown, in italics in all cases are direct quotations from this document. 
 Use  of capitals/underlined is ours, stressing key points.

"The EU Parliament in its Resolution of 14 November 1996 (A4-0364196) asked the Commission to present Proposals an a number of waste streams, including end of life vehicles (ELVs), and to base such  proposals on the principle of produce responsibility

                           The legislation on ELVs will take the form of a Directive for many reasons, including the need to ensure legal and long-term investment certainty for economic operators.

"Only a Directive can ensure that all actors in the automotive chain (such as vehicle manufacturers, materials producers, dismantlers, shredders, recyclers, ect) take the necessary responsibility to achieve the ... environmental  objectives... 'The large number of actors makes it impracticable use (sic) voluntary agreements as a general tool in the implementation of the Proposal"

Voluntary industry or other environmental initiatives at national level will have to brought in line with the contents of the Proposal. and "be complemented by the necessary laws, regulations and administrative provisions which Member States will have to take in order to transpose the Proposal into national legislation.  "

In other words, whatever environmental regulations or systems, whether voluntary or legally required, which are currently in place in each Member State will have to brought up to meet the requirements of the Directive and become national law in each Member State.

Between 8 and 9 million vehicles are discarded in the EU each year, equivalent to 8-9 million tonnes of waste.  This is expected to increase with the rise in numbers of vehicles on the roads.

Some 25% of the vehicles weight, often referred to as shredding residues, is hazardous waste, which is land filled, often causing soil and/or ground water contamination, This fraction amounts to approximately 1. 9 million tonnes of waste per year, or about 1 0% of the total amount of hazardous waste generated in the EU each year

Some 70-75% by weight of vehicles is made up of metallic fractions, ferrous and nonferrous, which is generally sold on through the scrap metal market through shredding.  Shredding activities are the source of pollution, causing emissions into the atmosphere of PcBs and heavy metals, discharge of organic substances and heavy metals (lead, c~@ copper, zinc, and nickel) discharges into the soil, as well as fire hazard.

The residues from shredding (approx 25% of vehicle weight) consist of a heterogeneous mix of materials such as plastics, rubber, glass, textile, paint oils and lubricants, paper and cardboard, which are often land filled.

                                                                               Conclusion

 

                                                                          The introduction of the ELV Directive is to effectively create a new industry in Ireland. With the current uncertainties in our ability to sustain permanent jobs from foreign companies and the growing disquiet by the public at the lack of substantial financial support for home developed businesses, the opportunity has now been given to those in authority to assist in the development of this new industry which will produce permanent, sustainable and secure jobs for our people. The representations and information distributed by the End of Life Vehicle Disposal Company over the past number of years has given those importer distributors who were not fully aware of the implications this Directive would have on their businesses, an opportunity to understand and question the relevance of this Directive.

                                                                          As it makes no sense at this stage to blame one or both industries for not attempting to address this problem from an earlier stage, the growing urgency at present is what can we do now. We really need to take the initiative collectively and develop a system that as a matter of urgency will endeavour to address this disposal problem and comply with the Directive.

At a time when jobs are being lost at an  alarming rate within our economy, the need for government to support home produced initiatives that has the potential to produce thousands of permanent and secure jobs for our people is staring those in authority, in the face. It is beyond belief that after five years of correspondence to government ministers and state agencies which includes agencies with an interest in the environment, not one agency has responded with any form of help or commitment to at least TRY.

 It can also be said that when the leader of a major Irish political party was approached at a constituency clinic meeting,( meeting previously arranged) the said individual accepted our report on the environmental disposal of motor vehicles and then started to fall asleep. Other party members had to apologise for the incident by saying that the leader had a very hectic schedule and was very tired. So much for an interest in the environment or even an effort to re- schedule another meeting at a more convenient time. We never heard from the party again.     

                                                     
                                                                         The only way in which we can achieve our goal and comply with the Directive is by all sectors of industry co-operating with one another in order develop and sustain a workable and professional method of disposal. This in itself is justification for the establishment of an independent body such as an ELV Centre to oversee the system on behalf of both industries. If one sector views this as an opportunity to exploit the other, then unfortunately whatever system is established to resolve this problem, will be plagued with mistrust. Will history repeat itself?

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                                          date of    issue September  2002

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We need your help

For nearly five years we have tried to convince the Irish motor industry that the way forward in environmental automotive disposal is to establish an ELV Centre and a research disposal facility that will endeavour to set a standard for future approved disposal centres.

 

So how can you help?

You can help by sending an Email to the the motor manufacturers just by going into their web site and clicking on feedback.

You can contact the Society for the Irish Motor Industry  by email

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        those in authority and all Irish newspapers

 

                                     Why do we constantly try to mis-interpret the Polluter pays Principal

                                                       by laying the blame on the consumer? 

                                                A written piece for the media to ponder upon 

Waste….. Whose problem is it?

Waste be it concrete, metal, plastics or even our everyday household rubbish, has become a hot potato for our overworked government ministers. The main reason for this is because, any minister who is directly or indirectly involved in a business or has business associates in any form will be directly involved in their obligations to environmentally disposal or recycles the products they produce. In the past, we were all prepared to place our commercial or household waste outside our businesses or homes in the hope that if the bag raiders did not get your throw outs then the local authorities will to do the mopping up. The very thought of having to go to a waste disposal facility and deposit something that you have no further use for was viewed as just a complete waste of time and effort. Sure, why not leave it for the itinerants to take it from your door or just wait until its dark when you think Joe and Mary next door has long gone to bed before you can haul the old rubbish out the door and dump it on some unfortunates doorstep or back lane. This sort of mental thinking went on for years with the full support and backing of government ministers who believed that by placing glossy television advertisements encouraging us to deposit our rubbish in litter bins scattered throughout the city and suburbs, then we would suddenly become litter conscious. The use of wheelie bins for the storage and disposal of waste was for a long time being used in European countries and America, while Ireland’s politicians sat back blindly in hope that nobody would expose the problem. Oh dirty Dublin was really dirty Dublin in them good old days. The days when you could cross the road without having to book an ambulance, just in case you happened to be creamed by a taxi driver who thought reversing up Dame Street was the easiest was of securing a fare. When someone spoke about the environment in those days what they really meant was the countryside. Ah yes the countryside, a place where man is in close harmony with nature and the land. A place where one could step out of the big smoke beyond the Poitin Still and find one’s self up to his knees in the beauty of nature and the environment.

So what has made us more environmentally conscious now, considering that there was times when nobody gave a hoot and you could not walk into the city without being choked by car and chimney fumes or industries that pumped toxic fumes into the atmosphere as if it was an unlimited skybound rubbish tip. As you made your way across that road in the thick of the smog and carefully manoeuvred around heaps of chip bags and ice pop sticks to witness the lads in the corporation discussing on a corner which six would hold the brush and who would push the cart. Mary Harney’s smokeless fuel legislation was an outward and progressive policy even if it meant that the poor so and so’s who could barely afford to keep themselves warm with what they had, were now obliged to purchase a fuel that had to be heaped onto the fire to get any form of heat return and was also more expensive to purchase.

So what obliges us now to be environmentally conscious, apart from the logical understanding in the value of protecting our environment. The answer is money.

You see Mary Harney got it right but failed to say that in order to clean up the mess that successive government ministers had allowed to escalate into disaster, we as consumers had to pay for the privilege. As consumers we are now being asked to become more environmentally conscious because instead of the consumer being told to pay for the mess, the EU in all its splendour introduced Directives on environmental disposal based on the "polluter pays principal" which means the manufacturer and not the consumer is responsible for the waste.

In the Dublin Waste Case the use by the Judge of the "polluter pays principal" to impose personal liability on the directors (where the Act only allows for criminal offences) is a very significant extension of the existing powers to prosecute directors ect personally for criminal offences under various environmental and other statutes.

What is now happening is that the consumer is being asked to pay for the disposal of a range of products that are clearly defined under the Directive’s as being with the "polluter pays principal" and that is the manufacturer. So long as the government drags its heels in enforcing Directives the more likely it will become, that the public will be coerced into paying for the recycling and disposal of manufacturers waste products.

The introduction of the plastic bag tax was not introduced as a method of reducing the problem of plastic bags (although the tax worked) purely because if you were prepared to purchase these bags then you were allowed to damage the environment. Under the EU Directive the manufacturer was responsible for the disposal/ recycling of these bags and therefore the consumer should not have had to pay for this process. The manufacturer could have included a hidden cost to the retailer for the purpose of disposal/recycling but in reality this cost would eventually in time be lost to competition between manufacturers of the product.

This in turn and under the EU Directive would have forced manufacturers to produce biodegradable bags and be competitive in the sale of these bags to the retail sector. They could also have included a return charge, which would have prompted the establishment of small to medium size home based recovery businesses or community funding recovery projects. Instead the government jumped on the bandwagon and introduced a bag tax, which we very well know will not go towards the support of any environmental initiatives other than the granting to established businesses profiteering funds.

What we now see is a whole range of environmental companies with initiatives based on the principal of " if you want to get rid of it they you have to pay for it" which is completely negative to the principals of EU Environmental Directives. This is why both government and a considerable number of companies here in Ireland are stalling with compliance of these Directives in order to create a public climate of "we as individuals have to pay for our waste". As in the past, Ireland will once again be threatened with the European Court for non compliance of EU Directives, these delays will allow the government time to introduce a range of taxes in the form of environmental initiatives in order to cushion the cost to industry.

If we take for example our general household rubbish bin and analyse the contents for recycling/ disposal we find that the cardboard packaging, bottling and plastic contents, are covered by the EU Directive and the "polluter pays principal". What are left are organic materials that in reality can be made into compost or will decay safely in landfill.

On behalf of manufacturers, Repak is supposed to look after the end destruction or recycling of these products but based on Irish companies willingness to comply voluntarily with EU Directives, time, will allow government ministers to act while at the same time appear to be complying with the EU Directives. So where does the charge come in for the collection of our waste, especially if the local authorities are telling us that the charge is not for the collection of the waste but for its disposal. If our local authorities are bogged down in fighting a court case on the validity of their charges then why have they not properly explained to both consumers and the anti bin charge movements exactly were this justification is coming from?

 

In a South Dublin County Council newsletter with the heading "Household Waste recycling to Increase from 10% to 60%" dated June 2002 the council stated:

"Under the plan all 75,000 households in the South Dublin County Council area are to receive three wheeled bins which will enable users to segregate waste for recycling. To fund this enhanced service, the council has introduced an annual waste charge of Euro190. The County manager Mr Joe Horan said the move is in line with that already taken by other local authorities in Dublin and across the country, to adopt the EU "polluter pays" policy to waste management and increase the level of recycling."

This in reality is incorrect because both the manager and the whole organisation of alleged county councillors are incorrect with the interpretations of the " polluter pays principal". You will notice that the County Managers quote of "polluter pays" policy is different to the EU wording of the "polluter pays principal". This leads back( Dublin Bus article submitted to you) to my analogy of Dail Eireann members as being a load of "twits". Now our councillors are in the same boat.

This was also the case when a colleague and I were called to a meeting with the Society for the Irish Motor Industry towards the end of 1999 to explain our research into environmental disposal of motor vehicles. After nearly two hours of explanations and examples of the "polluter pays principal" the penny suddenly dropped and the room went into a state of awe. Now I would have thought that a representative body like the SIMI who got a number of proposals to government wrong on previous occasions, would have learned by their mistakes and fully investigated this proposal for a Directive at that time. Now, in the year 2003 there is no credible move towards proper and acceptable environmental disposal of motor vehicles in accordance with the EU Directive. The laughable part of this continued saga is that the Directive is based on the "polluter pays principal". This is why Ford, Rover, Nissan and a number of motor manufacturers have got together in order to develop a system that will comply with this Directive because they know that the polluter pays principal means "them"

The Irish motor industry (once again relying on outside influences to solve their problems) in all its efforts is trying to include a charge when you buy a new vehicle for the environmental disposal of that vehicle. This charge will, in time, be forgotten and lost through price competition at the time of sale. So, in the case of our local authorities, if I put my old Nissan Micra in my wheelie bin (not to difficult) I am then obliged to pay for its disposal………I don’t think so.

Diredtive94/62/EC on packaging and packaging waste requires Ireland to achieve a 25% recovery rate by 2001, increasing to 50% by the end of 2005."Recovery" means energy recovery or recycling. In the absence of energy recovery capacity, Ireland is significantly disadvantaged in terms of meeting the specific recovery targets compared to other EU states and is primarily dependant on recycling to achieve the targets. The Directive is based in the "polluter pays principal". Producer responsibility is a fundamental element of this principal, whereby producers (manufacturers, importers, distributors, retailers) –as the effective generators of waste –are required to take responsibility and contribute towards the waste management cost at the end of life of products which they have placed on the market.

The Waste Framework Directive lays down basic obligations for member states when it comes to dealing with waste. The government and business is trying to re- interpret these Directives in order to give themselves more time (before judicial compliance) in order to oblige consumers to believe they are responsible for this waste.

In the case of the illegal dumping of clinical waste in a number of unapproved sites around the country, it must be said that the people who approved the dumping of this waste either by sheer unprofessional acts of silence or total negligence, are not the ordinary everyday people who we are told need to be informed and educated on environmental matters. The ordinary citizen who genuinely wants to environmentally dispose of an appliance in the interest of both the environment and his children’s future is forced to continuously consult the yellow pages in an effort to secure someone who will honestly and truthfully environmentally dispose of the appliance at a price that enables him or her to act as a concerned individual. But the price is not the argument; the argument is that the manufacturers and not the consumer are obliged to pay for the disposal. How the manufacturer goes about paying for this disposal is his own business, but one thing is for certain, the consumer should not.

The public’s contribution to environmental disposal should be looked upon as their efforts to assist the manufacturers through the separation of their products and the collection of the waste products by the local authorities. The public are constantly being asked by their local authorities for their assistance in promoting environmental awareness by storing and using waste bins but are then hit with a charge for using this un-asked for service. After all will South Dublin County Council or Dublin City Council allow you to park your car on their property without paying for the pleasure? I think not. But yet they ask you to store unsightly smelly bins that you never requested on your property for nothing. Councils please, business is business. It seem irionic that the dispicable waste of public money by government and local authorities on unnecessary projects and purchases and their lack of concerns for the welfare and health of our citizens is brought to a new level whereby the general public are now being asked to save themselves. The amount of money it takes to support and finance the number of government ministers in this small country and their auntorage combined with the local authority institutions with all their side kicks, makes our perception of the British Royal Family being a burden on the state a massive Irish joke. Environmental waste disposal charges are not about securing a better environment for all, because it penalises the very same people through unnecessary taxes. The very idea of a waiver application for those who say they are unable to pay makes the local authorities akin to the Revenue Commissioners, in other words there is no way out unless you spill your heart out, right down to what you had for breakfast. Local authorities are becoming more and more like judge, jury and executioner. But there is a simple way to show your disapproval to a system of penalising the consumer and that is by not paying the refuse collection charges. Those who have already paid should refuse to use any other bin for disposal purposes other than the general refuse bin. The Minister for the Environment and the local authorities efforts to introduce legislation whereby those who fail to pay their bin charges will not have their refuse collected makes those declared as insane and needing to be locked up are of more sound mind and body than the twits (again Dublin Bus article) that run our country. Should any form of legislation like this be passed it will then make this issue escalate into a health and safety matter. Now the Minister for Health is involved and the debate continues. What we are constantly trying to encourage the general public to do, (become environmentally conscious) will reverse these efforts and encourage mass illegal waste disposal.

Environmental disposal is big business and it is with this in mind that everything is based around convincing the general public that it is their duty to pay for environmental damages in the protection of business. The uncovering of the illegal disposal of clinical waste is not something that has suddenly come to the attention of the authorities as if there were moments in time when the nation fell asleep and the Garda mistook a lorry full of needles as a tractor pulling a cart full of bulls around for their evening ramble. This my friend’s was big business at a time when you could charge the earth for disposal and blame the travelling community for desecrating our land.

But you see now it’s a time of EU Directives and the withholding of EU grants and subsidies due to non-compliance with EU laws. Government and business cannot sweep everything under the carpet and pretend it does not exist because dirty washing is now required to be cleaned and hung out to dry. Despite our political leaders constantly waffling to us about the importance of Ireland and the skills of its workforce, Ireland is a two-bit country with little or no political clout other than a voting number for the big boys. With regards to the ability of its workforce, oh yes Ireland has a good workforce but so has China, England, Wales, Malta, Korea and need I go on. The reason that Ireland is so attractive to big business is because Ireland pays big business to employ its workforce. If Ireland had nothing to give to big business then Ireland would become a third world country at the flick of a switch. So where do I go from here, well if Ireland does not take the initiative and develop its own environmental recycling and disposal systems then nobody else will help unless we pay them handsomely for our inability’s.

Take another example, the EU Directive on End of Life Vehicles, this Directive makes manufacturers responsible for the environmental disposal of motor vehicles. There has been a proposal for the environmental disposal of motor vehicles submitted to the Department of the Environment and Irish motor importer distributors by an Irish company nearly five years ago. This proposal would enable both government and manufacturers the opportunity to establish approved disposal facilities for the recycling and disposal of motor vehicles in compliance with the Directive. It would remove the constant problem of abandoned cars and company cars, which in turn would save lives and clean up our environment. To date both the Department or the representative body (SIMI) of the Irish motor industry has not as much as sought a meeting in order to further this proposal. Why? Because owners of old vehicles are being asked to pay for the removal and alleged environmental disposal of these vehicles at a cost. Despite years of talking and discussion nobody has come up with a strategy for the disposal/recycling of these vehicles in accordance with the Directive and other associative Directives.

We are being asked to pay for a whole range of products from TVs to washing machines and three-piece suite. The Directive enables us to call the retailer where we purchased the product and request they take it back for recycling or disposal. The cost for this recycling/ disposal facility is paid for by the manufacturer as set out in the Directive. So, in theory if you purchase a pizza you can ask the retailer to collect the packet it came in when you are finished with it. If you bring the packaging back to the retailer you are doing him a favour and helping to protect our environment. This can also be said in the case where a fast food chain was taken to court by a local authority for littering a pavement with a hamburger box. The food chain argued that they had no control over the individual throwing the box on the pavement but lost the case because the court found that the food chain sold the individual the hamburger and provided the box as a means of carrying the burger. The food chain lost its case.

We cannot be completely negative about the successes of the EPA and other interested bodies. Their work and dedicated efforts has most certainly improved our environment but we must question to who did it costs. There are numerous projects that are publicly financed and constructed or operated by the private sector only to find that when the projects do not make money they are then thrown into the public lap until the day comes when it is right for a take-over. The Luas is both a financial and environmental disaster that the Minister Brennan has indirectly agreed with other people’s analysis. On his visit to the Red Cow roundabout Naas Road, he could not believe the traffic congestion that was taking place. No wonder the Irish Medical Organisation is calling for tachometers to be fitted in ministerial cars because if Minister Brennan has never seen this then speed restraint must not be his problem. What started as an Euro288 million project is now set to topple Euro700 million and rising. The damage to the environment around will be with us for years to come, combined with the total inconvenience caused by traffic delays and disruption of communities. Exhaust pollution will increase due to continue and prolonged traffic congestion. Passengers aligning the trams at the end of their journey especially on the Naas Road will be subject to traffic passing either side of the platform.

Elderly people will find it difficult to walk safely from point A to B. There will be an increased tail back of traffic on road that would normally be used to relieve congestion due to the frequency of trams passing given points. The security of track and the safety of children in nearby housing estates will be a major concern. The example of this is the stretch of railway line at the bottom of Ballyfermot when in the past children were injured or killed playing on the tracks. If the motorist are forced to use public transport on mass then the profits from the transport system will go to private interests and not in the public interest. The motor industry will go into decline, jobs will be lost and the state returns on fuel, road and service taxes will decline.

Luas was an ill-conceived badly researched project that was promoted by politicians with not a hint of environmental, social or engineering skills. Its success will be dearly paid for and subsidised, in order to prove a point and save blushes.We have built a fortified fence around the city that will strangle the life out of the city and condemn it to those who can afford to live within its expensive walls. God forgive me for saying, " Hitler did not do us any favours when he bombed Dublin in the Second World War." For if he had done this (and I mean no disrespect to anybody that was killed or injured) we might now have a city with a road infrastructure that was made for improved development and not rejuggling. The original construction proposals for the Red Cow roundabout was for a three lane roundabout but was scuttled again by interference for a two lane roundabout. Because motorist thought they were on the track in Mondello the big boys decided to make the Newlands Cross stretch from a three lane to a two lane to a bottle neck one lane. This in turn caused tailbacks as far as Rathcoole. When they got over this problem by widening the roundabout (now don’t forget the original proposal) and creating side slip roads the roundabout was just about coming right when O’Rourkey baby came up with another idea. Lets come up with a project that would cost millions and once started would be impossible to stop. And let us appoint a rail server whose track record is as shaky as the track it once operated. And let us give it to CO***x and sure if they fail then we can take it back into public ownership, after 10 years blame those who have died, set up a tribunal, waste more millions and then tell the public not to be supporting hair brained ideas in the future.

Now enter Luas …………ah let’s forget about the rest.

 

What has all this to do with our environment? Well quite a lot. You see ill thought out concepts and projects cause environmental damage that the public has to pick up in environmental financial costs. This in turn deprives other service like hospital admissions and operations to be delayed or cancelled. It causes under funding for our education system and stifles the progress of other public transport projects. It causes governments to raise taxes to fund services or at worse borrow to meet our everyday needs. It basically put our economy into a state of decline that in turn causes unemployment. With a total population of just over 4,000,000 people, this can be broken down into six categories

The young (school going ect)
Second and Third level students
Employers
Workers
Social welfare recipients
The Elderly

There is a huge responsibility being placed on the third and fourth categories who are being asked through all forms of taxes to support the system. Employers never seem to grasp exactly what in time this means to their businesses through wage increases and other operating costs. Their belief that the cost of a project like Luas will eventually enhance their business through the movement of people from one place to another rapidly, is ill founded. in all its efforts, government will try and justify the need to borrow in order to portray a sense of continued economic health leading up to another election. The opposition in all its splendour will silently go along with this plan for after all who wants to take over a declining and troubled economy with the future problems of taking the wrath of disapproval from the public at its decline, while the opposition sits back and reminisces on the good old days when they helped with the birth of the tiger. We seem to always try and compare Dublin to London, Milan, New York or any other country that has for decades been on the map of places to be. But let us not forget the people of Cork, Galway, Clare or anywhere else outside of the country called Dubin with its satellite countries around it. It is the people outside Dublin who are being forced through their taxes to pay for a system that is reckoned to accommodate 20,000,000 passenger fares and not 20,000,000 different people in a year. Sure at that amount of money you could really make Cork the capital of Ireland. But let the people of Cork not forget that while it is fanciful to see their politicians scream to them about what they are doing for Cork and its people, they are in reality depriving the people in Cork the development and job security they really needs. While the talk of cleaning up Dublin and its surrounding county is high on the agenda the surrounding counties have, as in the past, been viewed as hidden buriel sites beyond the worry of political disaster.

Jim Travers

email: jimtravers@eircom.net

 

Briefing Paper on the End of life Vehicle Proposal
                   (Society of the Irish Motor Industry)

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