Waste crime is now more lucrative than contract killing and criminals are getting more sophisticated. Could technology help end it once and for all?
“Our goal for waste crime is very simple: stop it. That’s an audacious ambition, about which we are totally unapologetic,” said a determined Sir James Bevan in a stirring speech to the waste industry earlier this year.
Bevan, who is chief executive of the Environment Agency (EA), noted that waste crime costs the economy around £1bn each year and attracts organised criminals, who invest their ill-gotten proceeds into cycles of violence. This is because rewards are high – often greater than robbery, drug dealing or contract killing – and the chances of being caught “have always been relatively low, and the penalties if you are caught traditionally light”, he said.
The EA is talking tough. Yet the concern is that six years ago Bevan made a similar speech, in which he famously likened waste crime to the “new narcotics” and pledged to bring down the “waste mafia”. Since then, the situation has deteriorated.
One former EA frontline officer tells E&T: “It is a sad state of affairs. Waste criminals are getting more sophisticated in their approach. There’s a real lack of leadership right from the top of the EA; I don’t think they have the right people in the right place. They’ve had a long time to get this sorted and they are so far off it that it’s frightening.”
Bevan accepts that “all the evidence suggests waste crime is on the rise”. The EA’s 2021 National Waste Crime Survey found that waste crime in England was endemic, and the EA estimates that 18 per cent of waste is managed illegally at some point in the waste stream – around 34 million tonnes every year.
How does the EA intend to confront the rising tide of waste crime? Bevan says the EA’s new approach is to be more proactive, “working much further upstream to prevent crime and harm before it happens; to be far more intelligence-led; to focus on the biggest threats across the country as a whole; and to be a lot more high-tech”.
Technological inroads will include using hardware, like drones for surveillance, and heat-sensitive cameras to identify what’s in shipping containers or warehouses.
However, it is the agency’s determination to introduce mandatory digital tracking of waste that promises the most.
In April, the National Audit Office (NAO), the body that scrutinises public spending for parliament, published an investigation into government actions to combat waste crime in England. One of its most telling findings was that the EA and the Department for Environment, Food & Rural Affairs (Defra) don’t have the data they need to understand the full scale of waste crime.
“While they understand its nature and complexity, they acknowledge the waste crime data they collect does not give an accurate picture of the actual incidence of waste crime because of under-reporting,” it found, which the government accepts.
In its consultation on mandatory waste tracking, which ran this spring, Defra noted that large amounts of data are not collected or collated centrally, while multiple IT systems are used to collect “certain elements of waste tracking data”.
“Some are paper-based, others digital, some are run by private contractors, others by the government, and where use of existing central digital systems is non-mandatory, take-up is very low. As a result, it is very difficult to determine what happens to our waste and to have a comprehensive understanding of whether it has been recycled, recovered, or disposed of,” it said.
Defra wants to join up these fragmented systems and move records online. It says this will make it “much easier and less time-consuming for legitimate waste companies to comply with reporting requirements”. At the same time, Defra says the move “will make it much harder for rogue operators to compete in the industry”.
‘If you take away low-rate landfill tax, then overnight you remove the temptation to turn water into wine, to misdescribe waste to make a profit.’
Huge riches are on offer, but can digital tracking really deliver this much?
Michael Groves is chief executive of Topolytics, a global waste supply-chain analytics business contracted by Defra in 2019 to build a prototype of the UK’s mandatory digital waste tracking system. The firm has developed an analytics platform called WasteMap, which pulls in data on locations where waste is produced, collected, processed, and transformed, along with supply-chain data on individual movements of material. “If we see enough of that from a number of different sources, we can model a view of what’s happening across the whole system,” says Groves.
The data comes from company spreadsheets, third-party software systems, and a small proportion of sensor data. “We pull the data in, clean it, normalise it and analyse it. Our customers, like manufacturers, are paying for a better-quality insight into how much waste they might be generating globally, where that waste is going and what happens to it,” Groves adds.
Therefore, the firm was well placed when UK regulators “decided they needed to be able to see data on material movement”. Quarterly submissions of collected data are supplied to the EA through paper transfer notes, explains Groves. Topolytics’ prototype is designed to give visibility of waste transfers to the UK’s environmental regulators, through a cloud-based digital dashboard.
Ultimately, Defra wants all waste movements and transfers to be recorded on the waste-tracking service in real time. However, those expecting something akin to websites tracking the immediate position of ships through satellite technology could be disappointed. Groves thinks true ‘real time’ is expensive, complex and “a big ask” for the industry, especially for smaller companies.
“In our view, if regulators could see a mix of data that’s been transferred automatically or uploaded daily, as well as some sensor-based sources. This still offers a huge step forward in transparency and oversight,” he comments.
While many waste industry experts agree that digital tracking is needed to generate a better picture of the sector, they are less convinced about its ability to stop waste crime.
Ray Purdy, senior fellow in environmental law at Oxford University, says: “Electronic tracking will likely have a positive impact on those operating within the regulatory regime… but it isn’t going to have much impact on determined people operating illegally outside normal regulatory waste regimes.” He says using blockchain to track movement of waste electronically should “increase visibility of waste streams”, but it is also “vulnerable to fraud at the ends outside of the blockchain and will only work effectively if the system is used honestly”.
Purdy doesn’t have high expectations. “The track record of some parts of the waste industry casts significant doubt,” he says.
A former EA waste regulatory officer, who did not wish to be named, says there is “no point” in digital tracking if it’s not in real time. “All you are going to do is identify more crime, but you’ve still got to investigate and talk to environmental crime officers, who are completely stretched,” they say.
The former officer adds: “It’s not about data, it’s about old-fashioned knowledge of the industry: people that know the area’s movers and shakers. I don’t think EA officers, on a local basis, know who to target.”
They say a better grasp on data could help, but there are tell-tale signs, such as high-speed shredders, which an experienced EA officer will pick up on. “There’s only one reason you have them – to shred residual wastes you can’t recycle, to send to landfill. This leads to a temptation to classify them at the lower rate of landfill tax.” The former officer says companies that can move, accept, treat, and dispose waste all in their own supply chain, warrant scrutiny.
However, they say years of staff cuts mean the regulator does not have as many experienced people. “I’m struggling to speak to officers on the ground that have been there for more than four years and many are demoralised.”
Government funding for the agency’s environmental protection work slumped from about £170m in 2009-10 to a low of £76m in 2019-20, and £94m last year, although it was provided with a further £30m ringfenced for waste crime from 2018-19 to 2021-22.
However, the EA cannot fund its enforcement via charges for permits and licences. This has led to it deprioritising low-level pollution incidents, as they do not generate an income.
Former and current EA staff members, who wished to remain anonymous, have told E&T that this is one reason why environment officer roles have been replaced with middle-management jobs.
Groves accepts digital tracking “will not be an instant panacea” but says filling the evidence gap will squeeze out criminality. “In data terms [waste crime] is material leaking out of the system, so if you have a better view of what that system looks like, you can start to identify bad actors… it’s the absence of information that can tell you as much as the information itself.
“There is an evidence gap. Even if we can’t see everything, we see enough of it and start to generate a better version of what is happening,” he adds.
Ray Purdy is managing director of Air & Space Evidence, a company that specialises in using Earth-observation satellite imagery as evidence in cases involving environmental crime, and develops detection models to find that evidence.
The firm describes itself as the “world’s first space detective agency”. It has carried out investigations for clients across the world, including New Zealand’s environment regulator. According to Air & Space Evidence, satellite intelligence can make routine and systematic monitoring of large areas possible and affordable. It can also reduce costs for regulators, showing officers precisely where to look.
This technology could prove vital. The EA says it knows of around 400 illegal waste sites dotted across England, but there will be many more it is unaware of. It notes: “The criminals can open a new site a lot faster than we can close down an existing one.”
The tech could also help with regulation of legitimate businesses, such as whether permit holders are operating outside a site’s official areas or exceeding the amount of stored waste allowed on site.
However, the EA has declined to work with Air & Space Evidence, saying it already uses GPS surveys of waste sites, and navigation data for airborne sensor systems like aerial photography and lidar (light detection and ranging).
The EA was also unable to say what the new technology is that Bevan referred to. Yet an EA spokesperson said: “We always consider technological advances and look at proven operational methodologies if they offer access to information we cannot acquire in other ways. We would need to carefully consider the value for money and operational effectiveness of any new system as this technology can be very expensive.”
The agency has been using airborne lidar since 2009 to precisely map waste. Lidar is a remote-sensing method that uses light in the form of a pulsed laser to measure the time taken for the reflected light to return to the receiver. It can also be used to make digital 3D representations of areas on the Earth’s surface by varying the wavelength of light.
The EA says this helps provide evidence of when waste activity took place, and the volume and height of waste involved. It says this information has been successfully used in prosecutions and Proceeds of Crime cases. In recent years, the EA says this work has expanded beyond lidar, to photogrammetry and drone data.
Last year, Kim Mynard, EA regulatory officer, wrote in an agency blog that drones are proving to be “particularly useful for collecting evidence of illegal waste sites for our Environmental Crime Teams. From the air we can see the whole site including skips and piles of waste stored behind buildings or trees that could be hidden from view during a visit on the ground.”
She added that drones also make it safer for officers “as we do not need to be physically on the site to collect images”.
Another crucial element in the waste crime fight will be the government’s reform of the Carrier, Broker and Dealer registration scheme (CBD) in England, consulted on earlier this year. Currently, any person or business that transports, buys, and sells waste, or arranges transportation of waste in England, must be EA registered on the CBD database. Yet in 2017, a consultant infamously registered his dead dog on the system, confirming fears that almost no checks are made on who can join.
Purdy says changes are “long overdue and welcomed”. The government plans to move from a registration to a permit-based system and introduce a required technical competence element for permits. However, for years the EA has struggled to clear a permit backlog the waste industry has said was constraining investment in the sector.
“It isn’t clear whether there will be resources in place to adequately review all permits, or to monitor social media and advertising platforms to identify those operating in the shadows without a permit and disrupt them,” adds Purdy. One potential advantage of the proposed permitting system is that it will be self-funded, so the EA should be well-resourced to enforce it.
The EA considers the misdescription of waste to avoid the higher rate of landfill tax its highest priority, above illegal exports and waste sites. HMRC (the UK tax office) estimates that in 2019 it failed to collect around £200m in tax due, but E&T sources say the amount is likely to be much higher – possibly rising to £600m.
Some think removing the lower rate of landfill tax could immediately tackle a huge chunk of waste crime. “If you take away low-rate landfill tax, then overnight you remove the temptation to turn water into wine, to misdescribe waste to make a profit,” says one former officer.
Purdy says the government is likely to look at the bigger picture, “because there are hundreds of thousands of small operators in England moving waste with anonymous advertising and low prices encouraging a race to the bottom”. Regulating such a sprawling is “extremely hard”, Purdy adds.
While technology could provide sorely needed data to fill the evidence gap, it alone will not defeat waste crime. It must be rolled out with well-organised policy changes and enforced by a regulator with experienced officers on the ground. Audacious or impossible? One thing is certain, says Purdy: “The EA is really up against it.”
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