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Heavy handed
Page 26
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I READ WITH CONCERN the article headlined "Salvage regs set to slash truck prices" (CM 18 December 2003).We are a major recycler,processing a major portion of the UK's HGV salvage, and have always strived to put the environment and legislation as a top priority For the past six years we have been aware of the forthcoming legislation on the "depollution" of end-of-life vehicles.All along our trade organisations — the British Vehicle Salvage Federation (BVSF) and the Motor Vehicle Dismantlers Association (MVDA) —have been in contact with government officials who have confirmed that the vehicles we process,as over 35 tonnes, would be outside the scope of the proposed new legislation.
At a meeting on 23 September 2003 Lennart Scharff. secretary of the European Group of Automotive Recyclers Association (EGARA), again confirmed that the Directive only applied to vehicles under 3.5 tonnes. It does not apply to HGVs in any other European state, and it will certainly not here because trucks are a relatively small number,and cars make up most of the volume.
The legislation became law on 3 November 2003. In late November the BVSF sent an e-mail telling us to check the regulations. It had been noted that the government had slipped in the words to include "all vehicles".
We checked with the Environment Agency who told us it does affect us and that we had until 1 February to comply. I asked what we had to do.The reply was:"We do not know yet as we were not expecting this to apply to HGVs either We are awaiting guidelines as to what to do."
You state that you contacted the Department for Environment,Food and Rural affairs and were told the BVSF had been consulted on the extension of the UK legislation.This is incorrect — I am a member of its management committee representing the HGV sector.All along we were told the directive applied only to cars (Ml Sz. Ni vehicles) and would not apply to trucks.
On 20 December I received two booklets from DEFRA and the Environment Agency entitled Guidance on Part VII and Schedule 5 of the End of Life Vehicle Regulations 2003.
The Environment Agency also asked us to submit "an improvement schedule and timetable for agreement with the agency" on any site work we have to do to comply.This was six weeks after the regulations became law.
On going through the guidance notes it is clear that they are modelled around ears. HGVs are not considered, and there is no indication as to what we are supposed to do, or realistically how it could be done. For instance: "put a vehicle onto a support frame". Yes, with a car you can fork-lift it up. But a refuse truck weighing 15 tonnes? I don't think so! We are going to have to devise our own methods in a purpose-built unit.
We can make it work but the cost is obviously going to have to be reflected in the value of end-oflife trucks — the cost of processing will have to be deducted from the values.The government has produced legislation without considering the implications.
To expect HGV dismantlers to get planning issues sorted, yards concreted, equipment manufactured to depollute.buildings constructed to house and process, all by February 2004. while car dismantlers have had six years to get systems in place. is,to say the least, unrealistic.
We are not against the depollution of HGVs or the regulations, but we strongly object to the heavy-handed way that this legislation has been dumped on this industry — legislation that is going to cost all operators large sums of money in the long run — without any prior warning, consideration or discussion.
Percy Snow Snows Commercials Compton Greenfield Bristol