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Barrierer for genanvendelse af forurenet, renset og ren jord
Background
The process
Obstacles to reuse of soil
Proposals for action
In preference to reuse, considerable amounts of contaminated, decontaminated soil and
clean soil are deposited every year in Denmark. In this project, an attempt has been made
to identify the causes of the limited reuse of soil, and a number of proposals for
overcoming the obstacles to a wider reuse are put forward. The options of levying a tax on
depositing of contaminated soil have been assessed. The project has been carried out by
use of the method of Logical Framework Approach. A working group with representatives from
authorities and players in the area e.g. contractors, consultants and haulage contractors,
has been the active part with regard to identifying the obstacles to reuse as well as to
putting forward proposals for a more widespread reuse of soil - contaminated,
decontaminated or clean.
According to the Danish national waste management plan "Affald 21"
("Waste 21"), reuse should be given priority in preference to depositing.
However, the government has not laid down an objective for reuse of soil. This is partly
due to incomplete data on amounts and degree of contamination. The point of departure of
the project has been the statement that "insufficient amounts" of soil are
reused.
Given the incomplete data in the area, the statement should not be interpreted strictly
quantitatively, but rather as an expression of the Danish Environmental Protection
Agencys intention of investigating the possibilities of optimising the reuse of soil
in order to comply with the priorities determined in the national waste management plan.
With the statement that "insufficient amounts" of soil are reused as a
starting point, observed or asserted causes and effects were arranged in a hierarchy in
the form of a so-called "problem tree". The problem tree was subsequently
transformed into an "objectives tree" and the problems were turned into positive
and desirable states. On the basis of the objectives tree, initiatives were proposed that
could overcome the obstacles to reuse.
The identified obstacles include the following:
![](../../_themes/nyt-milj-/dot.gif) | Reuse is not "rewarded" |
![](../../_themes/nyt-milj-/dot.gif) | There is no tax on depositing of contaminated soil |
![](../../_themes/nyt-milj-/dot.gif) | Only negligible tax on primary raw materials |
![](../../_themes/nyt-milj-/dot.gif) | Only a limited number of sites for separation, identification and interim storage of
soil |
![](../../_themes/nyt-milj-/dot.gif) | The players have insufficient knowledge of reuse options |
![](../../_themes/nyt-milj-/dot.gif) | There is no demand for reuse |
![](../../_themes/nyt-milj-/dot.gif) | The contractor/authority does not want to spread contaminated soil to new areas |
![](../../_themes/nyt-milj-/dot.gif) | The soil is not technically suitable |
![](../../_themes/nyt-milj-/dot.gif) | There is no reliance in the soil quality |
![](../../_themes/nyt-milj-/dot.gif) | Prolonged administrative procedures |
![](../../_themes/nyt-milj-/dot.gif) | Unnecessarily large amounts of contaminated soil are produced due to inadequate
separation at source |
![](../../_themes/nyt-milj-/dot.gif) | It is not possible to receive the soil at the right moment |
Thus, the obstacles originate in financial, tradition-bound and quality related matters
and the supply and demand are not in agreement with each other. Furthermore,
administrative procedures are identified as obstacles as the schedules for most
construction works do not harmonize with a long administration procedure regarding the
handling and reuse of soil. The knowledge of reuse options also seems to be sparse, and
there is no demand for reuse, neither a statutory demand nor a general demand in
invitations to tenders.
Furthermore, placing of contaminated soil can depreciate the value of property and
therefore constitutes a serious obstacle to reuse. As there is no comprehensive overview
of the available amounts and qualities of soil, obviously, this also puts a strict
restraint on the option of reuse.
A number of initiatives are proposed to surmount the identified obstacles. The
initiatives concentrate on:
![](../../_themes/nyt-milj-/dot.gif) | Information and guidance |
![](../../_themes/nyt-milj-/dot.gif) | Administration practice |
![](../../_themes/nyt-milj-/dot.gif) | Sites for separation |
![](../../_themes/nyt-milj-/dot.gif) | A market for soil |
![](../../_themes/nyt-milj-/dot.gif) | Taxation on depositing of contaminated soil |
Regarding information, it has been proposed that guidelines on handling of contaminated
soil from construction works should be prepared. The guidelines should contain detailed
instructions on how for example sorting at source can be carried out to prevent generation
of amounts of contaminated soil that are larger than necessary.
As to actions that can facilitate the administrative work in connection with
consideration of a case on reuse of soil, guidelines targeted at the competent authorities
and at contractors should be prepared. The guidelines should include descriptions of the
typical sequence and progress of a case on reuse of soil. This would put contractors in a
position to thoroughly prepare an application or notification to the authorities and give
authorities an accessible overview of how the progress of different cases can be managed
in order to carry out a consideration as quickly as possible.
The presence of a sufficient number of sites for separation, identification and interim
storage of soil is considered essential to promote reuse. Assessments of the current need
for sites should be made on a regular basis to ensure the right placement and capacity of
the sites.
Establishment of a soil market available for every player in the field could remedy the
incomplete picture of supply and demand for soil - this, in turn, could enhance the
possibilities of reuse of soil.
A database with specified and standardized data on the soil available or in demand
should be the backbone of a soil market.
Taxation of depositing of waste has been considered and the working group has discussed
the pros and cons, but agreement has not been reached on a recommendation. What speaks in
favour of taxation is that greater efforts will be made to reuse soil in order to avoid
taxation. The tax on depositing of other waste types is at present DKK 375 per tonne. What
speaks against taxation is that fewer remediation actions could be a result, as most such
actions are financed out of public means.
As a whole, there are no specific recommendations in the report, but the report
reflects the proposals and discussions in the working group.
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