Summary and results, Miljøstyrelsen

Barrierer for genanvendelse af forurenet, renset og ren jord

Summary and results

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.

Background

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 Agency’s 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.

The process

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.

Obstacles to reuse of soil

The identified obstacles include the following:

Reuse is not "rewarded"

There is no tax on depositing of contaminated soil

Only negligible tax on primary raw materials

Only a limited number of sites for separation, identification and interim storage of soil

The players have insufficient knowledge of reuse options

There is no demand for reuse

The contractor/authority does not want to spread contaminated soil to new areas

The soil is not technically suitable

There is no reliance in the soil quality

Prolonged administrative procedures

Unnecessarily large amounts of contaminated soil are produced due to inadequate separation at source

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.

Proposals for action

A number of initiatives are proposed to surmount the identified obstacles. The initiatives concentrate on:

Information and guidance

Administration practice

Sites for separation

A market for soil

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.