(GUF) NOT OUR RESPONSIBILITY

1. A Message to Government

Large-scale fly-tipping in England has evolved from opportunistic criminality into organised, repeatable and easily scalable waste crime. Recent incidents demonstrate a clear operational template involving logistics expertise, high-volume processing equipment and systematic exploitation of regulatory gaps.

This is not primarily a failure of law, technology or policy intent, it's a failure of clear ownership and operational accountability. Multiple public bodies hold partial responsibility for waste regulation, enforcement, clearance and intelligence. No one agency is required to own the outcome and for this reason organised waste crime operates precisely in this space, intelligently, efficiently and profitably.

2. Not Our Responsibility - The Core Systemic Failure

The most consistent response following major fly-tipping incidents has been the assertion by agencies that the issue falls outside their statutory responsibility. This has been particularly visible in recent high profile cases where local authorities are responsible for clearance but not investigation; the Environment Agency regulates permitted sites and carriers but not landowners; Police forces may investigate organised crime but only once criminal thresholds are crossed and the Joint Unit for Waste Crime (JUWC) coordinates intelligence but has no enforcement authority - each agency operates within a clearly defined remit - waste does not.

The result is a system in which responsibility fragments instantly after an incident causing action to be delayed by jurisdictional debate, resulting in criminal operators benefitting from inertia rather than concealment. This is not accidental, it's structurally predictable, nay, relied on.

3. The Landowner Liability Trap

A critical but underexamined weakness in the current framework is the position of the landowner. In many large-scale fly-tipping cases landowners are left liable for clearance costs. Criminality is acknowledged but remediation is prioritised over investigation and reporting is delayed or limited. This creates a perverse incentive where the victim bears the cost and the offender benefits from silence and delay and the evidence disappears before enforcement action begins.

Organised waste crime groups actively select sites where landowners are least able to resist financially, legally or politically. This is not collateral damage, it's a known and exploited feature of the current system.

4. Carrier Licensing: Regulation Without Physical Control

Waste carrier licensing in England remains administrative rather than operational. At present, licences are attached to entities, not vehicles which can operate across regions with minimal real-time oversight. Subcontracting obscures accountability and ultimately enforcement relies on chance interception. This would be considered unacceptable in other regulated transport sectors.

Waste carrier licences should operate like operator licences, explicitly linked to vehicle registration numbers, operating bases, permitted waste types and defined geographic operating areas. All relevant agencies, Environment Agency, police, local authorities and DVSA should be able to enter a vehicle registration number and immediately see who is operating the vehicle, under which licence, from where, for which waste types and within which authorised area. This capability does not require new technology, It requires regulatory will.

5. International Comparison: South Korea’s Allbaro System

South Korea’s Allbaro waste tracking system demonstrates what effective, joined-up enforcement looks like in practice. Under Allbaro, waste movements are digitally logged at source; vehicles are directly linked to licensed operators; geographic operating areas are defined. Regulators have real-time visibility of movements allowing enforcement to take place before disposal (fly tip), not after discovery.

Crucially, Allbaro integrates the waste producers, transporters, treatment facilities and regulators - absolute 'cradle to grave'. There's no ambiguity over responsibility because accountability is embedded at every stage of the waste journey.

By contrast, the UK system allows waste to effectively “disappear” between collection and treatment. Vehicles often operate with minimal real-time traceability, fragmented oversight and weak accountability, enabling operators to distance themselves from responsibility once an incident occurs. Allbaro is not radical, it's just competent regulation.

6. JUWC: Coordination Without Command

The Joint Unit for Waste Crime (JUWC) is frequently cited as evidence of a robust response to organised waste crime but in practice JUWC has no enforcement powers, no operational control, no authority to compel action and takes no ownership of outcomes. Its role is strategic and intelligence-based, dependent entirely on other agencies choosing to act.

Where responsibility is contested, as it routinely is in fly-tipping cases — JUWC becomes a forum of talking heads, not a solution.

Organised crime does not fear coordination, it fears clear command and accountability.

7. Digital Waste Tracking: Necessary but Too Late

Digital Waste Tracking (DWT) will improve transparency, but only once it operates fully across all waste producers, carriers and treatment facilities. That level of coverage is unlikely before 2030 at best. Organised waste crime groups understand this perfectly and are exploiting the gap now. DWT must not be sold as a future solution to today’s enforcement failures.

8. Key Recommendations

I urge the government to consider designating a single national body with explicit responsibility for preventing and responding to large-scale fly-tipping. Role to cover;-

• Reform waste carrier licensing; linking licences directly to vehicle registrations and operating areas
• Provide real-time vehicle lookup access; to all enforcement agencies
• Rebalance landowner liability; ensuring victims of waste crime are not financially penalised for reporting
• Accelerate producer accountability; mandating auditable reporting of waste type, carrier, destination, and collection date
• Adopt proven international models; including Allbaro-style integrated tracking and enforcement

9. Closing Statement

Large-scale fly-tipping in England is no longer a failure of awareness or policy intent, it's a failure of responsibility, carefully defined, politely defended and systematically exploited. Until responsibility is singular, visible and enforceable, incidents like Kidlington will not be exception, it will be the business model (and it's getting better). More like this (fly tipping) - link - more like this (EA) - link - more like this (random) - link