Friday, 12 July 2013

A Knotty Problem

The Environment Agency has updated its Voluntary Code of Practice for developers “managing Japanese Knotweed on development sites” changes amend the original 2006 code to correct subsequent changes in waste and environmental legislation.


Why is the Code of Practice Necessary?

The Wildlife & Countryside Act 1981 creates an offence for any person who “plants or otherwise causes to grow in the wild” any plant listed in Schedule 9 to the Act or a hybrid of such a plant.  However, it is a defence to prove that the accused took all reasonable steps and exercised all due diligence to avoid committing the offence and therefore complying with the terms of the Code of Practice would provide a complete defence to any charge.

Japanese Knotweed is listed in the Schedule to the Act amongst many other unwelcome species.   However, it is the extreme persistence and vitality of Japanese Knotweed that has made it of particular concern.  The revised Code of Practice makes it clear that soil screening and sieving to remove Knotweed may be effective.  However, the screened soil must still be regarded as potentially containing viable Knotweed rhizomes (roots capable of sprouting) and must not be re-used off site or sold for re-use.  If soil is taken off site it should be disposed of at an approved landfill.  If the soil has been sufficiently screened then it may be re-used on site in accordance with the provisions of the Code.

Controlled Waste

The Environmental Protection Act 1990 sets out in Part II provisions regarding “controlled waste”.  Soil or plant material contaminated with Japanese Knotweed that is to be discarded is highly likely to be classified under the Act as controlled waste.  This prevents anyone from knowingly causing or permitting such waste to be deposited in or on any land unless a waste management licence authorising them to deposit is in force and the deposit is in accordance with that licence.  A licence will also be required to treat such waste or to retain it on any land.  In short a suitably licensed person will be required to remove or deal with such material.  Thus Knotweed that is cleared from a development site will need to be dealt with by a licensed contractor correctly described and disposed of appropriately.

Re-use on Site

It is still acceptable to re-use treated soil on site without the need for a waste management licence or exemption.  The Code of Practice makes practical suggestions on how the soil can be re-used on site and in particular advises against putting it near to a watercourse, particularly as it may have been treated with a herbicide.

Any area where the soil is used needs to be identified in a suitable management plan and inspected.  It is acknowledged that the biggest problem is that Knotweed can take hold of a site prior to redevelopment.  Again there are suggested herbicides that can be used to clear the site as well as sieving.

Any developer should be aware of the Code of Conduct, particularly when assessing an open site and particularly in winter when nature die back may have disguised the infestation.

It should be noted that land for Remediation Relief is available for remediation of land infested with Knotweed the same way that it is available for other contaminated land.

A person found guilty of an offence under the Wildlife & Countryside Act is liable on conviction in a Magistrates Court for up to 6 months imprisonment and/or a fine (not exceeding the statutory maximum which is currently £5,000.00) and in a Crown Court conviction could result in up to 2 years imprisonment and/or a fine.

Failing to deal with a Knotweed problem will inevitably cause delay and could potentially impact on the saleability of any development.  Not to mention affect the developer’s standing with the local authority.

Enquiries are always raised on development sites regarding Japanese Knotweed, but it may be difficult to prove the Vendors knowledge of the problem, particularly in Winter,  there is no substitute for careful inspection by someone who knows what they are looking for, and this should lead to negotiation on remediation of the site by the Vendor or an allowance for the remediation costs prior to any purchase.

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