Rubbish beginning to stink?

According to The Guardian, leaked emails show officials planning crisis centres to manage halt in waste exports to EU.

The UK ships about 3m tonnes of waste a year to the EU, most of it household rubbish. Government officials are preparing to deal with “putrefying stockpiles” of rubbish in the event of a no-deal Brexit, according to documents leaked to the Guardian.

If the UK leaves the EU without a deal on 29 March, export licences for millions of tonnes of waste will become invalid overnight. Environment Agency (EA) officials said leaking stockpiles could cause pollution.

The EA is also concerned that if farmers cannot export beef and lamb, a backlog of livestock on farms could cause liquid manure stores to overflow. A senior MP said the problems could cause a public health and environmental pollution emergency. An EA source said: “It could all get very ugly, very quickly.”

The Guardian headline of "Officials warn of ‘putrefying’ rubbish after no-deal Brexit", as you might expect, is already attracting ridicule among Brexiters, but this is the stuff that's actually worth taking seriously - and certainly a lot more seriously than the lurid predictions of what might happen at the ports. The Belfast Telegraph two days ago gave us some insight into the issue.

Massive amounts of chicken and pig manure are sent south to anaerobic digestion (AD) plants each year to create energy. If the border becomes a frontier with the EU in less than 10 weeks, no one knows that will happen to litter from intensive farming, SDLP MLA John Dallat said.

The Ulster Farmers' Union (UFU) said solutions could involve spreading more on the land, incineration and the use of other waste at energy facilities. Historically it would have been burned in Scotland. Mr Dallat said ammonia levels, a gas from animal waste, are higher here than in the Republic or Britain.

He said: "I believe there is now a real risk to our rivers, watercourses, lakes and indeed the sea as ammonia and other nitrates build up to levels that are well above what is considered safe, and we have no Assembly to address this issue." The MLA estimated that some 75,000 tonnes of animal waste are sent across the border each year for processing into energy.

The Guardian further explores the issue touching more general waste which is also subject to tariffs while a number of other crossover regulatory controls kick in. A quick glance at the EU's own Notices to Stakeholders would seem to confirm there is cause for alarm.

What the Guardian hasn't bothered to do is find out precisely what will take effect. Without adequate preparation (and who is to say what is adequate?) we have something of a problem on our hands. It doesn't take much for the system to break down.

It is worth pointing out that the Notices to Stakeholders were published on 8 November 2018. It has taken the Guardian three months to notice something that has been in the public domain for nearly a quarter of a year - then only noticing because it is "leaked" from UK sources. Once again, we see the best way of keeping a secret is for the Commission to publish material openly on its own website.

To understand the real world implications there is a more recent example of EU officialdom reported recently in the Farmers Guardian when the European Commission failed to re-authorise the Red Tractor assurance scheme, along with four different schemes from other member states, despite the application for re-approval being lodged six months ago. The unexplained gaffe meant farmers whose grain was destined for the biofuels market were been left in the lurch, with some having to fork out for interim storage.

NFU combinable crops board chairman Mike Hambly said: "This current situation is a good wake-up call to Defra, the Department for International Trade, the end consumer and also farmers. No paperwork or tick in a box equals no trade, and it worries me it could happen in many ways, be that through chemical re-registration being missed or even a change in labelling. The importance of these things needs to be absorbed by us all and we need to be active in pushing for timely action to prevent issues rather than waiting until they become a major financial burden".

There are a number of sectors similarly dependent on authorisations and if the UK becomes a third country overnight then a number of sectors come to a grinding halt. We are told by hard Brexiters that we are exaggerating - and that it's all just a "millennium bug" panic but, categorically, it isn't. From aerospace to chemicals registration, if the certification system is not in good legal standing then trade simply does not happen. Now imagine all of these problems hitting simultaneously. Not good is it?

This is in line with my assessment earlier in the week that it is entirely possible that the headline effects of no deal can be mitigated to the point where on the face of it, Brexit day is a non-event. The blow will be felt more acutely further down the line. We can't say if contingency plans are adequate or whether the government has the absorptive capacity to deal with regulatory failures on every front.

This blog has frequently explored the theme of "invisible government"; that which most people are blissfully unaware of until it stops working. This is what much of the debate is unwilling to entertain since it is assumed this all runs independently of the EU. There is, therefore, virtually zero chance the Guardian story will be treated with the necessary seriousness by Brexiers while remainers will exaggerate it to the point of ridicule - not least since the report is littered with errors and assumptions.

At this point a more forensic analysis of the article would be utterly futile since firstly, no-one would bother to read it and secondly, BrexitCentral or Guido will by morning have invented a rebuttal citing an opinion of prestige (with no reference to primary sources) and be-leavers can carry on thinking this is all just a big hoax.

But then, one factor the Guardian neglects to explore fully is that these regulatory systems facilitating the export and control of waste are worth serious money - especially to the rural economy. This is domain of trade thus far not explored. Of the superficial debate there has been on trade it has been limited to tariffs on lettuces and the RO-RO logistics. As much as these specialist regulatory frameworks facilitate whole sectors, they also create a number of opportunities for trade in support services and transport.

Supposing this is all entirely within the realms of manageable disruption and business finds a way to adapt, they are still looking at sinking serious money into adaptation that goes with any change of regulatory regime. This is why so many SMEs hated the installation of the single market. This time, though, the adaptation reduces their export potential. The second problem is that the adaptation itself will register as economic activity within our own borders thus for a time will prop up GDP giving us false signals and we won't actually fully understand what is happening for a few months.

Brexiters will of course claim that because no deal Brexit does not produce scenes reminiscent of the Winter of Discontent, that their blase approach is entirely vindicated, but as ever, it wouldn't be them left to clear up the messes that will manifest in far more subtle ways. By Christmas, it will be their bullshit stinking up the town.