National Threat Assessment 2008. Organised Crime - Politie

This section explains how criminals misuse the opportunities offered
by the logistical chain involved in soil remediation.
3.4.2 General context
Before 1980 there was relatively little political or police attention focused on the
problem of seriously contaminated ground in the Netherlands. However, in 1980
the ground in a residential district in Lekkerkerk turned out to be seriously
contaminated by chemical waste.
There are various reasons why the ground gets contaminated:
• dumping/discharging of waste, sludge, process water;
• storage and transhipment of liquids and other materials;
• (former) business activities;
• working with contaminants without taking measures to protect the soil;
• spread from neighbouring sites;
• precipitation spraying the ground with airborne contaminants.
Even though the pollution is often not immediately visible, polluted ground
is equivalent to waste, which gives it a negative value. Remediation gives the
ground a positive value once again, making it usable as a raw material or for
building purposes. The main reasons for soil remediation are making the land
suitable for building on (38%), maintenance of the soil or repairing damage
to the soil (18%), tackling risks involved in current or future use (9%) and
purchasing/selling the land (7%).
However, soil remediation often involves major financial interests, as a result
of which there is frequently a certain tension between ecological and economic
interests. Customers want their ‘problem’ solved for as little money as possible.
Illegal working and pricing agreements have been identified, which, like
malpractice in the construction industry, can continue to exist thanks to the
process of ‘effective non-disclosure’ 44 . The non-disclosure of malpractice stems
from the fact that the soil remediation sector is a ‘small world’ where most of
the players know each other and a small number of players control a large share
of the market. Some of the business people involved believe that the rules for
reusing polluted ground are too strict. This attitude affects the way in which
some people interpret and follow the rules. Another important aspect also plays
44
Term introduced by Van de Bunt (2007). Source: Dienst IPOL, 2008. Bodemsaneringen. Verslag
van een onderzoek voor het Nationaal dreigingsbeeld 2008. Korps landelijke politiediensten
(Netherlands Police Agency), Dienst IPOL, Zoetermeer.
chapter 3 – Fraud and money laundering
113