This week, Alasdair is joined by a very special guest — Samantha Riggs, a criminal barrister from 25 Bedford Row and one of the UK’s few legal specialists working almost exclusively in environmental and waste management law. Samantha has spent over a decade navigating the complexities of regulation, enforcement, and prosecution in the waste sector — and she also happens to be a long-time Rubbish Talk listener.
Samantha’s legal career began in fraud, including notable cases like hallmarking scams in Birmingham’s Jewellery Quarter and even a nine-month trial involving a man posing as an MI5 officer — the subject of Netflix’s “Rogue Agent”. Eventually she moved away from lengthy fraud trials and into environmental regulation, a field she found far more meaningful and intellectually engaging. She has now specialised in waste for over 12 years.
Much of the discussion centres on the major illegal waste sites emerging across England, including high-profile cases like Hodes Wood and Kiddlington, where tens of thousands of tonnes of waste were deposited illegally despite the regulator being aware months earlier. Samantha explains why frustration is growing within the regulated industry: compliant operators face scrutiny for minor issues while enormous illegal sites flourish unchecked.
She highlights a critical question raised in the House of Lords inquiry into waste crime — if the Environment Agency knew these sites were active in July, why were restriction orders not issued until October? With mountains of waste reaching 30,000–50,000 tonnes, public concern is justified, especially when residents were swimming downstream of sites later found to contain contaminated waste.
Samantha emphasises that the regulator doesn’t need more authority — it already has extensive powers to restrict sites, seize vehicles, question suspects, and shut down illegal operations. The real issue is that these powers aren’t being used effectively. Slow action, weak coordination and unclear accountability mean illegal sites can operate long after being identified. As Samantha notes, the legislation is strong, but the system lacks the drive and structure to enforce it — a concern also highlighted in the recent Lords inquiry.
Samantha explains that sentencing law in England and Wales allows courts to recover full cleanup costs, remove illegal profits, and issue prison sentences of up to five years. Yet many cases never include cleanup cost submissions, and financial investigations are often skipped — meaning fines reflect what offenders claim to earn rather than what they actually gained. According to Samantha, the problem isn’t the sentencing framework but inconsistent application and a lack of specialist understanding within the system.
The conversation also dives into landfill tax fraud, blurred lines between legitimate operators and organised crime, and how producer pressure to keep costs low fuels illegal activity. Samantha stresses that digital waste tracking will help compliant businesses but won’t stop criminals who already avoid paperwork. Ultimately, she argues that England needs independent oversight — similar to Scotland’s split between SEPA and the Procurator Fiscal — because the Environment Agency currently investigates, prosecutes and effectively judges cases with little external scrutiny.
Useful Links 🔗
Independent review on waste crime needed following multiple failures and lack of action
House of lords letter regarding Waste crime enquiry
The National Fly-Tipping Prevention Group
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