Diritto Pubblico Comparato ed Europeo

Sommario

1. Breve introduzione sistemologica. – 2. I modelli “forti” di diritto (amministrativo e ambientale) dei rifiuti nell’esperienza comparatistica: gli ordinamenti germanico e britannico. – 3. Il modello francese. – 4. Il modello dei Paesi nordici. – 5. Conclusioni.

Abstract

The article classifies in 4 models waste management legislation in European countries. This classification is based on the degree of privatization. First, is the French model that is characterized by a scarce implementation of privatisation and by putting local public services in the jurisdiction of administrative law (except for household solid waste). Second, is the British model, which has been featuring, starting in the 1980s, the so called contractualization. Contractualization provides for an indirect management of local public services. Third, is the German and Austrian model, which represents a mixed hybrid solution combining elements of the French and of the British model. Fourth, is the Northern European model which stands alone because of its well known efficiency and capacity of controlling prices, rather than for a matter of relevance of private entrepreneurship in local services management.