I recently wrote about the proposed changes to Standard Rules Permits so it’s a logical next step to talk about proposed changes to the Exemptions from the need to obtain Environmental Permits.

Detailed information has been published about the proposed changes that are due to come into force in 2024. Essentially, some waste activities that are currently exempt from the need to obtain a permit will need a permit, to be undertaken.

A quick search on the internet will provide lots of the details about the proposed changes so I do not intend to cover these here. However, what I do want to cover is what action you should take to ensure that any changes are as painless as possible. I have listed below a number of suggestions to help you:

• Review your current registered exemptions – if you are not sure what you have registered then look on the Exemption Public Register on the environmental regulator’s website.
• Check each of your registered exemptions and consider if you still carry out the activity covered by that exemption.
  • If no, then let it lapse or ask for it to be de-registered.
  • If yes, then check the consultation document to see what the proposed changes are for that exemption.
  • If you still wish to carry out an activity that will no longer be covered by an exemption, then you will need to apply for a permit or vary an existing permit. Either of these actions can be expensive in both time and costs.

• If you need to obtain a new permit, seek early advice so you can understand the costs and the process for both obtaining the permit and putting in place other requirements for permit compliance such as the environmental management System (EMS) and Technically Competent Manager (TCM).

If you need to vary an existing permit to include those previously exempt activities it’s likely you are familiar with the permitting process and have a TCM in place. Don’t forget that your EMS will need to be updated to include the additional activities and any new permit requirements. Depending on the proposed activities and what is already in your permit the application fee can vary significantly so take early advice.

There are lots of reasons why permits may need to be varied. Not least so, the forthcoming changes to the Standard Rules Permits. Therefore, I strongly advise looking at your permitting needs for the foreseeable future to ensure that a comprehensive permit variation application can be submitted that will include all the required changes. Making just one application could potentially save you thousands of pounds in application fees compared to multiple applications.

I understand that all the proposed changes to permits and exemptions can be daunting so to help you navigate these changes I am preparing a FREE 1-hour webinar to be held on Wednesday 27^th September at 12pm. Further information will be released closer to the date. To register your place, simply click here to email us with the names and email addresses of those who wish to attend.