The ‘change’ I am referring to here is the proposed change to some Standard Rules Permits that many waste sites will be operating under. This includes waste transfer stations, metal recycling facilities, household waste recycling centres, waste wood recyclers, construction / demolition waste recyclers and others.

At present the proposed changes are progressing through the consultation process and it is unknown when or what changes will be implemented. You can read the full consultation document on the .gov.uk website by searching for standard rules consultation no 25.

However, there are a few things we can be certain of:

• There are likely to be additional infrastructure requirements / changes to processes required for operators who remain operating under the new standard rules permits.
• There is likely to be a considerable number of operators who need to change their standard rules permit to a bespoke permit.

Will you embrace the change?? Likely not, as either of the two options above could be expensive. So, my advice is to take advice early and weigh up the options and costs. There is no need for any nasty surprises, your site and operations can be reviewed against the proposed changes. The consultation document proposes that once the changes are implemented operators will have three months to comply with the conditions of the new std rules permits or get bespoke permits. How this will work with the current long delays with permit applications being determined by the regulators is unknown!

For example, a construction / demolition waste recycler operating under a std rules permit 2010 no. 12 would need to undertake operations inside an enclosed building if there is a residential dwelling or workplace within 200m and have an impermeable surface with sealed drainage if the site is located within a groundwater Source Protection Zone two or three. Sites located in a Source Protection Zone one will not be able to operate under the new std rules permit.

Another example, non-hazardous waste handling and treatment under the new std. rules permits will have to be undertaken within an enclosed building. An enclosed building will have a minimal sized door so that precludes the typical three-sided building.

Applications for bespoke permits are likely to require management plans for dust, noise and/or odour. These will describe the mitigation measures appropriate for the site, operations and its surroundings to ensure that such emissions are controlled to prevent nuisance. The preparation and determination of these can add significant costs to the application along with the potential cost of installing equipment.

Please don’t hesitate to give us a call if you have questions regarding the proposed changes and what they mean for your site / operations. We can advise you how the location of your site could impact your options going forward.