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Proposals to change waste exemptions - Your feedback needed

The Environment Agency have been working on some changes to the waste exemptions and they have asked REA to help gather comments from industry. They welcome comments which either support or object to their proposals.
 
The EA are working to tight time constraints.  Comments will be appreciated by mid-December at the latest.They are also interested in any additional issues and/or proposals which industry identifies. Any market analysis on waste types and flows will be appreciated.  Any supporting evidence which helps set out the case for change or other will again be appreciated. 

Proposals:
The proposed changes to the exemptions are outlined in this spreadsheet.

Please note that the EA is proposing to withdraw exemptions T24 (anaerobic digestion at premises used for agriculture and burning resulting biogas) and T25 (anaerobic digestion at premises not used for agriculture and burning resulting biogas). The reason for this is the number of environmental incidents recorded at sites operating under this exemption, which are of a severity inconsistent with a low risk activity. If these proposals are adopted, this will clearly add significant costs associated with obtaining a permit and complying with the permit requirements. 
 
The spreadsheet has a number of tabs arranged as follows:

Introduction – sets out the background to the work and some of the EA's high-level thinking;
Individual exemptions summary – a summary of the changes they might apply to each of the existing exemptions
All exemptions – details of the proposals that might be applied across the whole of the exemptions regime and that would affect many or all exemptions.
New Exemptions – possible new exemptions that the EA might seek to have introduced
 
There then follows a separate tab for each of the exemptions that the EA are proposing to change. Each tab has the following columns:

Issue – this details the particular issue associated with the exemption that they are seeking to address;
Proposal – the specific change that is being considered;
Rationale – the reasoning behind the change;
Supporting Evidence – the supporting evidence that demonstrates that there is an issue;
Industry comments -  a place to record the views of industry;
Transitional costs – an estimate of any costs involved in moving from the current arrangements to those that are proposed;
Annual costs to business – an estimate of any additional annual costs that would be incurred by business in the event that the proposal is adopted;
Annual costs to public sector – an estimate of any annual costs that would be incurred by the public sector in the event that the proposal is adopted;
Annual benefits to business – an estimate of the annual financial benefits that would accrue to business if the proposal is adopted;
Annual benefits to the public sector - an estimate of the annual financial benefits that would accrue to the public sector if the proposal is adopted. 

Please send Jeremy any comments you have on the proposals by 10th December at the latest, so that we have some time to collate and submit your comments.

Published: 27/11/2015

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