Fortnightly Bulletin – 4th December 2023
5 December 2023
Medium Combustion Plant (MCP) and Specified Generators (SG) update – England only
Submission date for existing 5-20Mwth MCP permit application expired 30th September 2023.
Standard Rules permit applications for existing MCPs 5-20MWth should have been made before 30th September 2023 to allow the Environment Agency the statutory time to determine them and issue a permit before the regulatory deadline of the 1st of January 2024.
Applications made after this date cannot be guaranteed to be permitted by the 1st of January 2024.
Operations which continue to operate without the necessary permit after the 1st of January 2024 may be subject to enforcement action. Submit the permit application as soon as possible to avoid this.
Using shredded waste carpet in equestrian surfacing: Regulatory Position Statement RPS 248
This RPS advises when you can use shredded waste carpets in equestrian surfacing without an environmental permit.
This RPS only applies to waste carpet that has been shredded or is in fibre form before it is used and is from the following sources.
- Discarded carpet fibres and carpet offcuts from new carpets manufactured in the UK and the EU that are classed as waste.
- Treated post-consumer waste carpet with all physical contaminants including, but not limited to metal, carpet grippers and non-carpet-based plastic removed.
Complying with all the requirements of this RPS, shredded waste carpet in equestrian surfacing without an environmental permit for a waste operation. The RPS does not apply to any other activity, even if it is under the same legislation and you may still need other permits or licences for other activities carried out.
However, the EA will not normally take enforcement action when following the conditions of the RPS 248 are met.
Treating microbiological laboratory waste on the site where it is produced: RPS 233
This RPS applies to treating waste microbiological cultures and other microbiologically contaminated wastes by autoclaving to sterilise them before they are removed from site.
This RPS does not change your legal requirement to have an environmental permit for a waste operation when treating microbiological laboratory waste on site where it is produced.
However, the Environment Agency will not normally take enforcement action when complying with the conditions of the RPS 233 are met.
Articles of Interest
Environment Agency (EA): Join the fight against waste crime
Waste crime is a blight on our communities and environment. From blatant examples like fly-tipping rubbish by the roadside to environmental permit breaches and money-laundering, these activities can endanger people’s safety and undermine legitimate waste businesses.
On top of that, waste crime costs the economy in England an estimated £1 billion per year. That’s the same as the combined starting salary of over 38,000 newly qualified nurses.
The EA, as England’s environmental regulator, is at the frontline of the fight against rogue operators and organised criminals.
However, only 25% of waste crime incidents are reported to the Environment Agency. Without those reports, it’s harder for the EA to identify where crimes have been committed and where we need to act.
Those working in the industry often have the expertise to recognise when something isn’t right, or they may know the offenders themselves. It is essential to report any potential incidents to help the EA carry out enforcement effectively.
The EA states that this won’t be an easy fight, but with the support of partners across the waste industry, the EA is determined to keep one step ahead of the criminals, shut them out of the system and move all towards an economy in which there is no space for waste crime.
If you know or suspect illegal waste activity is taking place, report it anonymously to Crimestoppers through their dedicated website or by calling 0800 555 111. There is a 24-hour incident hotline available on 0800 80 70 60.
If you work in waste disposal, check you have the right permits in place: Waste: environmental permits – GOV.UK (www.gov.uk)
EMS Ltd (Environmental Monitoring Solution) Advisory can support you with your permit application to the regulatory authorities.
53% of people in the UK support an outright ban on waste exports
New research shows 53% of people in the UK support an outright ban on waste exports, with only 11% disagreeing.
The poll of a nationally representative sample of 2,000 UK adults was undertaken. It found that 72% of the public believed the UK should “deal” with the waste it creates rather than exporting it overseas. 70% of the public also said the government should aim to divert all waste from landfill. While 75% agree that the UK Government should ensure the maximum amount of energy is recovered from unrecyclable waste.
Source: Circular (CIWM)
Environmental Services Association (ESA) calls for plastic packaging tax to be raised
The Environmental Services Association has criticised the Autumn Statement and called for the Plastic Packaging Tax to be raised to £500 per tonne and a 50% minimum recycled content threshold.
Source: Circular (CIWM)
COP28: United Arab Emirates (UAE) planned to use climate talks to make oil deals
The UAE planned to use its role as the host of the United Nations (UN) climate talks as an opportunity to strike oil and gas deals, the BBC has learned.
Leaked briefing documents reveal plans to discuss fossil fuel deals with 15 nations. The UN body responsible for the COP28 summit told the BBC hosts were expected to act without bias or self-interest. The UAE team did not deny using COP28 meetings for business talks and said, “private meetings are private”. It declined to comment on what was discussed in the meeting and said its work has been focused on “meaningful climate action.”
Source: BBC News
Quantifying methane emissions using inverse dispersion modelling
The Environment Agency (EA) has carried out a project to investigate how a technique known as inverse dispersion modelling, can be used to estimate the amount of methane released from industrial sites regulated by the EA.
The recommendations are that the most suitable inverse dispersion modelling depends on emission characteristics, such as, side width and emission height, as well as other nearby sources of methane, complex landscapes, or obstructions to air flow. The selection of a method should balance uncertainty, complexity, and cost.
The EA acknowledges there are methods ready to use, inverse dispersion modelling is an area of active research and development. The EA are to continue to assess emerging approaches and that, further case studies would help in developing protocols for quantifying methane emissions at regulated site other than landfill.
Prosecutions and Fines
North East waste tyre firm fined for illegal operation
A North East company in England and its director have been ordered to pay fines and costs totalling almost £13,000 for running an illegal waste tyre site in Gateshead, following an investigation by the Environment Agency.
The company and director pleaded guilty to running an illegal waste site, illegally depositing tyres at other sites, and making inaccurate statements in waste transfer notes.
The company was fined £4,615 and ordered to pay costs and a victim surcharge totalling £4,096, and the director was fined £2,769 and ordered to pay costs and a victim surcharge totalling £1,458.
The company started trading from Gateshead in August 2022 and collected waste types from paying customer and took waste tyres back to the site where they were processed and disposed of via a third party.
The company did not have an environmental exemption or environmental permit and was running an illegal waste tyre site.
Tyre dealer ordered to pay £1,325 for failing to produce records
A tyre dealer and repairer, has been prosecuted for failing to submit waste transfer notes when asked to move 844 tyres from their Derbyshire base.
Environment Agency officers visited the premises following information that a large number of tyres were being stored around the premises. The EA Officers visited the site a month later to find that all the tyres had been removed, however, the tyre dealer and repairer, had failed to produce the waste transfer note. The EA officers made further attempts to contact the tyre dealer and repairer, via mobile phone and email which were ignored.
The tyre dealer and repairer, admitted the offence and was fined £518, ordered to pay costs of £600 and the victim surcharge of £207 coming to a total of £1325. They were issued with a fixed penalty notice for failing to produce waste transfer notes which they failed to pay.
Failing to comply with legal requirements to keep and produce records undermines legitimate businesses that work hard to operate within the regulations. The regime is intended to ensure that waste is disposed of correctly. The production of transfer notes is an important aspect of that regime.
Online Learning and Events
COP28 Key outcomes and the impact on climate policy presented in collaboration with Pledge to Net Zero
13th December 2023 15:00-16:00
IEMA are holding a webinar on 13th December 2023 on a practical overview of the key decision made at COP28 and the practical impact on businesses and other organisation.