“However, if the proposed regulatory changes go ahead, many recyclers will have to live with a sharply reduced stock-holding. This would sound the death-knell for some of these businesses, which operate to very fine margins. Wood is a low-cost, high volume material and if the brakes are put too strongly on the amounts which recyclers can hold, a number of businesses may become unviable.


“A factor which many fail to grasp is the extreme seasonality of this industry. Most waste wood is available in the summer months,but peak demand for wood chip comes in the winter, meaning recyclers will always have peak stocks in late summer. Unless regulators grasp this point and work with the industry to manage the situation, there will be some serious unintended consequences.


“What disappoints me most about this guidance document is that it has been produced without any industry involvement. Had the authors spoken to us, then many of the inaccurate and potentially very damaging passages in the document might have been avoided. This is a good example of how government and industry need to work much closer together.


On the other hand, I am seeing evidence through the fire storage issue of close cooperation between WRA members (many of whom are competitors with each other, remember) and between the various sectors. The WRA is working closely with the Renewable Energy Association, the Wood Panel Industries Federation and the Tyre Recovery Association, to name but three, to oppose the contents of the draft guidance. This surely has to be a good sign for the future.”


For more information on the wood recycling association visit www.woodrecyclers.org

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