Are you ready for reform? I
t probably won’t have escaped your attention that there are changes afoot in the way the
waste and recycling sector is being regulated. T e weekly infl ux of trade association e-newsletters that typically land on a Friday aſt ernoon are full of updates on white papers, regulatory position statements, consultations, and draſt amendments. T e sheer volume of change can make it challenging to keep pace with evolution across our sector, and it is correct that many updates and reforms are confi ned to, and therefore impact upon, specifi c segments of the market. T ere are however more central issues which will have a wider reach across diff erent types of operators.
CHARGING REFORMS
T is is an issue that is covered in more detail in other pages of this edition, but it is clear that the impact will be signifi cant. WRM has seen indicative fi gures showing that the cost of deployments for materials to land will nearly double. T is will aff ect streams such as plasterboard that are collected in waste transfer stations which are oſt en used as land spreading materials to confer benefi t to agricultural land.
Such operational cost changes will no doubt make operators think about their existing outlets and consider options, and this has the potential to deliver business decisions that are perhaps not in the best interest of progressing the waste hierarchy. T e government’s desire to see the industry fund the Agency’s activities is clear, although it needs to be seen whether the additional cost pressure will bring a decline in recycling activity.
THE IMPACT OF UNCERTAINTY
It seems that 2017 has been, ‘the year of the consultation’. Specifi c consultations on eligibility for drying within the RHI scheme, a Working Group on the classifi cation of mixed wood wastes are just two examples where policy is up for review.
Rather than deliver timely announcements on proposed reforms, these consultations have delivered an extended period of uncertainty on long term policy and this has undoubtedly led to a climate of reduced investor confi dence. We see, from daily discussions with our clients, that the appetite to progress with new projects and investments is there, although company directors, boards and lending committees are reluctant to commit fi nance when long overdue announcements have the potential to impact projects at an early stage of their term. T is is particularly frustrating, and perhaps a policy tension that confl icts with the governments mantra of an industry, rather than policy led sector.
PERMIT APPLICATION REQUIREMENTS
Perhaps one of the most profound changes that we have seen is the way in which the Environment Agency is considering and determining permit applications. We have seen, in our recent work for some clients, greater challenges on land spreading deployments, and a more stringent approach to determining applications for new waste management facilities. On the latter point, we are seeing examples where by the traditional permit management system is no longer suffi cient, with the applicant instead being asked to submit a management system that fully
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