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aligns with, although is not necessarily certifi ed to, the ISO14001 standard.
Whilst measures to ensure that waste management facilities have adequate management systems in place for environmental protection, and the aspiration to align to a common standard need to be applauded, the means and timing by which this requirement is being introduced is alarming, with the full require- ments only being made known sometime aſt er the application has been duly made. We are also seeing signifi cant geographical variation on this matter which is unwelcome for all stakeholders involved in the process.
WHAT ARE THESE REFORMS SET TO ACHIEVE?
T ere is a fair chance that this is not the fi rst article you will have read which concludes that these developments are unhelpful and advocates clarity across a range of policy and regulatory matters. T e strong policy of previous governments combined with a regulatory approach of working with industry has in recent years created the drivers which have enabled our industry to make great gains in implementing the
Gradeley Green Farm, Hollins Green Lane, Burland, Nantwich, Cheshire, CW5 8NN
waste hierarchy, both in terms of the range of material and the quantity of recyclate.
It needs to be recognised that the current direction of travel, characterised by some of the examples discussed above, will create extra costs to operators and that this has the potential to be damaging to the progress our industry has made. As a consultant that advises operators, such a claim on cost could be construed as being protectionist on profi t, but we feel the impacts will be more severe as the low margins for some operations, such as land spreading, will not allow costs of the changes to be borne. In these instances, operators may give up, and progress will be lost as material will likely fi nd its way back into lower quality applications or even landfi lled. For new developments, increased uncertainty and permitting risk will turn investors away from the many great technologies that are prevailing at a variety of scales.
In short, it appears that the changes create conditions for certain segments of the market to stagnate or decline, and we need to take the opportunity to voice this opinion through UROC.
By Mark Richmond, Technical Director, WRM Ltd. 13
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