Low Risk Waste Positions (England)

UPDATE : instructions on Registered Waste Exemptions was updated today (21st August) – here.

The Environment Agency is not currently enforcing the need for an environmental permit in specific cases for some activities.

These low risk waste positions (LRWPs) explain when a waste producer does not need to apply for an environmental permit for those activities.

A number of LRWPs are issued – here.

The online source for Registering Waste Exemptions is here.

EU Exit regulatory position statements (UK Brexit)

Exit day is 12th April

Yesterday (1st April) the Environment Agency began issuing EU Exit regulatory position statements (UK RPS).

These set out (time-limited) environmental permitting and licensing situations where the Environment Agency will not take action for non-compliance due to EU Exit.

The first two relate to radioactive materials and radioactive waste – here.

I will add these to a separate category in the Brexit Law List (in subscribers’ Cardinal Environment EHS Legislation Registers & Checklists).

Waste Transport across borders will become more difficult and delayed after EU Exit. Make sure checks are carried out on amounts stored vis a vis EPR Schedule 3 exemption limits. Contact the Environment Agency if limits will be exceeded.

Scotland, Wales and Northern Ireland – contact the local regulator.

[the Exit day may change, please continue to follow this Blog]

Standard Rules Environmental Permitting (England)

The Environment Agency offers standard rules environmental permits in England for listed activities.

Further permits are now available (waste).

The full list is here.

Note : standard rules permits are cheaper, but

• the rules cannot be varied and there is no right of appeal against them

• any change in operations so a standard permit no longer works for the operation results in a requirement to make it a bespoke permit instead

• if there is a change in the local environment after the permit has been issued (for example due to a change in the definition of a groundwater source protection zone), the operation may need to be upgraded to a standard sufficient for the changed environment, or the permit changed to a bespoke permit