Changes to permits.
In our post of 7th January we highlighted the changes to Standard Rules Permits. The principle change we saw was to the definition of a building. Many sites have buildings that are three sided but the new definition requires a building to be fully enclosed with doors as small as possible. This will be a major issue for many operators and the Agency have recognised this giving operators until 19th June 2026 to comply with this requirement.
But there are other issues too. We have one client who is currently operating on one of the older permits who cannot comply with the location requirements of the new permit. The new rules mean that he will have 3 months from the date of introduction of the new permit type to make a bespoke permit application or he will be operating illegally. That means he has a deadline of 18th March 2025 in order to make the application.
Another issue under the new rules is found under Section 2.3 (d), which says;
(d) in the case of soils other than from domestic premises, the following information has been obtained:
- information about the pollutants that could be present in the soil;
- an assessment to determine if the soil has hazardous properties based on representative sampling and analysis; and
- confirmation of the appropriate waste code based on the assessment.
What does this mean? Basically it means that any soils not from households must be properly assessed to WM3 before being accepted. That can be costly, so operators are going to have to think very carefully about accepting soils in future.
If you have any concerns that you may be affected by the changes, please give us a call to discuss.