Waste Tansfer Notes....'fingers crossed!'

[AA Teccie (Paul)]

Hi all, hope you're well!

 

I acknowledge there was a very recent posting regrading WTNs but sorry I didn't have time to back search it.

 

Anyway I sincerely hope we have some good news coming from the EA National Policy Team on this matter as it would appear that:

 

1. IF you are transferring 'waste' (YES, I know...BUT!) from a domestic dwelling it is exempt from the requirement for WTNs.

 

2. IF you are transferring 'waste' to a site registered under an exemption, i.e. 'Para. 21 exemption then it is also exempt as no transfer has actually taken place.

 

I am currently awaiting confirmation of the above but it does look very promising...fingers crossed everyone!

 

Cheers..

Paul

 

PS The Para.21 exemption does not incur a cost and involves the completion and submission of a relatively simple (for me anyway) form. Obviously though it does then put the firm on the radar, so to speak, and more likley therefore to encounter an uninvited visit...not that that should be of any concern of course!

[Amelanchier]

Hi all, hope you're well!

 

I acknowledge there was a very recent posting regrading WTNs but sorry I didn't have time to back search it.

 

Anyway I sincerely hope we have some good news coming from the EA National Policy Team on this matter as it would appear that:

 

1. IF you are transferring 'waste' (YES, I know...BUT!) from a domestic dwelling it is exempt from the requirement for WTNs.

 

2. IF you are transferring 'waste' to a site registered under an exemption, i.e. 'Para. 21 exemption then it is also exempt as no transfer has actually taken place.

 

I am currently awaiting confirmation of the above but it does look very promising...fingers crossed everyone!

 

Cheers..

Paul

 

PS The Para.21 exemption does not incur a cost and involves the completion and submission of a relatively simple (for me anyway) form. Obviously though it does then put the firm on the radar, so to speak, and more likley therefore to encounter an uninvited visit...not that that should be of any concern of course!

 

Sounds promising Paul! Bet you've logged some hours on hold with the EA to get this far!

 

IIRC the form you mention can be completed online via the EA website - its been catchily titled; "T6 - Treatment of waste wood and waste plant matter by chipping, shredding, cutting or pulverising"

 

Environment Agency - T6 - Treatment of waste wood and waste plant matter by chipping, shredding, cutting or pulverising

[skyhuck]

Hi all, hope you're well!

 

I acknowledge there was a very recent posting regrading WTNs but sorry I didn't have time to back search it.

 

Anyway I sincerely hope we have some good news coming from the EA National Policy Team on this matter as it would appear that:

 

1. IF you are transferring 'waste' (YES, I know...BUT!) from a domestic dwelling it is exempt from the requirement for WTNs.

 

2. IF you are transferring 'waste' to a site registered under an exemption, i.e. 'Para. 21 exemption then it is also exempt as no transfer has actually taken place.

 

I am currently awaiting confirmation of the above but it does look very promising...fingers crossed everyone!

 

Cheers..

Paul

 

PS The Para.21 exemption does not incur a cost and involves the completion and submission of a relatively simple (for me anyway) form. Obviously though it does then put the firm on the radar, so to speak, and more likley therefore to encounter an uninvited visit...not that that should be of any concern of course!

 

This is great news, Paul

 

And I thank you for all your efforts!!

 

BUT if no waste has been transfered, you won't need a WCL, surely??

[Rupe]

Huck, I don't think they are going to budge on the classification of Waste issue, but applying common sense and saying its ok as long as its being used for something and not tipped is a good thing.

 

I think thats what the point is but I'm so confused by the whole thing. Someone tell me what forms I have to fill in ONCE ONLY and for FREE and I'll do it, anything to be filled in daily or costing me money then I would rather not bother!

[Yeti]

All this lot is makng my head spin haha

[Paul Smith]

Para 21 exemption http://www.environment-agency.gov.uk/business/topics/permitting/34813.aspx

[AA Teccie (Paul)]

Okay, the news is good...generally!

 

FIRSTLY, if you are dealing with 'waste' (IF any greenery/softwood etc. is involved we have to accept it is techncially 'waste' regardless of what we do with it in terms of recycling / reusing etc. The only possible exception here is the 'Virgin Timber', i.e. no greenery!) then the key question is whether you are deemed to be the 'producer' or not (by the EAs own admission a potentially 'grey' area.)

 

Regardless, if the 'waste' generated originates from a domestic dwelling there is no need for a Waste Transfer Note (WTN) provided this is delivered/tipped and stored at the contractors own site, or leased site, which is regsietered as an exempt site as no transfer has taken place (see previous postings to access this on EA website.)

 

However, if you are working on a commercial site, for instance, AND the commercial manager instructs you to remove a tree then he would be deemed the 'originator' (producer) of the waste and a WTN would be deemed a requirement. Indeed this would definately be the case if you were transferring the waste to a third party site AND the third party should require this of you. However, however, if YOU advise the manager the tree needs to be removed, and therefore you are deemed the 'producer' of the waste AND you are transferring it to your own (again, registered exempt site) then you don't need a WTN either (me thinks you need to be careful how you word you qotes here, i.e further to our recent site visit I would recommend etc. etc.)

 

Someone raised the issue of Waste Carriers Licences, and quite rightly so in light of the above, BUT the (very strong) EA advice is that you should as there will undoubtedly be occasions when you are legally deemed to be the 'producer of waste'. i.e. where someone else is responsible through advice for it's production (tree officer) OR where you clear a fallen tree (examples provided by the EA.)

 

In a nutshell: obtain a Waste Carriers Licence, albeit for that odd occasion you may need one, and register your woodchip site as an exempt site and be armed with the infomration above. However, there may still be the occasions when waste transfer notes are required.

 

Lastly they caveat all advice saying this is NOT a definitive statement of law, only the courts can decide that, but is advisory information.....the world we live in eh?, no-ones prepared to nail their colours to the mast, ah well!

 

Lastly, lastly...Tony can you make sense of this and put it in plain English?, many thanks!

 

Cheers all..

Paul

 

PS can we leave the 'revolution' for a coup,e of years until I get the new 'ARB Approved Contractor' scheme up and running and then I'll battle the EA and waste classification again...THANK YOU!

Edited November 10, 2010 by AA Teccie (Paul)

[tommer9]

Top stuff Paul. Excellent work.

[Recceboy]

Excellent information. Well done on the hardwork battling with the EA.

 

Now is there part of the forum where this information could be stored for future reference for any newbies?

 

basically a Law/legislation area were the important links, documents, forms could be stored for future use.

[Amelanchier]

Lastly, lastly...Tony can you make sense of this and put it in plain English?, many thanks!

 

I think you've done it yourself already Paul.

 

In a nutshell: obtain a Waste Carriers Licence, albeit for that odd occasion you may need one, and register your woodchip site as an exempt site and be armed with the infomration above. However, there may still be the occasions when waste transfer notes are required.

 

Maybe a pretty flowchart would be handy? If I get a chance (ha ha) I'll see if I can put something together.

 

I think the key (as has been said before) is not to get too hung up on the words used - "waste", "exempt". They're used in a legislative sense and mean specific things beyond their normal day to day use. Bit like the word "nuisance" in relation to protected trees.