By Neil Carrett, Technical Manager, London CRN (21 October 2005)

Comments are as follows:

• Paragraph 17- We agree with the broad changes to the exemption. However we would ask that it be made clearer whether or not paper and cardboard can be stored in an open top skip and covered during adverse weather conditions or when access is not required. For operational reasons requiring coverage at all times would limit this exemption’s capacity to encourage recycling on any reasonable scale whilst reasonable containment can still be assured.
• Paragraph 17- Strongly agree with the exemption of amounts of wood destined for reuse. However, the National Community Wood Recycling Project states that an enterprise following their business model turns over closer to 500 tonnes per annum. There are an increasing number of these projects in the UK and they have a very significant potential to make a contribution to the sustainable management of construction and demolition waste. We would ask that Defra extend the proposed exemption to at least 500 tonnes per annum for non-hazardous wood.
• Paragraph 17- we would argue that the exemption on paint should be extended to notifiable temporary collection points to allow for occasional events to encourage residents to donate unwanted paint. A greater priority is that the exemption should cover bulking and collection points where they are the same. This would allow householders to donate both directly to a community group operating a community repaint scheme and also via a CA site.
• Paragraph 17- the exemption should cover the bulking of both dry cell and car batteries for recovery/recycling. The inclusion of the storage of dry cell batteries in the low risk waste activities list has not caused any problems that we are aware of to date and we see no reason why this should not be formalised in an exemption. The exemption of bulking also poses no less risk than the corresponding exemption allowing publicly accessible battery banks. Clearly, if such an exemption is introduced a reduced timescale should be placed on it with regards to how long the batteries are allowed to remain on site so that they are not allowed to deteriorate.
• Paragraph 28- Agree that the exemption as it currently stands is problematic but have not come across any evidence of it being abused. Would argue that the exemption should be retained with broad conditions. It would not always be the decision of the retailer to discard any item. Consumer items are becoming more diverse and complex whilst being whilst often being less durable. Correspondingly householders are also increasingly subject to waste management compulsion measures by collection authorities such as alternative weekly collections and may increasingly seek to use instore takeback as an option. We also anticipate an increase in voluntary producer responsibility initiatives over coming years ahead of an increase in formal regulation. We therefore anticipate instore takeback to increase (whether by the retailer solicited or otherwise) and to be potentially valuable.