Do you think that any of the options will impose specific costs or bring benefits on yourself or your organisation? No comment Which of the proposed options for exemption T12 do you support and which do you prefer? We would support option 2 but prefer option 1. Do you have further evidence on the current unlawful use of this exemption? No comment Do you think that any of the options will impose specific costs or bring benefits on yourself or your organisation? No comment Do you have further evidence on the current unlawful use of this exemption? No comment Do you think that any of the options will impose specific costs or bring benefits on yourself or your organisation? No comment Which of the proposed options for exemptions S1 and S2 do you support and which do you prefer? We support option 2, provided it includes the EWC codes 10 13 12* and 10 13 13, and 10 01 01, 10 01 01, 10 01 05 and 10 01 15. Do think that the proposal to split the existing S1 and S2 exemptions into six new exemptions as set out under Annex 9 would help clarify what the exemptions are for and make the conditions clearer? Yes. The new S5 exemption should retain EWC codes 10 01 01, 10 01 01, 10 01 05 and 10 01 15 for synthetic gypsum and pulverised fly ash, which are currently included in S2. The new S5 exemption should also include 2 EWC codes 10 13 12* and 10 13 13 for kiln dusts. This would allow cement manufacturers to store and handle kiln dusts in the same manner already used for pulverised fly ash under S2. For all these EWC codes there should be no volume limit provided they are stored in silos for less than 12 months. Do you think that operators should be required to keep and make available to the regulator records of the activities carried under any exemption? Yes, we agree. Should operators be required to keep the records required in an electronic format and/or in a system identified by the regulator? Yes, we agree as long as it is appropriate to the risk posed by the operation.
Do you think that any of the options will impose specific costs or bring benefits on yourself or your organisation? No comment Which of the proposed options for exemption T12 do you support and which do you prefer? We would support option 2 but prefer option 1. Do you have further evidence on the current unlawful use of this exemption? No comment Do you think that any of the options will impose specific costs or bring benefits on yourself or your organisation? No comment Do you have further evidence on the current unlawful use of this exemption? No comment Do you think that any of the options will impose specific costs or bring benefits on yourself or your organisation? No comment Which of the proposed options for exemptions S1 and S2 do you support and which do you prefer? We support option 2, provided it includes the EWC codes 10 13 12* and 10 13 13, and 10 01 01, 10 01 01, 10 01 05 and 10 01 15. Do think that the proposal to split the existing S1 and S2 exemptions into six new exemptions as set out under Annex 9 would help clarify what the exemptions are for and make the conditions clearer? Yes. The new S5 exemption should retain EWC codes 10 01 01, 10 01 01, 10 01 05 and 10 01 15 for synthetic gypsum and pulverised fly ash, which are currently included in S2. The new S5 exemption should also include 2 EWC codes 10 13 12* and 10 13 13 for kiln dusts. This would allow cement manufacturers to store and handle kiln dusts in the same manner already used for pulverised fly ash under S2. For all these EWC codes there should be no volume limit provided they are stored in silos for less than 12 months. Do you think that operators should be required to keep and make available to the regulator records of the activities carried under any exemption? Yes, we agree. Should operators be required to keep the records required in an electronic format and/or in a system identified by the regulator? Yes, we agree as long as it is appropriate to the risk posed by the operation.
26-03-18_Waste_crime_response.docx