It applies to the storage of baled and securely wrapped refuse derived fuel (RDF), mixed municipal waste and waste wood destined for incineration.
The exemption only applies where the Environment Agency has agreed in writing.
The move comes in a Regulatory Position Statement (RPS) which was launched this week in response to calls from the Wood Recyclers’ Association (WRA) and other industry groups.
The groups called for more flexible storage due to the current issues with the offtake for certain waste streams, including waste wood.
Alastair Kerr, director general of the Wood Panel Industries Federation (WPIF), said: “The current wording in RPS 352 is restricted to those who are storing material for further transit to incineration.
“However, it must be broadened to include wood stored that is intended for panel board production.
“The panel board sector provides relatively stable demand throughout the year whereas bioenergy demand can fluctuate.
“The current market difficulties are putting pressure on all those storing wood for onward distribution and some of those sites are only handling material for panel board consumption, therefore, to limit the RPS to only incineration, would not resolve the current problem that is impacting on all sites storing waste wood for onward distribution regardless of end market.”
The WRA said the RPS comes as it has seen the shut down of several plants which process waste wood – some scheduled and some not. These plants have included biomass plants and panel board manufacturers.
The association added that there has been a fall in demand from the export market which has resulted in a surplus supply of the material.
WRA concerns
The EA and WRA are working together to address concerns that the RPS could be overly restrictive.
RPS 352 excludes wood recycling sites who supply the panel board industry – despite these sites also facing the same issues.
The WRA expressed concern that the RPS’ time limits do not take into account how long biomass plants stop taking material during shutdowns – which can start three months before and continue three months after, or more for unplanned outages.
The RPS will require sites to show that that their destination plants have ceased operating, which is not necessarily the case as many have just severely reduced their inbound tonnages.
Additionally, most wood processors do not have a direct agreement with the plants they feed into, as the supply chain is very complex and managed by much larger players at a national level in many cases.
Vicki Hughes, technical lead on the WRA Board, said: “We welcome this RPS in principle which is something the WRA has been calling for to help our members navigate the current market conditions and ensure no material is sent to landfill.
“However, in order for this to alleviate the current pressure on the market as intended, it is critical that the RPS is not too restrictive and takes into consideration how the waste wood sector operates.
“We look forward to working with the Environment Agency to resolve these concerns and ensure that the RPS can achieve what it was intended to.”
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