Alex,



Would get a view from EA but scenario you envisage but the Framework is worded to be a catch all so that the EU was not constantly adding wastes to the list and people potentially escaping the law.  This has the result of therefore catching scenarios such as this.  It all comes down to is there an intention to discuard which it appears in this case there is.



Re MMP these only cover site generated and materials from registered Hub site, so unless EA is not following its own guidance MMP probably does not apply as they are different ssites.



Re Nick's ebay point the EU framework does not apply to householders unless they dump material illegally by flytipping.







Brad Balmer,   BSc(Hons), FRSC

Associate Director, Land & Development

ATKINS

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-----Original Message-----

From: Contaminated Land Management Discussion List [mailto:[log in to unmask]] On Behalf Of Alex Bewick

Sent: 04 March 2014 14:06

To: [log in to unmask]

Subject: Re: Waste or not waste?



I appreciate that just because something doesn't need treating for reuse doesn't stop it being a waste.



What I think I was trying to get across was, what if the scenario was one of a stable required some rubber chippings and approaching another stable to see if they had any they wanted to sell. In this situation would the question of waste or not be completely moot? And if so, what would the difference be between that and the actual scenario we have, the end result is surely exactly the same?



Thanks for everyone's feedback on this. There have been a number of people agreeing with the permit option as well as a number suggesting that an MMP could well be appropriate.



Alex Bewick

Principal Environmental Consultant



Ashdown Site Investigation Ltd

The Old Dairy

Swanborough Farm

Swanborough

Lewes

East Sussex

BN7 3PF

www.AshdownSI.co.uk



Tel: 01273 483 119

Fax: 01273 483 104



-----Original Message-----

From: Contaminated Land Management Discussion List [mailto:[log in to unmask]] On Behalf Of Clive Williams

Sent: 04 March 2014 13:42

To: [log in to unmask]

Subject: Re: Waste or not waste?



"......surely you could also argue that the material could be sold off as it is anyway and therefore doesn't fall into the definition of waste as it is not being discarded?"





You need to be careful with this, just because your waste can be reused by someone else without any form of treatment does not mean your waste is not waste. The rubber chippings are being discarded by the first stables as waste; the fact the second stables wants them as they are does not mean they are not waste.





Karen's suggestion of the U8 exemption seems perfect for this scenario, I have lost track of the various exemptions these days as we don't tend to use them anymore.

Regards

Clive



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