This is the HBF response to the informal consultation on the fourth set of work packages. The formal consultation is to take place later this year.
The House Builders Federation reiterated that the proposals focus on the waste disposal industry with no consideration given to how these processes can be managed in the light of government targets for redeveloping brownfield sites for housing.
There is concern that under the current proposals, many standard house building practices would require waste permits.
The requirements for keeping records are very onerous and site managers are unlikely to have sufficient specialist knowledge of waste management. In addition, the vast majority will not be able to deal with electronic returns at present. Also, if a site is exempt from the waste framework directive, why keep records?
Given that construction (and contaminated land remediation) is already effectively regulated by existing legislation, what benefits would the introduction of such proposals bring?
There is concern that few Agency personnel have sufficient experience to be able to work effectively in compliance assessment in the house building sector.
There is also a potential for conflict between waste management and planning regulations: which legislation would supersede the other?
In conclusion, there is a danger that a deeply flawed regulatory system will be poorly and inconsistently enforced.
The full reply to Defra may be accessed via this link: