Response 606596862

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Standard Rule SR2019 No6 (treatment of waste tyres)

1. Do you agree with our approach to use standard rules to cover the treatment of waste tyres?

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No
I don't know

2. Do you understand the requirements of the proposed standard rules for the treatment of waste tyres?

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No
I don't know

3. Do you agree with the requirements of the proposed standard rules for the treatment of waste tyres?

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No
I don't know

4. Please let us know what you think would prevent people from using the proposed rule set for treatment of waste tyres.

To comply with the FPP guidance you only have to have at least a 6m fire break between waste tyres and non-waste tyres as non-waste tyres should essentially be treated as an ignition source. The FPP guidance fails to apply to non-waste tyres. Two thirds of a sites stock may be non-waste and therefore a considerable number of tyres can be stored collectively in larger pile sizes exceeding the guidance and with no fire breaks - How does this reduce the overall fire risk on site when only the waste tyre storage complies with the guidance? Whether they are waste or non-waste there is still the same risk of fire and potential for fire spread particularly from arson.

5. Do you agree that the waste quantity limits are viable for the treatment of waste tyres?

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Yes
No
I don't know
Please explain your answer
The quantities are too low for some operators.

6. Do you agree that the waste storage duration limits provide a viable throughput for the treatment of waste tyres?

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No
I don't know

7. Do you believe the requirements for having certain activities carried out within a building proportionate to the pollution risks?

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Yes
No
I don't know
Please explain your answer
If conducted outside of a building on impermeable surfacing and sealed drainage, where is the pollution risk other than noise?

8. Please list any other types of treatment or processing activities that you believe should be included in the treatment of waste tyre rule set:

N/a

9. Do you agree that the right waste codes have been listed for the treatment of waste tyres?

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No
I don't know

10. Would the exclusion distances prevent you from finding a site from which to operate?

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Yes
No
I don't know
Please explain your answer
Potentially

13. Do you intend to apply for a treatment of waste tyre rule set when published?

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No
I don't know