Exemptions - Crazy loophole!

Exemptions are self regulated so the applicant doesn't have a visit from the EA to ensure the site is suitable, nor does the EA check that the applicant has planning permission or indeed that the applicant has permission from the site owner (if leasing) to carry out the proposed storage and or processes. Neither does the EA check that the applicant has a valid use for, or method for disposing of the whole tyres or shredded tyres if processed! It's completely mad. Licensed sites lay out tens of thousands to ensure their site meets license regulations, and also to obtain the WAMITAB COTC certificate which is pretty intense. They then continue to pay an annual fee to maintain their license plus have several visits a year from the EA to check they're adhering to license regulations! In recent years the EA is frequently updating & changing the regulations and the battle to maintain an annual all clear gets harder. Thus with just a little of this knowledge many pop up tyre collectors/recyclers are skipping the legalities and opting for a nice easy little Self Cert Exemption. And what happens when the Exempt site is full? (which doesn't take long), usually, the collector vanishes leaving behind a massive tyre heap which becomes the responsibility of the landlord!

An Example of the result of Self Cert Exemptions