New Plan Disappoints
The DFFE published a draft Industry Waste Tyre Management Plan (IndWTMP) for comment on 7 December 2022, closing date 6 February 2023. This latest IndWTMP unfortunately falls short as much as the earlier Draft 9 previously commented on, and seems to have paid no attention to the commentary submitted on the Draft 9 plan.
Our commentary on the earlier Draft 9 pointed out numerous internal contradictions, deficiencies of precision (it is after all intended to be legislation), practicalities, and overlapping responsibilities, as well as a wilful eliding of a significant segment of history covering the REDISA era. Little has changed, and the new IndWTMP is subject to much the same critique. The bureaucracy of reporting, meetings and committees is if anything worse. The typography is as bad, with duplication of sub-list numbering and an incoherent mixture of item numbering styles that make referencing ambiguous and confusing. This is simply not permissible in legislation: it can lead to someone being prosecuted for “failure to comply with 4.8.3.b) – not the first one, the second one”! It is hard to understand how this document passed vetting before publication.
Our commentary on this latest IndWTMP, submitted on 2 February 2023, can be downloaded here.