Regulatory Decision 102: Using waste car tyres to construct escape ladders in water storage reservoirs

This Regulatory Decision (RD) is valid until 1 June 2025 by which time it will be reviewed. You should check back at that time to ensure the RD is still valid.

NRW can withdraw or amend this RD before the review date if we consider it necessary. This includes where the activities that this RD relates to have not changed.

Regulatory Decision

This RD applies if you use of waste car tyres to manufacture escape ladders in reservoirs without an environmental permit.

The guidance booklet: Thinking about an irrigation reservoir?, produced by Cranfield University and the Environment Agency, advocates the use of waste car tyres strung together to create a ladder to be used in the construction of synthetically lined reservoirs. The purpose of the ladder is to create both an escape route for use in an emergency and to weigh down the liner when the water level is low in the reservoir.

The Environmental Permitting (England and Wales) Regulations 2016 regulate the use and disposal of waste. There are currently no exemptions or Standard Rules Permits in place that allow for the use of waste car tyres in this manner.

If you cannot comply with the conditions in this RD, you need to apply for an environmental permit.

Conditions you must comply with 

We will not pursue an application for an environmental permit for the activity where:

• We have been notified of the proposed usage and have confirmed in writing that the proposal falls in line with the scope of this statement. The project must be undertaken in accordance with the agreed plan
• The placement of the tyre ladders must not be less than 10m distance apart
• The maximum amount of tyres used must not exceed 1000 in total for the project and must be stored in piles of no greater than 500 tyres with a 10 metre fire break between piles
• No tyres must be bought to site before the commencement of the works and shall be stored for no longer than 3 months prior to use
• An application for an abstraction licence has already been granted
• The project has been granted planning permission (where applicable) by the relevant authorities
  
  

Enforcement

This RD does not change your legal requirement to have an environmental permit for a waste operation when using waste car tyres to construct escape ladders in water storage reservoirs.

However, NRW will not normally take enforcement action if you do not comply with the need for an environmental permit if you meet the requirements in this RD.

In addition your activity must not cause (or be likely to cause) pollution of the environment or harm to human health, and must not:

• cause a risk to water, air, soil, plants or animals
• cause a nuisance through noise or odours
• adversely affect the countryside or places of special interest