Circular speaks to CIWM’s new president Dr Anna Willetts

Dr Anna Willetts

Hear from CIWM’s new president Dr Anna Willetts on her journey through the industry, from environmental consulting to practicing environmental waste defence law, and her plans for her term as president.

Practising law may not be the most obvious route to becoming president of the CIWM but, for Dr Anna Willetts, a 13-year stint as an environmental criminal defence lawyer has given her a broad and untypical insight into the waste and resources sector. She began her presidential term on 30 June with an inauguration at The Edwardian Manchester hotel.

Willetts’ journey into the waste and resource sector started after she graduated with a degree in geology. She decided not to join the Army as an officer (her original intention) but instead secured funding from waste-management firm Shanks & McEwan to study for a PhD in geology and environmental geochemistry at the University of Manchester.

This led Willetts into environmental consulting, working on issues such as environmental permits, hydrogeological risk assessments and environmental impact assessments.

I would like my presidential report to play a role in improving the procedures and the processes by which we get to EoW.

In 2005, she embarked on a career change, retraining as a lawyer. Qualifying in September 2009, Willetts has practised environmental waste defence law ever since and is now a partner at leading law firm gunnercooke. She is also currently the co-convenor for the UK Environmental Law Association’s Waste Working Party.

The CIWM has been a constant in Willetts’ career. She joined 22 years ago while studying for her PhD and has served in a number of roles, both on regional councils and for national bodies. She became a CIWM Fellow in 2014. She’s been vice-chair of the CIWM Regulatory special interest group, centre chair for the East Anglian Centre Council, and has served on the presidential team since 2013, before succeeding Dr Adam Read as the CIWM president for 2022-23.

As Willetts began her presidential term, Circular caught up with her to find out about her aims and ambitions for her tenure.

Circular (C): What made you switch from environmental consultant to lawyer?

Anna Willetts (AW): Around 2003, when I was a technical scientific adviser, environmental laws started changing because of European directives. Environmental misdemeanours became criminal offences and some of my clients were being prosecuted by the Environment Agency. Although I was a consultant, they needed the help of a lawyer. I realised that it was happening more frequently and it seemed to me to be a new and growing market.

After working on an environmental due diligence project for a hazardous-waste landfill sale with a law firm, and seeing the opportunities available, I decided to do a law conversion course at De Montfort University and then continued until I was fully qualified.

C: What do you like about this sector? What’s most rewarding for you?

AW: Waste is generally one of those issues that most people don’t consider: nobody wants to know about it; they just want it dealt with. They like to put their bin out and hope it just goes away. They may have a passing interest in recycling but not much knowledge of the rest of the resources and recycling industry. That’s one thing I really like about it – it’s something that isn’t commonplace, and you’re solving problems around issues that people don’t want to deal with. There will always be death, taxes and waste! It’s always been there – we can’t avoid it.

Waste is generally one of those issues that most people don’t consider: nobody wants to know about it.

In my day-to-day job, the most rewarding element is my clients. I’m a defence lawyer, so my clients may be facing prosecution or other enforcement by the regulator or needing proactive advice to avoid such a situation. They’re coming to me because they’re in trouble: they’re stressed, they’re anxious. They may be facing the prospect of custodial sentences.

I like that I can explain the situation and the technicalities to them – the regulations are often highly complex – then help them to understand where they stand and what I can do to help. Guiding them through that – and witnessing the relief that can bring – is probably the most rewarding aspect of what I do.

C: Is there a conflict in being CIWM president and a defence lawyer for those being prosecuted by the EA?

AW: I don’t think there’s any conflict. CIWM members are made up of very diverse sectors of the waste industry. In my day job, I’m professional and bound by a code of conduct by the Solicitors Regulation Authority (SRA), and with CIWM, I’m bound by the CIWM code of conduct.

I realise being a defence lawyer may be more controversial, but I’m there to do a job. I’m paid to do a professional job representing my clients – all of whom are entitled to a defence. That doesn’t affect what I do for CIWM, and I think the wealth of experience I’ve gained in acting for my clients greatly contributes to my sector knowledge. It gives me an ability to be an engaged and proactive president. All of us, as CIWM members, have the same aim – we all want the best environment possible.

Dr Anna Willetts' presidential inauguration
Dr Anna Willetts at her presidential inauguration.

C: What are the most important challenges you’re currently seeing in the waste and resources sector?

AW: One of the biggest issues is around how the definition of ‘waste’ aligns with the regulatory framework. Sometimes it feels like they are not aligned at all, and that can actually work against the ethos of the circular economy. That’s frustrating when you see the fantastic innovation and technology the waste and resources industry in the UK is generating.

My presidential report – Improving the way we regulate circular resources – seeks to explore and address some of the issues around which materials can be reused or recycled for use in the circular economy. One major issue is the point at which end-of-waste (EoW) criteria are met, which is vital to ensuring resources can be recycled into raw materials. At that point, a material is no longer subject to waste-management regulations and it can be sold and used in the same way as any other. Therefore, it’s vital that the point at which material reaches EoW is defined in law.

It’s vital that the point at which material reaches EoW is defined in law.

Some businesses in the waste and resources sector, and beyond, that would like to recycle materials, struggle with uncertainty around EoW and the practical application of the EoW tests by regulators. This is directly damaging existing businesses and hampering investment in crucial innovation and infrastructure.

The EU, for example, has acknowledged the key role EoW plays in delivering its Circular Economy Action Plan and is resuming its work on developing such criteria to create a well-functioning internal market for secondary raw materials.

Regulatory certainty is vital for investment in our sector. If materials from waste treatment remain classified as waste, their markets are limited. The material cannot be traded in the same way as other raw material and its value is likely to be constrained. The UK risks losing investment to other countries that have clearer positions on EoW criteria. My report looks into many of the issues around this and makes recommendations on how stakeholders can be given the regulatory certainty required to stimulate the investment needed to meet policy ambitions.

C: What would you like to achieve or see change over the next year?

AW: I would like my presidential report to play a role in improving the procedures and the processes by which we get to EoW. I’d like this to have a positive and practical influence moving towards a circular economy.

I want to get to a point where the waste industry, and the regulators, are comfortable and confident that the circular ideas and innovative techniques that are being developed are being viewed in a more positive, science-based way. That will encourage innovation and investment, rather than inadvertently stifling it. I hope that will help change the narrative around EoW and the circular economy.

C: Is it a good time to be focusing on the circular economy message?

AW: Definitely. Difficult economic climates drive change and innovation, because you have to come up with more cost-effective solutions. It may actually be a very good time to drive innovation. We certainly shouldn’t still be taking so much material to landfill sites – we should be reusing it where we can, and recycling it wherever possible.

With increasing restrictions on sending our waste abroad for reprocessing, coupled with the rising cost of doing so, the more we can keep resources within our shores and deal with them well – turning them into reusable, good quality raw materials and products – the better. There is some brilliant innovation in the marketplace that we should capitalise on. There’s hardly been a better time to talk about the circular economy, in my view.

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