Enviroman
FORGIVE me for being sceptical, but it’s that time of year when regulators issue consultations on changes to their fees and charge schemes, which take eff ect in April (if agreed).
In late November, the Environment Agency released details of their Strategic Review of Charges (SRoC). It is the biggest review of their charging scheme, which currently contains some charging tables drafted in 1994 - before the Agency was formed.
A complete change to the charging scheme is overdue, but will the proposals fi nd favour with industry?
The full consultation will take time to read, as it consists of numerous documents and presentations which are available online. By the time you read this the consultation will have closed, but the documents will still be available. If you can’t locate the documents we can email them to you.
The scope of the consultation includes:
• Environmental Permitting Regulations 2016
• Radioactive substances regulation nuclear and non-nuclear permits • Marine licences
• Waste Electrical and Electronic Equipment Regulations 2013
• Control of Major Accident Hazard Regulations 2015
• European Union Emissions Trading System • Defi nition of Waste Services • Planning advice
I have submitted a consultation response, for what it’s worth. The majority of questions started with “Do you agree…” which prompted a ‘yes’, ‘no’ or ‘not applicable’ response.
If you don’t agree, it then stated: “Please explain why and how we might otherwise cover the costs incurred in relation to this regulatory work?”
I couldn’t answer most of them without being vague, because I don’t have access to the detail of what it currently costs to do each of the jobs they are proposing to charge for. That crucial detail is missing from the consultation – or I couldn’t fi nd it, other than a pie chart.
The quickest way to review the scheme 30 SHM February, 2018
is the PowerPoint presentation which provides a useful and yet sometimes confusing summary of the scheme.
Some of the claims contained therein are dubious, such as: “Our approach to charging results in an even better environment for people, wildlife and growth”, and “We deliver the most effi cient and targeted regulatory service we can”. Experience tells me otherwise.
What are the key proposals for waste operators? The scheme claims applications will have a baseline charge with additional charges which will aff ect 15-20% of customers. The baseline fee will be similar to current application fees, while non-standard sites will have to pay the following:
• Material Recycling Facility, Physical Treatment of hazardous/non-hazardous waste = £7,930
• Metal recycling site (mixed metals) = £9,463
• Composting facility = £11,465
Permits for standard rules are increasing for the most common permits, such as SR2015 Nos 4 to 9 for transfer station (£3,926). That increase does include assessment of the fi re prevention plan.
Permit transfer applications are set at £2,529 for most waste transfer and treatment operations. Some surrender costs are reduced.
EA will keep 20% of the fee if your application returned
If you submit an application that is not ‘duly made’ and is returned, the EA will keep 20% of the fee – capped at £1,500.
The component charges for the EA to review documents you have submitted will incur the following charges PER DOCUMENT in addition to the application fee:
£779 - Habitats Directive assessment £1,551 – Complex odour modelling
£1,246 – Odour Management Plans and Noise Management Plans
£1,241 – Fire Prevention Plans, Pest Management Plans and Dust Management Plans
The old subsistence fees’ tables have gone and are replaced with a standard fee for each facility type, such as £4,169 for a HCI
transfer station; taking between 25,000 and 75,000 tonnes per annum.
Deposit of waste for recovery will cost £5,166 per annum, making small schemes non-viable.
In addition to the base line fee, the Agency will impose a time and materials charge of £100/hour for non-planned compliance work and submissions required by permit conditions.
What’s not clear is how the hourly rate charges will be accounted for, and whether the time recorded log will form part of the invoice to customers.
What the scheme amounts to is salami slicing of charges, to make them appear ‘palatable’ in some cases.
But given the inconsistency of approach with applications, it does appear to be a charter for charging more at the application stage. This is compounded by the proposal to charge new sites more in their fi rst year of operation - for example, eight hours at £84/hour (£672 for an additional site visit and advice).
The compliance band increases change very little, and are still a function of the scores made on CAR forms, such as Band A – 5% saving as before, and Band F - 300% of subsistence fees, as before.
If you are planning to do anything to your permit or apply for a new one, check the scheme to make sure what you are paying - and get the application in before April if there’s a saving to be had!
MARCO MUIA Marco Muia BSc (Hons) MSc MCIWM is
a Director of Oaktree Environmental Limited. He specialises in all aspects
of waste planning and regulation
consultancy. He also holds the level 4 COTCs for Hazardous Waste Treatment and Transfer. You can contact Marco on: 01606 558833.
If you have any questions about this article, e-mail him via:
marco@oaktree-environmental.co.uk Follow him on Twitter @wastechat
www.skiphiremagazine.co.uk
MARCO MUIA: DIRECT AND TO THE POINT
www.oaktree-environmental.co.uk
Page 1 |
Page 2 |
Page 3 |
Page 4 |
Page 5 |
Page 6 |
Page 7 |
Page 8 |
Page 9 |
Page 10 |
Page 11 |
Page 12 |
Page 13 |
Page 14 |
Page 15 |
Page 16 |
Page 17 |
Page 18 |
Page 19 |
Page 20 |
Page 21 |
Page 22 |
Page 23 |
Page 24 |
Page 25 |
Page 26 |
Page 27 |
Page 28 |
Page 29 |
Page 30 |
Page 31 |
Page 32 |
Page 33 |
Page 34 |
Page 35 |
Page 36 |
Page 37 |
Page 38 |
Page 39 |
Page 40 |
Page 41 |
Page 42 |
Page 43 |
Page 44 |
Page 45 |
Page 46 |
Page 47 |
Page 48 |
Page 49 |
Page 50 |
Page 51 |
Page 52 |
Page 53 |
Page 54 |
Page 55 |
Page 56 |
Page 57 |
Page 58 |
Page 59 |
Page 60 |
Page 61 |
Page 62 |
Page 63 |
Page 64
