Environment Agency Charge Proposals from April 2018
The EA is currently consulting on changes to fees and charges for its regulatory activities. This is a major overhaul of the charges scheme which aims to make the charges more reflective of the regulatory activity needed so as to achieve better cost recovery. The changes affect Environmental Permits, Abstraction Licences, COMAH sites, EU Emissions Trading Scheme and WEEE activities. The EA intends to introduce the changes from April 2018. Applications received before that date will pay charges under the existing scheme.
What does this mean for you?
Significant changes are proposed which are likely to have an impact on your business. The key changes include:
- Increases in application fees and subsistence charges for many activities regulated under the Environmental Permitting Regulations;
- Supplementary charges for the first year of a new permit and for site specific risk assessments including habitats, fire prevention plans, odour and noise management plans and waste recovery plans;
- Charges for applications that are not duly made and for repeat schedule 5 (request for information) notices;
- Introduction of time and materials charges for additional work required for novel activities or those that are of high public interest;
- Introduction of charges for discretionary services such as ‘enhanced’ pre-application and end-of-waste advice.
Implications of the changes to your business The EA expects overall charges to decrease for routine applications in the Chemicals, Energy from Waste, Food & Drink, Paper & Pulp and the Metals sectors. For all other sectors the proposed charges are likely to increase. Under the proposals a typical application would consist of the core application fee plus the cost of any additional components for site specific risk assessments required by the EA. Some examples of proposed application fees for industry sectors are given below. Proposed subsistence fees vary depending on complexity and components and this detail is provided in the consultation documents.
Examples of proposed fees for industry sectors:
- Food & Drink core application £13,984;
- Paper & Pulp core application £13,364;
- Organic Chemicals production core application £13,054-16,466;
- Large Combustion Plant core application £19,103;
- Medium combustion plant core application £2,028 (low complexity);
- Medium combustion plant core application £6,550 (high complexity).
- Assessment of fire prevention plans and dust, odour, bioaerosol or noise management plans: £1,241;
- Processing an application which is not duly made: up to £1,500;
- Assessment of a new, varied or revised waste recovery plan: £1,231.
The changes imply a major culture change for the Environment Agency as the proposals impose a greater accountability for officers to justify additional requirements and charges. It will be ever more important under these proposals therefore, to define the additional components and scope of requirements with the EA at the start of a project to avoid unexpected costs ‘down the line’.
Transparency of the EA’s procedures for assessing submissions, as well as consistency and continuity of advice throughout the application process will also be important, to help applicants reduce the risk of unwelcome fees for non-duly making or repeat notices for information.