- Increase baseline charges by 2 per cent for Environmental Permitting waste facilities, installations and radioactive substances regulations
- Increase compliance charge factors for Environmental permitting waste facilities and installations where sites have been recorded in bands D, E and F for more than 2 consecutive years – so in year 3 a compliance adjustment will be imposed (i.e. from 125 per cent to 200 per cent for Band D, from 150 per cent to 300 per cent for Band E and from 300 per cent to 500 per cent for Band F)
- Introduce a permit commencement charge for newly permitted installations and waste facilities proposed to be 40 per cent of the full subsistence charge
- Increase the Standard Unit Charge for abstraction in Northumbria for the next 3 years by 8 per cent
On the proposal to increase baseline charges by 2 per cent for Environmental Permitting waste facilities, installations and radioactive substances regulations, we called for increased clarity from the Agency on the reasons behind the changes.
In addition, one of our frustrations in assessing the impact of the proposals for the increase in the compliance factors was that very little data (such as sectors affected and reasons for failures in compliance) was provided by the Agency in support of its suggestion. We called for clear reassurances from the Agency would initiate a period of engagement and communication with operators at poorly performing sites to help improve their track record and avoid the increase of these charges, well ahead of the onset of any changes in charges.
On the proposals to introduce a permit commencement charge for newly permitted installations, we believe that a flat rate increase is a broad brush approach that may not appropriate at this stage. In our response, we noted that our strong preference would be for the Agency to work more closely with relevant trade associations and industry processors to discuss to decide whether alternative options to these charge increases exist.
We do not support the proposal to increase the Standard Unit Charge for abstraction in Northumbria for the next 3 years by 8 % and we urged the Agency to find an alternative and fairer outcome for abstractors in the region.