EA Consultation on assessing and scoring permit compliance
The consultation proposals include four main changes, which are:
§ To consolidate scores in such a way that the annual compliance band is reflective of the risk or impact posed by the site, and to avoid sites moving into bands associated with poorer compliance, simply because they have incurred multiple minor non-compliances under the same permit condition.
§ To suspend scores in such a way that the period of suspension can be flexible and related to the scale and complexity of the improvements that have been agreed and are being undertaken.
§ To report the outcomes of a compliance assessment involving periodic returns or other detailed reports to the operator within 28 days, to enable us to manage the workload of assessing many detailed reports which arrive simultaneously.
§ To explain how compliance assessment data is used in performance reporting and in the case of most waste activities and installations to generate annual subsistence charges
The principle of consolidation will include conditions relating to Emission Limit Values such as those found in landfill, installation and water discharge permits, in addition to amenity conditions.
There are no plans to amend the objectives of the remaining three principles, as described in the current Compliance Classification Scheme guidance, nor do we intend to change the categories of non-compliance or the scoring mechanism. However, the proposed guidance will be much shorter and simpler to understand, in line with the Gov.UK format
For waste activities and installations (with the exception of intensive farming sites that are part of farm assurance) the scores are added together each year to generate the compliance band, which is then used to apply a multiplier which determines the subsistence charge in the following year. As a consequence of the proposed changes, no permitted sites would be disadvantaged by a higher subsistence charge or a worse compliance band.
We publish compliance data including banding on an annual basis, and so it is important that sites are in a compliance band which appropriately describes their level of impact or risk
We propose to introduce any revisions from 1 January 2019 at the start of the compliance year. This will not affect subsistence charges for waste operations and installations until 2020.
The EA have already run one WebEx on the 3rd October and have another on the 11th, with Q&A sessions to explain the proposed amendments. You can listen to the recording or sign up using the links below:
Wednesday 3rd October 2018 recording:
Register for the 14:00-15:00pm – Thursday 11th October 2018:
The consultation launched on 17 September and will be live for six weeks, till the 29th October and can be found at the following link:
Please make any comments either to email@example.com or direct using the link above.