According to our analysis of the EA’s fee increase proposals, the basic subsistence fee for an IED permitted anaerobic digestion (AD) facility (operating as a reasonable operator in band B) will increase by over 170% from £4,029 to £11,019 from 1st April 2018, if proposed changes to the charging scheme are applied following the current consultation.
The calculations are based on the figures given in the Environment Agency’s Standard Review of Charges (SRoC), the consultation for which is due to close on 26th January 2018.
Our assessment considers an organic waste recycling operator, operating an AD plant under a bespoke IED permit as above. Wiser Environment’s calculations for reasonable EA input for an ‘average site’ (based on a single person) include quarterly site inspections (4 at 3.5 hours each), annual compliance audit (37.5 hours), an annual OPRA review (1 hour) and an annual data review (1 hour), however this may vary depending on local priorities and perceived risks. The expected cost is in the region of £6,000 based on the EA’s proposed new rate of £115 per hour.
If a site is operating in compliance band E i.e. is considered by the EA to be a poor operator, a 150% multiplier would be applied bringing the basic subsistence fee to over £16,500. The appropriate compliance band multiplier (based on your Operator Performance Risk Assessment (OPRA) profile) would be applied at the end of the year to calculate the proposed subsistence fee for the following year.
The EA can also apply ‘time and materials’ following any future category 1/2 incidents or potentially once your basic subsistence fee has been spent regulating your site. Please note that if multiple Regulatory Officers are required to attend, then, their time is likely to be charged individually and include travel time.
Do you think this is a fair price for organic waste recycling operators? Have your say before 26th January at the EA consultation website.
