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Proposed PPC charges increase for 2006/07 and 2007/08
Response of the Scottish Environmental Services Association
The Scottish Environmental Services Association (SESA) is the sectoral trade association representing Scotland's managers of waste and secondary resources. SESA's Members provide essential waste and secondary resources management services to the public and private sectors across Scotland.
SESA supports SEPA’s aim of full cost recovery of regulated activities and notes that, in general, charges paid by waste management licence (WML) and PPC operators cover SEPA’s costs in regulating these activities. We welcome the gradual move towards full cost recovery for PPC subsistence charges particularly during a period of significant change in the regulatory regime.
The Environment Agency’s licence/permitting system is currently being examined by Defra who hope to reduce the administrative burden on business by 25% while contributing to a more effective proportionate and risk-based approach to enforcement. SESA suggests that SEPA should consider how the regulatory regime could be similarly improved in Scotland.
In the past SESA has suggested that SEPA consider moving towards a risk-based approach to licensing and regulation and incentive-based charging schemes - such as the Environment Agency’s EP OPRA system - whereby the charges imposed on companies relate to performance, reflecting the actual, rather than perceived, risks to the environment. Such an approach would improve efficiency by focusing SEPA's resources on environmental criminals and other areas of high environmental risk rather than high quality, well-managed, sites operated by SESA's Members. This approach could also provide incentives to operators to manage facilities to the best possible standards of compliance and to penalise poorly performing operators.
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