1. Innes Garden EP Charges Programme Manager

2. PPC Charging Discussion Document Follows on from previous consultations Proposing charge calculated from OPRA Score –Different attribute bands awarded weighted scores –Reflects contribution to effort expended by the Agency.

3. PPC Charge Calculation EP OPRA Score PPC Charge

4. EP OPRA Output

5. Consultation Look Up Table Charge Multipliers

7. Charge

8. Charging Options

9. Main Points Raised So Far It’s Complicated Timescales - too tight/long overdue What is overall impact on charges Insufficient reward for good Operator Management Implications for small businesses/farmers More simplified standardised permits Monitoring - individual sites should pay Want transparency of basis for charges Emissions - a tax Not enough reward for in- house EMS Location - penalise operators for planning issues Any more issues?

10. Agency Reasoning Much not included in Discussion Document to keep as simple and short(ish) What follows is some of our reasoning But we are here to listen! We would welcome feedback

11. It’s Complicated Yes! - But so is interim scheme! Needs to cover very wide range of installations and circumstances Replacing 3 existing schemes with 20+ tariffs types Spreadsheet/electronic application to simplify Why are we doing this:- –Agency wants to directly link environmental risk to workplans to charges –Improves cost reflectivity –Integration & Efficiency –Signal to operators

12. Timescales - IPC OPRA for several years PPC Charging consultation in 1999 Support in principle for OPRA based charging Desire to move to risk based regulation FMPR recommendation - risk based charging by start of F/Y 2003/04 Delays in implementing IPPC and Landfill Directives Waste OPRA only for 2 years Need to develop EP OPRA system Need to do charge modelling Consultation Training of staff “long overdue” or “too tight”

13. What is overall impact on charges Overall cost neutral –We are only allowed to recover our costs Improved OPRA scores –Reduced effort by Agency – savings returned to charge payers

14. Insufficient reward for good Operator Management Charges must reflect Agency effort Complexity –Understand installation and industry sector issues –Is correct technology being used –Compliance issues (and costs) for companies Emissions & Location –Understand environmental impacts –Credibility and acceptance by public “Phasing in” of system to –accommodate those who will pay more –help reduce impact of uncertainties

15. Implications for small businesses & farmers More simplified standardised permits Low Impact Installation provisions continue Low risk installations pay less than current one component charge Option for farmers to go for Standard Farming Permits Where appropriate we are looking to extend Simplified Standard Permitting arrangements Charge is related to environmental risk not size

16. Monitoring - individual sites should pay Agency position neutral Inconsistency within PPC –IPC based process invoiced individually –Waste sites cost recovered through general subsistence charge Agency moving to self monitoring hence less check monitoring and lower costs Most sites will require check monitoring at some point so potential for periodic larger bills if charged separately.

17. Want transparency of basis for charges So does Agency! Links from OPRA to work plans to charges should help demonstrate:- –As monopoly supplier shows principles by which we operate –Reasons for charge down to individual site level What more information would be helpful?

18. The Following are mainly EP OPRA issues but:- Emissions - a tax Use of Emission indices means that it is a surrogate for environmental harm, not directly related to releases Not enough reward for in-house EMS Section 4 guidance to Agency is to encourage moves to use of EMAS and ISO 14001 Location - penalise operators for planning issues Factors such as SSSI, Habitat sites and population effects Agency effort in assessing applications and in compliance.