By Marco Muia, aka "Enviroman":
Is it a bird, is it a plane, no its Enviroman, fighting for truth, justice and struggling with a 6' banner for the Skip’s stand at the Recycling and Waste Management (RWM) show at the NEC last week. Sadly I had to drive there as my cape was at the dry cleaners.
So another show is over and despite offering a bottle of malt last month for the best name for a National Skip Hire Association I had no takers, apart from the cheeky suggestion of the Irish Recycling Association which doesn’t abbreviate well. So come on get your thinking caps on!
The RWM exhibition was busier than ever this year with an estimated 7,100 visitors, 420 exhibitors and a total attendance of 9,000 showing that the recycling industry is a large beast indeed, confirming that a voice is definitely required for the skip industry. During the show I spoke to over 150 visitors regarding waste related matters and was asked a multitude of questions, luckily some hastily copied Skip articles were at hand to be given out and I was reliably informed that the EA has now ‘gone public’ with their position statement on WEEE which was discussed in Issue 13. Many waste operators are still unaware of the exemptions they can benefit from so I will concentrate on them next month.
EA Consultation on 2007-8 charges.
This month the Environment Agency issued their consultation on the proposed fees and charges schemes for 2007-8, including waste management licensing, PPC etc. The skip industry has a limited representation out of the 290 organisations and individuals on the consultee list (which includes 127 trade associations). If the British Egg Industry Council, National Association of Funeral Directors and British Trout Association can be bothered to comment on charges that affect their members I dare say someone should comment on behalf of the skip industry, given that the industry makes a significant contribution the Agency’s coffers every year.
To make life easy the Agency have prepared a comments form to fill in which directs consultees to a narrow range of issues but does not invite wider comment (which is encouraged but should be sent to the Agency’s National Customer Contact Centre). I have repeated the main questions relating to proposed changes, as follows, with suggested comments and urge you all to read the consultation document and make additional comments which will be sent to the Agency:
Q. “As a result of our efficiency savings, we have been able to keep the baseline increases down to 2.3%. Do you have any comments or queries about the increases for such charges?”
A. “A complete revision of the waste charging scheme is required to remove the many anomalies, such as the excessive application fees for smaller sites and the charging of many recycling sites as disposal operations because they do not recycle 100%. Get rid of the existing tables and standardise charges - it costs the Agency no more to licence a site with a throughput of <5,000 tonnes than a site with a throughput of <25,000 tonnes.”
Q. “We would welcome your comments on our proposal to increase charges by a further 1.5% on top of the 2.3% baseline increase, to recover the costs of additional IT services and fund a programme to fundamentally modernise our approach to waste regulation and compliance work.”
A. “Strongly object. Existing subsistence fees should cover the costs. The current charging scheme requires a radical overhaul as many charges bear no relation to the level of work involved in dealing with the applications or regulating the sites.”
Q. “We would welcome your comments on our proposal to introduce a reduction of 10% to WML subsistence charges where a site is partially regulated by PPC and WML, a similar activity is being undertaken under both regimes, and the operator is the same person for both regimes.”
A. “10% seems to be a favourite discount for waste charges – why not reduce the charges further by ensuring that one key officer regulates the site to avoid duplication, 10% is an insult.”
Q. “We would welcome your comments on our proposal to introduce two new tiers of modification charges, a zero charge for administrative only changes, and a low-level charge of £1,200 for simple modifications. This arrangement would similarly apply to Environment Agency-initiated modifications.”
A. “EA initiated modifications should not be charged for – if a licence requires modification because it is deficient in any way the regulator should foot the bill because the applicant will at some time have had to pay an application fee, unless the site was licensed under COPA in which case the EA has a duty to review licences periodically. Simple modifications need to be well defined.”
Q. “We would welcome your comments on our proposal to introduce a capped fixed subsistence charge of £3,000 where construction has not yet started on a WML installation.”
A. “If construction has not started there should be no charge – a non-operational business should not be faced with excessive fixed charges which have no relation to the regulatory cost. £3,000 would be better spent on site infrastructure. A licence holder can notify the EA when works start, which (apart from landfill) requires little regulatory input.”
Q. “We would welcome your comments on our proposal to introduce a lower fixed surrender charge of £2,800 for closed inert and redundant landfills.”
A. “A charge reduction should equally apply to all transfer stations to reflect the level of regulatory work involved.”
Q. “We would welcome your comments on our proposal to continue to increase the range of fixed licences that benefit from a reduction of 10% in the application charges. How about reducing exemption charges?”
A. “The 10% reduction is laughable. The reduction should be increased proportionately i.e. there is significantly less work involved in issuing a fixed licence which should justify a reduction of at least 50%.”
Q. “We would welcome your comments on our proposal to extend the types of hazardous waste that benefit from lower subsistence charge to include hazardous Waste Electrical and Electronic Equipment.”
A. “All WEEE should benefit from lower charges.”
The deadline is 8 December 2006 and I will be responding as a consultee but would also like to able to state how many skip firms support a strong response to the consultation. I know this is a boring subject but I have yet to meet an operator that says “Aren’t EA fees good value for money?” so make your comments known. The consultation documents are available from Alan Day at the EA on 01454 624003.
Marco Muia BSc (Hons) MSc MCIWM specialises in all aspects of waste regulation consultancy and is a WAMITAB accredited assessor for the COTCs in waste transfer, treatment and inert landfill. He also holds the level 4 COTCs for Hazardous Waste Treatment and Transfer. You can contact Marco via The Skip Magazine
