Environmental Authorisations (Scotland) Regulations 2018: Proposed changes to the Charging Scheme
3.3. Consolidation of existing authorisations
Currently, authorised persons may hold more than one authorisation. This could be multiple activities under the same regulations or across multiple regulations, e.g. WML, CAR and PPC.
Under the Regulations, we may consolidate existing authorisations. Either by application from the authorised person or by its own initiative (a SEPA-initiated consolidation). There are three scenarios where an authorised person or when we may wish to do this:
1) The authorised person holds a single authorisation that has been varied multiple times resulting in numerous versions of the authorisation.
In this scenario, the authorised person may prefer a consolidated authorisation, including all the conditions they must comply with in one document. In such circumstances, we propose to apply the equivalent of a standard variation charge, which is 30% of the application fee for the activity, to recover the costs of the work we would have to undertake. This would be in addition to any fees should the authorised person wish to vary or surrender part of their authorisation.
2) The authorised person holds multiple authorisations across one or more existing regulatory regimes (WML, CAR, PPC, or Radioactive Substances), and they are connected, for example, to the same geographical site.
In this scenario, the authorised person may prefer a consolidated authorisation, including all the conditions that they must comply with in one document. In such circumstances, we propose applying the equivalent of a standard variation charge: 30% of the application fees for each activity we would consolidate. This proposal would recover the costs of the work we would have to undertake. This would be in addition to any fees should the authorised person wish to vary or surrender part of any of their existing authorisations.
As these activities are connected, the existing rules in our current charging scheme for discounted fees for multiple connected activities would apply (see rule 8(3)(a)).
3) The authorised person holds multiple authorisations across one or more existing regulatory regimes, and the activities are not connected.
In this scenario, the authorised person may prefer a consolidated authorisation, which is effectively a Corporate permit, as the activities are not connected. While we can foresee potential efficiency savings for operators, we would be required to develop new charging systems and carefully consider how we recover our costs. Therefore, for a period after the Regulations come into force, we will only accept applications for activities at multiple locations where they are inter-connected. We may review this as part of a wider review of our charging scheme; as such, we are interested in stakeholders' views on whether developing a Corporate Permit would be desirable.
To share your views on scenario 3, please see section 3.2.