EPP and the waste management industry

1
EPP and the waste management industry

• Gev Eduljee

2
Key requirements of the industry

• Proportionality
• Consistency
• Clarity
• Speedier determinations and confidence in the
  regulator
• Burden on industry must be justified (eg
  monitoring)
• The regulators ability to combat environmental
  crime

3
Proportionate approach 90 of the industry is
well managed
4
Will the EPP deliver ?

• Generally, YES.
• Better sites are now generally receiving less
  frequent inspections
• Consolidation of multiple permits into a single
  site permit
• Simpler forms and less form-filling
• Allowing more than one deliverer of competency
  training and accreditation
• Single system by merging A2 and B activities

5
What we like (1)

• Electronic submissions v. Printing costs of
  paper submissions ca. 2,000 per application
• Who and what must be permitted v. Support the
  proposal that all permits to be issued to the
  person who has control over the activity
• One stop, integrated permits v. Consolidate PPC
  and WML
• Speed up permit decisions v. Cheaper permits,
  flexible operator competence

6
What we like (2)

• Changes to terms and conditions v. Simpler
  permit variations
• Changes to area covered by a permit v. Will
  improve cumbersome method of licensing at many
  WML sites. Current rules allow for such within a
  PPC permit.
• Transfer of EPP permits v. Support the proposal
  to allow full or partial transfer of EPP permits
• Duty on EA to inspect and review permits v.
  Support the proposal to rationalise the PPC and
  WML systems

7
Consolidation of permits on a landfill site
8
Cost to develop a complex site Clifton Marsh
One sub. fee for landfill leachate plant would
save 20 K
9
Current total annual costs for Clifton Marsh
92,000
92,000 3 of sites annual revenue
10
Effect on SITA UK of one permit for one site ?
329 licences/permits reduced to 247 (25 fall)
Standard Rules Permit could apply to 187 WMLs
11
Total annual compliance-related costs for SITA UK
12
Total costs to SITA UK related to re-permitting

• Average application cost (including consultants)
  
• 89,000 X 28 sites 2,500,000
• Consequential costs
• Loss of void space
• Additional lining costs
• Additional monitoring (flare/engine, flux box,
  PM, asbestos)
• Increased reporting/notifications to EA
• Site-specific improvement programmes

13
Re-permitting timescales depend on EA office
Permitting delays cost money !!!
14
The jury is out on

• Deemed refusal with no right of appeal X.
  Essential that timescales for formal requests for
  information are realistic. Discretion must be
  objective and proper
• Standard Rules Permit X. OK in principle, but
  devil is in the detail given no right of appeal.
  Industry must be properly and effectively
  involved in development of guidance
• Charges for regulator initiated variations X.
  Preference is for the charge to be made through
  the subsistence fee
• Due diligence defence X. Without effective
  guidance on BAT and EMS, most operators will want
  to retain this right.

15
Working as partners to make EPP a reality
Environment Agency
Waste Industry

• Early and meaningful dialogue with industry
• Consistency with OPRA
• Level playing field (catch the cowboys)
• Improve levels of consistency, competence and
  general efficiency

• More and better integrated EMS. More
  self-reporting
• Improve levels of competency
• Improve level of compliance vis-à-vis OPRA
• Reduce number of pollution incidents

16
Consistency in applying OPRA

• Three systems WM OPRA, CCS and EP OPRA. CCS is
  more risk-based and must be rolled out
  consistently.
• No right of appeal
• Inconsistent application across the UK
• New versus historical significant
  non-compliances

• 2002 109 (New) 76 (Historical)
• 2003 68 (New) 66 (Historical)
• 2004 30 (New) 53 (Historical)
• 2005 15 (New) 27 (Historical)

17
Lighter touch from EA more self-regulation

• 25 SUEZ Environment parent company audits
• 1,787 SITA UK audits in 2005 to ISO 17025
• 1484 landfill audits (101 landfills)
• 48 recycling plant audits (12 plants)
• 215 transfer station and depot audits (79
  plants)
• 40 compost facility audits (10 plants)
• EMS/self-auditing is paying dividends at SITA

18
Waste Sector Plan must link with delivery of EPP
19
Efficiencies can still be made for example

• Environmental monitoring SITAs annual
  commitment
• 6,600 groundwater samples
• 1,200 surface water samples
• 3,600 leachate samples
• 36,000 gas samples
• 300 dust and flux box monitoring
• Streamlining of planning and permitting regimes
• Rationalisation of information to be provided
• Consolidation of public consultation phases

20
Some challenges

• Penetrating the SME sector
• 3,000 companies employing 1 10 workers
• 1,000 companies employing 10-50 workers
• 8 companies employing 2000 5000 workers
• Exemptions a potential Trojan horse for poor
  practices. DEFRA consultation still awaited.
  Recycling Registration Service initiative of ESA
  to maintain standards.
• Resources for the EA to effectively combat
  environmental crime

21
Cutting Red Tape The Environmental
Permitting Programme in Practice 25 April
2006Painters Hall, London