Charging Scheme Consultations
Summary
Agency board report number: SEPA 43/23 - September 2023
SEPA is currently consulting on changes to three charging schemes: Reservoirs, Transfrontier Shipments (TFS), and Emissions Trading Scheme (ETS). This is to enable full cost recovery and implementation of revised charges before 1 April 2024.
The Board is asked to note that following consultation, Board approval will be sought prior to Scottish Ministers signing the scheme off.
For Noting
For Public session of the Board
Angela Milloy, Chief Officer, Finance
John Burns, Charging Scheme Manager
Introduction - Methodology
Any changes in addition to in year inflationary increases requires a consultation before ministerial approval will be given. Three charging schemes that require review and revision are detailed in the remainder of the paper.
Reservoir charges
There is a legal requirement to review the scheme every 3 years, the last review was undertaken in 2017-2018, although the charges have been increased in line with RPI since, a full review of the scheme is now due.
The scheme has historically under recovered; in 2022-2023 the cost recovery rate was estimated at 77%. The review with the Reservoirs Unit captures all regulatory and support work which should be covered by charges. The review has shown that charges should be increased in line with the table below.
| Reservoir fee type | Type of controlled reservoir | Current charge | Proposed charge | Percentage increase |
|---|---|---|---|---|
| Registration fee | Any | £668 | £736 | 10% |
| Application fee | Any | £469 | £469 | 0% |
| Annual subsistence charge | High risk | £527 | £669 | 27% |
| Annual subsistence charge | Medium risk | £355 | £448 | 26% |
| Annual subsistence charge | Low risk | £216 | £272 | 26% |
Transfrontier Shipments (TFS)
The current scheme was last reviewed in 2015 and historically has under recovered.
The charges for notifiable waste shipments should cover:
- the processing of applications,
- liaising with other relevant competent authorities about them,
- data input about movements and reporting, and
- compliance monitoring.
Since the last review, the nature of the applications SEPA deals with has changed significantly, most notably an increase from the offshore sector.
To assess the appropriate level of charge we have calculated the time taken to process notifications for different types of waste, make amendments to notifications and data handling and reporting, and applied this to the resource cost to SEPA for this time.
The result of this review is that charges will be increasing, to accurately reflect SEPA’s cost in processing those activities as per the table on the next page. In particular, we are proposing to increase the charge for single notifications concerning offshore installations to £9,080 to ensure full cost recovery.
The current charge is £1,450 - the increase from 2015 is in order to achieve cost recovery but reflects the additional work that the TFS unit must undertake. Industry is aware we are considering increases for this work.
It is proposed that shipments of between 6-20 and 21-100 increase by approximately 30-37% and 25% respectively.
| Notification type | Single shipment | General notification | ||||
|---|---|---|---|---|---|---|
| 2 to 5 shipments | 6 to 20 shipments | 21 to 100 shipments | 101 to 500 shipments | More than 500 shipments | ||
| Shipment from Scotland for recovery (non-interim) | £1,450 increases by 79% new charge £2,600 | £1,450 increases by 93% new charge £2,800 | £2,700 increases by 37% new charge £3,700 | £4,070 increases by 25% new charge £5,070 | £7,920 increases by 13% new charge £8,920 | £14,380 increases by 7% new charge £15,380 |
| Shipment from Scotland for non-interim disposal | £1,540 increases by 82% new charge £2,800 | £1,540 increases by 95% new charge £3,000 | £3,330 increases by 30% new charge £4,330 | £5,500 increases by 18% new charge £6,500 | £10,600 increases by 9% new charge £11,600 | £19,500 increases by 5% new charge £20,500 |
| Shipment from Scotland, including interim disposal | £1,700 increases by 76% new charge £3,000 | £1,700 increases by 88% new charge £3,200 | £3,330 increases by 30% new charge £4,330 | £6,000 increases by 17% new charge £7,000 | £12,900 increases by 8% new charge £13,900 | £24,000 increases by 4% new charge £25,000 |
| Shipment to Scotland for non-interim recovery | £1,250 increases by 80% new charge £2,250 | £1,250 increases by 96% new charge £2,450 | £2,700 increases by 37% new charge £3,700 | £4,900 increases by 20% new charge £5,900 | £10,600 increases by 9% new charge £11,600 | £19,500 increases by 5% new charge £20,500 |
| Shipment to Scotland, including interim recovery | £1,450 increases by 69% new charge £2,450 | £1,450 increases by 83% new charge £2,650 | £2,830 increases by 35% new charge £3,830 | £5,500 increases by 18% new charge £6,500 | £12,900 increases by 8% new charge £13,900 | £24,000 increases by 4% new charge £25,000 |
| Shipment to Scotland for non-interim disposal | £1,540 increases by 84% new charge £2,840 | £1,540 increases by 97% new charge £3,040 | £3,330 increases by 30% new charge £4,330 | £5,500 increases by 18% new charge £6,500 | £10,600 increases by 9% new charge £11,600 | £19,500 increases by 5% new charge £20,500 |
| Shipment to Scotland including interim disposal | £1,700 increases by 76% new charge £3,000 | £1,700 increases by 88% new charge £3,200 | £3,330 increases by 30% new charge £4,330 | £6,000 increases by 17% new charge £7,000 | £12,900 increases by 8% new charge £13,900 | £24,000 increases by 4% new charge £25,000 |
Interim shipment charges would be increased where they are going to a recovery facility. Previously these were kept under the general notification charge.
| Notification type | Single shipment | General notification | ||||
|---|---|---|---|---|---|---|
| 2 to 5 shipments | 6 to 20 shipments | 21 to 100 shipments | 101 to 500 shipments | More than 500 shipments | ||
| Shipment from Scotland for recovery (interim) | £3,100 | £3,300 | £4,700 | £6,070 | £9,920 | £16,380 |
We are also going to implement a charge for inputting data into the International Waste Shipment online service. Currently many operators do this themselves however, those who do not should cover SEPA’s costs. We will charge £25 per shipment.
If SEPA undertakes work to get a shipment returned, then the work for this will be charged at an hourly rate of £110.43 to the repatriation plus any additional costs (e.g. shipping, port fees etc).
Finally, where operators amend details after transmission, they will be charged £175 to cover the work SEPA has to undertake.
SEPA have benchmarked with the Environment Agency who are going to consult soon.
Emissions Trading Scheme
There is an omission in the scheme covering aviation activities which needs to be changed. Whilst this is a relatively minor legal change, it ensures consistently with other agencies, and there will be no changes in charges.
Consultation
For each consultation, the main regulatory or policy lead has worked with the Charging Team and Scottish Government to undertake the review and development of the consultation.
Recommendations
The Board is asked to note that following when consultations are concluded, the consultation responses will be assessed and summarised and brought to the SEPA Board for sign-off before going to the Scottish Ministers for their sign off of the scheme.