Basis of proposed charges for WR abstraction licensing pre-app

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Dear Adrian,
 
Thank you for your e mail concerning our proposed charges for abstraction
licensing pre-application.
 
I have forwarded this to one of our subject specialists who will respond
to your enquiry as soon as possible.
 
In the meantime, should you require any further information or assistance,
please do contact us.
 
Kind regards,
 
Diane Hudson
Customer Services Advisor
Environment Agency
National Customer Contact Centre
Part of National Operations
03708 506506
 
 
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Let us know by completing our short online customer survey.
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show quoted sections

Dear Mr Clayton,

 

Thank you for your request for information in regard to our current
consultation on charges, and specifically in relation to the planned
introduction of Abstraction pre-application charges.

 

We have an established principle under the EPR regime (installations,
waste facilities, water quality consents) relating to pre-application
work, where we provide up to 15 hours of pre-application advice free to a
potential applicant (less for simpler / cheaper permits).This
pre-application advice is to assist the potential applicant in
understanding the application process and what may required from them in
their application.  The ultimate aim being to enable them to be able to
provide a complete application to us.  This advice is supported by the
published guidance we make available to potential applicants.  

 

For the EPR regime the initial “up to 15 hours” is funded from the EPR
charges income.  It was considered that after this initial free time of up
to 15 hours, it was more appropriate to recover the cost of this advice
from the individual benefiting from this advice, rather than EPR
subsistence charge-payers.

 

The abstraction permit application fee of £135 is set at a level to
recover the administrative costs associated with the recording and
production of an abstraction licence after the application has been
determined. 

 

This proposal to extend the common framework to include abstraction
licence pre-application advice allows for up to 15 hours of advice free to
the potential applicant and gives them the option of being charged a
clearly defined hourly rate if they wish to receive additional advice. 
This allows us to provide helpful advice to potential applicants. We are
also aware that this advice can be sought from other sources and companies
are not obliged to seek our advice. Clearly the £135 application charge
does not recover the cost of provision of unlimited free application
advice. Our proposals will still result in the such application being
subsidised.

 

From this you will see that the proposal is based on principles of
applying cost recovery. Note that for simpler applications in EPR we only
offer one hour “free” pre application advice. And the thresholds are
chosen based on a judgement of seeking to be helpful to applicants
balanced with a reasonable attribution of costs. As it is based on
judgement and existing precedent, there is not the large dataset that you
referred to in your request.

 

Obviously with some abstraction pre-application advice this may include
the time to discuss the implications of the proposed permit on the water
environment, and its flora and fauna, with technical colleagues from
related functions.  At the pre-application stage we would not be
undertaking technical assessments, but providing advice on the key issues
to be addressed within the application, and on how to provide a complete
application.  This is in addition to the advice that we publish to help
potential applicants across our regulatory regimes.

 

We would welcome your views on the proposal to introduce the abstraction
pre-application charges and would invite you to respond to the
consultation via our website which can be found at
[1]https://consult.environment-agency.gov.u....

 

Yours sincerely,

 

Alastair Waite

Charges Strategy Advisor

Information in this message may be confidential and may be legally
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the sender immediately, delete it and do not copy it to anyone else.

 

We have checked this email and its attachments for viruses. But you should
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We may have to make this message and any reply to it public if asked to
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litigation.  Email messages and attachments sent to or from any
Environment Agency address may also be accessed by someone other than the
sender or recipient, for business purposes.

 

If we have sent you information and you wish to use it please read our
terms and conditions which you can get by calling us on 08708 506 506. 
Find out more about the Environment Agency at
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