Following on from his previous article on applying for an environmental permit for an ATF, Simon Walker, Founder and Director of SJW Enviro Consulting Ltd, provides his expertise on how to go about taking over an existing environmental permit.
In the last article, we looked at how to go about obtaining the correct environmental permits when a new operator starts an Authorised Treatment Facility (ATF) from scratch. This was shown to be time consuming and expensive. However, there is an alternative to opening a new site which involves taking on the running of an existing or former site that already has the benefit of an environmental permit.
While this might appear to be an obvious solution, there are still significant cost implications, and there is a limited number of permitted ATFs in England, with 1,580 currently listed on the Environment Agency’s (EA) public register. Locations for all these sites can be found by downloading the whole register at Environmental Permitting Regulations – End of Life Vehicles (data.gov.uk). Of these permits, approximately 70% are bespoke, with the remainder being Standard Rules.
When looking at an existing site, ensure that the permit meets your requirements, especially if it is a Standard Rules permit. Standard Rules cannot be varied to increase quantities or waste types, so you must be sure that you can work within all the criteria, especially the annual quantities of waste allowed on site.
Having agreed to take over an existing site, you will still have some paperwork to complete to satisfy the EA. This involves transferring the permit into yours or your company’s name, updating the Environment Management System (EMS) to reflect your way of working, and the possible submission of a Fire Prevention Plan (FPP).
Once again, it is strongly advisable to seek professional assistance when compiling a transfer application with associated documents, as this could save time and money during the process.
The EA make a charge for processing a transfer application. For both Standard Rules and bespoke permits, this is £2,529. Should it be necessary to submit an FPP, the EA will charge a further £1,241 to assess it.
There may also be a requirement to vary the permit. For example, a permit may limit the annual waste input to 5,000 tonnes, but you require a limit of 10,000 tonnes. A variation can only apply to a bespoke permit unless you require an increase in the site area.
The EA also levies a charge for varying a permit which currently stands at £4,442. An increase in annual tonnage would also automatically require the submission of an FPP. Or, if the site already has an FPP in place, this will need updating to reflect any on-site changes.
Both Standard Rules and bespoke permits can be varied to increase the permitted area of the site. This is done with a minor variation for which the EA charges £2,652 for a bespoke or £1,178 for a Standard Rules permit.
The previous article also laid out the requirement to have a technically competent manager (TCM) to oversee operations on site. These can be found at Applying for an environmental permit for an Authorised Treatment Facility – ATF Professional. You will have to show the EA when a transfer application is made that you have a relevant TCM in place when the application to transfer the permit is made. If your TCM has joined the CIWM and WAMITAB scheme, then they will also be required to pass a continuing competency assessment every two years.
Finally, there is the consideration of the annual subsistence fee, also payable to the EA. Details of the charges are also set out in the previous article and can be found here.
While this route into the world of ATFs is less onerous than starting from scratch, there are still considerable hurdles to overcome. Whichever way you choose, good luck.
See the previous article at Applying for an environmental permit for an Authorised Treatment Facility
For further information, please contact Simon on 07471 910102 or email him at simon@sjwenviroconsulting.co.uk
