Paul Downing, Environmental Consultant provides us with information on how permits are costly to ATFs large and small. Is it fair that these costs are the same no matter what your site size?
The costs associated with being a legally permitted ATF cannot be avoided.
Environment Agency Application Fees (especially for bespoke permits), consultancy fees (if you need help putting everything together), WAMITAB course fees, site infrastructure upgrade fees such as installing firebays, site security, sealed drainage systems and other requirements impose a high financial burden in order to comply.
If you are a large ELV dismantler site or a smaller site but with a high throughput then all of the costs mentioned might have a pay back time that works with your business plans and investment schedule. You might invest for the future and realise that the money spent now on getting “legal” will pay back dividends if you decide to sell the site at some point down the line.
For smaller traders who have been selling parts on eBay or only breaking a few cars a month then the story is a different one. I have had several enquiries from smaller operators who seem to have no idea of the costs or processes involved in gaining an ELV permit. A quick discussion around the Fire Prevention Plan requirements for new permit applications soon establishes that they are unable or unwilling to invest to such a level in order to carry on doing what they have been doing in some cases for many years.
I can only assume that a number of these enquiries are from small volume online sellers who are curious about gaining an ELV permit after being contacted by the EA as part of their crackdown on online traders without the requisite ELV permits. Although there is a waste exemption for using ELVs to refurbish classic cars you cannot use this to sell break & sell parts to a third party. Similarly even smaller volume standard rules permits require the FPP guidance to be implemented in full even if you are highly unlikely to meet the upper threshold in terms of annual volumes and tonnages. For now it seems that smaller breakers yards either have to invest and grow to make it worthwhile or give up entirely.
Perhaps a solution is to rethink the permit legislation and look towards a model that takes into consideration the volume of vehicles. If a ratchet scheme was introduced it might encourage more dismantlers to apply for licenses instead of them being priced out and making a conscious decision to operate outside of the law. Of course there are those that make a decision to never apply for the relevant licenses but if there are incentives to encourage smaller operations to become legitimate it will be easier for the EA to establish that those that do not comply are purposely running illegal yards and better placed to prosecute.
If you would like to contact Paul Downing, please call 07790147084. Alternatively visit www.pauldowningltd.co.uk