The recent review of the EPA, published by the EPA Review Group makes 58 recommendations. For those with IPPC and Waste licences, there are some recommendations and remarks worth highlighting
- The Review Group notes Ireland’s poor current financial climate and that this has impacted on the EPA adversely. It is obviously important that the EPA is adequately funded to order that the environment is adequately protected; however, some recognition that industry is also affected adversely by financial pressures would perhaps haved helped give more balance to the review.
- The Review Group notes that licence application fees have remained unchanged since 1994 and recommends upwards revision. This blog has calculated that if the Consumer Index is applied, a typical licence application fee of €5,078 would now be €7,714, an increase of 52%. It is not clear from the review, but presumably the recommendation is that these increases would also apply to reviews, revisions and surrender of licenses.
- The recommendation that the role of the Ombudsman be extended to the EPA is welcomed. It makes sense for there to be an independent mechanism for review where there are allegations of maladministration, this would help maintain confidence in the EPA amongst the public and industry and such confidence is ultimately to the benefit to the EPA.
One issue that taxes holders of licences is that improvements in emissions abatement or improved processes often trigger a review of the licence. The actual fee payable to the EPA for the review, and it is noted that this may increase, is only a small part of the cost – many man-hours of work are required to make the application for the review. The recommendation that legislation should be changed to allow amendments to be made to a licence without a full scale review is therefore welcomed.