Natural Resources Wales (NRW) Strategic Review of Charges 2022

Introduction

Following engagement with industry NRW have launched a consultation seeking views on new charging proposals. In NRW’s view they are aiming to fully recover the costs of the activities its regulates and monitors. There are a number of schemes the consultation covers:

• Industry Regulation;
• Site Based Waste;
• Water Quality;
• Water Resources;
• Reservoir Compliance.

In addition to reviewing charging on the above schemes they are also reviewing species application licences in addition to the costs of compliance monitoring. There are a range of changes to the existing fees with some charges increasing significantly, some staying broadly similar and some being reduced. Some schemes are much more likely to affect CLA members than others and it is important we gather evidence from members operating such businesses to determine the level of impact on business. Rural businesses are facing multiple challenges and it is important any charges do not undermine the viability of such businesses and there is parity between England and Wales. At the same time, we must acknowledge the need for taxpayer value for money. NRW have not undertaken a wide-ranging review of charges since 2013 with many fees fixed below inflation (something that could be seen as negligent if the result is a drastic increase in charge in a short period of time).

This paper summarises the proposals and aims to present them clearly for scrutiny for members. There are a large number of annexes alongside the actual consultation that can be found at the link below if members wish to see all the charges in full.

If you have any views on how the proposed changes to fees will affect your business then please email fraser.mcauley@cla.org.uk or call on 07702926069 by the 5th January.

https://ymgynghori.cyfoethnaturiol.cymru/sroc/strategic-review-of-charging/

Charging proposals

As covered earlier there are a wide range of changes affecting many different types activity. It is important that as a member you consider what permits you use and how the changes may affect you.

Appendix 3 Installations (including intensive rearing of pigs and poultry), medium combustion plant and specified generators and non-nuclear radioactive substances

Appendix 3 includes permits for intensively reared pigs and poultry units in addition to permits for on-farm anaerobic digestors. The majority of charges are increasing significantly ranging from 150% to 200%. Please use the appendix 3 link to see the full breakdown of charges. There are too many to include in this paper.

Appendix 4 Reservoir Charging Scheme

Appendix 4 covers charges for registering new reservoirs, bringing older ones into use and vice versa. The proposed charge increases are from zero to between £300 and £800 which should not impact too much on the ability of members to apply for these permits.

Appendix 5 Site-based waste management

Appendix 5 covers a complex number of charges for waste-management. The majority of these charges are increasing however bespoke applications will be charged at a fixed rate of £9719 compared to a range between £2800- £22051 currently. On first analysis we do not think too many members are likely to undertake such activities although please contact the CLA if you are.

Appendix 6 Species licensing charging scheme

Appendix 6 introduces charges for applications for species licensing. These actions could include:

• the capturing, picking, taking, killing, or disturbing of European protected species under Regulation 55 of the Conservation of Habitats and Species Regulations 2017;
• the capturing, picking, taking, killing, or disturbing of species under Section 16 of the Wildlife & Countryside Act 1981;
• the release of species listed on Schedule 9 of the Wildlife & Countryside Act 1981;
• the marking, taking, or killing of badgers and interference with setts under Section 10 of the Protection of Badgers Act 1992;
• the eradication, management, commercial use or keeping of invasive species under Article 36 of Invasive Alien Species (Enforcement & Permitting) Order 2019.

There are currently no charges for these actions with the majority of new charges being around £133. There are proposed waivers for applications by those from low incomes, work to assist disable people, dealing with pest affected trees and invasive species.

Appendix 7 Water Quality Charging Scheme

Appendix 7 deals with a range of charges relating to water quality permitting. The increases within this appendix are significant- up to tenfold with NRW arguing it will cover their costs of operating the permitting scheme. An increase to land spreading charges- notably sheep dip is of most concern with a permit to allow it to be spread to land being proposed at £3728.

Appendix 8 Water Resources Charging Scheme

Appendix 8 deals with charges for applying for an abstraction license and to change, vary or apportion an abstraction license. These charges represent significant increases to the existing charges and the appendix does not appear to outline the existing charges- something we will be querying with NRW as to why they have not included a comparison. An example of the level of increase is a temporary license is currently £1500 and the proposed new charge is £6327.

Conclusion and next steps

The proposed changes to fees are generally high and will have an effect on rural businesses. As an organisation we are concerned it will place even more pressure on our members currently experiencing increasing energy and input costs. The consultation is complex and we ask you as a member to consider what permits/licences you currently use, and are likely to use in the future and read the appendix that applies to those charges in order to determine how it may affect you.