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Written June 2019: If anyone in DEFRA or "higher" is reading this, please hire us to restructure the Permit "Support" Centre:
The reason that the Environmental Permit Application Process is so so so
terrible is because it is so badly organised.
The EA
Enter the EA, if something is missing from you application . . . what will they do. Why ask for it of course. . . after they have rejected (or "returned") the application.
So yes instead of asking for the information required they literally post your application back to you, and you have to resubmit it. Now this is pretty annoying, but imagine if you had been waiting in a queue for 12 weeks just so they can reject your application. Your 4 month application process is now a 8 month application process.
If we combine this brain numbingly stupid permit return system, with a the 12 week waiting until you can "have another go" it is not uncommon for even a permit variation to take a year. A whole year.
I will now give an anonymous real life example:
You are adding a process line to a factory the original "factory" throughput was 4000 tons, the new throughput is 5000 tons. What is the capacity of the new line?
The answer is 1000. I checked this with my 7 year old daughter to make sure I got it right.
We had an application returned because the duly making officer could not work out the capacity of the new process line . . . . this application was supported with 40,000 words of detailed information and it was returned without asking for clarification on this simplest of points. 12 weeks delayed.
If you haven't died of stress or old age by the time you get you permit duly made then you will have reached the magical realm of "determination".
Once again the EA enter in to their headlong rush to . . .you've guessed it . . . return you application.
At best you can expect a huge list of requirements, and after waiting of months to get to this point the EA, are often generous enough to give you 10 days to provide everything they need. These schedule 5 requests and 90% of the time are impossible to meet, so you have to reapply.
Your 24 week application is now a 36 week application.
Perhaps the most disastrous episode of determination history was the botched implementation of "fire prevention" where by consultants are expect to author a 10,000 word "fire prevention" document based on 8 pages of guidance, 1st time around, with no errors.
I expect God might manage this on a good day, but I am not overly intelligent and find this a tricky obstacle to overcome. Although via a combination of late nights, keyboard RSI, and begging I usually do.
"I would laugh if my heart were not so heavy" Milos Columbo - James Bond - For Your Eyes Only |
You can design a factory, get planning, build the factory, install the equipment, train your workforce and . . . . still be waiting to get an Environmental Permit. I saw this actually happen.
Small under resourced planning offices all over the country deal with environmental enforcement all day every day. They use specific consultees for specific subjects, they have a portal based system, which prompts for information based on the type of application you are making. This is the type of system the EA should adopt.
Part of me thinks that they will not adopt this system. Because, if they were truly committed to delivering an effect compliance route they would have implemented it already. Whoever is pulling the strings on this one, is not thinking clearly, in fact I doubt they are thinking at all.
So we need a complete restructure of the EA Permitting Application Process. Now you may say that I am writing from a pro-industry perspective, but I can assure you I am definitely not:
I have seen ships left falling apart in to harbors whilst we wait to get a recycling permit.
I have seen factories for recycling plastic film go un-built because the company went bust before we could obtain a permit.
Our world is drowning is plastic film, and most ships are exported to 3rd world, and ripped apart on beaches. Yet when someone is tries to take domestic responsibility for our waste, or do things correctly then they are faced with this debacle.
There is no "support" at the permitting support centre and in effect the EA are mainly concerned with reducing their work queue, turning down applications as fast as they come in.