November - December 2004 Feedback on consultation
Licence fee structure: November/December 2004 feedback on consultation
Thank you to all those who submitted responses to the EPA discussion paper on options for a conceptual licence fee structure. Your comments are valuable to us, and have assisted the EPA, the Licence Fee Structure (LFS) Reference Group, the LFS Steering Committee and the EPA Board in selecting a conceptual licence fee structure.
A letter, fax or email was sent to all respondents, including information on the selected licence fee structure.
- Conceptual licence fee structure
- Consultation process
- Analysis of submissions
- Selection and endorsement of conceptual licence fee structure
The EPA Board endorsed the following conceptual licence fee structure on 8 March 2005:
Combined environment management and load based performance fees, without revenue recycling
A discussion paper and introductory letter were sent to the following groups:
- all licensees—sent to the address on the licence.
- other SA government departments—Primary Industries and Resources South Australia, Department of Treasury and Finance, Department for Trade and Economic Development, Small Business Advisory Council, and the Manufacturing Consultative Committee
- all members on the Licence Fee Structure Reference Group
- prescribed bodies and other associations—Australian Conservation Foundation, Conservation Council of SA, SA Chamber of Mines and Energy, Business SA, SA Farmers Federation, Engineering Employers Association, Environmental Defenders Office, Local Government Association, SA Wine Industry Association
- interstate EPAs.
The discussion paper and consultant report were available on the EPA web site. An online consultation forum was available.
In addition, a media release was issued and advertisements were placed in the public notices of the following newspapers:
- The Advertiser
- all Messenger and regional newspapers.
The SA EPA consulted with all stakeholders on options for a proposed conceptual licence fee structure for the SA EPA in November and December 2004. A total of 84 responses were received in the following formats:
- discussion paper form filled in and posted (12%)
- discussion paper form filled in and faxed (27%)
- e-mail response (23%) and e-mail query (4%)
- telephone query (note that not all telephone queries were included, only those where issues were raised, eg on the process) (9%)
- letter posted or faxed (19%)
- on-line submission using consultation forum (6%).
The submissions were grouped into the following categories, and the number of responses per category is shown as a percentage:
- small industry 36%
- medium industry 10%
- large industry 8%
- community 1%
- other SA govt. departments 6%
- industry associations 8%
- not-for-profit clubs (licensed by the EPA) 4%
- councils 14%
- hospital/funeral services 6%
- interstate or international government agencies 2%
- other 5%
Very useful comments were received, and assisted the EPA and the Reference Group in selecting a conceptual licence fee structure.
The responses were collated in an Access database and a summary of comments on the process, revenue recycling, and the proposed options for a licence fee structure was presented to the Reference Group and the Steering Committee, together with all submissions (with personal details omitted).
The Reference Group consists of members representing the Engineering Employers Association, SA Wine Industry Association, SA Water, Business SA, SA Chamber of Mines and Energy, Energy sector in Port Adelaide Region, Local Government Association, Department for Trade and Economic Development, Environmental Defenders Office, Waste Management Association, SA Farmers' Federation and the Northern Industry Environmental Forum.
Some respondents requested that their details be kept confidential. For this reason, personal details of respondents and their organisations were kept separate. This had the added benefit that ideas raised in submissions were considered on merit, and not based on where the ideas originated.
The Reference Group analysed submissions and reached consensus in selecting the following option for recommendation to the Steering Committee:
Combined environment management and load-based performance fees, without revenue recycling.
The Steering Committee endorsed this for recommendation to the EPA Board. The EPA Board endorsed this as the conceptual licence fee structure for the SA EPA.