Response 1073524070

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About You

What is your name?

Name
john thom

Are you responding as an individual or an organisation?

Please select one item
(Required)
Individual
Ticked Organisation

What is your organisation?

Organisation
Royal Burgh of New Galloway and kellls parish council

Part 3: Key features of the new framework for authorisation holders.

4. Do you agree that the framework should include a set of universal outcomes?

Please select one item
Ticked Yes
No

5. If so, are the outcomes proposed the right ones?

Comments:
in some parts

6. Do you see any opportunities within your sector for industry- led guidance to be produced to support this approach and how could it support you to deliver better?

Please select one item
Ticked Yes
No
Comments:
Less of a confrontational attached

7. Do you understand the descriptions of the regulated activities in Annex 2?

Please select one item
Ticked Yes
No
Comments:
yes that okay

9. Do you agree that SEPA should consult on the guidance setting out the likely tier of authorisation for particular activities?

Please select one item
Ticked Yes
No

10. Do you agree that standard rules will deliver the benefits we have set out?

Please select one item
Yes
Ticked No
Comments:
I can see the old problems reappearing in that one size cannot fit all and a lot of miss understanding with how the book is interpreted

11. Do you agree with the procedure for making standard rules?

If not, why not?
in certain circumstances, the book has to go out the window removing Debray from rivers during Flooding removal of dangerous trees and the clean up after words most of these things happen out of normal working hours are the persons involved in throws activities, now going to have to pay for volunteering to help their communities

12. Do you agree that SEPA and Scottish Ministers should have the ability to make GBRs?

Please select one item
Yes
Ticked No
Comments:
only ministers should be able to introduce a GBR as they are accountable SEPA is not

13. Do you agree that all regulated activities should have an authorised person responsible for overall compliance and that this person should be named in a permit and registration?

Please select one item
Ticked Yes
No

14. Do you think it is proportionate to require the person in control to be the person that notifies an activity in the notification tier?

Please select one item
Ticked Yes
No

15. Do you agree that SEPA should include more than one person as the authorised person where appropriate?

Please select one item
Ticked Yes
No

16. Do you have any views on how SEPA should decide if a person is in “control”?

Comments:
the person that asked for the works to be cared out and the one in charge of the works force

17. Question 17 – Do you think the core requirements set out here will deliver the right approach to FPP for the integrated authorisation framework?

Please select one item
Yes
Ticked No
Comments:
the potential for small individual plant operators ie Digger dump truck being disregarded in applying for contracts is evident in this passing such intrusive powers over to a non-accountable agency and also appears to breach the computer data protection act or has SEPA now became part of law enforcement with access to the police data basis with what they wish to know about an individual operators

18. Do you think that the criteria set out above will achieve the stated purpose of the FPP test?

Please select one item
Yes
Ticked No
Comments:
parts of this proposal is going to drive the reputation of this agency and its employees further into the hole of despair, have you lot at the top no consideration for the well-being of you employees with the ramifications of some of the proposals in this you are going to end up with more flytipping, Water contamination as the vetting procedure that is proposed is adopted for it will end up if you do not have a permit you will not be able to go to the reclamation dump with waist household goods, or any other waste products thereby increasing the illegal dumping problem

19. Do you agree with the proposed application processes?

Please select one item
Yes
Ticked No
Comments:
if Roral Scotland had an internet system that was workable yes this was tried with the single farm payment we all know what that got us right up the creek without a paddel

20. Do you agree with the proposal to have a statutory determination period of four months for the majority of permit applications?

Please select one item
Yes
Ticked No
If not, what do you think the determination period should be?
within 20minets max for goodness sake step into the real world Small individual companies do not know from week to week what they may be doing that may require a permit and that will be about 80% of you income Even when it was stated to the parliamentary comity this was not a Money raising proposal it looks very much So

21. Should the legislation make a clear distinction for applications for “non-standard” activities?

Please select one item
Ticked Yes
No
Comments:
if they are not capable of doing the job the agency should not have the powers intrusted to them

22. What other alternative arrangements would you suggest for managing non-standard applications?

Comments:
for water fisheries and hydro installations and invasive Species, I wouled recommend that they don't take advice from the other non-accountable government sponsored agencies with their track record.

23. Do you agree with the proposals for variations?

Please select one item
Yes
Ticked No
If not, why not?
being able to change the rules when and if SEPPA wishes is just going to cause confusion and they shouted not have the power to do so that's why we have ministers to hold to account

24. Do you agree with the proposals for transfer?

If not, why not?
I guess sepa is now going to be employing building and construction personnel that know how to operate plant

25. Do you agree with the proposals for surrender?

Please select one item
Ticked Yes
No

27. Do you agree a notice used in the way set out in 3.7.10 to 3.7.12 is a different type of notice and should be therefore be called something different, such as an improvement notice?

Please select one item
Yes
Ticked No
Comments:
if a company is not in breach of the regulations then how can they shut it down just bcos they are about to introduce new standards that's not right

29. Do you agree we should retain suspension notices for use in circumstances where we wish to suspend an activity in order to protect the environment, but the authorised person is not being ‘enforced’ against?

Please select one item
Ticked Yes
No

30. Do you agree SEPA should have the power to revoke authorisations in these circumstances?

Please select one item
Ticked Yes
No
Comments:
is a pity that the local council is about to remove from SEPA any and all authority from them regarding Invasive signal Crayfish within the Ken Dee catchment

31. Do you agree that appeals against SEPA decisions should continue to be heard by the DPEA on behalf of Scottish Ministers?

Please select one item
Ticked Yes
No

33. Do you have any suggestions for how SEPA might manage the workload to implement integrated, and corporate, authorisations?

Comments:
employ a lot more personnel to answer the phones as the volume of rural urgent jobs required doing in bad weather conditions is rather larger than appears to have been accounted for it looks as if is all set up for large companies totally ignoring the small two or three person operators that require quick licences to carry out works in various locations miles apart

Part 5: Pollution Prevention and Control

37. Do you consider that the provisions of the universal outcomes contain equivalent protection as BAT in relation to domestic activities?

Please select one item
Ticked Yes
No

38. Do you have any comments on the potential impact of this change for other industrial pollution risk activities?

Do you have any comments on the potential impact of this change for other industrial pollution risk activities?
stopping projects half way through can some times have the effect of creating the problems that we are all trying to avoid which will happen if the inspectors have no experience with the operations beeing carried out especially in the construction and farming industries as was evident in the Foot and mouth outbreak and with the larch tree seedlings that were allowed into the country when knowledge of this problem was well known in the country they came from and hear Sometimes you have to stand up to the EU regulations and do what is right Ignore them and adopt a bit of common sense

Part 7: Radioactive Substances

39. Do you agree that it is appropriate to have controls on radioactively contaminated materials whilst they remain on the premises where they were contaminated?

Please select one item
Ticked Yes
No

40. Do you foresee any practical implications of the proposal to have controls on radioactively contaminated materials whilst they remain on the premises where they were contaminated?

Do you foresee any practical implications of the proposal to have controls on radioactively contaminated materials whilst they remain on the premises where they were contaminated?
Yes between yourselves and the Westminster government and the industry regulators and the NBCMAT=Nr Teams they are in charge over all other agencies hopefully, they won't have to call them out again this year

41. Do you agree that all substances associated with NORM industrial activities should be subject to control under the integrated authorisation framework, where they exceed the out-of-scope values, irrespective of whether or not they are classed as radioactive material or waste?

Please select one item
Yes
Ticked No
If not, why not?
all radioactive material is radioactive material it is never called waste. Only called that on press releases to pacify the general public giving the impression that it is not harmful When in fact Waste as you call it Can be just as deadly as standing next to the Chernobyl reactor, cores melted graphite grading of how much radiation is given off

42. Do you foresee any significant implications of this proposed change, e.g. are there any finished products (consumer products or construction materials) that would become classified as radioactive material?

Do you foresee any significant implications of this proposed change, e.g. are there any finished products (consumer products or construction materials) that would become classified as radioactive material?
luminous dials isotopes Medical luminous tunnel signage old railway tunnels old Mine works opened up by open cast mining Granite quarries Airfields prier 1967 runway markers glowed now you know how Ash felt plants new housing est foundations built over old gas works coking plants paint works luminous coated object's

43. Do you agree that we should continue to exclude the public from the scope of the radioactive substances regulatory regime?

Please select one item
Yes
Ticked No
If not, why not?
In the warbled climate of today, I wouled have expected you to know why not

45. Do you agree with the proposals for applying the new regulatory regime to nuclear licensed sites?

Please select one item
Ticked Yes
No

46. Do you foresee any problems with removing the requirement to display certificates?

Do you foresee any problems with removing the requirement to display certificates?
if they are not laminated first

47. Do you agree that SEPA should have the power to impose conditions in an authorisation requiring the permit holder to carry out operations off their site?

Please select one item
Yes
Ticked No
If not, why not?
forcing a contractor to carry out work and clean up other people's however. if he was asked he probably wood help out if the cost was not too Extravagant