Response 284866020

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Ian Cowan

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

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

Do you agree that SEPA should consult on the guidance setting out the likely tier of authorisation for particular activities?
The features of each tier of authorisation are mostly* fine, but the term used for each tier should reflect the distinguishing feature(s) of the tier. How does each tier of authorisation differ from the previous tier? All the tiers feature activity-specific standard rules in some form or other; Tier 1 features only such rules. New features of each successive tier are shown in bold in the table below, as follows: • Tier 2 introduces contact with SEPA and registration of details (e.g. location). (*At this tier no document is issued, so it would be unfair for SEPA to identify an ‘authorised person’.) • Tier 3 introduces prior assessment and issue of a document to an authorised person. • Tier 4 introduces a longer determination period and site-specific conditions. TABLE available Tier 2 is currently described using the term ‘notification’, but it is distinguished from Tier 1 by both a process of ‘notification’ and a process of ‘registration’. Authorisation is granted subject to standard pre-published rules. The terms suggested for Tier 2 in the final row of the table above reflect this. Tier 3 is currently described using the term ‘registration’, but the process of registration is a distinguishing feature of Tier 2. The distinguishing feature of Tier 3 is the issue of a document or permit to an authorised person. The terms suggested for Tier 3 in the final row reflect this. Tier 4 is currently described using the term ‘permit’, but the issue of a permit is a distinguishing feature of Tier 3. The distinguishing feature of Tier 4 is the complexity of the assessment and the need for site-specific conditions. The terms suggested for Tier 4 in the final row reflect this.