Response 756254326

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About You

Are you responding as an individual or an organisation?

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Organisation

Part 2: Policy Overview

1. Do you agree with the benefits set out here?

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Ticked Yes
No

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?

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Ticked Yes
No

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

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Ticked Yes
No

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

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Ticked Yes
No

8. Do you agree that these are the right factors for SEPA to consider?

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Ticked Yes
No

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

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Ticked Yes
No

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

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Ticked Yes
No

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

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Ticked Yes
No

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

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Ticked Yes
No

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

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

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

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Ticked Yes
No

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

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Ticked Yes
No
Comments:
Still need to see the guidance from SEPA but qualified Yes

19. Do you agree with the proposed application processes?

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Ticked Yes
No

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

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Ticked Yes
No

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

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Ticked Yes
No

23. Do you agree with the proposals for variations?

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Ticked Yes
No

24. Do you agree with the proposals for transfer?

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Ticked Yes
No

25. Do you agree with the proposals for surrender?

Please select one item
Ticked Yes
No

26. Do you agree with the proposed approach to enforcement notices set out above?

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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
Ticked Yes
No

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?

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Ticked Yes
No

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

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Ticked Yes
No

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

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Ticked Yes
No

Part 4: Key features of the new framework for the public

34. Do you support SEPA having more flexibility in how information is made available to the public?

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Ticked Yes
No
Comments:
SEPA website will need to be changed and improved to allow public to find the content they are looking for.

35. Do you agree that a consistent, flexible and proportionate approach to public participation should be adopted?

Please select one item
Ticked Yes
No

36. Do you agree that the procedural arrangements for third party call-in under CAR should be extended to all regulated activities?

Please select one item
Ticked Yes
No

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

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
Ticked Yes
No

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

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Ticked Yes
No

44. Do you agree with the proposed radioactive substances regulated activities?

Please select one item
Ticked Yes
No

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?
No

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
Ticked Yes
No