In June last year the EA modified their CCS as it was being applied inconsistently to industry which was causing problems for operators.

This note is just a reminder on how the scheme works and the importance this has in respect to your Operational performance Risk Appraisal (OPRA) scoring.

The Compliance Classification Scheme (CCS) provides consistency across different regulatory regimes in the reporting of non-compliance with permit conditions. The information from this scheme contributes to an activity’s Operational Risk Assessment (OPRA) risk rating or profile, through the compliance rating attribute. The scheme categorises non-compliance based on the potential to cause environmental damage. It follows the same approach that the EA use in their Common Incident Classification Scheme (CICS).

Fees can be significantly adversely affected if your site falls into D, E or F banding, for example, under a Standard Rules Permit the fee can move from £2k PA under B and B to £6k PA under a B and F. With a bespoke permit this range moves from £3k PA to £9k PA making it a very costly exercise.

The success or failure to achieve low scores rests not only with your actual performance but also with your management system (MS) and how you are able to demonstrate its effectiveness. Your MS should include:

• A risk assessment of the impacts your site may have on the surrounding environment.
• A plan of the measures you have put in place to manage these risks, this is referred to as ‘Appropriate measures’.
• A description of how your site operates.
• How emissions are controlled.
• Staff training.
• A site plan.
• A list of complaints and how they were handled.
• A detailed HACCP plan.

This is not a comprehensive list and further guidance on the CCS scheme is available in this link: New CCS Operational Instruction

It will also be useful to reference the ‘How to comply with your Environmental Permit’ guidance found in the link: How to comply with your permit (EA)

Source: Renewable Energy Association