training costs associated with improving service delivery. These activities are important for supporting and maintaining the NSP function, and benefits may accrue to the public and to applicants. Consenting and monitoring activities in the EEZ The EPA should review how it calculates overheads, in particular to ensure management time (among other corporate services) is adequately captured. Hazardous substances and new organisms (HSNO) The cost recovery regime for HSNO should be reviewed by the Ministry and the EPA. The review should include consideration of: the existing target rate of cost recovery (currently at 17%) the method of charging (ie, comparing the existing fixed fee model with other options such as recovering actual and reasonable costs (like its other cost recovery regimes), or charging a levy) the scope of cost recovery including: the possibility of recovering the cost of supporting the HSNO Committee the possibility of charging interested parties to view the EPA’s ‘HSNO applications’ and ‘substance exposure limits’ registers. Ozone and import-export regulations The issuing of ozone and import-export permits should remain a free service. While our high-level analysis has identified this as a mixed benefit service (ie, there are benefits for both the applicant and the general public), imposing partial cost recovery of these activities risks creating non-compliance issues. Administering the New Zealand Emissions Trading Scheme (NZETS) and New Zealand Emissions Unit Register (NZEUR) We do not recommend any changes to the current system at this time. A review of the regime is scheduled for the end of 2015 and this would be a more appropriate time to consider and make any possible cost recovery changes. Table 1: Summary of cost recovery approaches Ozone depleting and Hazardous Hazardous Nationally substances substances, significant Marine Marine and new imports and NZETS and proposals consenting compliance organisms exports NZEUR Target cost Close to Close to Limit of 80% 17% N/A In theory recovery rate 100% 100% could be up to 100% Method of cost Hourly rate, Hourly rate, Hourly rate, Fixed fees Cost recovery Hourly rate recovery set by the prescribed in prescribed in not allowed after 4 hours EPA regulations regulations by legislation of processing, prescribed in regulations Charge for an EPA $108.43 $116.12 $116.12 N/A N/A $117.50 senior adviser
training costs associated with improving service delivery. These activities are important for supporting and maintaining the NSP function, and benefits may accrue to the public and to applicants. Consenting and monitoring activities in the EEZ The EPA should review how it calculates overheads, in particular to ensure management time (among other corporate services) is adequately captured. Hazardous substances and new organisms (HSNO) The cost recovery regime for HSNO should be reviewed by the Ministry and the EPA. The review should include consideration of: the existing target rate of cost recovery (currently at 17%) the method of charging (ie, comparing the existing fixed fee model with other options such as recovering actual and reasonable costs (like its other cost recovery regimes), or charging a levy) the scope of cost recovery including: the possibility of recovering the cost of supporting the HSNO Committee the possibility of charging interested parties to view the EPA’s ‘HSNO applications’ and ‘substance exposure limits’ registers. Ozone and import-export regulations The issuing of ozone and import-export permits should remain a free service. While our high-level analysis has identified this as a mixed benefit service (ie, there are benefits for both the applicant and the general public), imposing partial cost recovery of these activities risks creating non-compliance issues. Administering the New Zealand Emissions Trading Scheme (NZETS) and New Zealand Emissions Unit Register (NZEUR) We do not recommend any changes to the current system at this time. A review of the regime is scheduled for the end of 2015 and this would be a more appropriate time to consider and make any possible cost recovery changes. Table 1: Summary of cost recovery approaches Nationally significant proposals Marine consenting Marine compliance Hazardous substances and new organisms Ozone depleting and Hazardous substances, imports and exports NZETS and NZEUR Target cost recovery rate Close to 100% Close to 100% Limit of 80% 17% N/A In theory could be up to 100% Method of cost recovery Hourly rate, set by the EPA Hourly rate, prescribed in regulations Hourly rate, prescribed in regulations Fixed fees Cost recovery not allowed by legislation Hourly rate after 4 hours of processing, prescribed in regulations Charge for an EPA senior adviser $108.43 $116.12 $116.12 N/A N/A $117.50