Licence fee system
The licence fee system (LFS) is based on ‘user pays’ and ‘polluter pays’ principles, where licence fees reflect the EPA’s regulatory effort as well as the amount and type of pollutants discharged to the environment.
The LFS enables the EPA to:
- recover, in an efficient and equitable manner, the costs we incur due to the assessment and environmental management of licences
- provide an economic incentive to reduce pollution.
The application fee applies to each new licence application and has 2 distinct components: lodgement fee and an assessment fee.
A lodgement fee is charged for new licence applications to cover the administrative component of processing an application. The current lodgement fee is $227.
The assessment fee is charged for new licence applications to reflect the time taken by technical and administrative staff to assess each activity and prepare the licence conditions for each of those activities.
The assessment fee considers the nature of the activity to be undertaken by the licensee. Each type of activity has a fee unit assigned to it (referred to as the Environment Management Fee or EMF) for the purpose of a licensee’s annual fee (see Annual licence fee below).
The EMF component of the EPA’s licence fee model reflects the regulatory effort, which is aligned to environmental risk, for managing an activity. The assessment fee is only charged as 20% of the activity with the highest EMF component. By charging an assessment fee based on a percentage of the EMF, applicants will be charged based on their potential risk to the environment and therefore the regulatory effort required by the EPA to assess the application.
Assessment fee for waste transporters, dredging and earthworks drainage
Exceptions to this are waste transporters (category A & B), dredging and earthworks drainage activities. For waste transporters, the assessment fee is based on time taken by an administrative staff member to process the application as there is no technical assessment required. This administrative time is greater for category A transporters due to the nature of the waste being transported. For dredging and earthworks drainage activities the assessment fee is based on the costs of the technical staff assessing the application as well as ongoing assessment each day the dredging or earthworks activity is undertaken. Assessment fees are:
- Category A waste transporter $90.80
- Category B waste transporter $45.40
- Category A & B waste transporter $136.20
- Dredging and earthworks drainage $771.80
If a business seeks to undertake an expansion or infrastructure development which does not require approval under the Planning, Development and Infrastructure Act 2016 but when a works approval is required. The works approval assessment fee is 20% of the fees payable which is dependent on the value of the estimated cost of proposed works as set out in the Environment Protection Regulations 2009. The assessment fee reflects the time taken by technical staff to assess the works approval.
Annual licence fee
The annual licence fee consists of three components. The split between these components is:
- 1% flat minimum fee
- 39% resource efficiency fee
- 60% environmental management fee.
The flat minimum fee applies to almost all licences and is 1 fee unit at the granting, anniversary or renewal of a licence plus 1 fee unit each time new activities or sites are added to a licence. The flat minimum fee component applies even if no environment management fee is paid.
Resource efficiency fee
Pollutant load fee
Pollutants and thresholds
A licensee with emissions above threshold levels pays a fee for each liable pollutant. The air and water pollutant emission thresholds are shown in Tables 1 and 2. The load based component only applies for emissions above the threshold levels shown in these tables.
The load based component does not apply to the following:
- suspended solids from activities 7(4) dredging and 7(6) earthworks drainage
- ethanol emissions as volatile organic compounds from activities 6(2) breweries and 6(11) wineries and distilleries.
There are 2 types of resource efficiency fees (REF), which only apply to a subset of licences:
- Pollutant load fees are for the discharge of key pollutants from the licensed site to the environment (air or water). Emission thresholds apply to ensure that only significant emissions are captured.
- Water reuse fee for the discharge of fresh water to the marine environment
It is important to note that REF is calculated retrospectively and is for emissions that have been emitted in the preceding full year period.
Most licence-holders give consent for the EPA to use the most recently published National Pollutant Inventory (NPI) data. Alternatively, a licence-holder can supply its own data and this would then be reviewed by the EPA for validity and consideration.
Due to differences in timing of licence anniversary date and NPI publication, this data can be over a year old by the time it is used. For example, calendar year 2015 NPI report published March 2017 (2015–16 period) and available to the EPA for use anytime up until March 2018.
Table 1: Air pollutant emission threshold levels
|Pollutant||Emission threshold level per pollutant per year|
|Sulfur dioxide, nitrogen oxides||10 tonnes|
|Particulates (PM10)*, volatile organic compounds||1 tonne|
*Particles include red dust particles
Table 2: Water pollutant emission threshold levels
|Pollutant||Emission threshold level per pollutant per year|
|Heat||10 MW (megawatt)|
|Suspended solids, total nitrogen, total phosphorus, organic matter as BOD5, zinc||1 tonne|
|Lead, copper||0.1 tonne|
If the pollutants on the list are not discharged from your site or the discharge is less than the emission threshold, then pollutant load based fees do not apply. As a guide, if you do not need to report your pollutant emissions to the National Pollutant Inventory (NPI), the pollutant load based component may not apply to you. However, some pollutants such as suspended solids, which although not NPI pollutants, are important environmental issues in South Australia and included in the load based fee. If you are unsure whether the load based component applies to you, please contact your licence coordinator.
Zone weightings are multipliers in the pollutant load fees that reflect the relative importance of reducing certain pollutants in specified areas. This provides a greater incentive for immediate pollutant reductions in those areas. Information on the zones relevant to the pollutant load fee can be found in the Maps of REF zones.
All pollutant load based fee are multiplied by zone weightings. The default zone weighing is 1 except for the pollutant and zone combinations shown in Tables 3 and 4.
Table 3: Environmental zones and weightings for air pollutants
|Whyalla||Red dust particulates||4|
|Adelaide metro airshed||Volatile organic compounds||1.5|
|Adelaide metro airshed||Nitrogen oxides||2|
|Outside council areas (very remote regional sites)||Volatile organic compounds||0.5|
Table 4: Environmental zones and weightings for water pollutants
|Metro coasts||Suspended solids||2|
|Upper Spencer Gulf||Zinc, lead, copper||2|
|Lake Bonney (South East)||Organic matter||2|
Pollutant fee units
Tables 5 and 6 show the pollutant fee units per tonne of pollutant (excluding zone weighting) for pollutants discharged to air and water respectively.
Table 5: Fee units for pollutants discharged to air
|Pollutant||Load based fee units per tonne of pollutant|
|Sulfur dioxide, nitrogen oxides||1|
|Particulates, volatile organic compounds||10|
Table 6: Fee units for pollutants discharged to water
|Pollutant||Load based fee units per tonne of pollutant|
|Heat (fee per megawatt heat added to water)||1|
|Suspended solids, total nitrogen, total phosphorus, organic matter as BOD5, zinc (fee per tonne of pollutants)||10|
|Lead, copper (fee per tonne of pollutants)||100|
Calculation of the pollutant load fee
The pollutant load fee is calculated for each relevant pollutant as:
Pollutant load fee =
(tonnes of pollutant emitted) × (number of pollutant fee units) × (value of the pollutant fee unit) × (zone weighting)
The current value of the fee unit for pollutant load fees is available at value of fee units.
Water reuse fee
The water reuse fee applies to discharges of water to marine waters where average annual salinity (as total dissolved solids) of the discharged water is less than 1,500 mg/l. It does not apply to discharges of water to inland waters.
This fee is charged per megalitre of water discharged and applies to discharges of 10 ML or more per year.
The water reuse fee is calculated as 1 water reuse fee unit per ML. Note if you breach the fee you pay the fee for all water discharged, including the first 10 ML (per site).
The current value of the fee unit for water reuse fees is available at value of fee units.
Environment management fee
The environment management fee (EMF) applies to almost all licences and varies depending on the activities carried out on the site. It does not apply to dredging and earthworks drainage if no activity is carried out or to closed landfills. Only the highest environment management fee of all activities carried out on a site will apply (per site). Waste transport, dredging and earthworks drainage, if applicable, are an additional charge.
To find out which scheduled activities apply to you, refer to the front page of your licence. The number of fee units applicable to each activity can be found in the schedule of environmental management fees. The schedule also outlines the available criteria for discount. In some cases, the number of fee units relates to your location. Information on the zones relevant to the environment management fee can be found in the Maps of EMF zones.
The current value of the fee unit for environment management fees is available at value of fee units.
When a licence application is made, or each year when licence-holders lodge an annual return, licence holders are required to select the level of activity they expect to undertake in the coming year. In this way, the EMF is always calculated based on projected activity levels for the coming year.
If licence-holders then operate at a higher or lower for that year, they are obliged to notify the EPA. The Environment Protection Regulations 2009 set out the circumstances in which an adjustment of annual authorisation fee can be requested and made.
Value of fee units
The values of fee units for the financial year from 1 July 2022 to 30 June 2023 are:
- Lodgement fee 10 fee units at $22.70/fee unit = $227
- Flat fee component = $74
- Environment management component = $826/fee unit
- Pollutant load-based component = $7.30/fee unit
- Water reuse component = $18.30/fee unit
- Any other charge = $22.70/fee unit.
Options for reducing fees
There are a number of opportunities available for licensees to reduce their licence fee and to make payments easier. These are outlined below:
- Reduce emissions
Some licensees emit key pollutants above threshold levels and have to pay a resource efficiency fee. You can lower or even eliminate this fee by reducing pollutant emissions.
- Specified environmental measures and improving environmental performance
Licensees can reduce their fees by making environmental improvements. You can determine if fee reductions could apply to you and the specific requirements for your particular activity by referring to the environment management fee schedule, or contact you licence coordinator for further information. For example:
– sewage treatment works can reduce their licence fees by reusing
wastewater instead of discharging it to inland or marine waters
– landfills can reduce their fee level by meeting certain requirements.
- Surrender licence
If all your activities are below threshold (refer to Schedule 1 of the Environment Protection Act 1993), you may not require a licence. You can apply to surrender your licence using the Surrender of Environmental Authorisation form. If activity levels increase at a later, date you can then reapply for a licence at that time using the Licence Application form.
- Pay by instalments
Your licence fees can be paid in quarterly instalments. If you wish to do this, please request this in writing addressed to (please note that the flat minimum fee component will be charged to your first invoice).
- Senior Licensing Officer
- EPA Licensing and Community Response
- GPO Box 2607
- Adelaide SA 5001 or email
- Fee reduction or waiver
Under circumstances approved by the Minister, the EPA has the power to waive or reduce licence fees under section 116 of the Environment Protection Act 1993. Reductions are only granted under exceptional circumstances. If you feel you have a case for a fee reduction on the basis of fairness or hardship, please get in touch by contacting (08) 8204 2058 or email.